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Figure 4.8: Meghna River Water Level Near the MPSA - Daily Highest and
Lowest
NOTE: the light line represents the highest daily water level
the dark line represents the lowest daily water level
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The results indicate a high level of turbidity in the Meghna River when compared to the drinking water
standards of Bangladesh. It is anticipated that these levels will decrease during the drier winter season as
lower water flow rates during this period will decreases sediment transport. It should be noted that in both
sampling locations, the ambient level of lead (Pb) and dissolved oxygen (DO) was found to be higher and
lower, respectively, than the corresponding GOB standard.
Additional sampling of DO concentrations near the project site was undertaken in August 1999. The
results also indicate a low DO value of Meghna at 3.04 mg/l (Appendix I9). In comparison, DO sampling
conducted as part of the AES Haripur power project on the Shitalakhya River, indicates fluctuations in DO
which appear to vary by season, but remain relatively low:
April 1998: 6.16 mg/l;
October 1998: 3.68 4.41 mg/l; and
November 1998: 3.38 mg/l.
Likely causes contributing to the low DO levels may include, but are not limited to: little whitewater/ chop
in this reach of the river, high levels of turbidity may marginalize aquatic photosynthesis, warm water
temperatures, and industrial discharges.
4.2.3.3 Salinity Regime
As noted in Section 4.1, the Meghna joins the Dhaleswari and Shitalakhya Rivers approximately six
kilometres downstream of the project site. This combined flow then joins the Padma River a further 13
kilometres downstream of their confluence, above the Town of Chandpur. Like most rivers originating in
the Himalayas, the river flows of the Padma (the Ganges) are regulated as they pass through Indian
Territories.
DHI/SWMC, as part of the Meghna Estuary Project Study (2000), conducted an analysis of the intrusion
of salinity into the Meghna estuary for both the dry and wet seasons (Figures 4.9 and 4.10). As shown
on the figures, salinity reaches into the lower Meghna, but not up to Chandpur. As noted, the MPSA is an
additional 40 kilometres upstream of Chandpur and it is very unlikely that saline water will ever intrude up
to the MPSA unless there are drastic changes to the combined flow regime of the Meghna, Padma, and
Jamuna.
4.2.3.4 Sea Level Rise
Specific information on the possible extent of sea level rise (SLR) in Bangladesh is meagre and current
models of anthropogenic climate change are not accurate enough to provide useful information in regard
to SLR. However, using predictive information from the Woods Hole Oceanographic Institute and the
Climate Research Unit, University of East Anglia (United Kingdom), SWMC carried a simplified simulation
of SLR based upon a SLR of 30 cm; which is predicted to occur sometime between 2050 and 2100
(SWMC, 1993).
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Figure 4.9: Salinity Distribution (1996 Dry Season)
Chandpur
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The results of this study were summarized in SWMCs 1997 report that was presented as part of the MEP
1997 EIA report. The results indicated that with a peak inflow increase of five percent and dry inflow
decrease of 15%, corresponding to a SLR of 30 cm, river stages between Chandpur and Bhairab Bazar
would increase by approximately 15 20 cm. (SWMC, 1997).
Figure 4.10: Salinity Distribution (1998 Monsoon Season)
Chandpur
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Since the river seasonally fluctuates between +1 to +6.76 metres PWD, and the project site has been
constructed to approximately +8 metres PWD, the foreseeable effects of SLR are negligible, with regard
to this project.
4.2.3.5 Groundwater
Previous studies have estimated that the approximate depth to the water table in the project area during
the dry season is six metres. However, it has also been determined that depth to the top of the main
aquifer is close to 50 metres (MEP, 1997). The regions groundwater is used extensively for both
domestic and agricultural purposes. It is believed that 53% of the population uses groundwater for
domestic purposes, and one-third of agricultural lands are irrigated by groundwater (MEP, 1997).
Rivers, canals, and other surface waters are relied upon by 40% of the countrys population for their
entire domestic supply of potable water, however, within the project area approximately 91% of
households access potable water via hand tube wells (DPC, 1999a). The two villages closest to the
project site, Islampur and Ganganagar, use groundwater as their main source of water (MEP, 1997).
A concern for approximately one-half of the Countrys population is the naturally high levels of arsenic in
groundwater. Arsenic is known to exist at elevated rates in the groundwater of 28 administrative districts.
The World Health Organization (WHO) states that acceptable levels of arsenic should be no higher than
0.05 mg/litre of drinking water. However, arsenic levels in Bangladesh have been as high as 2.9 mg/litre
of drinking water. For reference, high rates of groundwater extraction can leach arsenic from the soil and
lead to arsenic contamination of well water (Gain, 1998).
Groundwater sampling at the MPSA was undertaken on September 2, 2000 from a deep tube well bored
to approximately 100 metres at the project site. Selected results are shown in Table 4.6 with the
complete results contained in Appendix I9.
Table 4.6: Selected Groundwater Analysis Results
Parameter Unit Concentration Bangladesh Equivalents
for Drinking Water
WHO Guidelines
(1996)
pH -- 6.70 6.5 8.5 6.5 8.5
turbidity NTU 4.80 5 10
total dissolved solids mg/L 619.00 1000 1000
arsenic mg/L 0.010 0.05 0.01*
iron mg/L 0.40 0.3 1.0 0.3
fluoride mg/L 0.36 1 1.5
manganese mg/L 0.17 0.1 0.1
* This is a provisional guideline of the WHO. This is a provisional guideline because of lack of suitable testing methods. The
previous guideline was 0.05 mg/L.
Based upon the results of the laboratory analysis, pH, turbidity, total dissolved solids, arsenic, and
fluoride levels at the project site are within both GOB standards and WHO guidelines. Iron is 0.1 mg/L
above the WHO guidelines, while the concentration of manganese is 0.07 mg/L above both the GOB and
WHO guidelines. Such small exceedences are unlikely to have any human health effects.
4.2.4 Biological Conditions
4.2.4.1 Terrestrial Flora and Fauna
The landscape of the project area is flat, with village settlements and industrial units on lands raised to
about 45 metres above sea level (Figure 4.7, Photo 5). Open fields, as well as artificial and natural
water bodies, characterize the area surrounding the rural villages adjacent to the MPSA. Much of the
regions agricultural land is subject to annual inundation and remains submerged for up to four to five
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months during the summer. Thus, there is drastic seasonal variation in the environment. However,
because of extensive agricultural, industrial, and residential development, truly natural terrestrial habitats
characterized by indigenous flora and fauna are absent from the project area. No designated nature
reserves or parkland areas are present in the project area (DPC, 1999d).
Although the project site and surrounding area have limited natural habitats, Bangladesh as a whole is an
important wintering ground for nearly 300 species of migratory birds. Specifically, the country is situated
at the crossroads of two migratory flyways for species such as the Asian Dowitcher and the Indian
Skimmer (Gain, 1998).
Flora
Low growing grasses, herbaceous vegetation, and other common plant communities constitute the floral
habitat in the project area and vary with the seasons. Data collected through field visits, observations,
interviews, and investigations suggests that the project area contains a plant community of approximately
82 floral species. As the project site was used for growing agricultural crops, only those plants (e.g.,
paddy, vegetables, wheat, and jute) and some common low growing grasses, were present on the MPSA
prior to the site filling activities of the BPDB (DPC, 1999d).
Besides seasonally cultivated agricultural crops and vegetables, the major plant species as identified
during the site survey are shown in Appendix I10. Institutional sources, local community members from
the project area, and field observations indicted that no vulnerable, threatened, or endangered plants are
anticipated to be growing on the MPSA.
Fauna
The fauna near the project site is representative of urban fringe area species. Primary consumer species
at the project site consist mainly of small organisms such as insects, and large herbivores such as hoofed
mammals. Oligochaetes, soil mites, nematodes, along with other insects and invertebrates play an
important role in the terrestrial ecosystem (MEP, 1997).
Of a possible 600 avian species in Bangladesh, approximately 35 to 40 species were identified as being
possible within a 10-kilometre radius of the project site. Most avian species in the project area are
common and include the Pariah Kite, the House Crow, and the Brahami Kite. Four avian species whose
range includes the project region have been categorised by the IUCN as being lower risk but near
threatened
4
. These include the Red-Headed Vulture, Tawny Fish Owl, White Rumped Vulture, and the
Grey Headed Fish Eagle. The Imperial Eagle and the Blyths Kingfisher were identified as vulnerable,
while the Oriental Stork was identified as endangered (DPC, 1999d).
Approximately 20 species of mammals can be found near the project site. The only endangered terrestrial
species whose range includes the project site is the Asiatic Golden Cat. It has been identified as lower
risk but near threatened. Again, site conditions and field observations suggest it is unlikely that this
species would be found at the MPSA. Other mammals in the area include the Jackal and the Mongoose
(DPC, 1999d).
There are 11 species of reptiles and amphibians whose range includes the project site. Of these, the
Gharial is endangered, the Spotted Pond Turtle is lower risk but near threatened, and the Black Soft-shell
Turtle is critically endangered (DPC, 1999d). MEP (1997) stated that while all of these species may be
found within a ten-kilometre radius of the project site, no endangered or threatened species occur at the
MPSA itself. The field information collected as part of this EIA study confirms MEPs conclusion. More
information on species living near the MPSA can be found in Appendix I10.
4
The IUCN categorization scheme includes: Extinct, Extinct in the Wild, Critically Endangered, Endangered, Vulnerable, and Lower
Risk. There are three categories within Lower Risk that include, Conservation Dependent, Near Threatened, and Least Concern (IUCN,
1996). See Appendix I10 for definitions of each category.
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4.2.4.2 Aquatic Flora and Fauna
The many rivers that flow into Bangladesh, and through the project area, annually contribute alluvium
from Nepal and India to Bangladesh, continually expanding and creating river chars in perpetuity. It is
estimated that Padma alone carries over 1.4 billion tons of alluvium per year, enriching the surrounding
floodplain soils (Bigalow, 1995).
Even though there is a large sediment to water ratio in the Meghna River, it still provides rich habitat for
many flora and fauna species. There are a wide variety of fish and shellfish species near the project site,
many of which are of great significance to both subsistence and commercial fisher folk (Appendix I11).
Common river species include the grass carp and the mirror carp. There are a number of endangered
species in the Meghna River, and include the Lalchanda, Kali baus, Boal, Bacha, Gonia, Ayre, Kajuli,
Tatkini, and Ghaura. Furthermore, there are 21 species of threatened fish in this Meghna (DPC, 1999e).
Following the annual flood cycles, there are four phases of aquatic habitats for inland water species that
provide seasonal habitat for a variety of fish:
dry season: occurring from December to March, water remains only in perennial rivers and
canals and most fish congregate to live through this dry season;
pre-monsoon season: from April to early June water level rise and fish move to shallower areas
in search of spawning grounds. Migrations occur over both great distances (e.g., major carps)
and small distances (e.g., floodplain breeders such as koi and mola);
monsoon flood season: during the months from June to September, river larvae and fry move to
floodplain areas for easier feeding and growth, although they are highly susceptible to natural
and fishing mortality during this season; and
post-monsoon season: during October through December, the flood waters recede, shrinking
the floodplain feeding areas and fostering the movement of fish back into the deeper waters
where they await to begin the cycle again (Ali, 1997).
Although not observed during the field investigations, a notable species whose reported seasonal range
includes the Meghna river area is the Ganges River Dolphin (locally known as Shushuk). According to
IUCN, this species falls within the endangered species category. This porpoises range extends into the
Padma, Brahmaputra, Karnaphuli, and Meghna river systems of India, Bhutan, Nepal, and Bangladesh.
The IUCN has stated that the entire population of Ganges River Dolphins are considered endangered due
to a population reduction of at least 50% over the last three generations. This is based upon direct
observations, a decline in quality of habitat, and possible exploitation. Perhaps the greatest threats to this
porpoise are dam construction on the Ganges River (now over 20 and which have fragmented the
population), boat traffic, pollution, and loss of habitat (DPC, 1999e).
Aside from the main riverine tract of the Meghna, other aquatic habitats can be found at the project site
and along the main channel. These include shallow channels, marshy areas, and floodplains within which
water levels vary greatly between the dry and wet seasons. Within these varied habitats, a variety of
aquatic plants, algae, macro-invertebrates, plankton, and fish are typically found depending upon the
seasonal habitat phases (MEP, 1997).
4.2.5 Socio-Economic Conditions
Six villages, considered representative of the socio-economic make-up of the greater MPSA area, were
surveyed as part of the General Household Socio-Economic Survey conducted for the EIA (Appendix I2),
and include: Islampur, Ganganagar, Dhudghata, Char Goaldi, Panchani, and Kurbanpur (Figure 4.11).
These villages were the main focus of the social analysis as approximately 97% of the project-affected-
persons live and/or work within these villages. For continued reference, the remaining project-affected-
persons were also surveyed during the collection of baseline conditions.
Lifestyles in the project area have adapted to the annual cycle of summer inundation by floodwaters,
often in quite complex ways. The project site, the low lying paddy lands along the side channels of the
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Meghna, and extensive areas leading further inland beyond the line of villages, are all flooded for
anywhere from four to nine months of the year, depending on the strength of the summer monsoon and
the height of the land. For this reason, the villages are built on platforms a few feet above the normal high
inundation level, with protection and anchoring by trees and other vegetation.
Undoubtedly, most parts of these villages were raised by hand filling long ago. This process is still visible
where new residential or bazaar lands are being created or where older land is in need of repair. The
village platforms provide space for houses, sheds for cattle, kitchen gardens, medicinal plants, fruit trees,
small orchards, a local market, schools, and other public buildings. Depending upon the severity of
monsoon rains, some village platforms themselves go under water, forcing people onto their roofs or over
to the main highway embankment for reprieve from the high waters.
4.2.5.1 General Village Features
Similar to most villages in Bangladesh, each of the six villages surveyed consists of traditional institutions
like neighbourhoods (para), lineages (gushti), and community (samaj). For example, Dhudghata has
seven paras that collectively contain nine gushtis. In most samajs, there is a leader who provides
commanding influence over the community members. The role of community leaders in Bangladesh is
quite important from a social control and power structure perspective (DPC, 1999a).
In the rural areas of Bangladesh, hunger characterizes poverty, as is also the case with the villages
surveyed. At the time of the survey, approximately 20% of the households reporting had experienced
prolonged hunger in the seven days prior to the survey, with more than 80% reported the consumption of
fish over the same period (DPC, 1999a).
Within the villages surveyed, flooding is a seasonal event, but varies in scale and intensity most years.
Under normal climatic conditions, approximately 10% of households in the river fringe areas experience
flood conditions. However, in 1998 when one of the most severe floods was recorded in Bangladesh,
more than 91% of the households were inundated by waist high water which also disrupted road and
communication networks (DPC, 1999a).
Additional information obtained from the General Socio-Economic Household Survey is contained in
Appendix I2. The following village specific socio-economic profile was attained from a study sample of
sixty households; ten from each of the six villages. The study was carried out between July 25 and
August 25, 1999 and is reflective of the seasonal lifestyles experienced by those who live in the villages.
Additional data is provided in Appendices I3.
4.2.5.2 Islampur
Islampur is located immediately adjacent to the proposed project site. Figure 4.7 (Photo 6) shows the
section of the village that lies at the southeast corner of the project site. The village has approximately 80
households and a total population of 1,200 people. The average household size is 15 people. Of the
communitys population, there are five main lineages. The population mix is approximately 70% male and
30% female (DPC, 1999b). The male literacy rate in Islampur is 38.9%, while the female literacy rate is
17.9% (Bangladesh Bureau of Statistics, 1994). While the community is predominantly Moslem, however,
one or two families observe other religions. As in all six of the villages, conflicts are settled through
meetings with the communitys elders.
The village has very few amenities. For example, Islampur has one canal that is primarily used for social
and economic purposes and one shop that sells essential goods only. The majority of the community
lacks both electrical and sewage facilities. However, a small group of 100 men live close to the ship repair
yard and have access to electricity. A single hand pump, located in the middle of the village, supplies the
communitys water (MEP, 1997).
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Figure 4.11: Location of General Household Socio-Economic Survey [8 x 11]
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To access other amenities, such as education and medical care, villagers must travel several kilometres.
For example, there are two high schools within five kilometres of the village, a madrasa
5
within seven
kilometres, a college is five kilometres away, and the closest hospital is six kilometres from the village
(DPC, 1999b).
4.2.5.3 Ganganagar
Ganganagar is a slightly smaller community than Islampur, although it covers a greater land area. It is
located northeast of the project site. Its location with respect to the MPSA access road is illustrated in
Figure 4.7 (Photo 7). There are 70 households and a total of 800 people in the village with an average
household of 11 family members. The community has three main lineages and a male to female ratio of
60:40 (DPC, 1999b). The male literacy rate in Ganganagar is 31%, while the female literacy rate is 13.2%
(Bangladesh Bureau of Statistics, 1994). Almost 100% of this village is Moslem.
There are two ponds and two canals in the village. While there is no primary school in Ganganagar, there
are two high schools located one and four kilometres away, and two colleges within three kilometres of
the village. Ganganagar is located within two kilometres of a madrasa. The closest hospital is five
kilometres away (DPC, 1999b).
The housing standard in Ganganagar is generally better than that found in Islampur. While the village is
connected to the power grid, not all homes have electricity. Additionally, there are no sewage facilities
and water is supplied via hand pumps (MEP, 1997).
4.2.5.4 Dhudghata
Dhudghata occupies a large area and is located to the north of the project site. There are 425 households
in the village with a total population of 5,000, primarily from nine lineages. Each household contains
between nine and ten individuals and almost 100% of the villagers are Moslem (DPC, 1999b). The male
literacy rate is 26.8%, while the female rate is 12.5% (Bangladesh Bureau of Statistics, 1994).
Dhudghata has four ponds, two canals, and two ditches. Most educational institutions are located within
close proximity to the village. A primary school is located within three kilometres, a high school is within
one kilometre, with both a madrasa and a senior madrasa located within one kilometre. The closest
college is two kilometres away from Dhudghata. Although Dhudghata does not have direct access to a
hospital, there is a health clinic within two kilometres (DPC, 1999b). Water is supplied to the village via
tubewells and hand pumps. While there are no sewage facilities, the village does have access to
electricity (MEP, 1997).
4.2.5.5 Kurbanpur
Kurbanpur is located northwest of the project site. The village has 241 households with a population of
2,100. The average household size is roughly nine individuals and there are three main lineages in
Kurbanpur. The male literacy rate in the village is 25.2%, while the female rate is 13% (Bangladesh
Bureau of Statistics, 1994). Like the other communities, almost 100% of the individuals are Moslem.
The village has two ponds and three ditches. All schools are within close proximity of the village; partly
since Kurbanpur is very close to Dhudghata. The primary school, the high school, and the senior madrasa
are all within one kilometre, while the college is within two kilometres of the village. Like Dhudghata,
Kurbanpur has access to a health clinic, which is one kilometre away (DPC, 1999b). Although the village
5
A madrasa is an institution for religious education
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is connected to the power grid, not all houses have electricity. The community has no sewage facilities
and water is supplied via hand pumps (MEP, 1997).
4.2.5.6 Panchani
Panchani is located to the west of the project site and there are 176 households in the community. The
total population is 2,400, for an average household size of between 13 and 14 individuals. Panchani has
six main lineages (DPC, 1999b).
The male literacy rate in the community is 30.1%, while the female rate is 18.8% (Bangladesh Bureau of
Statistics, 1994). The community has two ponds, one canal, and three flood plains. The primary school
and madrasa are both within 0.5 kilometres of the village and the closest college is two kilometres away.
There is no hospital in the community, but there is a health clinic (DPC, 1999b).
4.2.5.7 Char Goaldi
Char Goaldi is located adjacent to Panchani, to the west of the project site. It has 241 households with a
total population of 2,500, for an average household size slightly over 10 individuals. (DPC, 1999b). The
community is comprised of six lineages. The communitys male literacy rate is well above average at
52.5%. The female literacy rate is also high at 31.8% (Bangladesh Bureau of Statistics, 1994).
The village has one pond, one canal, and two ditches. The primary school is within 0.5 kilometres, the
senior madrasa is within 1.5 kilometres, and the college is within 2.5 kilometres. As the health clinic is
located in Panchani, it is 1.5 kilometres from Char Goaldi (DPC, 1999b).
4.2.5.8 Road and River Transportation
The road and highway infrastructure in Bangladesh is not well-developed. The existing infrastructure has
also suffered from neglect and from flooding damage. For example, the devastating 1998 flood seriously
damaged the Dhaka-Chittagong highway, which passes through the project region. The flood eroded the
slopes and shoulders of the road, carved pockets, pits, and holes, and weakened old bridges. To help
mitigate future flood damage, the government has taken recent initiatives to build more bridges, and
widen and elevate roads.
Road traffic often consists of a mixture of cars, buses, trucks, auto-rickshaws, pedal rickshaws, and
pedestrians. Approximately 80% of vehicles are reconditioned and in disrepair. Air quality along the major
roadways is seriously degraded due to the high pollutant emissions from vehicles (DPC, 1999g). Traffic
along the Dhaka-Chittagong Highway is busiest between 13:00 and 14:00 hours. Appendix I12 contains
detailed information on vehicle traffic, pedestrian traffic, and traffic accidents in the project region.
The Meghnaghat river port is a major inland port and trading centre. Development in the region continue
to increase this ports importance to cargo ships, fishing boats, passenger boats, and trawlers. As a
result, a two-day survey was undertaken to estimate total river traffic flow near the project site (Appendix
I13). Results indicate that the most popular traffic includes trawlers, country boats, cargo ships and
fishing boats (DPC, 1999h).
4.2.5.9 Agricultural Development
With mixed crop vegetation, limited monoculture tree plantations, and homestead based agro-forestry, the
project area is no different than many other areas of alluvial delta in Bangladesh. Generally a very fertile
agricultural area, the study area predominately grows high yielding rice varieties and rabi crops on a
seasonal basis. The villages near the project site typically have backyards with scattered trees comprised
of species common throughout the country.
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As discussed previously, the project site prior to filling was predominantly covered with mixed crop
vegetation driven by seasonal variations in the environment. The crops include rice, wheat, pulses,
oilseeds, vegetables (tomato, eggplant, etc.), sweet potato, and watermelon. These are grown mostly
during the dry months (October-November to March-April) because the agricultural land remains under
water during the summer months.
Rice is the most popular crop in the region accounting for 31% of overall production. Its popularity can be
attributed to its importance as a subsistence food for most villagers. Other important crops in the region
include wheat (20.84%), oil seeds (20.72%), vegetables (18.54%), and jute (9%). Of the available
agricultural land, 88% is under cultivation of which 49% of that land can be found in the villages. More
than 67% of cultivated land is under irrigation (Appendix I2). This is well above the national average of
40%. The rest of the land remains irrigated by traditional methods such as the swing baskets and ditches
(DPC, 1999a).
4.2.5.10 Gender Issues
The majority of women in the project area live within the confines of the household; an arena still
thoroughly regulated by custom and devotion to domestic work and the raising of children. Purdah, in the
form of strict veiling, is not strongly observed in the area, although women lack mobility and expeditions
outside the home usually require permission from the head of the household. There is a strong tradition of
female modesty, based upon the perceived requirements of Islam.
Given the sensitive nature of interactions with village women, a Bangladeshi female sociologist conducted
both field interviews and a focus group session with potentially affected women. The field interviews and
focus group feedback confirmed the expectation that women have important roles in the agrarian cycle.
Women are particularly involved in the care of kitchen gardens, seeds and seed beds, and the processing
of paddy when it is brought in from the fields. These functions are undertaken in the home and women of
the affected households say they did not visit the char area during the period of cultivation. Women do not
claim to have a role in family decision-making, but their knowledge of the crop cycle and fishing
arrangements indicate that their role is important, albeit informal (DPC, 1999a).
In the six villages surveyed, female literacy rates were an average of 16% lower than male literacy rates.
This is reflected in school enrolment, where only 30% of rural primary school students are female even
though there is a 1991 government declaration that primary education be mandatory for all children.
Similarly, less than 25% of secondary students and fewer than 15% of university students are female
(Bigelow, 1995). However, new programs have been developed to assist older women who bypassed
school in their youth to improve their literacy.
Of the 46 women who attended a focus group session, only six could not write their own name. The fact
that 189 local women work in the garment factory is a significant figure. However, there was reluctance by
the women to admit this, perhaps because this kind of factory work is still regarded as unconventional,
suspect, and injurious to their reputations (DPC, 1999a).
While gender ratios in the six villages tend to be more or less even among those aged 44 and below, the
gender distribution is very uneven among those 45 and above. Among those aged above 45 years, there
are 60.7% males and 39.3% females. In the villages surrounding the project site, 51.7% of families use
birth control. The most common contraceptive method is the birth control pill. Infant and maternal mortality
rates are considered low in the project region (Appendix I2). The infant (under 5) mortality rate in 1998
was 1.7%, whereas the maternal mortality rate was also 1.7% (DPC, 1999a).
4.2.5.11 Public Health
Although the villages are faring well economically, malnutrition and health issues remain a concern. In the
seven days prior to the household interviews, 20% of households reported that they had experienced
some form of starvation (DPC, 1999a). In terms of diet, 81% of households reported that they had eaten
fish within the last seven days. While many households cultivate their own food, that source is not
sufficient for all their dietary needs. Approximately 63% of households obtain rice from the market, 91%
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obtain vegetables from the market, and 70% of households obtain their fish from the market. Close to
20% of households were forced to rely entirely upon the river as their only source of fish (DPC, 1999a).
When asked what type of medical treatment they sought, 76% of households reported having been to one
of the regions hospitals. However, 43.3% also reported visiting folk healers when they are ill. Diseases
villagers must contend with include Malaria, Hepatitis A, B, and C, Typhoid, Dengue fever,
Schistosomiasis, and Cholera (Appendix I14). Very few households have latrines, which makes for poor
sanitary conditions in the villages. Only 33.3% of households reported using latrines (DPC, 1999a)
(Appendix I2).
4.2.5.12 Aesthetic Values
The landscape at the MPSA does not offer natural aesthetic value to the project. The topography of the
area is relatively flat with elevations typically less than 2.3 metres above mean sea level. Thus,
opportunities to use natural landscape features to obscure the power station are limited. Other land-uses
near the MPSA include industrial, commercial, and residential developments. The visual nature of these
buildings and structures are similar to those structures of the power station and may lessen its visual
impacts (MEP, 1997).
Further, the Meghna River Bridge, situated approximately 1000 metres north of the MPSA, extends to a
height of approximately 20 metres above the river, while the existing Meghnaghat Comilla transmission
line towers are 140 metres in height. Both of these elevated features, coupled with the other existing
industrial land-uses surrounding the MPSA, may also serve to lessen any visual impacts associated with
the power station. Furthermore, aesthetic issues are not considered significant by local people
particularly in this densely populated area of Bangladesh and are secondary to the peoples desire for
reliable electricity (MEP, 1997).
4.2.6 Cultural Conditions
4.2.6.1 Religious Characteristics
Sonargaon Thana, part of former Bengal, boasts a rich history. While the area was under competing
influences for some time, it is believed that Moslem rule was officially established throughout all of Bengal
between 1322 and 1328. Prior to Moslem rule, Sonargaon Thana was predominantly Buddhist. Even
today, the relics of a 13
th
century Buddhist palace can be found within a 10-kilometre radius of the project
site (Appendix I15).
Under Moslem rule, Sonargaon became the capital of East Bengal. Fifteenth century Chinese voyagers
wrote that Sonargaon was a splendid walled city, with broad roads, temples, and bazaars. This history
has left the region with a number of forts and tombs, which reflect the architectural influences of the time
(Figure 4.10). Within a 10-kilometre radius of the project site are the Hajiganj, Sonakanda, and Idrakpur
forts (~1660 A.D.), the tomb of BibiMarium (1700 A.D.), and the palace of Isha Khan (DPC, 1999c).
Todays Bangladesh is 84% Moslem, 15% Hindu, 0.6% Buddhist, and .03% Christian (Bigelow, 1995).
These variant religious influences have resulted in a number of mosques, Hindu shrines, and other holy
areas within a 10-kilometre radius of the project area. These include the Jam-e-Mosque (1700-1750), the
shrine of Noor Mohammad Shah, the QadamMobarak Mosque, the holy place of Langalband, the shrine
of Sultan Giyasuddin (1399-1410), the SreeSree Joy Kali temple (1277), the SreeBasudeb temple (1277),
and the Mahakali temple (1500), and are shown on Figure 4.12 (DPC, 1999c).
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4.2.6.2 Quality of Life
In the survey, when asked how they spent their spare time, 90% of villagers stated that they spend most
of their leisure time gossiping, visiting neighbours, and having tea. Approximately 50% of villagers,
primarily those who have access to electricity, reported spending time watching television and listening to
the radio (Appendix I2). Music, theatre, dance, and art also remain important components of rural life
(DPC, 1999a).
Only 2% of villagers earn incomes that are below the Bangladesh poverty line (i.e., 15,000 Taka or USD
330/annum). Of the villages surveyed, more than 40% of households earn between 15,000 and 40,000
Taka and 10% of households earn more than 100,000 Taka (US$ 2,200) annually. This income range
suggests that the local population is faring relatively well economically as compared to other areas of
Bangladesh (DPC, 1999a).
Housing conditions also indicate a better than average economic situation. Approximately 90% of houses
are built with corrugated iron (CI) sheets, while 5% of houses are made of brick. Only 1.7% of houses are
made completely of mud (DPC, 1999a).
Approximately 25% of households reported receiving aid from various non-governmental organizations
(NGOs), with 20% receiving loans from commercial banks, and 27% of people having salaried
occupations with commercial, government, and NGO organizations. Male household heads generally
dominate these salaried positions. Approximately 16.3% of people are involved in fishing, 15% are
involved in small trade and cultivation, and 6% work as wage labourers in both agricultural and non-
agricultural sectors (DPC, 1999a) (Appendix I2).
4.2.6.3 Knowledge of Proposed Project
Through the fieldwork activities, it has been determined that approximately 85% of household members
have heard about the proposed power station. These numbers are now expected to be virtually 100%
since the completion of site filling activities and Phase of the II PCDP. When asked, 78.3% felt that they
would not be affected by the project and were in favour of the project proceeding as long as sufficient
compensation packages were offered to the villages (Appendix I2).
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Figure 4.12: Location of Archaeological Sites [11 x 17]
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5. IMPACT IDENTIFICATION, MANAGEMENT, AND MONITORING
5.1 Introduction
This EIA adopts a project life cycle assessment format and builds upon the findings of the IEE report
(ESG International, 1999b) and the MEP 1997 EIA study. It focuses on the development of specific
management initiatives during the construction, operation, and decommissioning phases of the project to
ensure that: i) the people closest to the project receive the projected benefits; ii) environmental and socio-
economic impacts are minimised; and iii) health and safety impacts are kept to a minimum. To optimize
the life cycle assessment, linkages between potential impacts (i.e., key environmental issues), mitigative
measures (i.e., management actions), net effects (i.e., residual effects), and monitoring programs (i.e.,
management decision tools) are explicitly made.
A summary of project issues, based on the project site configuration, is presented in tabular format in
Section 5.5. The tables provide the basis for development and implementation of a detailed
Environmental Action Plan, which is discussed in Section 6 of this EIA study. Certain issues have been
identified as requiring a greater level of information and analysis than can be conveyed solely through the
use of tables. These are referred to as project specific key issues and are summarised in Section 5.4.
Where appropriate, supporting technical information is provided in the appendices to which the reader
with a specific interest can refer.
5.2 Compliance with World Bank Operational Policies
IDCOL guidelines require the project to comply with all World Bank environmental and social safeguard
policies. The applicable World Bank policies, along with a brief statement indicating project compliance
with each policy, are provided in Table 5.1. Included also are comments on compliance of the power
station with the draft World Bank polices on Labour and Public Disclosure of Information.
Table 5.1: Compliance of the Power Station with World Bank Operation Policies
WB Policy Status: Rationale
OP 4.01, Environmental Assessment Power station complies: An environmental assessment is being prepared following the
requirements for a Category A project.
OP 4.04, Natural Habitats Power station complies: Power station site is located adjacent to a developed national
highway corridor in an area away from critical natural habitats.
OP 4.11, Pest Management Power station complies: No significant pest management activities will be undertaken.
OP 4.20, Cultural Property Power station complies: No cultural property or artefacts are located on or immediately nearby
the power station site.
OP 4.36, Forestry Power station complies: No deforestation activities are to be undertaken.
OP 4.37, Safety of Dams Power station complies: The power station does not involve dam construction.
OP 7.50, Projects on International
Waterways
Power station complies: The power station does not have a significant effect on navigation or
water flow in the Meghna River.
OP 7.60, Projects in Disputed Areas Power station complies: The power station is not situated in a disputed area.
Draft OP/BP 4.12, Involuntary
Resettlement
Power station Complies: A RAP has been prepared to ensure those affected by the power
project are adequately supported for losses
OD 4.20, Indigenous People's Not Applicable: no indigenous peoples as defined by the OD have been identified to be living
in the vicinity of the power station
Labour Standards Power station complies: The Project Sponsor will not utilize forced or child labour.
Disclosure of Information Policy Power station complies: Information about the power station will be made available locally and
nationally in Bangladesh. The PCDP will be made available in the native language.
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5.3 World Bank Key Issues
The World Bank guidelines for new thermal power stations (1998) summarize the key production and
emission control practices necessary to achieve compliance. This section identifies the applicable issues
and describes how each has been addressed during project planning activities.
Issue 1: Choose the cleanest fuel economically available.
As natural gas is available domestically and is cleaner-burning than oil or coal, the power station will
utilize indigenous natural gas for fuel.
Issue 2: Select the best power generation technology for the fuel.
Selection of the power generation technology and pollution control systems should be balanced with
the environmental and economic costs and benefits based on the site-specific EIA. Combined cycle
technology, utilizing dry low NO
X
burners, will be used to generate power. Combined cycle technology
possesses the most efficient process for producing power from natural gas, in addition to minimizing
the rate of air emissions per unit of power produced. The EIA identified no significant environmental
costs that could be alleviated by using alternative power generation technology (e.g., conventional
steam boiler, simple cycle gas turbine).
Issue 3: For pollution control, consider that particulate matter smaller than 10 microns in size (PM10) are
most important from a health perspective, and acceptable levels of removal are achievable at
relatively low cost.
The emission rate of PM10 will be well below both the emission guidelines of the World Bank and the
emission standards of the GOB.
Issue 4: For pollution control, consider that low NO
X
burners and other combustion modifications can
achieve NO
X
reductions.
The gas turbines will be equipped with dry, low NOx burners that at loads above 50% have NOx
emissions well below emission guidelines of the World Bank and the emission standards of the GOB.
Issue 5: Before adopting expensive control technologies, consider the option of achieving offsetting
reductions in emissions of critical pollutants at other sources within the airshed to achieve acceptable
ambient levels.
Preliminary baseline ambient air quality monitoring indicates that the project site is located in a
relatively clean airshed, as defined in the World Bank guidelines (1998). The combination of
combined cycle technology, sulphur and dust-free natural gas, with dry, low NOx burners will allow the
power station to operate within ambient air quality guidelines and preclude the need for offsetting
emission reductions.
Issue 6: Sulphur oxides removal systems that generate less wastewater are normally preferred.
The sulphur-free natural gas being used precludes the need for desulphurisation technologies.
Issue 7: Ash disposal and reclamation should be managed to minimize environmental impacts.
Ash will not be generated by the power station.
Issue 8: Consider re-circulating cooling systems where thermal discharge to water bodies may be of
concern.
The power station is situated on the Meghna River, one of Bangladeshs largest rivers. Thermal
plume modelling indicates that the power station can operate within the applicable World Bank and
Bangladesh guidelines for thermal effluent (Appendix J3).
Issue 9: A comprehensive monitoring and reporting system is required.
The Project Sponsor will follow the comprehensive monitoring program that has been set out in the
Environmental Action Plan, in Section 6 of this EIA Report.
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5.4 Project Specific Key Issues
The key project issues were determined to be:
dredging of the Meghna river for material to raise the site;
cooling water abstraction and discharge;
noise levels in adjacent rural villages; and
ground level concentrations of NO
2
and PM
10
; and
economic dislocation of project affected people.
These key issues are addressed in the following subsections. Other issues of a more routine nature,
including occupational health and safety, waste disposal, and natural hazards are addressed in Section
5.5.
5.4.1 River Dredging and Site Filing
The Land Lease Agreement, implemented under the laws of Bangladesh, required the BPDB to raise the
project site one meter above the 1 in 200 year flood level by November 15, 1999. This translates
approximately to eight metres above the mean water level based upon Public Works Datum (PWD). The
filling was required as the undeveloped site was subject to seasonal flooding.
Dredging and site filling activities are not included in the Bangladesh Environment Conservation Rules
(1997) list of project categories that require an IEE or EIA report. The BPDB did, however, obtain Site
Clearance from the DOE to execute the site filing works and construction of the access road based upon
the 1997 EIA report prepared by MEP. The BPDB and their subcontractor, the China National Water
Resources and Hydropower Engineering Corporation (CWHEC), were responsible for mitigating and
monitoring the associated effects.
River sediments are the principal indigenous source of fill material in the low-lying areas of Bangladesh.
Fill material for the project site, as for the entire MPSA, was obtained from the Meghna River by dredging
a total area of approximately 2 km
2
, to an average depth of four metres. Approximately 8,000,000 m
3
of
fill were required to raise the MPSA to the desired level and was completed in the first quarter of 2000.
Typical effects associated with dredging (e.g., scour and turbidity) are discussed in sections 5.4.1.2 and
5.4.1.3.
The CWHEC undertook the dredging and site filling works under the supervision of the state run agency
BPDB. AES was not involved in assisting with or overseeing any of these works, and were given only
controlled/limited access to inspect the works completed up to August 1999. The numerical modelling
testing report and post-dredging bathymetry carried out by CWHEC and Survey 2000 are contained in
Appendix I4 and Attachment I4-1. Since dredging was completed approximately one year ago, no other
documentation is expected from the BDPB.
5.4.1.1 Waterlogging
During the public consultation meetings, local residents from Islampur and Ganganagar noted that the
waterlogging of lands had occurred as a result of construction of the BPDB access road. Water that had
once moved freely across the land, prior to the access road, was then restricted in its flow and
accumulated on the land.
At the time the access road was constructed, the BPDB also constructed a culvert beneath the road to
facilitate the movement of water. Maintaining the openings of the culvert has partially resolved this
problem, however, recent site filling activities and industrial discharges by adjacent landowners have
altered the areas drainage characteristics; increasing the effects of ponding.
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Construction, operation, and maintenance of the access road are the direct responsibility of the BPDB.
Therefore, in November 2000, the Project Sponsor formally requested the BPDB to review the
performance of the culvert, and if found ineffective, to undertake any corrective measures necessary to
rectify the situation. The BPDB has indicated that it does not consider drainage to be an issue and plans
no corrective actions (Appendix M6).
Should the problem persist into the second quarter of 2001, it is anticipated that the Project Sponsors
Community Liaison Officer will be alerted to the issue and again take the appropriate follow-up actions
with the BPDB.
5.4.1.2 Scouring and Flow Effects
The CWHEC analysis of scouring and flow effects related to dredging (Appendix I4) included
examination of:
flow conditions for the embankment protection adjacent to the MPSA;
changes in river flow velocity distribution after dredging; and
riverbed scouring distribution and local scouring after MPSA development.
It is understood that the dredging plan implemented by CWHEC included three borrow areas in the
vicinity of the MPSA (Figure 3.4):
i. Borrow Area A: located immediately west of the MPSA, with an area of approximately 0.5 km
2
.
According to the Tender Documents, CWHEC concluded that dredging of this area would have
little effect on the flow conditions and riverbed scouring;
ii. Borrow Area B: located immediately to the south of the MPSA and adjacent to Borrow Area A,
roughly centred within the main channel of the river, with an area of approximately 1 km
2
.
CWHECs modelling predicted that dredging of this borrow area would have limited adverse
effects to local scouring depths and velocity distribution. The modeling report commented that
dredging of Borrow Area B may strengthen the transportation capacity of the main channel; and
iii. Borrow Area C: located outside of the main channel of the Meghna River immediately north of the
MPSA with an area of less than 0.25 km
2
. CWHECs modelling report did not discuss potential
scouring effects for Borrow Area C.
Survey 2000, on behalf of CWHEC, has prepared a post-dredging bathymetry report, a copy of which is
provided in Appendix I4-1. Relative to the pre-dredging river bottom level, the report lists the depth to
which sediments were removed from the Meghna riverbed during the dredging activities. Consistent with
the initial dredging plan, dredging occurred to an approximate depth of four metres through the majority of
the dredge area.
5.4.1.3 Turbidity and Sedimentation Effects
Dredging activities can affect aquatic life through direct physical effects to organisms in the dredging area
(e.g., sessile organisms including plants, molluscs, and benthos) and through indirect effects related to
organisms in proximity to the dredging area. The indirect effects are caused by increased turbidly levels in
the water and by downstream deposition of sediments released in the water by the dredging activity.
Given that the Meghna River has naturally high turbidity levels and high rates of sedimentation,the
indigenous populations of aquatic life are pre-adapted to these conditions. The dredging was not
expected to significantly affect long-term sediment loadings in the river, and had only a short-term effect
on benthos (i.e., bottom dwelling organisms) within the borrow areas and in downstream areas affected
by increased sedimentation. Such organisms are expected to quickly recolonize the affected areas
following the completion of dredging activities. Generally, solids suspended during river dredging
operations re-settle within 500-1000 meters of the dredge (Bohlen et al., 1979; Koba and Shiba, 1981).
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The river is sufficiently wide (i.e., ~1,000 metres) to allow fish and other active swimmers that might have
been affected by the turbidity to avoid the highest turbidity areas. Overall, no long-term deleterious effects
are expected on aquatic life due to the temporary increased turbidity levels and corresponding
downstream sedimentation.
5.4.1.4 Flood Water Distribution
As noted, the project site has been elevated to approximately +8 metres PWD, roughly one metre above
the 200 year design storm event level. The riverbanks north and south of the project site have been
spuriously built up to accommodate various industries and commercial ventures, however, some areas
remain in a relatively natural state.
Given the width of the Meghna River in the proximity of the project site, elevating the MPSA to its current
height is not anticipated to have a significant effect on downstream land-uses. Considering the existing
seasonal fluctuations of the Meghna River, elevating the project site is not expected to affect local rises in
river water depth.
5.4.2 Cooling Water Discharge
The power station will withdraw approximately 15.5 m
3
/sec (56,000 m
3
/hr) of water from the Meghna River
for once-through cooling purpose. The Project Sponsor has obtained a No Objection Certificate for the
water withdrawal from the Bangladesh Inland Water Authority (Appendix D7). Under normal operating
conditions the cooling water will experience a 5.5 C temperature rise as it passes through the steam
condenser. It will be returned back to the river at a downstream point located approximately one
kilometre from the water intake (Figure 4.3).
In rare circumstances it will be necessary to operate in by-pass mode, routing the steam from the HRSG
around the steam turbine (i.e., ~1% of the operating time and only for approximately ten minutes to allow
for the safe shut down of the power station). In bypass mode, the increase in temperature across the
condenser will be rise to 9.5C and then decrease again as the shut down process advances towards full
stop.
The average of the annual minimum discharges recorded by Bangladesh Water Development Board
during the years 1990 through 1995 was 1,987 m
3
/sec. Abstraction of water at 15.5 m
3
/sec for cooling
purpose is 0.78% of this average minimum discharge. The past record shows that minimum discharge
occurs during the last week of November. During this period, the river becomes tidal and exhibits bi-
directional flow.
Cooling water dispersion simulations were carried out by the Danish Hydraulic Institute (DHI)/Surface
Water Modelling Centre (SWMC) as part of the 1997 EIA report. The 1997 modelling was based upon a
conceptual design and layout for the power station. Specifically the 1997 modelling assumed a cooling
water output of 8 m
3
/sec at a temperature 8C above ambient from each of the three power stations at the
MPSA. The 1997 modelling predicted that the warm water effluent could be released to the river in
compliance with DOE standards and World Bank guidelines and without significant effects on aquatic life.
These simulations were updated as part of the September 2000 EIA study using the specific design
parameters for the power station (Table 5.2). The model also examined the potential for cumulative
effects from development of the Phase II power station at the MPSA. Phase III was not considered as the
timing of its development is uncertain and the BPDB had not issued any bid package for the project.
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Table 5.2: Thermal Plume Modelling Discharge Parameters
Scenario Flow/Temperature Operating Phase
1 15.5 m
3
/s, 5.5 C above ambient Phase I normal operation
1
2 15.5 m
3
/s, 9.5 C above ambient Phase I steam turbine bypass
2
3 31.0 m
3
/s, 5.0 C above ambient Phase I & Phase II normal operation
1
4 31.0 m
3
/s,6.5 C above ambient Phase I normal operation & Phase II steam turbine bypass
2
1. Normal operation occurs when the power station (including gas turbine, HRSG, and steam turbine) is operating at or near maximum
operating load conditions, expected 99% of the time.
2. Steam turbine bypass may only occur during emergency situations due to a mechanical malfunction in the steam turbine.
For modelling purposes, it was assumed that the Phase II power station would be of the same design as
the Phase I power station and would discharge from the same point (i.e., an open cooling water discharge
canal running along the riverbank and discharging into the Meghna River at the south-west corner of the
MPSA). The detailed results of the modelling are provided in Appendix J3. The following subsections
summarize the model methodology and results. In addition, a detailed analysis of potential effects on
aquatic life was carried out, as documented in Appendix J4.
5.4.2.1 The Model and Its Inputs
Two professional computer based numerical modelling packages were applied to the study: MIKE 11 and
MIKE 21. The primary modelling tool used was MIKE 21, a comprehensive two-dimensional modelling
system used to examine hydrodynamics, heat and mass balances, and sediment transport, including
thermal discharges. The modelling was based upon the operational discharge characteristics as provided
by the Construction Contractor for the power station (Table 5.2). Figure 5.1 shows the intake and
discharge locations used in the model, together with the control points that were selected for presentation
of time series (TS) data from the hydrodynamic (HD) and advection dispersion (AD) simulations. The
corresponding co-ordinates are shown in Table 5.3.
The cooling water design characteristics were integrated into the model along with the flow velocities,
water level data, and bathymetry of the River. The modelling focused upon the worst case, low flow dry
season conditions that may occur once in every 50 years as determined from a hydrological analysis of
the River (SWMC, 1997). Under a normal low flow dry season, the water levels and flows are much
higher than the worst case situation assumed in the model. During periods of moderate and high river
flows, typical of wet season conditions, cooling water is quickly assimilated by the relatively high flow
volume of the river and thus does not pose a concern.
Based upon the SWMC hydrological analysis of the Meghna River (1997), it was found that the first two
weeks of February 1991 represent the worst flows in the 50-years return period (i.e., an adverse dry
season period). Thus, this time series represents a practical worst-case situation in terms of the extent of
the mixing zone and potential for recirculation of the cooling water, as it is based upon adverse
assumptions about water flows and levels (Figure 5.2).
Figure 5.1: Intake and Discharge Locations and Time Series Points
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Table 5.3: Intake and Discharge Locations and Control Points for the Time Series
Feature Phase I Phase II
Intake I 45,66 --
Intake II -- 43,64
Discharge 36,61 36,61
AD-TS 25,58 Downstream
AD-TS 39,55 Downstream
AD-TS 55,67 Upstream
HD-TS 55,60 Midstream
Figure 5.2: Calculated Current Velocity and Water Level (Dry Season)
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The graph of current velocities presented in Figure 5.2, shows that the river is tidal during the selected
dry season time series (i.e., at the HD-TS point), with velocities ranging from 0.5 m/s (flood flow) to
+0.31 m/s (ebb flow). Surface water levels over this same time series range from 0.85 meters (low tide)
to 1.6 metres (high tide) above the zero mark. All elevations are relative to PWD.
5.4.2.2 Model Results
Based upon the model inputs and using excess temperatures, the largest distance from the discharge
port to the estimated envelope of the 3C isotherm has been calculated using the worst-case flow as
described above. Table 5.4 shows the calculated distances for the four operating Scenarios.
Table 5.4: Results of Thermal Plume Modelling for AES Meghnaghat Power Station
Operating Scenario Distance from Discharge Port to Estimated 3C Isotherm
of Excess Temperature
1 1.0 km
2 3.6 km
3 2.2 km
4 4.5 km
When the phase I power station is in operation, the maximum distance that the 3C envelope may extend
downstream is one kilometre based upon the worst case low flow (i.e., 1 in 50 years). Under operating
scenario 2, with the phase I power station operating in bypass mode, the downstream distance was
calculated on the basis of continuous operation in bypass mode over an extended period of time (i.e., 360
hours). However, in actuality, the phase I power station will only operate in bypass mode for a short
period of time; a maximum of ten minutes as it shutdowns. Thus, the effect of the 9.5C excess
temperature increase under bypass operating conditions will only persist for a short time period and will
likely be similar in effect to scenario 1.
Under operating scenario 3, when the phase I and II power stations will operate in normal mode, the
downstream distance of the 3C envelope will extend to 2.2 kilometres. Under operating scenario 4,
phase I in normal operation and phase II in bypass mode, the downstream distance of the 3C envelope
will extend 4.5 kilometres. Both distance were calculated based upon the 1 in 50 years worst case flow
conditions and an extended operating time (i.e., 360 hours) in bypass mode.
It is expected that the above distances would rarely, if ever, be encountered during the lifetime of power
station due to the: i) limited operating time in bypass mode of the phase I power station (i.e., maximum of
10 minutes); and ii) flow conditions occurring once in every 50 years at the same time as the power
station is operating in bypass mode. Thus, in an average dry season, the downstream distances will be
much lower than those predicted by the model.
Dilution percentages, including the effects of cooling water recirculation at the isotherm edge, were also
calculated and are discussed in section 5.4.2.4.
Scenario 1: Normal Operating Conditions
The modelling indicates that under worst case low flow conditions (i.e., 1 in 50 years), the maximum
distance from the discharge port to the downstream edge of the 3C isotherm is one kilometre as
discussed above. However, under a normal dry period, the downstream distance would be much shorter,
possibly around 100 metres, and is not expected to have any significant effect on aquatic biota.
Figure 5.3 shows the time series of excess temperature at selected locations (i.e., the AD-TS points) in
the river within the model area (see Figure 5.2). As shown in Figure 5.3, at the downstream point
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located approximately one kilometre from the discharge port (illustrated by the black line in the upper part
of the figure), the excess temperature does not exceed 3C at any time during the 15 day modelling
period. In fact, most of the time the increased temperature is around 1C. Although these values apply to
the specific simulation period, recall that this time series was selected as the adverse dry season period
based upon hydrological analysis of the River (SWMC, 1997).
In a reversing tidal flow that prevails in the driest part of the dry season, the thermal plume will extend
upstream part of the time and downstream part of the time. Under these conditions, any given location
will only be affected by the thermal plume part of the time (except in close vicinity of the outfall), in which
case the average excess temperature will become much less as can bee seen from the time series.
Such a plume is not expected to have any long-term effects on aquatic life: i) for the short duration that
the plume is present fish would be able to avoid it; and ii) the warm water of the plume is buoyant
compared to the cooler ambient water of the river and thus bottom dwelling species and benthos would,
for the most part, be unaffected. The plume will not present a lethal barrier to plankton and will not have a
long-term effect on plankton abundance.
Excess temperature increases at cooling water intakes I and II are limited to roughly 1C or less
throughout the modelled cycle as illustrated in the bottom graph of Figure 5.3. Such a limited increase,
coupled with the short duration of the increase, is not anticipated to affect the operating conditions of the
phase I power station. This potential for water recirculation is discussed further in Section 5.4.2.4.
Figure 5.4 shows the time series of excess temperature during a normal wet season. As shown in the
figure, the excess temperature at the furthest downstream point (i.e., AD-TS point 25,58) is negligible
(~0.1C). During this period, cooling water is quickly assimilated by the relatively high flow volume of the
river and thus does not pose an environmental concern. The potential for cooling water recirculation
under this model cycle is also negligible, not affecting power station operations.
Figure 5.3: Time Series of Excess Temperature (Scenario 1 Dry Season)
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Scenario 2: Bypass Operations
The chance that bypass operations will coincide with the 50-year worst-case flow is extremely remote. As
noted, the power station will only operate in bypass mode when the steam turbine is out of operation due
to mechanical malfunction and/or for the time required to reduce the combustion turbines to 50% load.
Similar to the malfunction shutdown period, the required time for such a load reduction is also ten
minutes. For this short duration, the power station will discharge cooling water at 9.5C. For continued
reference, steam turbines have a higher reliability factor compared to combustion turbines. Thus, plant
mechanical malfunctions are more likely to be related to the reliability of the combustion turbines rather
than that of the steam turbine.
The distance from the cooling water outfall to the downstream edge of the 3C isotherm during bypass
operations was estimated to be 3.6 km during the 50 year worst case flow. This distance has been
estimated based upon the assumption of continuous power station operation in bypass mode for 360
hours. Thus, the actual 3C isotherm resulting from the ten minute bypass operation period will be much
less in distance and duration, posing minimal concern for aquatic biota.
Scenarios 3 and 4: Cumulative Effects
To examine the possible cumulative effects, modelling was also carried out to assess the effects of
operation of the AES Meghnaghat power station in combination with the second phase power station,
both discharging at the same location. Two scenarios were considered: Scenario 3 both plants in
normal operation; and Scenario 4 AES Meghnaghat in normal operation and the Phase II plant in
bypass operation. The chance of both plants operating in bypass mode was considered so remote a
possibility as to not warrant consideration.
The time series of excess temperature for operating scenario 3 is shown in Figure 5.5. At AD-TS point
25,58, situated in the side channel approximately one kilometre downstream of the discharge port, a
maximum excess temperature of 3C is experienced only a few times and for a short duration during the
two week model cycle. An average excess temperature at this point is roughly 2C over this model cycle
compared to a 1C excess temperature under operating scenario 1. At the other two AD-TS points, the
3C marker is not exceeded at anytime throughout the same model cycle. The bottom graph on Figure
5.5 shows the excess temperature at intakes I and II which are discussed further in Section 5.4.2.4.
Figure 5.4: Time Series of Excess Temperature (Scenario 1 Wet Season)
Figure 5.5: Time Series of Excess Temperature (Scenario 3 Dry Season)
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For Scenario 3 the thermal plume, in worst-case conditions, extends 2.2 kilometres downstream of the
discharge port. Similar to Scenario 2, Scenario 4 is of minor concern due to the short duration of time
that bypass operations will persist (i.e., ten minutes).
Figure 5.6 shows the time series of excess temperature during the west season for scenario 3. The
excess temperature at the downstream AD-TS point (25,58) is roughly 0. 2C. The figure also indicates
that during the wet season, thermal discharge poses no concern for aquatic biota.
Figure 5.6: Time Series of Excess Temperature (Scenario 3 Wet Season)
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5.4.2.3 Summary of Thermal Plume Modelling
The majority of time throughout the year, the thermal plume coming from the cooling water of the AES
Meghnaghat power station will be relatively small, with the distance to the downstream edge of the 3C
isotherm falling well within 100 metres from the discharge port. This is not expected to have a significant
effect on aquatic biota and is considered to comply with World Bank guidelines.
Under unusual worst case conditions corresponding to the 50 year low flow event, the 3C isotherm will
extend up to one kilometre downstream if the power station is in normal operation. Again, the short term
and infrequent nature of this operation mode, coupled with the 1 in 50 year low flow event, is not
expected to cause any significant long-term effects on aquatic biota.
5.4.2.4 Potential for Cooling Water Re-circulation
Computer modelling was also undertaken to determine the potential that cooling water recirculation might
have on the thermal discharge plume. Specifically, MIKE 21 modelling was undertaken for the dry
season, when the Meghna River is dominated by tidal flows with negligible net flows.
The results of the computer modelling predicted that, with tidal conditions, thermal accumulations would
occur in front of the MPSA under reversing flow conditions (i.e., the upstream movement of water).
Consequently, recirculation will occur, further increasing the discharge temperature. The predicted effects
of thermal accumulation upon cooling water discharge are summarised in Table 5.5 with the detailed
results shown in Appendix J3.
Table 5.5: Predicted Thermal Effects of Cooling Water Recirculation
Scenario Intake I Intake II
Ave Max Ave Max
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Phase I in normal operation 0.1C 0.9C -- --
Phase I and II in normal operation 0.1C 1.8C 0.2C 2.2C
Note: ave and max refer to the actual simulation period that covers a fortnightly tidal cycle with a negligible net flow.
As indicated in Table 5.5, the temperate effects of recirculation under the worst case low flow conditions
(i.e., 1 in 50 years) at intakes I and II will be negligible under average tidal cycle, even with both power
stations operating. For example, when the phase I power station is in normal operation, the predicted
average excess temperature at has been calculated at 0.1C, while the maximum excess temperature will
be 0.9C. When both the phase I and II power stations are in normal operation the average excess
temperatures are still negligible at 0.1C at intake I and 0.2C at intake II. Such a small change in the
intake water temperature will have a limited, if any, effect on the discharge temperature or the
characteristics of the thermal plume.
Over the modelled tidal cycle, there are some minor variations to the mean recirculation values shown in
Table 5.5. The variations, based upon the worst case low flow tidal conditions, are shown in Table 5.6.
The table indicates that if the phase I power station is operating during the adverse low flow period, intake
I will experience excess temperatures above 0.5C, but below 1.0C, 4.9% of the time. Such limited
occurrence are not anticipated to affect operating condition or aquatic biota.
Table 5.6: Predicted Excess Temperature at Intake I
(Phase I in Normal Operation Dry Season)
Factor Value
Temperature (T) in C 0.5 1.0
Percent of Time above T 4.9 0.0
Values are related to adverse flow conditions (i.e., 1 in 50 year flows) and are not valid in general
Table 5.7 shows that under normal operation of the phase I and II power stations, with worst case dry
season flows, the predicted excess temperature at intake I will be above 0.5C 9.6% of the time, above
1.0C 4.9% of the time, and above 1.5C only 1.4% of the time. At intake II, under the same conditions,
excess temperatures of 0.5C are predicted 12.2% of the time, while excess temperatures of 1.0C,
1.5C, and 2.0C are anticipated 7.2%, 3.5%, and 0.6% of the time, respectively.
Table 5.7: Predicted Excess Temperature at Intakes I and II
(Phase I and II in Normal Operation Dry Season)
Factor Value
Intake I
Temperature (T) in C 0.5 1.0 1.5
Percent of Time above T 9.6 4.9 1.4
Intake II
Temperature (T) in C 0.5 1.0 1.5 2.0
Percent of Time above T 12.2 7.2 3.5 0.6
Values are related to adverse flow conditions (i.e., 1 in 50 year flows) and are not valid in general
Under maximum adverse river conditions (i.e., the estimated 50-year return period), the temperature
effects of recirculation are more noticeable at intakes I and II, ranging from 1.8 2.2C. However, as
noted the 50-year return period is of limited occurrence and therefore contributes little in terms of
assessing power station operations with regard to recirculation and environmental effects (DHI, 2000). In
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the event that these recirculation conditions occur, the effect will be of a relatively short duration and is
not expected to have a significant effect on aquatic life.
Based upon the predicted modelling results, no protective or mitigative measures are recommended to
minimise the potential effects of cooling water recirculation (Appendix J3). However, an alternative
discharge method, that is an underwater pipeline discharging 100 150 metres into the Meghna River,
was investigated by the Project Sponsor at the request of the BPDB following the completion of the
September 2000 EIA report. This design, while technically and economically feasible, has since been
abandoned because the BPDB has been reluctant to commit to the additional resources involved with this
discharge design.
Consequently, the conservative modelling carried out as part of the September 2000 EIA report is being
re-reviewed by the Construction Contractor in an effort to refine the downstream mixing zone. As part of
this review, the Construction Contractor will redo the modelling with regard to average station operations
and river conditions. Regardless of the reviews outcome, the Construction Contractor is contractually
obligated to ensure compliance with DOE standards and World Bank guidelines.
5.4.2.5 DOE Effluent Temperature Standards
Under normal operating conditions the power stations discharge will be 31.5C during winter when the
ambient temperature is estimated to be 25C, and 37.5C during summer when the ambient temperature
is assumed to be 32C. These temperatures meet the DOE requirements that discharged effluents be
45C or below during winter and 40C or below during summer.
Under the unusual circumstance when the power station must operate in bypass mode, the effluent
temperatures will be 34.5C in winter, which is well within the DOE limit of 45C, and will be 41.5C in
summer, which marginally exceeds the DOE limit of 40C. The power station is expected to operate in
bypass mode ten minutes only on each occasion the steam turbine is tripped. As noted, steam turbines
are more reliable with than gas turbines and operation in bypass mode would be limited and/or unlikely.
Thus, exceedance of the DOE limit of 40C will rarely occur and due to its short duration (i.e., ten
minutes), it is anticipated that rare exceedance will not have adverse impacts on aquatic biota.
5.4.2.6 Fish Impingement and Entrainment at Water Intake
Damage to fish and other aquatic animals may occur by either impinging larger organisms against the
fixed bar screens or by entraining small organisms in the cooling water as it is pumped through the power
station. Impingement of aquatic organisms can be caused by hydraulic forces in the intake stream prior
to its flow through the coarse bar screen and rotating band screen, and is often lethal due to starvation,
exhaustion, asphyxiation, and exposure to descaling or rake mechanisms. Entrainment may damage
organisms passing through the MCWS by physical impact, pressure changes, thermal shock, or chemical
toxaemia (USEPA, 1976).
The fixed bar and travelling band screens, or similar less lethal screens such as inclined-plane screens,
will aid in reducing the number of aquatic organisms entering the CWS. Impingement will be reduced
through the installation of electronic fish deterrent devices. The effect of impingement on small aquatic
organism populations is expected to be minor as these organisms typically have high recruitment rates.
In addition to the consideration already given to these factors in the EIA, the Construction Contractor will
further evaluate these recommendations during the detailed design phase, and in light of the detailed
description of potential effects on aquatic life as provided in Appendix J4.
5.4.2.7 Water Circulation Patterns
Based upon the findings of the Aquatic Environment Evaluation (Appendix J4), no significant effects are
expected on river water circulation patterns due to the operation of the water intake and discharge
structures. Any minor changes in water circulation patterns will be limited to the area immediately
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adjacent to the intake and discharge structures, thus allowing sufficient room for fish movement outside of
the affected areas.
However, there may be some localized effects on turbidity levels in the immediate vicinity of these
structures. Given the high ambient concentrations of suspended solids within the Meghna, the existing
adaptations of the aquatic flora and fauna, and the eventual return of the affected areas to pre-operation
conditions once the substrate has stabilized, any effects associated with turbidity will be temporary and
minor (Appendix J4).
5.4.2.8 Fisheries Survey
While no significant long-term adverse effects are anticipated to the local fishery due to the construction
and operation of the power station, the Project Sponsor will undertake a new baseline survey on the fish
species present in the Meghna River. This survey will be implemented as outlined in section 6.3.8 and
used to confirm the judgements presented in this Updated EIA report. Where appropriate, the findings of
the study will be used to refine the fisheries monitoring program and assist the DOE in the assessment of
future projects at the MPSA and surrounding area.
5.4.3 Noise
5.4.3.1 Construction Phase
During construction, noise will be generated by the operation of heavy equipment and pile drivers on the
project site, vehicular traffic on the access road, and boat traffic on the river. The most sensitive receptors
for construction generated noise are the residential areas of Islampur Village and Ganganagar Village.
The Construction Contractor is contractually obligated to meet DOE noise standards and World Bank
Guidelines at the nearest residential receptors during the construction period. Generally, it is expected
that the Construction Contractor will be able to manage noise levels to meet this obligation. However, it is
also expected that in certain circumstances noise will exceed the targets (e.g., noise generated during
construction of facilities that are in close proximity to the villages).
It is generally accepted that construction activities will result in short term nuisance effects, including
noise. To minimize these effects, the Construction Contractor should restrict potentially significant
nuisance noise activities, such as pile driving, to daytime hours. In addition, sources of continuous noise,
such as portable generator sets, should be shielded or located so as to not be a nuisance to adjacent
residential areas.
Implementation of the above measures, along with the noise management measures set out in "Section
23.5 - Noise" of Hyundai's Safety, Health and Environment Policy and Procedures Manual (Appendix F)
and the good site practices set out in Table 5.11, will ensure that noise impacts will be limited to a short-
term intermittent increase in daytime noise levels.
5.4.3.2 Operation Phase
During operations the power station will be a continuous sources of noise emissions. The potential for the
emissions to result in nuisance noise has been determined by comparing the noise levels contributed by
the power station at surrounding, offsite receptors to the applicable standards and guidelines (section
4.2.2.3).
Land-uses adjacent to the MPSA include residential (rural villages), commercial, open/agricultural, and
industrial. There are no institutional land uses, such as a school or a hospital, in the vicinity. The most
sensitive noise receptors in the vicinity of the power station were identified as the adjacent villages of
Islampur and Ganganagar (Figure 1.2).
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Propagation of the noise emissions from the power station into the surrounding environment was
modelled using environmental noise modelling software. Details of the noise modelling methodology and
results are provided in Appendix J1. A summary of the salient details is presented below.
Information input into the environmental noise model included: the noise emissions levels of the various
equipment of the power station; the layout of the equipment on the site; the topography and surface
characteristics of the surrounding area; and, climatic conditions, to generate noise isopleths (or contours)
for the area surrounding the site. A conservative approach was utilized when considering the effects on
the model by the following variables:
information on the actual sound levels to be emitted for certain power station equipment was not
available. For this equipment, sound level inputs were estimated from the maximum allowable
noise levels as specified in AESs Master Specification document and from worst-case sound
levels from similar equipment presented in published literature;
it was assumed that all equipment would be operating continuously;
no provisions were made to account for the attenuation effect of buildings and structures; and
historical meteorological data from Dhaka airport indicate temperature inversions occur 40% of
the time and periods of calm winds occur about 50% of the time. These climatic conditions, which
occur primarily during the night, present worst-case conditions for noise propagation.
The model predicts that daytime noise levels at all surrounding villages, commercial, and industrial areas
will comply with GOB standards and World Bank guidelines (Table 5.8 and Figures 5.7 and 5.8).
However, during the nighttime GOB standards and World Bank guidelines are exceeded in the
homestead areas of Islampur Village, while only the World Bank guidelines are also exceeded in
Ganganagar Village. These exceedances occur at nighttime because allowable noise levels are lower at
night and because noise propagates further during the frequent nighttime temperature inversions.
Table 5.8: Predicted Noise Levels at Selected Receptors
Village Predicted
Daytime
Levels
[dB(A)]
World Bank
Daytime
Guideline
[dB(A)]
Bangladeshi
Daytime
Standard
[dB(A)]
Predicted
Nighttime
Levels
[dB(A)]
World Bank
Nighttime
Guideline
[dB(A)]
Bangladeshi
Nighttime
Standard
[dB(A)]
Islampur 53 55 60 56 45 50
Ganganagar 44 55 60 48 45 50
Bhanipur 41 55 60 45 45 50
Dhudghata 36 55 60 44 45 50
Naogaon 34 55 60 41 45 50
Asharia Char 38 55 60 44 45 50
Kurbanpur 33 55 60 42 45 50
Note: grey shading represents predicted exceedance.
These results are considered worst-case as they are based on conservative noise emission levels for
certain machineries and because the attenuation effects of existing buildings and structures are not
accounted for. It is expected that the actual noise levels will be less than the levels predicted by the
model and will likely fall within the applicable standards and guidelines. Several mitigation measures are
also available that will ensure noise levels are managed to acceptable levels as detailed in the following
section.
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5.4.3.3 Mitigation
A number of mitigation measures are available to control the noise from the power station, to ensure that
noise levels in Islampur and Ganganagar meet GOB standards and World Bank guidelines. However, the
specific mitigation measure to be applied will be the prerogative of the Construction Contractor, as the
Construction Contractor is contractually obligated to build the power station so that it can be operated in
compliance with DOE standards and WB Guidelines at the nearest residential receptors (Appendix D6).
Several possible mitigation measures, as outlined below, have been identified that could be utilized by the
Construction Contractor to meet this obligation. The Construction Contractor may also, during detailed
design, determine additional or alternative measures to meet this obligation. The mitigation measures that
have been identified are:
1. Acoustical shielding and silencing of the prime noise sources.
The most significant noise sources are the gas turbine air intake filters, the transformers, the
HRSGs, and the HRSG feedwater pumps. Potential mitigation options for reducing the noise
contributed by these sources include:
installation of acoustic silencers (e.g., acoustical louvers or duct silencers) on the gas turbine
air intake filters;
increasing the acoustical effectiveness of transformer enclosures or erecting a noise barrier
between the transformers and the receptor(s) of concern;
installation of an acoustic enclosure or barrier around the HRSG feedwater pumps or on-site
relocation;
installation of acoustical insulation on the outer surface of the HRSGs, increasing the mass of
the HRSG walls, or erecting a noise barrier between the HRSGs and receptor(s) of concern;
and
on-site relocation of support buildings to act as a noise barrier between the major noise
sources and the receptor(s) of concern.
2. Planting a 15 metre wide green belt around the eastern edge of the project site.
That is, separating the power station from the villages will be undertaken by the Project Sponsor.
Where feasible, a smaller green belt will be planted around the remaining perimeter of the project
site. Species will include local vegetation such as Jackfruit, Mango, Mahogany, Jalpai, Black
Berry, Teak, etc.
Figure 5.7: Daytime Noise Contours [11x17]
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Figure 5.8: Night-Time Noise Contours [11x17]
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3. Planting vegetative screens.
Vegetative screens will be planted immediately adjacent to extraneous ground level noise
sources, assisting in lowering the noise emissions from the power station.
These and/or other measures identified by the Construction Contractor will allow the power station to be
constructed to meet the applicable noise standards and guidelines. Noise levels at the residential
receptors will be further monitored while the plant is in full operation and during worst-case nighttime
conditions. If the monitoring indicates that there is an exceedance, the Construction Contractor will be
required to undertake remedial measures to bring the power station into compliance, as specified in
AESs Master Specification document.
5.4.3.4 Cumulative Noise Effects
Using the current location of the AES Meghnaghat power station and positioning the other two possible
power stations on their respective plots equidistant from each other, noise contours were reanalyzed.
This was done to gain an understanding of the potential cumulative effects of all three power stations,
which may be developed at the MPSA. Input parameters for each power station were considered to be
the same as the AES Meghnaghat power station.
The modelled results (Figures 5.9 and 5.10) indicated that there are significant increases in predicted
ambient noise levels at locations adjacent to the MPSA. Using a conservative, worst-case scenario it is
calculated that noise impacts would increase by 5 dB(A) at nearby receptors with all three power stations
operating at full load. This increase in ambient conditions has been calculated on the basis that
mitigation measures have not been implemented at any of the power stations (Appendix J1).
With the installation of appropriate mitigation measures at each power station, required to bring each
consecutive power station into compliance with the applicable guidelines, coupled with additional
greenbelt planting and maintenance, the cumulative noise effects of the MPSA are anticipated to be
within regulatory levels.
Since the Project Sponsor cannot regulate nor control the activities of other power developers, it will be
the responsibility of each new power station owner to ensure the cumulative noise effects remain within
the applicable guidelines.
5.4.4 Air Quality
The combustion of fossil fuels in thermal power stations can results in emission of airborne pollutants
including sulphur dioxide (SO
2
), particulate matter, oxides of nitrogen (NO
x
) and greenhouse gases
[primarily Carbon dioxide (CO2)]. Emissions of particulate matter and sulphur are primarily determined by
the content of sulphur and dust in the fuel. The natural gas fuel for the AES Meghnaghat Power Station is
naturally free of sulphur and dust. Therefore, there will be negligible emissions of these pollutants from
the power station. This leaves NOx and CO2 as the pollutants of concern. The following subsections
discuss compliance of the power station with the applicable guidelines and standards for emissions of
NO
x
and CO
2
.
5.4.4.1 Oxides of Nitrogen
The power station has been designed to operate in compliance within the NOx emission guidelines of the
World Bank and the standards of the GOB. The NO
X
emission rate of the V94.2 gas turbine engines at
varying load factors is shown in Figure 5.11 and Table 5.9. As shown, at loads above 50%, the low NO
x
burners to be installed on the turbines will reduce the NOx emissions of the engines to levels well below
the applicable standards of GOB and guidelines of the World Bank.
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Table 5.9: NO
X
Emission Guidelines and Rates
Applicable Guidelines Operational Load Scenarios - the Power Station
DOE
A
World
Bank
B
100%
DF
100%
NDF
90% 80% 70% 60% 50% 40% 30% 25%
Load scenarios of each gas turbine while two gas turbines in
operation
Load scenarios while one gas turbine
is in operation
100%
DF
100%
NDF
90% 80% 70% 60%
100%
DF
80% 60% 50%
82 mg/Nm
3
wet
125 mg/Nm
3
dry
57.46 41.04 41.04 41.04 41.04 41.04 57.46 41.04 41.04 217.53
Notes: DF = duct firing. NDF = no duct firing. Grey boxes denote emissions above the guidelines.
A. Ministry of Environment and Forest Environment Conservation Rul es. Schedule 11 - Gaseous Discharge Quali ty Standards for
Industrial Units or Project (August 1997). Values were converted from ppm using the Worl d Bank conversion factor of 2.05.
B. Worl d Bank Pollution Prevention and Abatement Handbook. Thermal Power - Guideli nes for New Plants (July 1998).
C. The tabl e assumes that at plant loads of 50% or less, one turbine will be shut down in order to increase the load of the remaining
operating turbine (i.e., at 50% plant load, one turbine will be shut down and the remainder wil l operate at 100% load).
Source: Ansaldo, 1999.
At loads between 5% and 50%, the NO
x
emission rate will exceed the World Bank guideline and GOB
standard without selective turbine use. However, in accordance with World Bank guidelines, the plant will
operate with GT loads at or below 50% less than 5% of the time. In terms of actual time required for the
power station to reach 50% load after initial start-up, the Project Sponsor has provided calculations based
upon their past experience in operating similar CCGT power stations and plant start-up and shut-down
curves provided in the Construction Contractors (EPC) contract:
Hot Start Warm Start Cold Start
GT 1 90 min 120 min 150 min
GT 2 30 min 35 min 40 min
Although the power station is capable of up to 150 starts per year, the predicted frequency of hot starts is
20 times, warm starts 10 times, and cold starts twice per year. Based upon these stoppages, the Project
Sponsor has calculated the total duration of the plant running at loads of 50% or less will be
approximately 38.5 hours per year. This accounts for less than 1% of the total forecasted operating time
(8,000 hours/year) and includes a nine-minute stop time for the GTGs after each occurrence.
Essentially, the only times that a gas turbine will operate at loads below 50% are during start-up and
shutdown and/or when the overall station load is below 28% (Table 5.10). Start-up and shutdown
conditions will occur less than 3% of the total operating time; consistent with the World Bank guidelines.
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Figure 5.9: Cumulative Daytime Noise Contours [11x17]
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Figure 5.10: Cumulative Night-time Noise Contours [11x17]
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Figure 5.11: Ansaldo Emissions Curve [8 x 11]
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Table 5.10: Gas Turbine Loads at Varying Overall Plant Loads
GT-1 Load (%) 100* 100 90 80 70 60 100 80 60 50 40
GT-2 Load (%) 100* 100 90 80 70 60 0 0 0 0 0
Plant Output with Steam Turbine (MW) 465* 445 407 369 332 295 256 205 154 128 103
Plant Load (%) 100* 96 88 79 71 63 55 44 33 28 22
* with Duct Firing
The operation of the power station at loads below 28% will be rare, and is not expected to exceed 2% of
the stations operating time, considering: i) the terms of the Power Purchase Agreement identify the
minimum dispatch rate for the power station at 25%; and ii) the power station is designed to operate as a
base load plant.
The cost of power from the power station will be low compared to other power sources in Bangladesh.
Thus, it is expected that the dispatch rate will be at loads of 90% or more at least 90% of the time. The
dispatch load will depend upon sufficient demand and upon sufficient transmission infrastructure to
distribute the power. These factors provide a reasonable basis for the assumption that the power station
will operate at loads below 50%, less than 5% of the time.
During operation NO
x
emission rates will be monitored to verify compliance with the applicable standards
and guidelines. Details of the monitoring program are set out in Section 6.
Particulate Matter
The power station emission rates for particulate matter with a diameter of ten microns or less (PM10) and
the applicable guidelines are shown in Table 5.11. Based upon the available data from the Supply
Contractor, the power station will operate within the applicable standards and guidelines.
Table 5.11: PM Emission Guidelines and Rates
Guidelines Operational Load Scenarios - the Power Station
World Bank
A
100% DF 100% NDF 90% 80% 70% 60% 50% 40% 30% 25%
Load scenarios of each gas turbine whil e two gas turbines in operation
Load scenarios while one gas turbine is
in operation
100% DF 100% NDF 90% 80% 70% 60% 100%DF 80% 60% 50%
50 mg/Nm
3
5.93 6.62 7.07 7.54 8.08 n/g 5.93 7.54 n/g n/g
Notes: DF = duct firing. NDF = no duct firing. n/g = emissions not guaranteed.
A. World Bank Pollution Prevention and Abatement Handbook. Thermal Power - Guidelines for New Plants (July 1998).
B. The table assumes that at station loads of 50% or less, one turbine will be shut down in order to increase the load of the
remaining operating turbine (i.e., at 50% plant load, one turbine will be shut down and the remainder will operate at 100% load)
Source: Hyundai, 1999.
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5.4.4.2 Stack Height Calculation
Screening level dispersion modelling was completed to identify the optimal design height for the power
stations exhaust stacks. The following summary of the modelling is based on the detailed report provided
in Appendix J2.
Stack height is a key consideration when determining a power stations contribution to ground level
concentrations of air pollutants. A preliminary estimate of the required stack height was calculated using
Good Engineering Practice (GEP), as defined by the U.S. EPA (1985). These calculations indicated a
GEP stack height of 64 metres.
A range of stack heights around the GEP height (i.e., 50 75 metres) was then modelled using the U.S.
EPAs screening level dispersion model, SCREEN3. The screening level modelling indicates that the
optimal stack height, to minimize off-site impacts, is 60 metres. This corresponds closely to the GEP
height of 64 metres. Consequently, the final optimal stack height identified was 60 metres (Figure 5.12).
5.4.4.3 Effects on Ambient Air Quality
Detailed numerical air quality modelling was completed to predict the effect that plant emissions will have
on ground level concentrations of air pollutants in the airshed of the power station. The following
summary of the modelling is based on the detailed report provided in Appendix J2.
Ground-level concentrations of NO
2
and PM
10
were predicted using the U.S. EPAs recently developed
dispersion model known as AERMOD. AERMOD offers several advantages over previous models,
including better simulation of plume rise and buoyancy, dispersion around hills, effects of terrain
roughness, and plume dispersion in both convective and stable boundary layers.
The modelling was undertaken for two scenarios. Scenario 1 assumes the plant will operating
continuously at 100% load with duct firing. Scenario 2 assumes that both turbines will operate
continuously at 50% load (in actual practice this scenario will occur rarely and only during start-up and
shutdown). These load situations are considered the worst-case scenarios as the mass flow rates for
pollutants of concern (NOx and PM10) are at their highest (Figure 5.8). The calculation of background air
pollutant levels is provided in Appendix I7.
The modelling indicates that ground level concentrations of NO
2
and PM
10
will remain well within the
applicable guidelines and standards (Tables 5.12 and 5.13). During full load conditions (i.e., Scenario 1),
the maximum predicted contribution to 24-hr average ground level concentrations of NO2 is 9 g/m
3
. The
total with background is 72 g/m
3
, which is well below the World Bank guideline of 150 g/m
3
. The
projects effect on the annual average concentrations of NO
2
is also small, and is well below the
applicable guidelines and standards. In addition, PM
10
concentrations are negligible and remain well
below the relevant guidelines.
Ground level concentrations will remain below the relevant guidelines and standards even if the power
station were to operate continuously with both turbines at 50% load (Scenario 2 in Tables 5.12 and 5.13).
In reality, the power station will rarely operate in this worst-case emission scenario, as described in
Section 5.4.4.1.
Figure 5.12: Stack Height vs NOX Ground Level Concentrations [8 x 11]
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Table 5.12: Maximum Predicted NO2 Concentrations from Operation of AES Meghnaghat Power Station
Load Scenario Maximum NO2 Concentrations (g/m
3
)
24-hour Annual
Plant
Contribution
Background Total Plant
Contribution
Background Total
Scenario 1 9 63 72 2 21 23
Scenario 2 64 63 127 12 21 33
Most Stringent Guideline 150 80
Table 5.13: Maximum Predicted PM10 Concentrations from Operation of AES Meghnaghat Power Station
Load Scenario Maximum PM10 Concentrations (g/m
3
)
24-hour Annual
Plant Contribution Plant Contribution
Scenario 1 3 Less than 1
Scenario 2 4 Less than 1
Most Stringent Guideline 150 50
5.4.4.4 Cumulative Effects on Ambient Air Quality
Detailed modelling was completed to assess the cumulative effects on ambient air quality by the AES
Meghnaghat Power Station, as well as the phase II and III power stations (Appendix J2). The modelling
assumed that the phase II and III power stations would have emission characteristics identical to the AES
Meghnaghat project.
Two scenarios were analysed: Scenario 1 assumed continuous operation of all three plants at 100% load;
and Scenario 2 assumed that at each power station one turbine would operate continuously at 100% load
while one turbine would operate continuously at 50% load. Scenario 2 is considered a reasonable worst-
case situation and in actual practice is not expected to occur with any frequency, and certainly not
continuously for any extended period of time for reasons set out in Section 5.4.4.1.
Results from the modelling indicate that ground level concentrations of NO
2
and PM
10
will remain well
within the applicable guidelines and standards during operation of the three power stations (Tables 5.14
and 5.15). During full load conditions (i.e., Scenario 1) the maximum predicted contribution to 24-hr
average ground level concentrations of NO
2
is 19 g/m
3
(Table 5.14). The total with background is 82
g/m
3
, which is well below the World Bank guideline of 150 g/m
3
. Effects on the annual average
concentrations of NO
2
are similarly small, and are well below the relevant guidelines and standards. The
cumulative effect of the three power stations on ground level concentrations of PM
10
levels are smaller
still, and are not considered to pose a significant concern.
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Table 5.14: Predicted Cumulative NO2 Concentrations from Operation of the Phase I, II, and III Power
Stations at the MPSA
Load Maximum NO2 Concentrations (g/m
3
)
Scenario 24-hour Annual
Plant
Contribution
Background Total Plant
Contribution
Background Total
Scenario 1 19 63 82 4 21 25
Scenario 2 65 63 128 14 21 35
Most Stringent Guideline 150 80
Table 5.15: Predicted Cumulative PM10 Concentrations from Operation of the Phase I, II, and III Power
Stations at the MPSA
Load Scenario Maximum PM10 Concentrations (g/m
3
)
24-hour Annual
Plant Contribution Plant Contribution
Scenario 1 5 Less than 1
Scenario 2 6 1
Most Stringent Guideline 150 50
5.4.4.5 Greenhouse Gas Contributions
United Nations Framework Convention on Climate Change
The objective of the 1992 United Nations Framework Convention on Climate Change (UNFCCC) is to
achieve stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent
dangerous anthropogenic interference with the climate system. All countries that ratify the Convention
agree to jointly assume responsibility for the protection of the global atmosphere, with the recognition that
developing country greenhouse gas emissions will exceed those from the industrialized nations within the
coming generations. The Convention took effect on March 21, 1994 and has been ratified by over 100 of
the 165 countries that are signatories. Bangladesh signed the Convention on June 9, 1992 and ratified it
on April 15, 1994. In Bangladesh, the Convention came into force on July 14, 1994.
As a Least-Developed Country (LDC) under the Convention, Bangladesh does not have any emission
restrictions. However, it does have obligations to measure and monitor greenhouse gas emissions within
the country. According to the UNFCCC, Bangladesh has not instituted a National climate change website,
nor has greenhouse gas emissions data for Bangladesh been reported in the UNFCCC Greenhouse Gas
Inventory Database (United Nations, 2000).
Kyoto Protocol
The Kyoto Protocol to the UNFCCC, limiting carbon dioxide and other greenhouse gas emissions, was
adopted on December 11, 1997. Over 84 countries have signed the Kyoto Protocol, but Bangladesh is
not yet a signatory member. The Kyoto Protocol calls for industrialised countries to reduce their average
national greenhouse gas emissions to about 5% below 1990 levels by the year 2012. However,
developing and least-developed countries (including Bangladesh) are not required to limit their
greenhouse gas emissions.
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The World Bank and Carbon Dioxide
The World Banks guidance note, Greenhouse Gas Abatement and Climate Change, is included within
the Pollution Prevention and Abatement Handbook (1998), and describes the World Banks efforts in
reducing greenhouse gas emissions. The following three focal areas are identified: i) energy efficiency; ii)
renewable energy; and iii) mainstreaming of global environmental concerns. The guidance note includes
a summary of relative emissions factors for utility and industrial combustion systems, including combined
cycle gas turbines.
Of all the alternatives listed in the guidance note, with the exception of wood-fired boilers, combined cycle
gas turbines offer the lowest carbon dioxide (CO2) emission factor. As in many places throughout the
World, wood is not a viable fuel source for large-scale electricity production in Bangladesh. Straw or other
biomass fuels might be available but again are not practical for large-scale electricity generation.
CO2 is a by-product of the combustion of fossil fuels and currently there are no GOB, IDCOL, World Bank,
or ADB guidelines for CO
2
emissions. However, the World Bank has published an emission factor for
natural gas fuels. Although not an emission guideline, the emission factor does provide an indication of
average relative CO2 emissions among varying technologies without taking into account combustion
efficiencies. For natural gas utilized in combined-cycle gas turbines, the World Bank emission factor for
CO
2
is 56,100 g/GJ energy input. Natural gas to be utilized by the proposed power station has a
comparable CO
2
emission factor of 59,177 g/GJ energy input at full load.
As discussed in the World Banks handbook and in Appendix B, combined cycle systems typically
operate at higher efficiencies than conventional thermal power systems. This allows a greater amount of
electricity to be generated per unit of fuel used and thus, minimizes the volume of greenhouse gases
released per unit of electricity produced. The efficiency of the CCGT design, coupled with the use of
indigenous natural gas fuel, will result in the lowest possible greenhouse gas emissions per unit of
electricity generated by the power station.
5.4.4.6 Afforestation Program and Greenbelt
The Bangladesh DOE, in its issuance of Site Clearance indicated that the Project Sponsor should
address Afforestation in the EIA, and that it should develop a greenbelt around the project site
(Appendix E1).
Afforestation Program
It is understood through additional personal communication with DOE that the afforestation condition of
approval refers to the planting of trees along local highways as a measure to help improve local air
quality. However, in Bangladesh, tree planting along highways is understood to be the responsibility of
the Roads and Highways Department and the Department of Forestry.
The Department of Forestry has established standard programs for roadside plantings. For example,
mahogany is considered a suitable roadside species and is planted at a density of 48 trees per km. The
Project Sponsor will discuss how it can contribute to the roadside planting efforts of the Department of
Forestry. Specifically, the Project Sponsor will suggest that it sponsor a tree-planting program for the
stretch of the Dhaka-Chittagong Highway between the Kanchpur Bridge on the Shitalakhya River and the
Meghna River Bridge near the project site.
Greenbelt
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The DOE has indicated that the Project Sponsor should develop a greenbelt at the perimeter of the power
station. As discussed previously, there is sufficient land within the project site to develop an attractive
greenbelt area. The greenbelt being developed will be compatible with site lines required for site security
and will assist not only with the absorption of CO2 emissions, but will also soften the view of the power
station from ground level, improving the aesthetics of this industrial area.
Initially, 800 young trees will be planted along the southern and eastern boundaries of the project site as
part of the greenbelt plantings. As of September 2000, the Project Sponsor had planted 500 mahogany
trees along the eastern boundary of the project site; the remaining 300 trees will be planted by the
seasons end.
5.4.5 Economic Dislocation
5.4.5.1 Meghnaghat Power Sites Area
In 1995, the Deputy Commissioner of Narayanganj District, for the BPDB, instituted eminent domain
proceedings to acquire 230.77 acres of land, comprising 145.515 acres of privately owned land and
85.255 acres of government land, under powers granted to him by the Acquisition and Requisition of
Immovable Property Ordinance, 1982 (Ordinance) and subsequent amendments. This land area was
acquired for the MPSA on Char RamzanSonaullah, Sonargaon Thana, in the Narayanganj District.
As per the Deputy Commissioners property assessment under the 1982 Ordinance, the BPDB deposited
Taka 55,694,474.83 in the Commissioners public account on January 7, 1997, as the compensation for
land, other properties, and administrative fees, and requested the land be handed over to the BPDB. At
that time, the government also held some lands that were leased out to local persons for agricultural
activities.
On May 14,1997, the Deputy Commissioner formally handed over possession of the 230.77 acres to the
BPDB. On September 2, 1997, the Deputy Commission further confirmed with the BPDB that since
compensation had been distributed to the affected people, and possession of the land had been
transferred to the BPDB, there was no legal restriction (barring DOE Site Clearance) to start construction
of the power stations.
However, the BPDB did not make any efforts to occupy the MPSA lands until March 1999, when
construction of the access road and site filling activities were initiated. Until March 1999, the former
private landowners and public leaseholders continued to cultivate the MPSA lands. As of the end of July
1999, approximately 85% of the compensation payments had been distributed with the remaining 15%
being withheld due to the fact that the true landowners could not be identified. A summary of land
acquisitions and compensation payments is shown in Table 5.16.
Table 5.16: Land Taking for MPSA and Compensation Assessed Under the Laws of Bangladesh
Land Taking (MPSA): Privately Owned Land 145.515 acres
Government (Khas) Owned Land 85.255 acres
Total = 230.770 acres
Compensation (MPSA): Government Contingency* 3,885,661.03 Taka
Cost of Khas Land* 19,092,857.00 Taka
Cost of Private Land 24,316,070.97 Taka
Balance 8,399,885.83 Taka
Total = 55,694,474.83 Taka
* moniestransferred by the BPDB to the GOB.
Source: Deputy Commissioner, Narayanganj
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Building upon the initial compensation paid by the GOB on behalf of the BPDB to the project affected
peoples of the MPSA, the Project Sponsor prepared a Resettlement Action Plan (RAP) for the
development of Phase I of the MPSA (Appendix K). The RAP sets out the Project Sponsors plans to
provide further support to the project-affected persons, recognizing that the GOB may not have fully
compensated these individuals.
5.4.5.2 Project Site
According to the field surveys undertaken for this project, land acquisition and site filling activities for
Phase I of the MPSA have already affected approximately 544 households. The major resettlement
impacts identified in the Project Sponsors RAP are summarised in Table 5.17 and are as follows:
1. Permanent loss of 0.20 acres of homestead land by four households. This translates into the loss
of five dwellings, 12 trees, homestead crops (e.g., melons, squash, and gourds), and four latrines;
2. Permanent loss of 50.81 acres of privately-owned agricultural land (which includes 42.60 acres
for the power station, 6.49 acres for the access road, and 1.72 acres for Titas RMS);
3. Permanent loss of access to 27.40 acres of government-owned land (khas), most of which was
leased out to cultivating households. The remaining portion was informally held by 25
households, comprised of a mix of influential people and squatters; and
4. Immediate loss of access to land and water resources by landowners, leaseholders, tenants,
renters (bandhakee), permanent field labour (bandha), and households involved in individual and
community fishing enterprises. Loss of such access had an immediate impact on the incomes of
these households, including incomes from the cultivation of crops, fruit, and fuel wood, care of
livestock, and fishing.
Table 5.17: Summary of Losses for Phase I Development of the MPSA
Item of Loss
No. of
HH
Quantity
Aggregate
Value of
Loss (Tk)
Comment
1. Privately owned
Homestead Lands
a. Land 4* 0.20 ac 67,185 This land was identified as Vitiland (i.e., high
agricultural value) and was assessed @
335,925 TK per acre (1996 price)
b. Dwelling 4 5
(994 sqft)
102,117 Compensation was paid based upon the
assessment made by the Public Works
Department, Narayanganj (1996 price) under
Bangladesh law
c. Trees 4 12 Not designated in DC land acquisition
d. Homestead
Crops
4 44 Not designated in DC land acquisition
e. Latrines 4* 4 Not designated in DC land acquisition
2. Privately owned
agricultural land
50.81 acres 11,378,900 Assessed under Bangladesh law @ 223,950
Taka per acre (1996 price)
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Table 5.17: Summary of Losses for Phase I Development of the MPSA
Item of Loss
No. of
HH
Quantity
Aggregate
Value of
Loss (Tk)
Comment
3. Leased Government
Land (Khas)
27.50 acres 6,136,230 The BPDB paid compensation to the GOB @
223,950 Taka per acre (1996 price)
4. Livelihoods
a. Landowner/
Leaseholder HH
171 NA 3,728,282 21.13% (as per baseline survey)
b. Agricultural
Wage Labour
288* NA 1,793,911 34.54%
c. Sharecroppers/
Bandakees
28 NA 151,683 24.56%
d. Jhop Community
Fisherfolk
32 NA 253,010 17.01%
e. Unauthorised
holders of Khas
25 NA 269,300 22.49%
5. Specially Affected HH
a. Women Headed
Household
11
* these numbers will be further verified and checked for accuracy and duplication.
Private Landholders
Private land lost forms part of the project site area (i.e., 51.01 acres which includes homestead lands).
Specifically, 78 plots have been identified on the project site, 23 on the RMS site, and 69 plots cross the
access road area for a total of 170 plots held by 196 title holders. The demised corridor (i.e., cooling
water channel) affected no private land holdings.
Immovable Properties
It was found in the baseline surveys that a small number of immovable properties were affected by the
development of the project site, which included five structures, four latrines, and 12 trees. As the BPDB
had already taken possession of the site land, and their contractor, CWHEC, was carrying out site filling
works thereon, baseline surveys did not locate any dwellings, trees, or latrines on the project site.
At the time of survey, all four of the dislocated households had relocated in the nearby villages of
Islampur, IslampurAdarsha Gram, and Ganganagar. Two of the households had resettled in
Ganganagar, one was found living on unauthorized khasland in IslampurAdarsha Gram, while the last
family was living with relatives in Islampur. To the extent possible, the households had relocated their
houses and other infrastructures onto their new homestead lands.
Public Leaseholders
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The BPDB has paid the GOB for 27.40 acres of land to form Phase I of the MPSA. Specifically, 45 plots
have been identified on the project site with an additional 10 plots crossing the demised corridor. This
creates a total of 55 plots leased by 45 leaseholders. The access road and RMS do not affect public land
holdings. Initial compensation has been paid by the GOB to these project-affected peoples.
Loss of Livelihood
Approximately 283 households have lost more than 50% of their annual income due to site preparation
and site filling works. Specifically, loss of livelihood, related to the development of the project site, has
affected five groups: leaseholder households; agricultural wage labour; sharecroppers; individual and
community fisherfolk; and unauthorised holders of Khas land. This group will be provided with appropriate
vocational skills training to compensate for loss of livelihood and/or be recommended for priority jobs
during the construction phase.
Others
Titas is responsible for the acquisition of the easement required for the natural gas pipeline. Titas will
acquire this easement through the Deputy Commissioner at Narayanganj, and will make compensation to
the affected landowners as entitled under Bangladesh law.
The designated pipeline land, generally adjacent to the access road, is currently used for cultivation
during the dry season only. As the pipeline is of linear construction, the landowners who will be affected
will mainly be those affected by construction of the MPSA access road, but it is expected that they will
only be marginally affected as most work could be overlapped with the existing easement.
The PGCB is responsible for the acquisition of the right-of-ways (ROW) for the electrical transmission line
that will interconnect the power station to the existing 230 KV substations at Haripur and Comilla North.
Since development capital is being provided by the ADB for the transmission line, the PGCB will be
subject to the ADBs environmental and social policies and guidelines. These policies are expected to be
sufficient to address the land compensation issues expected to arise as part of development of these
lines.
5.4.5.3 Entitlement Framework
In addition to the compensation distributed by the BPDB for the MPSA lands acquired under Bangladesh
Law, the Project Sponsor will provide supplemental programs and facilities via the RAP that are within
their Social Responsibility Programme budget. These items include:
access to construction jobs: the Project Sponsor will ask the Construction Contractor to first
hire qualified PAPs based upon the identification card system to be implemented by the Project
Sponsor. The ID card will be issued to those households losing 20% or more of their income as
a result of the project or whose annual income falls below the poverty line;
vocational skills training: the Project Sponsor will secure funds within their Social Responsibility
Programme to ensure skills training for project affected households losing 20% or more of their
family income or whose annual income falls below the poverty line. One member per
household would be eligible for the training program;
elementary school construction: the Project Sponsor will construct an elementary school in the
Village of Islampur;
village road construction: the Project Sponsor will provide financial assistance for construction
of an earthen access road to the Village of Islampur; and
hospital construction: the Project Sponsor will also construct a land based or floating hospital
that is equipped with primary health care and treatment facilities. It is expected that preference
will be given to a floating hospital so that it may service a wider area.
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The various PAPs that have been identified as eligible for the above programs include: agricultural wage
labourers, sharecroppers, fisherfolk (both individual and community), private landowners, leaseholders,
and unauthorised PAPs on government land. The underlying objective of these programs is provide the
affected groups with skills necessary to find jobs in the burgeoning industrial centre at Meghnaghat.
5.4.5.4 Implementation Costs
Not including any administrative costs, the direct costs associated with the implementation of the RAP for
MPSA Phase I works, within the responsibility of the Project Sponsor, are shown in Table 5.18. At the
time of writing, it is anticipated that Project Sponsor will spend US$1,220,000 on the programs and
facilities described in section 5.4.5.3.
Table 5.18: Estimated Resettlement Cost for the Project Sponsor
Item
Cost in Taka
Cost in USD
[US$1= 50 Taka]
Responsible
Party
A. Programs and Facilities
1. Vocational Skills Tr. Programme*
2. Elementary School at Islampur
3.Construction of Earthen Access Road
to Islampur Village
4.Construction of hospital
6,000,000
700,000
350,000
50,000,000
120,000
14,000
7,000
1,000,000
Project Sponsor
Project Sponsor
Project Sponsor
Project Sponsor
Subtotal
57,050,000
1,141,000
B. RAP Implementation Costs
5. ID Cards: Preparation and Distribution
6. Training Programme Support
200,000
2,000,000
4,000
40,000
Project Sponsor
Project Sponsor
Subtotal
2,200,000 44,000
C. Staffing and Office Costs
7. CLO and RC
500,000
10,000
Project Sponsor
D. Monitoring
1,250,000
25,000
Project Sponsor
TOTAL for RAP
61,000,000
1,220,000
*Based on estimate of 300 households eligible for training programme
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5.4.5.5 Follow-On Activities
Since the release of the September 2000 EIA report, the Project Sponsor has undertaken various
activities in an attempt to maintain the livelihoods of affected landowners in both the short and long terms.
Specifically, the key activities have revolved around creating temporary employment opportunities and
implementing training programs designed to assist all PAPs in finding alternative employment. Other
works undertaken to date by the Project Sponsor as part of their Social Responsibility Programme are
also summarized below.
Temporary Employment
During the various hiring phases of construction personnel, the Construction Contractor has attempted to
preferentially hire from among the identified PAPs (section 5.4.5.3). However, few PAPs possess the
necessary background and skills required to complete the technical tasks. In keeping with the spirit of the
RAP, the Construction Contractor recently presented the Project Sponsor with a proposal for employment
of up to 200 PAPs during 2001; the first year of project construction. Given the lack of appropriate
construction skills, most of these new hires will be as assistants, helpers, and/or unskilled labourers.
Training Program
In an effort to immediately increase the skill levels of the PAPs, to facilitate their participation in power
station construction while providing other life skills, the Project Sponsor secured enrolment spaces at the
Rabita Vocational Training Institute in Dhaka. As of March 30, 2001, 63 PAPs and/or their designates
have received vocational skills training. The Project Sponsor has been, and will continue to provide fixed
monthly allowances to the PAPs throughout the duration of their training program as well as any personal
protective equipment they may require.
In addition to the PAPs who have already received vocational training, 60 PAPs and/or their designates
will soon be enrolled at MAWT in Dhaka for vocational skills training and at the Islami Bank Training
Institute in Dhaka for computer training. The goal is to provide training to 200 250 PAPs to assist them
in finding new employment.
Land Compensation
As indicated during the public consultation process, persons who lost land due to the development of the
MPSA complained that the financial compensation received from the GOB was low compared to the
actual market price. The PAPs further noted that due to the loss of land, and low compensation, many
had experienced a substantial decline in their standard of living.
While the Project Sponsor has implemented a job creation and vocational skills training program to help
landowners regain some of their lost income, they have also requested the BPDB to reassess the level of
compensation paid out to the landowners. Specifically, the Project Sponsor has requested that the BPDB
consider using some of the lease rent (paid by the Project Sponsor) to pay landowners who have been
unable to restore their original standard of living (Appendix M6). As appropriate, the Project Sponsors
CLO will follow-up on this issue with the BPDB.
Elementary School
The villagers of Islampur have identified a location for the elementary school that will be constructed and
initially operated by the Project Sponsor. The school site, approximately 0.6 acres, borders the south-
east corner of the project site and would be bound by the village access road currently under construction
by the Project Sponsor.
Although the villagers of Islampur claim that the proposed school site belongs to them, none of them
could produce any such proof. Thus, ownership of the land has yet to be verified. Once the land
ownership is verified site filling activities will be initiated to raise the school site above the one in 200 year
design storm level. Construction of the school building will follow site stabilization.
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Islampur Access Road
As noted, construction of the village access road began in March 2001 and is scheduled for completion in
June 2001. The road initiates at the south-east corner of the project site and will link with the existing
road at the property line of Ananda Groups. To further facilitate the easy movement of villagers, the
Project Sponsor will also extend the village road along the project site boundary to link it with the Islampur
village mosque. Approximately 13,000 15,000 m
3
of sand will be required to complete the road to a
finished elevation above the one in 200 year design flood level.
Land-Use Map
Due to the industrial nature of the Meghnaghat area, concerns have been raised regarding the unplanned
growth and development of residential colonies adjacent to industrial sites. At the present time,
government authorities in the Meghnaghat area have very limited control over where and when residential
colonies are developed since the area has not been officially demarcated as an industrial estate or zone.
Furthermore, there is no municipal authority to control land-use.
In an effort to assist both the central and local government authorities in managing the future growth of
the Meghnaghat area, the Project Sponsor is developing a new land-use map. This map will be updated
on an annual basis, the key purpose of which is to record the progressive development of the
Meghnaghat area. It is anticipated that the DOE as well as local government authorities will use the
information conveyed by the map to assist in their review and planning of future development activities
and lobby for controlled residential growth. At a minimum, the progressive land-use map will be provided
to the DOE and local Thana and District of the mapped area.
As of March 30, 2001, the field survey work for the land-use map had been completed. This information
is currently being transcribed onto a hard copy map for digital integration. Once completed, the Project
Sponsor will circulate the land-use map as indicated above.
Assistance to Titas
Construction, operation, and maintenance of the RMS, gas pipeline, and related facilities are the direct
responsibility of Titas as per the terms and conditions of the Gas Supply Agreement. As part of the
construction process, Titas is required to conduct an EIA under Bangladesh law and submit it to the DOE
in order to obtain Environmental Clearance for their project. To date, however, no such submission has
been made by Titas.
In an effort to ensure the smooth implementation of the gas related project works, while at the same time
transferring EIA knowledge to Titas staff, the Project Sponsor has offered its assistance to Titas
(Appendix M6). Specifically, the Project Sponsor has offered project oversight and technical support
from its staff to assist Titas in completing their EIA report. Where appropriate, the Project Sponsors CLO
will follow-up on this issue with Titas.
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5.5 Identification, Management, and Monitoring of Impacts
The Safety, Health, and Environment Policy and Procedures Manual of the Construction Contractor, is provided in Appendix F. The manual
specifies the environment and occupational health and safety procedures that shall be implemented by the Construction Contractor and its
subcontractors during construction. The assessment of construction-related effects assumes these management measures will be implemented.
In addition to these requirements, a summary of the potential environmental impacts of the construction phase of the project, the measures taken
by the Project Sponsor to manage them, and the estimated net effects of construction (assuming the implementation of mitigation measures) is
provided in Table 5.19. A comparable summary for the operation phase of the project is provided in Table 5.20. Chapter 6 expands on the
monitoring measures identified in the two tables.
Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Air Quality
Exhaust emissions from heavy equipment
and generator sets
Fugitive dust in the immediate vicinity of
the project site or haul route.
Implement good site practices, as summarized in "Section
9.1 - Traffic Safety" and "Section 23.3 - Air Quality
Control" of Hyundai's Safety, Health and Environment
Policy and Procedures Manual, including:
maintaining equipment in good running
condition;
switching off engines when not in use;
protecting stockpiles of friable material with a
barrier, vegetation, or windscreen;
providing wheel washing facilities at the exit of
the site to prevent dusty material from being
carried off-site and deposited on public roads;
covering loads of friable material during
transportation;
enforcing posted speed limits of 25 km/h to 40
KPH; and
suppressing dust on roads during dry periods
by use of water sprays.
As soon as possible following acceptance of the site from
BPDB, undertake stabilization of the site using vegetation
of other means to prevent dust being blown off the site by
strong winds
Short-term, localized effects on air quality,
primarily in relation to fugitive dust.
See Chapter 6, Section 6.2.4
Regular checks by the Construction
Contractor's Safety and Health Manager
(SHM)
1
to ensure implementation of good site
practices by contractors.
Maintain liaison with the public including
systematic recording of complaints and follow-
up.
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Noise
Noise disturbance at adjacent residential
and/or sensitive receptors.
Implement noise management measures as summarized
in "Section 23.5 - Noise" of Hyundai's Safety, Health and
Environment Policy and Procedures Manual.
Additional good site practices include:
ensure that all vehicles and construction
equipment have properly functioning silencers
or mufflers; and
schedule road traffic movements to avoid
noise-sensitive periods (e.g., night-time)
Short-term intermittent increase in daytime and
night time noise in the vicinity of the project site.
See Chapter 6, Section 6.2.4
Regular checks by SHM to ensure
implementation of noise management
practices by contractors.
Maintain liaison with the public including
systematic recording of complaints and
follow-up.
Natural Habitats
Potential for impacts to wildlife (i.e., loss
of habitat)
Where space is available, provide green belt areas around
and upon project site using indigenous species to supply
habitat for terrestrial and riparian species and improve
aesthetics
Possible contribution of planting of trees along portions of
the Dhaka-Chittagong Highway or other reasonable
alternative site(s)
No significant changes in populations of terrestrial
or aquatic organisms expected.
Loss of monsoon foraging/breeding areas of
aquatic organisms.
Net increase in number of trees along Dhaka-
Chittagong Highway or other reasonable
alternative site(s)
See Chapter 6, Section 6.3.7
Maintain liaison with the public including
systematic recording of complaints and
follow-up.
Human Sanitary Waste
Potential for impairment of surface water
quality and spread of disease vectors.
Implement management measures as summarized in
"Section 23.10 - Others" and "Section 25.1 - Sanitation" of
Hyundai's Safety, Health and Environment Policy and
Procedures Manual including:
providing an appropriate numbers of toilets and
hand-washing stations at the work site;
providing on-site treatment of sanitary waste;
and
training construction employees on project
sanitation practices.
Minimal risk of environmental or human health
impacts World Bank guidelines and GOB
standards for effluent quality will be met.
See Chapter 6, Section 6.2.4
Regular checks by SHM to ensure
implementation of sanitation requirements.
Periodic inspection by SHM of operational
status of on-site sewage treatment
facilities.
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Solid Waste
Air pollution (e.g., particulates and gases)
from on-site burning of solid waste.
Landfill disposal impacts (e.g., land,
groundwater, and surface water
contamination).
Implementation as summarized in "Section 23.8 - Solid
Waste Control" of Hyundai's Safety, Health and
Environment Policy and Procedures Manual.
Additional Good Site Practices consisting of:
systematic collection and protected temporary
storage on-site;
a waste management program consisting of
reduction, reuse, and recycling of materials;
burning should be considered only as a last resort
and used only when material cannot be disposed
of at a municipal disposal location;
only dry, clean-burning material (wood, cardboard,
paper, dry vegetal material) to be burned; and;
waste with a high potential for environmental
contamination (e.g., paints and batteries) will be
separated and clearly marked for proper disposal
at the designated municipal location.
Minor short-term decrease in air quality.
Minor incremental impacts on soil, groundwater,
and surface water at municipal disposal location
due to improper storage.
See Chapter 6, Section 6.2.4
Regular checks by the SHM to ensure
implementation of waste management
practices.
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Release of Contaminating Material
Environmental contamination from
spillage or disposal of fuels, lubricants,
oils and solvents on the construction site.
The risk of release of contaminating material will be
reduced through implementation and enforcement of
"Section 15 - Hazardous Substances", "Section 23.6 -
Water Quality Control", and "Section 23.8 - Solid Waste
Control" of Hyundai's Safety, Health and Environment
Policy and Procedures Manual.
Additional measures include:
prohibition of dumping of any contaminating
material product into the environment/onto the
ground, included waste oils;
storage and routine handling of fuels, lubricants,
and other potentially contaminating substances in
a weather-protected area equipped with a
secondary containment system for spills;
storage areas shall be designed such that they will
contain 110% of the largest container/vessel
stored in the storage area;
implement spill prevention procedures and a spill
contingency plan. Have available on-site all
equipment and materials required to execute a
clean-up; and
all wastes recovered during cleanup operations to
be collected and stored in labelled and secured
containers for subsequent disposal.
Negligible risk of significant contamination. See Chapter 6, Section 6.2.4
Monitoring of refuelling and other material
transfers will be conducted by the SHM where
appropriate.
Contractors report all spills greater than 5 L to
the SHM.
The SHM will notify the appropriate
Bangladesh agencies of any notable or
reportable spills.
Environmental contamination from
spillage of fuels, lubricants or solvents
during off-site transportation.
Implement "Section 9.1 - Traffic Safety" of Hyundai's
Safety, Health and Environment Policy and Procedures
Manual.
Additional measures include:
safety program [signage, speed restrictions, lights
on trucks, truck load restrictions, equipment
inspections (i.e. brakes, horn, etc)];
establish spill response procedure to allow a quick
response to clean up any off-site spills.
Negligible risk of significant environmental
contamination.
See Chapter 6, Section 6.2.4
Periodic inspection by SHM and daily
inspection by vehicle operators of vehicle
safety equipment.
SHM to investigate and report upon all spills
associated with the project.
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Disposal of Potentially Contaminating Wastes
Release of waste oily liquids and solvents
into the environment.
Implementation of "Section 15 - Hazardous Substances"
and "Section 23.6 - Water Quality Control" of Hyundai's
Safety, Health and Environment Policy and Procedures
Manual.
Additional Good Site Practices consisting of:
subcontractors to recover all liquid wastes (used
oil, drained hydraulic fluid, spent solvents, etc.) in
appropriate, labelled containers;
where appropriate, wastes to be stored in
weather-protected areas equipped with a
secondary containment system for spills;
transfer of materials will also occur within the
dyked area and sorbent materials kept on-site
spills greater than 5 litres will be reported to the
SHM; and
contaminating substances will be recovered in
appropriate containers and transported to proper
disposal facilities (e.g., incineration facilities).
Minor risk of soil contamination on-site or off-site.
See Chapter 6, Section 6.2.4
Regular checks by SHM to ensure
implementation of waste management
practices.
Regular maintenance checks by SHM of
waste storage area and containment
mechanisms.
Road Traffic
Community disturbance and potential
safety hazard.
Implement "Section 9.1 - Traffic Safety" of Hyundai's
Safety, Health and Environment Policy and Procedures
Manual.
Additional measures include:
providing safety training for truck drivers; and
implementation of safety program [(signage,
speed restrictions, lights on trucks, truck load
restrictions, equipment inspections (i.e. brakes,
horn, etc)].
Accidents are expected to be infrequent, but
cannot be precluded.
See Chapter 6, Section 6.2.4
SHM and/or Community Liaison Officer to
investigate all complaints about unsafe vehicle
operation and any accidents.
Capacity of existing roads (weight limit
and width of existing bridges, obstacles
such as power and telephone lines)
Survey roadway for weaknesses and obstacles that could
be affected by project traffic
No significant deterioration to road infrastructure
are anticipated
SHM and/or Community Liaison Officer to investigate
all complaints.
River Traffic
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Community disturbance The Bangladesh Inland Water Transportation Authority
(BIWTA) is the official monitoring authority for river
navigation. However, the Project Sponsor will bear the
responsibility for resolving potential navigation problems
with respect to project related river traffic and construction
of the temporary wharf on the Meghna River.
No significant increase expected in the volume of
river traffic.
No significant obstruction anticipated in
connection with construction and operation of the
temporary wharf.
See Chapter 6, Section 6.2.4
SHM and/or Community Liaison Officer to
investigate all complaints
Occupational Health and Safety Hazards
Work-related injuries and health
problems.
Exposure of personnel to hazardous
substances in the workplace.
The Construction Contractor will implement an
occupational health and safety program (OHSP) that will
address all aspects of worker health and safety relevant to
the construction of the power station. This will include
complete implementation and enforcement of Hyundai's
Safety, Health and Environment Policy and Procedures
Manual.
As contained in Hyundai's Safety, Health and Environment
Policy and Procedures Manual, the procedures will include
all of the accepted safety administration features including:
employee safety orientation; the format/structure for
regular safety meetings and inspections; and the provision
of qualified medical personnel and facilities.
Hyundai's Safety, Health and Environment Policy and
Procedures Manual and employee training will be
implemented in a culturally appropriate context and will
outline to the employees how Hyundai's Safety, Health
and Environment Policy and Procedures Manual applies to
their particular function.
Bangladesh standards (Labour and Industrial Law
of Bangladesh First Edition May 1996) and
World Bank and ADB health and safety guidelines
will be met.
Key chapters in Labour and Industrial Law of
Bangladesh First Edition May 1996 include
Chapter 1: Workmans Compensation (Workmans
Compensation Act 1923); Chapter 3: Health
(Factories Rules 1979); and Chapter 4: Safety
(Factories Act 1965).
See Chapter 6, Section 6.2.4 and 6.3
Regular checks by the SHM to ensure
implementation of site safety procedures.
SHM review the monthly, weekly and/or daily
safety report forms to be prepared and
submitted by sub-contractors.
Insect and Food Diseases. The Construction Contractor will be required to have a
program in place that reduces the risk of malaria and
Hepatitis A among construction personnel. This will
include the elimination of potential insect breeding sites
and the provision of preventative medicines where
appropriate.
Potential employee health risks will be minimised,
however, no preventative medicine is 100%
effective.
See Chapter 6, Section 6.2.4 and 6.3
Employees will be informed of possible
symptoms and can approach on-site medical
personnel should they feel sick or experience
symptoms
Social Concerns
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Table 5.19: Construction Impact Mitigation, Monitoring, and Management Measures
Issue/Concern Management Measures Net Effects Monitoring
Economic Dislocation of Agricultural Plot
Holders, Tenants, JhopFisherfolk, and
Day Labourers.
A community liaison officer (CLO) has been appointed by
the Project Sponsor to resolve any issues in a mutually
acceptable way to those involved. The CLO will also aid in
easing the transition of the resettled families between
communities [refer to the RAP (Appendix K) for additional
information].
The landowners, tenants, and lessees, who are
found severely affected by land taking for the
project, will be provided vocational training so that
they can restore their income earning capacity
through alternative employment and will be given
the opportunity of a job in project during
construction.
With the effective implementation of the RAP, no
significant long-term net effects are anticipated.
See Chapter 6, Section 6.3.7
The CLO will maintain open channels of
communication between the resettled families
and the Project Sponsor. Where unforeseen
issues arise, the Project Sponsor will take an
active role to help resolve the issue with those
directly involved.
Monitoring activities will occur as specified in
the RAP (Appendix K)
Influx of Temporary Labourers Where appropriate, the Construction Contractor will
provide suitable on-site accommodations for the imported
workforce.
Where appropriate, the Construction Contractor will also
provide educational material on public health issues
The influx of workers may result in increased
demand for goods, services and public health
facilities in the local area.
It is seen that most effects will be beneficial to the
economics of the area through the use of local
goods and services.
The Project Sponsor and SHM will monitor impacts to
the local villages during construction of the power
station and will work with Construction Contractor, the
CLO, and local community leaders to mitigate any
adverse effects.
Procurement of Local Labour, Goods, and Services
Economic benefits to the Meghnaghat
Region.
Contractors will be encouraged to utilise local labour,
goods, and services. Whenever these are available at
competitive quality and price, contractors will be expected
to follow a local procurement policy.
As discussed in Appendix C1, the construction
phase of the project will create:
Short-term employment of a large local
work force during construction;
Local and regional benefits associated
with the procurement of domestic goods
and services; and
Direct foreign investment into
Bangladesh and its power sector.
Contractors to provide the Project Sponsor with
estimates of actual amounts spent on local labour,
goods, and services on a quarterly basis.
Construction Reports
Status of construction progress and issue
resolution
A Construction Monitoring Report will be prepared and
submitted by the Project Sponsor twice annually to the
project lenders.
Implementation of a proactive approach to
identifying and resolving construction issues early
in their development.
The monitoring of construction activities and related
issues will be on-going throughout this phase by the
Project Sponsor, CLO, and SHM.
Notes:
1
Assumes Construction Contractor's Safety and Health Manager (SHM) is responsible for environmental issues.
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Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
Air Quality
NOxemissions below 50% plant load
operating conditions.
Use dry low-NOx burner for the gas turbines.
Plant Manager will monitor and optimize operating load
conditions to maximize efficiency and thus minimize
emissions.
As the power station is designed as a base load
facility, it is anticipated that the power station will
operate at loads of 90% or greater more than 90%
of the time. Operation under low-end load
conditions are expected to be infrequent and of a
short duration only (start-up and shut-down
activities). At plant loads of 50% or less, one
turbine will be shut down in order to increase the
load of the remaining operating turbine (i.e., at
50% plant load, one turbine will be shut down and
the remainder will operate at 100% load) to keep
NOx emission within guideline values.
The NOx emission rates comply with World Bank
and Bangladeshi emission guidelines.
See Chapter 6, Section 6.3.1
Regular monitoring of NOx at start-up,
shutdown and low loads (50% or less) during
the 1
st
quarter of commissioning, and there
after intermittent yearly monitoring of NOx.
Monitoring of gas quality by Titas.
Ground-level concentrations of NO2.
Use of a 60 metre high stack (calculated according to GEP
and confirmed through computer modelling using US EPA
Screen-3) to optimize dispersion of exhaust gases.
Use dry low-NOx burner for the gas turbines.
Monitor operating load conditions.
Ground level concentrations of NO2 are predicted
to comply with World Bank and Bangladeshi air
quality guidelines.
See Chapter 6, Section 6.3.2
Monitoring of NO2 ground-level-concentrations
(minimum of three locations) for 24-hour
periods during the first six months of plant
operation
Noise
Noise levels at nearby receptors. Where the noise model indicated the possibility for
exceedance, mitigation options were examined to bring
the power station into full compliance with applicable
World Bank, ADB and Bangladesh guidelines. The
Sponsor is incorporating appropriate mitigation measures
in design of the power station to ensure the full
compliance with noise emission limits.
Implementation of appropriate mitigating
measures should bring the power station into
compliance with the applicable guidelines.
See Chapter 6, Section 6.3.3
At nearby sensitive receptors, measure noise
contribution during first quarter after Plant
start-up, thereafter following any major
overhauls that might affect noise emissions
but not less than once every 12 months.
Cooling Water Discharge
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Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
Thermal cooling water discharge to
Meghna River
Effects on local fishery
Implementation of management measures identified in the
detailed modelling report (Appendix J3), including:
No need of mitigation measures (in order to
increase the mixing of the cooling water) has been
identified during this study.
The outfall should provide for a reasonable initial
velocity (1-2 m/s) at lowstages, in order to direct
the plume away from the bank.
The outfall should be designed in such a way that
the energy loss becomes moderate.
A submerged diffuser is advised against, as this
type of outfall is vulnerable to erosion and
sedimentation, and will increase the energy loss
unnecessarily.
Temperature of effluent discharge meets
Bangladeshi standards.
River water temperature increase at the edge of
the mixing zone will meet World Bank and ADB
guidelines most of the time.
Minimal effect on aquatic biota.
See Chapter 6, Section 6.3.5
The Project Sponsor will undertake one time
monitoring at the first occurrence of worst-
case ambient conditions (low-flow), following
power station start-up to delineate the extent
and characteristics of the thermal plume in
relation to model predictions.
The conservative modelling undertaken during
the preparation of the September 2000 EIA is
currently being re-reviewed by the Construction
Contractor in an effort to refine the predicted
mixing zone. Regardless of the outcome of this
review, the Project Sponsor is committed to
operating the power station within the applicable
guidelines of the World Bank and the standards
of the DOE.
The Project Sponsor will also undertake a new
baseline fisheries survey to confirm the opinions
provided in this Updated EIA report. Where
appropriate the monitoring program will be
adjusted to reflect the results of this survey.
Natural Habitats
Potential for impacts to wildlife (i.e., loss
of habitat)
Where space is available, provide green belt areas around
and upon project site using indigenous species to supply
habitat for terrestrial and riparian species and improve
aesthetics
Possible contribution of planting trees along portions of the
Dhaka-Chittagong Highway or other reasonable
alternative site(s)
No significant changes in populations of terrestrial
or aquatic organisms expected
Net increase in number of trees along Dhaka-
Chittagong Highway or other reasonable
alternative site(s)
See Chapter 6, Section 6.3.7
Maintain liaison with the public including
systematic recording of complaints and follow-
up.
Sanitary Waste
Spread of disease vectors. Odours. On-site treatment of sewage by Project Sponsor. Little or no off-site impact any sanitary effluent
will meet World Bank and Bangladeshi guidelines.
See Chapter 6, Section 6.3.6
Quarterly checks of the sewage treatment
system by the plant manager to ensure
continuing proper functioning.
Solid Waste
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Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
Air pollution (particulates, gases) from
burning of solid waste.
Incremental effect at municipal disposal
location.
Implementation of Good Site Practices consisting of:
Systematic collection and protected storage on-
site
An on-going waste management program
consisting of reduction, reuse, and recycling of
materials.
Minor incremental air quality impacts.
Minor incremental impacts on soil, groundwater,
and surface water at municipal disposal location.
See Chapter 6, Section 6.3.8
Periodic checks by power station manager to
ensure that waste management procedures
are being followed.
Site Runoff
Alteration of surface drainage patterns
and flows in vicinity of power station.
Potential for flooding on adjacent lands.
Detailed site design will determine howto divert site
drainage to minimise impacts to the land and water
adjacent to the project site.
Stormwater management drains will divert on-site surface
flows
No significant net effects are anticipated as a
result of site grading activities.
Monitoring will be conducted by the SHM
where appropriate.
Potentially Contaminating Wastes
Release of sludge, waste oil, hydraulic
fluid, paint, solvents, and similar materials
into the environment.
Dumping or burial of any potentially contaminating waste
product will be strictly prohibited.
All oil-contaminated drainage from the powerhouse floor
pits, fuel unloading areas, and fuel oil, lubricating oil and
waste oil storage tank areas will flow to a sump from which
it will be pumped to an oily water separator.
All other potentially contaminating wastes (used oil,
drained hydraulic fluid, spent solvents, etc.) will be
recovered in sound, properly labelled containers and
disposed of off-site to recycling facilities. Where viable
options to incineration are available (e.g., re-refining of
lubricating oil, solvent recovery), these will be pursued
upon verification of their environmental acceptability.
Minimal contamination of soil, groundwater, and
surface water.
Discharge water will meet World Bank and
Bangladeshi guidelines of 10 mg/l for oils and
grease.
See Chapter 6, Section 6.3.6 and 6.3.8
On-going program to ensure proper training of
personnel who operate systems to treat
hydrocarbon wastes.
Periodic maintenance and inspection of
environmental systems to ensure continuing,
proper operation.
Monitoring of discharged treated water to
verify compliance with guidelines.
Wastewater discharges from pre-
treatment system, boiler blowdown,
sumps, make-up water treatment system,
and sewage treatment system.
Treatment of all waste prior to discharge into Meghna
River.
Construction and operation of waste water effluent
treatment systems.
Discharge wastewater will comply with
Bangladeshi standards and World Bank
Guidelines.
See Chapter 6, Section 6.3.6
Quarterly monitoring of effluent quality will
also be undertaken by the Project Sponsor to
ensure compliance with applicable guidelines.
Accidental Spills
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Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
Spills of fuel or other contaminating
waste.
Tank storage areas will be designed for complete
containment of a worst-case spill (largest tank enclosure,
plus 10%).
AES will develop a facility-specific Spill Prevention,
Control, and Contingency Plan, outlining plant
environmental design features, spill prevention, and
control procedures.
Materials and equipment required to respond to the
various types of potential spill incidents will be available
on-site or nearby on a stand-by basis.
Escape of hydrocarbons or other spilled
contaminants into the environment is expected to
be limited to levels well below those that could
cause significant adverse environmental effects.
After clean-up procedures, monitoring of water
discharged to surface drains to ensure that criteria are
being met and that systems are operating as per
specifications.
Periodic testing and checks of spill response
readiness and emergency response equipment and
material.
Natural Hazards
Earthquakes, cyclones, and floods may
affect power station operations.
Preparation of an Emergency Response Plan.
Staff training in emergency shutdown procedures and
other emergency responses.
Minimal risk from natural hazards. See Chapter 6, Section 6.2.3
Periodic checks of emergency response
readiness; both of equipment and personnel.
Involuntary Resettlement
Assistance to households resettled by the
development of the MPSA.
Assistance to households affected by loss
of income
During initial operation of the power station, the CLO
should visit each family (bi-annually) to ensure
resettlement has occurred consistent with the World Bank
Group guidelines.
Implementation of the management measures as
described in the RAP (Appendix K).
All of the families had resettled prior to the Project
Sponsors take over of the MPSA (May 26, 2000).
The Project Sponsor has determined that the
measures provided for in the RAP, along with the
compensation already provided by BPDB, are
sufficient to support the affected parties make up
for loss of property and for effects on livelihood.
The CLO will monitor the success of the support
programs for the resettled households
Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
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Table 5.20: Operation Impact Mitigation, Management, and Monitoring Measures
Issue/Concern Management Measures Net Effects Monitoring
Occupational Health and Safety Hazards
Health and well-being of on-site
personnel.
Implement a comprehensive occupational health and
safety program that addresses all aspects of worker health
and safety relevant to the operation of a power station.
Develop a facility-specific safety manual.
Require use of proper protective clothing and footwear
Require use of hearing protection in high noise areas.
Employees who adhere to the occupational health
and safety requirements outlined in the manual
should be able to work in the power station for an
indefinite period of time without experiencing
significant hearing impairment or chronic health
problems from exposure to chemical substances.
Risk of lost-time accidents minimised.
Bangladesh standards (Labour and Industrial Law
of Bangladesh First Edition May 1996) and
World Bank and ADB health and safety guidelines
will be met.
Key chapters in Labour and Industrial Law of
Bangladesh First Edition May 1996 include
Chapter 1: Workmans Compensation (Workmans
Compensation Act 1923); Chapter 3: Health
(Factories Rules 1979); and Chapter 4: Safety
(Factories Act 1965).
See Chapter 6, Sections 6.2.5 and 6.3.8
The Project Sponsor will undertake
appointment of a safety officer and safety
committee to monitor and report (monthly)
upon health and safety conditions within the
plant on an ongoing basis.
Ongoing monitoring of employee health and
hearing acuity. The Project Sponsor will also
undertake status reports.
Local Employment
Approximately 30 mainly skilled and semi-
skilled personnel will be hired to operate
the power station. Initially, the plants top
management will be expatriates.
Hire competent local persons for top management
positions as soon as all routines are in place.
Implement training programs to facilitate advancement of
local persons and processes.
Positive impact on local employment and skill
upgrading.
Annual report on work force composition, training, and
new hires by Plant Manager.
Local Procurement of Goods and Services
Participation of the local economy in the
operation of the power station.
The Project Sponsor will follow a policy of preferential
local purchase goods and services whenever they are
available locally at an appropriate level of quality and at
competitive prices.
The project by its nature will create positive
benefits that will be enhanced by adopting a
proactive procurement approach.
A list of local suppliers of goods and services required
by the power station will be developed and updated on
an ongoing basis by the Plant Manager.
Bangladesh Power Supply
Power supply to the National Grid. Maintain power station in good running order. Positive contribution of a reliable 450 MW of
power to the national grid.
On-going maintenance activities.
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6. ENVIRONMENTAL ACTION PLAN
The mitigation and monitoring actions proposed to avoid or minimize impacts during construction and
operation of the power station were identified in Section 5 of this EIA Report. This section presents the
specific plan for implementing the mitigation and monitoring requirements within the framework of an
Environmental Action Plan (EAP). The following principles were used to guide the preparation of the EAP:
focus on occupational health, safety, and environment risk prevention;
affordable, safe technologies are used wherever failure of equipment would have a significant
effect on safety, health, or the environment;
conformance with relevant standards, codes, and practices will be considered in the application of
the safe technologies;
all activities will be performed in a safe and effective manner and all equipment will be maintained
in good operating conditions for the protection of health and safety of all persons and the
conservation of the environment and property;
all necessary precautions are carried out to control, remove, or otherwise correct any hazardous
materials leaks and/or spills, or other health and safety hazards; and
construction of the power station will meet relevant international standards which ensure sufficient
technical levels of safety.
At the time this EIA was completed certain detailed planning and design activities were still to be
completed. Thus, this section describes the EAP at the level of detail available at the time of writing.
When the detailed actives are completed, they will be integrated within the framework of the EAP and an
update prepared by the Project Sponsor. Currently, the EAP address the following key components:
management activities and systems;
plans, procedures, and programs;
monitoring activities;
implementation schedule and cost estimate; and
plans for integrating the EAP within the overall development plan for the project.
6.1 Environmental Management
The Project Sponsor is committed to constructing and operating the power station in an environmentally
responsible manner and in compliance with all applicable environmental laws, regulations, and
guidelines. The Project Sponsor will adopt an environmental policy that states the principles and
intentions of the enterprise in relation to its overall environmental performance. Such principles and
intentions will be communicated to each employee as well as the nature of their individual environmental
responsibilities. Where appropriate, staff training will be undertaken to ensure their continued
environmental performance.
The Project Sponsor is also committed to the creation and implementation of programs to reduce the
probability of occurrence of deleterious environmental incidents. As required, contingency plans will be
developed for dealing with such adverse incidents, should they occur.
The Project Sponsor will expect the same level of environmental performance from its agents, suppliers,
and contractors and will stipulate this in any legally binding agreements it enters with these parties.
The Project Sponsor will also ensure that appropriate corporate resources, personnel and reporting and
accountability systems, are in place for the successful implementation of the EAP. They will, on a
continuing basis, review the objectives of the EAP as well as the companys success in achieving them.
Where objectives are not being achieved corrective action will be taken. The EAP objectives will also be
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modified over the life of the project, as appropriate, to reflect changing environmental laws, regulations,
standards, and technologies.
6.2 Plans, Procedures, and Programs
As part of the EAP objectives outlined above, several plans, procedures, and programs will be developed.
They will guide all stages of project construction, operation, and decommissioning so that the
environmental performance of the power station is optimized. The following sections present an overview
of the plans, procedures, and programs that will be developed for the power station.
6.2.1 Resettlement Action Plan
The Project Sponsor will implement the RAP as discussed in Section 5 and detailed in Appendix K. For
reference, the RAP was finalized following the public consultations that were completed on the findings of
the Draft EIA. Where revisions are required, based upon lending agency comments, they will be
incorporated into the RAP. The RAP has been designed to ensure that certain groups of project-affected
persons receive training to assist in compensating them for losses of income and of structures directly
related to development of Phase I of the MPSA.
6.2.2 Public Consultation and Disclosure Plan
Specific elements of the Public Consultation and Disclosure Plan (PCDP), described in Section 7, extend
beyond the timeframe of the EIA. The Project Sponsor will carry out such elements based upon the
schedule set out in the PCDP.
6.2.3 Emergency Response Plan
During pre-operational mobilization the Project Sponsor will develop an Emergency Response Plan
(ERP) for the operational activities. The manual will be based upon existing manuals that have been
developed for other power stations owned and operated by the AES Corporation worldwide, including the
AES Haripur Power Project in Bangladesh.
The ERP will address, among other things: a Chemical and Petroleum Spills Contingency Plan (e.g.,
chemical handling, storage, and spill management); a Natural Hazards ManagementPlan (e.g., cyclones
and flooding); civil unrest; and fire and explosions.
6.2.4 Health, Safety, and Environmental Procedures
The Construction Contractor has in their Construction Contract committed to the health and safety
procedures as outlined in their Safety, Health, and Environment Policy and Procedures Manual
(Appendix F). The procedures will be revised to include the additional procedures set out in Table 5.2 of
this report.
The Project Sponsor will operate the power station and will be responsible for the development of Health,
Safety, and Environmental Procedures Manuals for both construction and operational activities. The
manuals will be based upon existing documents that have been developed for other combined cycle
power stations owned and operated by the AES Corporation worldwide, including those approved for the
AES Haripur Power Project in Bangladesh.
A summary occupational health and safety handbook will be created and supplied to every operations
employee to promote on-the-job safety and environmental performance. Once the manual and handbook
are finalised, and where required, they will be forwarded to the appropriate reviewing agencies.
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6.2.5 Operation and Maintenance Program
During pre-operational mobilization the Project Sponsor will develop a Plant Operation and Maintenance
Program for operational activities. The program will be based on existing programs that have been
developed for other power stations owned and operated by the AES Corporation worldwide, including the
AES Haripur Power Project in Bangladesh.
This program will cover predictive/preventive maintenance, routine maintenance, annual overhauling,
inspection of equipment and vessels, the procurement of spare parts, and maintenance of optimum
inventory levels in order to reduce inventory carrying costs and working capital costs. It will also include a
schedule for regular inspections of vehicles and equipment, sanitary facilities, and waste collection,
containment, and disposal facilities. If appropriate, this program will also include measures for the
periodic inspection of the access road and its drainage culverts.
The regular maintenance that will occur through the Plant Operation and Maintenance Program will
optimize the operating condition of equipment, thereby ensuring that production and emission of
pollutants are minimised.
6.2.6 Staff Training Program
The Project Sponsor will develop a training program to ensure power station staff receive training
appropriate to implement the Emergency Response Plan, the Health, Safety, and Environmental
Procedures, and the Plant Operations and Maintenance Program, as appropriate.
Training will begin as the initial staff complement is hired during the pre-operational mobilization period.
There will also be ongoing training and specific training for new-hires. Graduated testing and certification
by supervisors and the operations manager will ensure that all trainees perform at an acceptable level
prior to being assigned a position.
Various equipment suppliers will supplement the staff training program while they are available at the
project site during pre-commissioning and commissioning. They will provide training for plant start-up,
shutdown, maintenance, and troubleshooting. The training will cover the gas turbines, compressors,
steam turbine, boiler, water treatment, switchgear, distributed control system, analyser, and other
specialized instruments.
The Project Sponsor will develop the staff training program that will be implemented by the Construction
Contractor under their supervision.
6.3 Monitoring
Environmental monitoring, which started with the collection of primary background data as part of the EIA
study, will continue with appropriate follow-up activities during operation. The monitoring will provide data
on key environmental, social, and occupational health and safety aspects and on the effectiveness of
mitigation measures implemented as part of this project. The monitoring procedures noted here directly
link to the impacts and the mitigation measures discussed in Section 5. This section sets out in specific
detail the key aspects of the Project Sponsors monitoring program.
The Project Sponsor will implement the monitoring and follow-up programs summarized in Table 6.1.
Additional details of the programs are set out in the following subsections. Once a year, or at shorter
intervals if required by the regulatory agencies and project lenders, a summary of the monitoring
information will be submitted to the DOE, IDCOL, and the ADB. The compilation of the report will be the
task of the person(s) nominated by the Project Sponsor to be in charge of environmental issues. The
report will follow the format of the form provided as Appendix L3.
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Table 6.1: Health, Safety, and Environmental Monitoring Program
Monitoring Issue Monitoring Method Measured Parameter Frequency of
Measurement
NOx Emissions Probe sample collection (US EPA
Method 7 or equivalent) and
determination of nitrogen oxides in
laboratory by colorimetry and other
techniques
Concentration of nitrogen oxides
(NOx) in the exhaust flue gas
regular monitoring during start-
up, shutdown and operation at
low loads (i.e., gas turbine(s) at
<50% load) for the first quarter
intermittent yearly monitoring
throughout the life of the project
Ambient Air Quality Passive samplers (minimum of three
locations around the project site)
24-hour and 30 day ground level
concentrations of NO2
continuously for 6 months after
plant start up
biannual monitoring, for two, 30
day periods for each of the first
five years of operation
Noise Noise measurements (minimum of two
locations) taken while power station is
operating at 100% load using an
integrating noise analyser for a period of
48 hours at each monitoring site
day-time and night-time hourly Leq
measurements at representative
receptors outside the power station
boundary (adjacent to sensitive
receptors)
during initial station testing and
twice throughout the first year of
operation
thereafter monitoring would be
completed following any major
overhauls that might affect
noise emissions, but not less
than once every 12 months
River Morphology In-river measurement using analogue or
digital monitoring equipment
Measurements will be conducted at the
nearest existing upstream monitoring
station operated by BWDB
water level; water flow will be
derived from the recorded water
level
at a minimum, once annually or
as appropriate co-ordination
with SWMC/BWDB
Bathymetric survey using manual,
analogue or digital monitoring equipment
channel morphology after completion of project-
related dredging activities and
five years thereafter
Ambient Water Temperature
Field testing of river water ambient
temperature near the cooling water intake
using an electronic temperature probe
temperature at one metre depth weekly for the first year of
operation
monthly there after (especially
when worst-case ambient
conditions are anticipated)
Cooling Water If discharged via the open channel, field
measurements of undiluted effluent at
point of discharge as well as 1 m deep
along a transect oriented downstream of
the discharge point using an electronic
temperature probe.
Measurements taken while power station
is at 100 % load and/or under by-pass
conditions.
temperature at one metre depth quarterly basis for the first year
of operation
at the first occurrence of worst-
case ambient conditions (low
flow) following power station
start-up
annually there after, if
discharged via the open
channel, when operating under
by-pass conditions
Effluent Quality Field measurement and grab samples
taken for laboratory analysis from
undiluted power station effluents
temperature
total suspended solids
chromium (total)
copper
iron
zinc
Chlorine
quarterly for life of project
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Table 6.1: Health, Safety, and Environmental Monitoring Program
Monitoring Issue Monitoring Method Measured Parameter Frequency of
Measurement
Fisheries Fisheries survey within 1000 metres of
the project site (i.e., 1000 metres
upstream and 1000 metres downstream)
using one or more of the following
methods:
trap nets
experimental gill nets (with varied
mesh sizes)
seine nets
minnow traps
angling
species composition during power station
construction to establish
baseline conditions
once every two years
throughout the operational life
of the power station
Vegetation Growth Site inspection of trees planted as part of
the project development activities
(including any trees planted as part of the
Afforestation program)
Success of planting activities
(including both growth and
adaptability)
once annually for the first five
years of operation
Social Concerns Mandatory completion of and filing of
Project Affected Persons contact records
Comments, concerns, questions
from individuals and surrounding
communities
as specified in the RAP and
PCDP
Occupational Health and
Safety
Mandatory completion and filing of
incident reports
Accidents, damages, and safety
offences
All incidents compiled on a
quarterly basis
6.3.1 NO
x
Emissions
NOX emissions will be measured in each stack on a routine basis during start-up, shutdown, and
operation at low loads (i.e., when any gas turbine is operating at 50% load or less). This emission
monitoring will be conducted for the first quarter after plant commissioning and on an intermittent basis
every year following the U.S. EPA Method 7 [40 CFR Part 60 (Appendix A)] or equivalent. Samples will
be collected by a probe installed in the stack and analysed for NOX by colorimetry and other techniques in
the laboratory.
6.3.2 Ambient Air Quality
A monitoring program will be carried out to measure ground level concentrations of NO
2
in the airshed of
the power station for the first 6 months of operations. This monitoring program will be implemented prior
to power station start-up to confirm baseline conditions, and will be carried out at a minimum of three
locations: one being at the project site and two being in areas where worst-case effects are anticipated.
Suggested monitoring locations are the Villages of Dhudghata, Tangarchar, and/or Sonargaon. Final
locations will be determined during the detailed design phase.
Twenty-four hour samples would be collected once every three days (for a total of 10 per month) at each
monitoring station. At each station one-month averages would also be collected. The monitoring program
will utilise passive sampling devices available from the Canadian based Maxxam Laboratories, or
equivalent. These passive devices are capable of successfully monitoring 24-hour concentrations. The
monitoring program should use good sampling procedures including use of replicates, travel blanks, and
field blanks.
In addition, the monitoring program will make provisions for collecting or purchasing the following
meteorological parameters from the vicinity of the MPSA: wind speed, wind direction, temperature,
humidity and cloud cover.
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6.3.3 Noise Emissions
Noise monitoring should be scheduled to commence with the start of power station testing at full load and
at two other times throughout the first year of operation. The monitoring should take place at the locations
were background noise monitoring was completed (see Appendix J1) and the program should be
designed to collect the maximum hourly L
eq
value that occurs during the day and during the night using an
integrating type 1 noise level meter. The program should be designed to distinguish between noise
generated by the power station and noise generated from background sources. The measurements at
each location should be completed over a minimum 24-hour period.
The monitoring should be repeated following any major overhauls that might affect noise emissions, but
not less than once every 12 months.
6.3.4 River Morphology
There have been concerns that the project may alter the pattern of river flow and river morphology due to
dredging activities, river scour, and thermal discharges. Where feasible, the Project Sponsor will co-
ordinate with the SWMC, BIWTA, BWDB, and the BPDB to monitor river flow and scour patterns in the
Meghna River. Such monitoring activities will not be the prime responsibility of the Project Sponsor,
however, they will assist in such monitoring, as reasonable, when asked by these agencies. As owner
and leasor of the project site, BPDB was responsible for development of the project site and maintenance
of the embankment protection works along the Meghna River and all other sides of the project site.
6.3.5 Ambient River Temperature
During the public review of the project, concerned was raised over the ambient river water temperatures
referenced in the EIA report. To assist the Project Sponsor in their monitoring efforts, that is to
continually examine the potential effects that increasing ambient river water temperatures may have on
the power stations preformance, testing will be undertaken using a temperature probe during both
construction and operation as outlined in Table 6.1.
6.3.6 Cooling Water
Should cooling water be discharged via the open channel, effluent temperature will be measured at the
point of discharge (see Table 6.1), on a quarterly basis. Monitoring of surface water temperature will also
be undertaken in the area of the mixing zone as defined by the thermal plume model. A temperature
probe will be utilized to map the location of the mixing zone on a quarterly basis (incorporating worst-case
periods) following the start of commercial operations. Worst-case conditions are expected to occur during
February to April when net river flow is at a minimum.
Monitoring will also occur during extraordinary circumstances, such as when the power station is
operating in steam turbine bypass mode. To aid in defining low net flow periods, on a monthly basis the
power station manager will obtain data regarding water levels from relevant Bangladesh authorities such
as BWDB.
6.3.7 Effluent Quality
On a quarterly basis throughout the life of the project, grab samples of undiluted effluent will be taken for
laboratory analyses of total suspended solids, oil and grease, chlorine, chromium (total), copper, iron, and
zinc, while temperature, dissolved oxygen content, pH, and conductivity will be measured in the field.
Sampling would also be completed following any spills, plant upsets, or other events that could affect
effluent quality.
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6.3.8 Fisheries
Once during power station construction, and once every two years throughout the operational life of the
power station, the Project Sponsor will undertake a fisheries survey in the immediate vicinity of the power
station. Assisted by specialized personnel from Dhaka University, or other reputed institutes, in-water
surveys will be completed to determine specific species compositions within 1000 metres upstream and
1000 metresdownstream of the project site. Various methods of survey are available (Table 6.1), with the
most available and appropriate methods ultimately selected by the Project Sponsors study team.
6.3.9 Vegetation Growth
The Project Sponsor, in conjunction with the Department of Forestry, will carry out bi-annual site
inspections during the first five years of operation on the success and growth of any trees planted as part
of the Afforestation Program (section 5.4.4.6). Where trees have been damaged or ultimately die off, the
Project Sponsor in consultation with the Department of Forestry will replant an alternative species to
maintain the CO
2
offset created by the initial planting.
6.3.10 Social Concerns
The procedures for monitoring of resettlement issues are specified in the RAP (Appendix K). The Project
Sponsor will also be responsible for reporting on ongoing consultation activities and results as part of its
annual reporting requirements as detailed in the PCDP (Chapter 7) and tracking of other PAP issues as
they arise. Where appropriate, the Project Sponsor will implement a complaint tracking procedure with the
summary results provided on a monthly basis to the plant/environmental manager(s).
Formal and informal public consultations were undertaken as part of MEPs 1997 EIA report. At that time,
the residents of Ganganagar and Islampur were also able to express their concerns regarding the
conceptual development of the MPSA. Their concerns are described in Section 7.4.2, however, most
residents elected to continue their residency in the villages despite the proposed development of the
MPSA.
Additional meetings were held during September and October 1999 to supplement and complete Phase I
of the PCDP. Both formal and informal consultation techniques were utilized during activities held with
governmental organizations, NGOs, and local PAPs. A description of the key issues identified by the
stakeholders is set out in Section 7.4.4.
Following similar implementation techniques utilized during the Phase I consultations, Phase II of the
PCDP was carried out based upon the findings of the draft EIA report during the period from April to July
2000. A description of the stakeholders key issues is provided in Section 7.4.5.
During the in-country review of the September 2000 EIA, several project related issues were identified by
project stakeholders. The key issues are summarized in Section 7.4.6. Additionally, various comments
were received from the project lenders and reviewing agencies, which have subsequently been integrated
into this Updated EIA report; specifically throughout sections 5 and 6.
6.3.11 Occupational Health and Safety
The Project Sponsor will implement an internal incident tracking and corrective action program to monitor
any incidents that may occur at the power station. The details of the monitoring and corrective action
mechanisms will be set out in the Health, Safety, and Environmental Procedures for the power station,
which will be prepared during the detailed design phase.
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6.4 Implementation Schedule and Cost Estimates of EAP
Cost estimates for the mitigation and monitoring measures and their implementation schedule are
provided in Table 6.2. This table also lists the mitigation and monitoring programs included in the RAP
along with their approximate implementation costs.
Table: 6.2: Implementation Schedule and Cost Estimates (1999 US$)
Issue Mitigation Implementation
Procedures
Responsibility Capital
Cost
Recurrent
Costs/Year
NOX
emissions
Dry, low NOX burners installation during
construction
Construction
Contractor
-- --
NOX emissions
monitoring
develop operations
monitoring program
Project Sponsor 28,000 5,000
ambient air
quality
60m stack height
installation during
construction
Construction
Contractor
-- --
exhaust exit velocity
During manufacturing Construction
Contractor
-- --
establish a 6 month
ambient air quality
monitoring program
As discussed in Table 6.1 Project Sponsor 35,000 5,000
noise meet regulatory
emission levels
installation during
construction
Construction
Contractor
-- --
hearing protection and
signage
employee distribution and
appropriate location
Project Sponsor 2,000 --
on- & off-site
monitoring
develop operations
monitoring program
Project Sponsor 10,000 5,000
water quality establish an
appropriate monitoring
program
Selected thermal and water
quality parameters
Project Sponsor 25,000 10,000
fisheries careful site selection
of water intake and
discharge system
implement monitoring
program
Project Sponsor 50,000 20,000
vegetation
growth
n/a design Afforestation Program Project Sponsor 10,000 5,000
social nominate a
community liaison
officer (CLO)
CLO to respond to on-going
public concerns
Project Sponsor 10,000 5,000
CLO to follow-up on
recommendations/
commitments in the EIA
Project Sponsor 10,000 5,000
resettlement action
plan
contained in RAP (Appendix
K)
Project Sponsor 1,220,000 --
project plans develop an
emergency response
plan
staff training and awareness Project Sponsor 15,000 Included in
employee
training
develop an operations
and maintenance plan
staff training and awareness Project Sponsor 50,000 Ibid.
develop an
occupational health
and safety plan
staff training and awareness Project Sponsor 30,000 Ibid.
employee
training
training on EIA issues
and commitments
policy and procedure,
environmental management,
and analytical techniques
Project Sponsor 5,000 10,000
aesthetics site landscaping Vegetation planting Project Sponsor 10,000 15,000
TOTAL: 1,510,000 85,000
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6.5 Integration of EAP with Overall Project
Implementation of the EAP will occur simultaneously with the planning and development of the power
station. Specific responsibilities to carryout the various programs and plans of the EAP will be assigned to
project personnel and an accountable management system established. Management will also provide
the essential resources for the EAP to be implemented.
An environmental compliance manual will be prepared which clearly states the environmental
responsibilities of the Project Sponsor. Ensuring environmental compliance will primarily be the
responsibility of the SHM and Plant Manager. The SHMs responsibilities will include the overall co-
ordination of the environmental issues during construction. The SHM will also be responsible for the
implementation of mitigation measures, monitoring programs, supervision of personnel and monitoring
laboratories, and reporting the results within the company and to the relevant authorities during the
operational life of the power station.
Contractors will be responsible and accountable for the actions of their company and employees. These
responsibilities will be incorporated into the contract documents consistent with the recommendations of
the EAP.
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7. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE
For this project, public consultation and information disclosure activities were undertaken based upon the
public consultation and disclosure plan (Appendix M1) and in accordance with the applicable regulatory
guidelines. The public consultation and disclosure plan (PCDP) was implemented using a phased
approach that involved a wide spectrum of stakeholders.
Consistent with current consultation and disclosure techniques, the PCDP and this section of the EIA
outline various methods and techniques to facilitate meaningful consultation with the project stakeholders,
including formal and informal meetings, courtesy calls, in-field contact, and surveys of project affected
villages and groups in a culturally appropriate manner.
The identification of stakeholders, conceptual design consultations, and Phase I consultations were
undertaken by Mott MacDonald. A summary of all completed and planned public consultation and
information disclosure activities are shown below:
Phase Month / Year Consultant EIA Report Structure Reviewing Agency
Stakeholder
Identification
1996, ongoing Mott MacDonald generic project design ADB
Conceptual design 1996 Mott MacDonald generic project design ADB
Develop PCDP July 1999 Mott MacDonald preliminary project design ADB, IDCOL, DOE
Phase I August 1999 Mott MacDonald preliminary project design ADB, IDCOL, DOE
Phase II April July 2000 ESG International project-specific design ADB, IDCOL, DOE
Public Review of EIA Jan Feb 2001 Project Sponsor Complete EIA report Project Stakeholders
Construction May 2001 Project Sponsor progress report ADB, IDCOL, DOE
Operation October 2002 Project Sponsor progress report ADB, IDCOL, DOE
This section provides the results of the public consultation and information disclosure activities completed
to date as well as the planned future consultation and disclosure steps that will be undertaken following
submission of this final Updated EIA report to project lenders and regulators.
7.1 Defining the Terms
Public Consultation
Public consultation is a tool for initiating and managing communications among the Project Sponsor,
project stakeholders, and other project affected persons. It provides an avenue for the reviewing
agencies, lending institutions, and the Project Sponsor to improve their decision-making capabilities,
while fostering an environment of understanding by actively involving organizations, groups, and
individuals directly affected or involved in the project.
Consulting with project stakeholders involves those persons or groups who have the ability to influence
the projects outcome. Early identification of these groups, especially those stakeholders who are poor or
marginalized, is essential to generating good consultation results.
Information Disclosure
Effective consultation is driven in part by adequate and culturally appropriate disclosure of information to
project stakeholders in a timely fashion (i.e., in the local language and before irreversible project
decisions are made). Disclosure of information is critical if project stakeholders are to have meaningful
input and participation in the decision-making process. Exchange of information will also allow project
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stakeholders to better understand the trade-offs between project benefits and disadvantages and, if
executed properly, can facilitate a greater trust in their new corporate neighbour (IFC, 1998).
7.2 Regulatory Context
The consultation and disclosure activities have been developed and carried out to address the following
regulatory requirements and guidelines:
EIA Guidelines for Industries, DOE, Ministry of Environment and Forest, Government of the
Peoples Republic of Bangladesh, June 1997; Section 4.11, Public Participation.
Environmental and Social Framework, IDCOL, Dhaka, Bangladesh, May 1997; Annex 8, Public
Consultation and Consensus Building.
Pollution Prevention and Abatement Handbook, the World Bank, 1998; Part II, Public
Consultation.
Environmental Assessment Requirements and Environmental Review Procedures of the Asian
Development Bank, ADB Office of the Environment, 1993; Appendix 3, Public Involvement.
Handbook for the Incorporation of Social Dimensions in Projects, ADB Social Dimensions Unit,
1994.
The following subsections summarize the requirements of the DOE, IDCOL, and ADB as set out in the
documents listed above.
7.2.1 Bangladesh DOE Guidelines
In June 1997, the DOE, under the purview of the MEF, issued the EIA Guidelines for Industries. The
general requirements for public participation as set out in the guidelines are:
...an EIA study should involve the public as part of the decision-making process....To
achieve effective public participation, it is necessary to communicate with as many
people as possible, as early as possible, and through as many different ways as possible.
This requires pre-planning, resources, identification of target groups, and a variety of
techniques for effective communication. [Section 4.11]
The guidelines do not provide any specific guidance on consultation or disclosure methods or timing.
7.2.2 IDCOL Guidelines
The public consultation and disclosure requirements of IDCOL are set out in their ESF (Appendix E4).
The ESF adapts World Bank Group guidelines for IDCOL projects, but emphasises this in a context first
of awareness building followed by consensus building:
(i) awareness building: the provision to the affected communities of information regarding project
activities, likely impacts, and possible mitigation measures. At this stage, the stakeholders can be
communicated with through a variety of methods, including small group discussions, public meetings,
and reviews of the environmental and social assessment activities.
(ii) assessment of perceptions: a directed effort to record the views of the community about the
project, its impacts, and options to mitigate such impacts.
(iii) building consensus: a stage where major disagreements that may emerge in stage two can be
addressed. Should such disagreements occur, efforts should be made to resolve them amicably
through negotiated agreements. Less important unresolved issues should be documented.
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(iv) finalisation of agreements: the final stage, where agreements are translated into commitments and
an allocation of responsibilities, together with agreements to provide resources, if required.
IDCOL, through the World Bank guidelines, directs project sponsors to consult with relevant stakeholders,
including affected groups, non-governmental organisations (NGOs), and local authorities regarding the
environmental and social aspects of the project, and take their views into account (World Bank, 1998).
The World Bank also recommends that preparation of the PCDP should define a technically sound and
culturally appropriate approach to public consultation and disclosure of information about the project.
7.2.3 Asian Development Bank Guidelines
The ADB has no official guidelines for the inclusion of a PCDP, however, they do advocate public
consultation. In their Handbook for Incorporation of Social Dimensions in Projects (1994), they encourage
the use of key informant interviews, group interviews, workshops, and rapid reconnaissance surveys to
gather information from villagers, government officials, farmers, women, and vulnerable groups on local
environmental and social conditions. The ADB feels that these opinions are crucial to the overall project
success.
The Environmental Assessment Requirements and Environmental Review Procedures of the Asian
Development Bank (1993b) is another relevant ADB document that outlines how public involvement can
be incorporated into the EIA process.
7.3 Consultation and Disclosure Methodology
When developing a methodology for public consultation and information disclosure it is important to
understand the extent to which stakeholders may be interested in the project; based on their perceptions
and concerns (Petts, 1999). Interested stakeholders may include those who:
are affected by spatial proximity to the proposed project;
are economically affected by the proposed project;
feel the project threatens their culture or traditions; and
believe their values are challenged by the proposed project (Creighton, 1981).
Another objective of the methodology must be to develop a representative understanding of peoples
views about the area in which they live, community characteristics and environmental resources that are
important to them, and the extent to which they have knowledge about certain issues. Additionally,
special considerations may be required to facilitate the participation of indigenous peoples, those who
pursue traditional lifestyles, or those who constitute a minority (Canter and Sadler, 1997).
Since many of the issues addressed within an EIA are of public concern, or are matters that would benefit
from public review and comment, a procedural framework that facilitates public participation and input is
required. Such a framework must also contain mechanisms to monitor consultation and disclosure
activities on a continuous basis during construction and operation activities.
Building upon the various methodological objectives and the applicable regulatory requirements, the
following consultation and disclosure methodology was developed and implemented for this project
(Figure 7.1). Where possible, the methodology conforms to traditional Bengali mechanisms for
consensual consultation and local decision-making.
Figure 7.1: Consultation and Disclosure Methodology
Increasing Level of
Information Disclosure
Public Consultation
Progression
Conceptual Design
Stakeholder Identification
Phase I Consultations
Phase II Consultations
Construction Consultations
Operation Consultations
Planning for Public Consultation and
Information Disclosure
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The consultation and disclosure methodology utilised several techniques to communicate and exchange
information with project stakeholders, which included:
informal, small group discussions with stakeholders during field activities;
group meetings with women stakeholders;
community/village meetings at Islampurand Ganganagar;
meetings with regional political and administrative leadership;
courtesy calls on NGOs, local corporations, and other interested parties;
an EIA workshop; and
socio-economic surveys of adjacent villages.
In all cases a contact record was kept of those attending each meeting in addition to the meeting
minutes.The project minutes record questions and concerns expressed by meeting attendees and the
answers provided by the Project Sponsor and/or its representative. The resulting documentation is used
as a tool to help identify community perceptions and concerns.
7.4 Results of Consultation and Disclosure
Based upon the consultation and disclosure phases presented in Figure 7.1, the following subsections
describe each phase of the methodology as well as the relevant information obtained during the
consultation and disclosure process.
7.4.1 Stakeholder Identification
Stakeholder identification is generally undertaken to determine who will be affected by the project (i.e.,
project affected persons) and who can contribute to the decision-making process (e.g., non-governmental
organisations). Additionally, special techniques may be required to facilitate the involvement of
disadvantaged persons and/or gender groups.
Provisional Stakeholders
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Although there was no explicit methodology given in the 1997 EIA report (i.e., conceptual design phase)
related to stakeholder identification, provisional stakeholders were identified and included:
Islampur villagers;
Ganganagar villagers,
Dhudghata villagers;
the Bangladesh Centre for Advanced Studies;
World Conservation Union; and
Department of Environment.
Current Stakeholders
Identification of project stakeholders is an ongoing process and consequently the list will be refined during
each phase of the process. The current list of project stakeholders and their stake in the project are
shown in Table 7.1. This table has been created as working inventory, to be utilized by the Project
Sponsor and associated project representatives throughout the entire consultation and disclosure
process.
Table 7.1: Inventory of Project Stakeholders (1999)
Stakeholder Group / Individual Stake in Project
Area Political and Administrative Leadership
AlhajSirjulHaqueBhuiyan
Chairman of Pirojpur Union Parishad
offered assistance in keeping people fully informed and for Phase II
PCDP activities
interested in developing a market centre at the tip of the MPSA char
MdZillarRahman,
Sonargaon Thana Executive Officer
NOC approval needed for the project to go ahead
Md. EmdadUllahMian,
Assistant Land Commissioner (Sonargaon Thana)
co-ordinating land plot numbers and names
Md. NurAhmen (Executive Officer)
Sonargaon Thana Police Station
offered assistance for residents meeting
Md. AbdurRahman,
Deputy Commissioner of Narayanganj District
Head of civil administration of Narayanganj District
Responsible for acquisition of land and making compensation to
landowners under Bangladesh law
Abdullah al-HasanChowdhury,
District Land Acquisition Officer, Narayanganj District
co-ordinating land and compensation records of the MPSA
Government of Bangladesh
GM Mandal, Secretary, Power Division, Ministry of Energy and Mineral
Resources
Framing policies and giving direction to the power sector in general and
overseeing the activities of the individual companies responsible for
generation, transmission and distribution of electrical power in the
country
Md. Reazuddin (Deputy Director, Dhaka Division now Technical
Director)
Department of the Environment
responsible for EIA process
Bangladesh Power Development Board responsible for supply and distribution of power
Md. Abdul Matin (Director General)
Department of Fisheries
responsible for protection of fish and fish habitat
Non-Governmental Organizations (NGOs)
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Table 7.1: Inventory of Project Stakeholders (1999)
Stakeholder Group / Individual Stake in Project
Dr. AinunNishat
World Conservation Union (IUCN)
fisheries, agriculture and protected areas
National Association for Bangladesh (NEAB) independent NGO organisation in Bangladesh
Dr. AtiqRahman
Bangladesh Centre for Advance Studies (BCAS)
advises the Government of Bangladesh, familiar with World Bank EIA
guidelines and public consultations
Development Agencies in Bangladesh (DAB) independent NGO organisation in Bangladesh
Ms. RizwanaHasan
Bangladesh Environmental Lawyers Association (BELA)
independent NGO organisation in Bangladesh
Centre for Sustainable Development (CFSD) independent NGO organisations in Bangladesh
Md. Mocklesur
Centre for National Resource Studies (CNRS)
interest in wetland resources management
Associations and Industries
Md. Jahangiir, Production Manager and Md. A. Kharhens, Managing
Director
Apparel Ltd.
interested in a continuous electricity supply to increase productivity, cut
operating expenses, and employ additional persons (e.g., ~200
additional jobs could be created) if uninterrupted supply of electricity is
ensured
Md. TIM Latiful Husain
Bashundhara Paper Mills Ltd.
discharge water into Meghna (`20% of total plant use)
MD. ShahajadaBhuiyan (Safety and Security Manager)
Md. Bong Jeon Kim (Factory Manager)
Hyundai Cement (Bangladesh) Co. Ltd.
offered to help organize local people for upcoming consultation
meetings
Magura Paper Mills Ltd. no direct contact established
Engr. Md. ShahidUllah
Meghna PET Industries
interested in a continuous electricity supply
7.4.2 Conceptual Design (1997 EIA Report)
Public consultation and information disclosure during the conceptual design of the project were
undertaken to ensure that strategic project decisions avoided major environmental and social risks while
optimizing project benefits. Public participation and input received during this stage of project
development were useful mechanisms for assisting with preliminary determinations related to site
selection, infrastructure requirements, production capacities, and process designs.
Based upon the findings of the 1995 PSMP, the MPSA was identified as a top ranked site for
development of three new private sector power stations to be developed in three phases (Acres, 1995).
Consequently, an EIA Report (1997), containing both formal and informal consultations and information
disclosure mechanisms, was undertaken based upon a conceptual project design (Appendix M2). A
summary of the provisional stakeholders (identified above) perceptions and concerns is provided below.
IUCN the MPSA is not covered by any wetland areas or other protected areas
use of natural gas fuel versus coal fuel should be considered
BCAS study should be seen as a model for other power developments
highlight the fact that an EIA is being undertaken
Village of Islampur village should not be shifted and people did not want to be relocated
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adequate compensation should be provided to each landowner whose
land is to be taken as part of development of the MPSA
would be pleased if jobs could be provided and other bonus
compensatory measures such as supply of running water, renovation of
the mosque, access to site medical facilities, and supply of electricity
would be viewed as a net benefit
Village of Ganganagar major issue was that of compensation for land being taken adequate
compensation package be developed
additional requests included jobs for village persons, a new school be
constructed in the village, and renovation of the village mosque
Village of Dhudghata generally in favour of the project provided an adequate compensation
package was provided
The 1997 EIA Report included a two-tiered list of recommendations, which were:
minimum requirement:
the project should assure Islampur villagers that they will not be resettled or relocated;
the project should provide an adequate compensation package;
the project should provide jobs during construction for at least one member per family for those
families whose land is being taken away; and
the project should provide jobs during construction for others from nearby villages.
additional benefits
the project should provide running water for the villages of Islampur and Ganganagar;
the project should provide some street lighting for the villages of Islampur and Ganganagar;
the project should provide access to site medical facilities for the residents of Islampur and
Ganganagar;
the project should construct a primary school for children for these two villages; and
the project should renovate the two existing mosques at these villages.
The stakeholder perceptions and concerns, and the 1997 EIA Report recommendations, represented the
starting point for development of the PCDP for the specific project design. These recommendations have
been reviewed as part of the detailed project planning process and were addressed during Phase II
consultations.
7.4.3 Planning for Public Consultation and Disclosure
A PCDP was developed by Mott MacDonald in July 1999 in order to bring continuity to the consultation
and disclosure process, avoiding confusion among the project stakeholders (Appendix M1).
Subsequently, the PCDP and the results generated by it to date have been used to guide the consultation
and disclosure section of the EAP as discussed in Section 6. Where appropriate, the EAP will be
updated by the Project Sponsor based upon the outcome of future consultation and disclosure activities.
Contact Vectors
Public contact at the MPSA initially occurred as a consequence of orientation visits to the project site by
government officials, the Project Sponsor, and other interested parties. Representatives from the
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following groups have visited the project site in the period from 1996 through to August 2000, having
contact with local persons and groups:
Asian Development Bank;
IDCOL and the World Bank;
Bangladesh Power Development Board;
Titas Gas Transmission and Distribution Company Ltd.;
AES Meghnaghat Ltd. (the Project Sponsor);
ESG International Inc. (Canadian based environmental consultancy);
Deodar Associates Inc. (USA based socio-economic consultancy);
Development Planners and Consultants (Bangladesh based environmental consultancy);
Development Design Consultants, Ltd. (Bangladesh based land surveyor); and
Mott MacDonald, formerly Mott EwbankPreece (U.K. based environmental consultancy).
These site visits were to appraise the MPSA for multiple power station development and to review
potential environmental and social issues associated with development of Phase I of the MPSA. During
the site visits, the groups have come into contact with interested or curious local people and dialogues
about the project have resulted. While these dialogues were not part of a structured PCDP, they served to
impart general information about the project to local people and have helped form local perceptions about
the project.
7.4.4 Phase I Consultations
Phase I consultations were undertaken in July, August, and September 1999 following award of the
Phase I project at the MPSA to the Project Sponsor by the BPDB. Various stakeholders were identified
and consulted, based upon the works undertaken during the conceptual design stage, including the
IUCN, BCAS, DOE, the District Commissioner of the Narayanganj District, Sonargaon Thana Land
Commissioner, and the Chairman of Pirozpur Union Parishad, among others (Appendix M3).
The key issues identified by the project stakeholders during Phase I consultation activities included:
concerns regarding the land acquisition process;
interest in developing a market centre on the toe of the char;
potential emissions impacts (i.e., air, noise, and thermal);
potential for nearby industry to expand and employ additional persons should a stable supply of
electricity be provided (e.g., Apparel Ltd. could employ an additional 200 person half of whom
could be female and Meghna PET Industries could employ an additional 150 male workers);
health and safety risks associated with gas explosion;
effects on the existing fishery;
impact of dredging on the geology and flow stability of the river, downstream erosion, and local
ecology; and
public participation and interaction are key components.
A summary of the meeting notes, along with a list of the project stakeholders, meeting dates, issues
raised, and the project responses are provided in Appendix M3.
7.4.5 Phase II Consultations
The second phase of public consultations was carried out following the completion and public circulation
of the draft EIA report. Prior to commencement of Phase II PCDP activities, the Project Sponsor prepared
an executive summary of the EIA reports findings (Appendix M4) and disseminated it to project
stakeholders. The project team also prepared a Project Brochure in Bangla for distribution at the village
meetings and a Fact Sheet for distribution at the National Workshop (Appendix M4).
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During development of the draft EIA and Phase I consultations, several mechanisms were identified to
best solicit public comment on the project during Phase II activities, including:
mouza meeting at Dhudghata village for project-affected-persons;
womens meeting at Dhudghata village;
meeting for regional stakeholders in Sonargaon Thana;
national workshop on the EIA in Dhaka city for project stakeholders; and
courtesy calls as necessary on district and national representatives not otherwise brought into the
discussions on the EIA.
Building upon these suggested consultation mechanisms, various meetings and discussions were held
with other project stakeholders during the course of the second phase of PCDP, and included:
village meeting with the inhabitants of Islampur (April 25, 2000);
village meeting with the inhabitants of Kurbanpur (April 26, 2000);
village meeting with the inhabitants of Kurbanpur (May 9, 2000);
village meeting with the inhabitants of Islampur (May 10, 2000);
village meeting with the inhabitants of Ganganagar (May 12, 2000);
village meeting with the women of Kurbanpur (May 15, 2000);
village meeting with the women of Ganganagar (May 17, 2000);
village meeting with the inhabitants of Panchani (May 19, 2000);
regional meeting with local and area elites and other PAPs at Pirojpur Union Parishad office
(June 13, 2000); and
a national workshop in Dhaka for project stakeholders (July 3, 2000).
A record of those persons and groups attending each meeting was kept by the project team. In addition,
meeting minutes recorded the questions and concerns expressed by the participants and the answers
provided by the Project Sponsors representatives (Appendix M5).
The key issues identified by the project stakeholders during Phase II consultation activities included:
BPDB access road: the fenced access road to the MPSA has blocked previously existing field
equipment, livestock, and human transportation pathways and has increased vehicular traffic
volumes where there once was none.
water logging: development of the access road has lead to increase water logging on lands that
were previously dry during the growing season. This has reduced crop productivity and affected
planting practices.
sand transport: site filling activities, with no subsequent vegetative cover, has resulted in sand
blowing off the MPSA, affecting both local food and water resources for human consumption.
Sand transport off-site has also affected the productivity of the adjacent lands.
site filling: during this activity the BPDB filled lands beyond those they officially acquired
resulting in additional land losses to those immediately adjacent to the MPSA site boundaries.
labour: since the MPSA has been acquired and filled by the BPDB, local persons have lost
access to agricultural labour jobs, which has in turn affected their personal incomes.
housing: it was noted that four houses and one structure had been relocated/lost due to the
acquisition of the MPSA lands.
river bank erosion: at the village of Islampur, there was concern about bank erosion associated
with dredging and the subsequent slide of the village into the river.
shrimp nala: it was suggested that the small, back river channel north of the project site,
currently closed as a result of the access road, be reopened to re-establish shrimp catches in this
area.
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compensation: comments were received claiming that the compensation paid by the GOB was
low. Also surveys indicated that compensation money could not be invested in alternative income
earning means. Consequently, many of those affected by the acquisition and filling of the MPSA
may have experienced a decline in their income.
local improvements: it was suggested that the Project Sponsor undertake construction of two
primary schools one at Islampur and the other at Kurbanpur. It was suggested that local road
improvements be established to increase the accessibility to the various villages affected by the
MPSA.
Although most of the issues raised during the Phase II consultation process are the result and
responsibility of the BPDB, the Project Sponsor has committed to undertaking various follow-up and
supplementary activities, which are shown in Table 7.2.
Table 7.2: Key Stakeholder Issues and Project Response
Stakeholder Issue Project Response Target Completion Date
1. Access Road
pathway blockage
pathway blockage
continued
the Project Sponsor passed the complaint of
pathway blockage to the BPDB and requested
them to open a gate on the access road in
November 2000 (Appendix M6).
in response, the BPDB indicated that since the
power stations at Meghnaghat will be Key Point
Installations (KPI), it would be not possible to
open a gate on the access road for security
reasons. Further, the BPDB noted that as most of
the land on the south side of the MPSA access
road is gradually filling up with industries, the need
for opening gates on the access road is no longer
justified as the villagers will no longer need to go
to the south side of the access road for cultivation
or harvesting (Appendix M6).
completed
water logging the Project Sponsor also brought the issue of
water logging to the attention of the BPDB in
November 2000. As with pathway blockage, the
BPDB has indicated that with the development of
industry on the south side of the MPSA access
road, water logging will not exist in future.
presently, dredge filling of land by a private
entrepreneur has caused the temporary flooding
of the remaining empty land throughout the
current dry season. The culvert under the access
road is helping to drain out the water coming with
dredged sand and the BPDB is maintaining the
culvert in functional state during all seasons.
completed
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Table 7.2: Key Stakeholder Issues and Project Response
Stakeholder Issue Project Response Target Completion Date
2. Site Filling
sand transport preliminary construction works began in October
2000 and thus no vegetative cover material has
been planted by the Project Sponsor on the Phase
I land.
the Project Sponsor brought the issue of sand
transport by wind and its consequential damages
to food, drinking water, and crops in the
surrounding villages, to the attention of the BPDB
in November 2000. Specifically the Project
Sponsor requested the BPDB to put a thin layer of
brick chips or soil cover on Phase II and III lands
to facilitate the growth of grass and other
vegetation (Appendix M6).
the BPDB is of the opinion that because the
Phase II and III lands are mostly surrounded by
the river that sand blow should not cause any
damage to the standing crops or to the villagers
(Appendix M6).
no action
completed
on-going
(as appropriate the CLO
will follow-up with the
BPDB should complaints
continue)
additional land taking in January 2001, concrete pillars were posted at
turns and at suitable distances along the boundary
of the Phase I lands in presence of the villagers
and representative of the BPDB. Since then, no
complaints have been received from private
landowners that their land was unfairly included in
the acquisition process.
the BPDB further confirmed that before filling up
the MPSA land, they demarcated the land
boundaries and again checked the boundaries
after filling.
based upon the information provided by the BPDB
(Appendix M6), it appears that the site boundary
dispute is unsubstantiated. The basis of this
complaint may have been the fact that some
dredged sand from the MPSA spilt over onto
private lands during high water levels. This land is
outside the site boundaries of MPSA and is now
back in the possession of private landowners.
completed
river bank erosion as part of the EAP, the Project Sponsor intends to
monitor river morphology in conjunction with the
BPDB (the owner of the MPSA lands).
on-going annually
throughout the life of the
project (dependent upon
BPDB participation)
loss of labour during construction, the Project Sponsor will ask
the Construction Contractor to preferentially hire
up to 200 PAPs who have been directly affected
by the development of the MPSA Phase I lands
and Access Road if they possess the required
skills (as per the RAP Appendix K).
for those directly affected by MPSA Phase I and
Access Road development a vocational skills
training program will be offered (one
person/household).
on-going until December
2001
on-going until 2002
3. Other
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Table 7.2: Key Stakeholder Issues and Project Response
Stakeholder Issue Project Response Target Completion Date
shrimping thenala has been permanently lost. No feasible
way has been identified to re-establish it.
not Applicable
GOB compensation several groups were identified within the Project
Sponsors RAP for supplemental assistance
(Appendix K).
additional assistance has been undertaken by the
Project Sponsor as outlined in section 5.4.5.5.
on-going until 2002
local improvements as discussed in the RAP, the Project Sponsor has
committed to building an elementary school in the
village of Islampur subject to land donation by the
villagers and/or availability of public land
(Appendix K and section 5.4.5.5).
the Project Sponsor has also committed to finance
construction of an earthen access road to the
village of Islampur subject to land donation by the
villagers and/or availability of public land
(Appendix K and section 5.4.5.5).
to be determined
June 2001 (unless
suspended by any land
related disputes)
7.4.6 Public Review of EIA Report
In addition to the public consultation and information disclosure process shown in Figure 7.1, the
completed EIA report, along with its appendices (dated September 2000), was made available to in-
country stakeholders for review and comment. The EIA report was available at the Pirojpur Union
Parishad office and the office of the Liaison Committee for the PAPs (situated at the Toll Plaza of Meghna
Bridge). The public review period lasted for 60 days and began on January 1, 2001.
During the in-country review period, comments were collected from a total of 25 persons (Appendix M6).
Their key issues can be summarized as follows:
translated report: a Bengali translation of the EIA report should be available to the general
public for review and comment.
vegetative plantings: requests were made for a tree plantation in the vacant spaces in the site
area.
pollution free environment: it was requested that a pollution free environment be ensured to
protect human and environmental health especially for air quality, noise, water, and fish.
land compensation: there was concern that land lost due to the acquisition and preparation of
the project site was not fairly compensated. In some cases the affected individual was currently
unemployed and experiencing financial hardship.
employment: it was requested that employment opportunities be made available to the persons
who lost their land to the plant site, leasors and sharecroppers who used to cultivate land there,
as well as people from the locality.
gated entrance: a gated, secondary entrance was requested at the north-west corner of the
MPSA Phase III lands to assist in reducing travel time and cost to the construction employees.
This would assist in offsetting personal costs against the construction wage and minimize the
potential of robbery for construction workers leaving late at night.
local improvements: complaints were made that the school promised by the Project Sponsor
has not yet been built nor has the access road to the highway from the village of Islampur. An
additional request was also made for a road between Islampur and Ganganagar.
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drinking water: it was requested that a drinking water access arrangement be established for
the PAPs working on the construction of the fence along the demised corridor.
tube wells: it was requested that deep tube wells be set up at the nearby villages to ensure the
safe drinking water of the villagers.
canals: it was suggested that the canals around the project site area not be filled in, which
would facilitate continued fishing in these areas.
Although several of the issues identified during the in-country public review are the ongoing responsibility
of the BPDB, the Project Sponsor has committed to undertaking various follow-up activities (Table 7.3).
Table 7.3: In-Country Review Issues and Project Response
Review Issue Project Response Target Completion Date
1. translated report a translated copy of the Executive Summary will
be provided to interested stakeholders upon
request.
May 2001
2. vegetative plantings along the eastern perimeter of the project site,
three rows of Mahogany and one row of native
fruit trees (a total of 800 trees) were planted in
September 2000. Once power station construction
work is finished, additional trees will be planted on
all empty spaces of the site as part of the site
landscaping.
September 2003
3. pollution free environment
air quality modelling has shown that air pollution from the
power stations stacks will be minimal with a very
low contribution of NOX in the flue gas (stack
emission) and the associated contribution to
ground level concentration.
the concentration of NOX in the flue gas and its
ground level concentration will be monitored
during initial operation of the power station to
check the actual level of pollution by the station.
the Project Sponsor is fully committed to
implementing the measures identified in this EIA
report. If all such measures are implemented, the
environment will not be exposed to significant
adverse pollution by the power station and the
project will be compliant with all regulatory
requirements in this respect.
June 2003
Noise
the power station has been designed with
adequate mitigation measures to keep the noise
emissions within Bangladesh and the World Bank
limits.
monitoring will be undertaken as outlined in the
Environmental Action Plan (section 6).
June 2003
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Table 7.3: In-Country Review Issues and Project Response
Review Issue Project Response Target Completion Date
water and fish the wastes to be discharged into the river will be
treated up to the DOE and World Bank standards
prior to disposal. Such treated wastes are not
expected to cause any damage to the local
fishery.
the Project Sponsor agrees that water pollution
caused by the discharges of other industrial
facilities in the vicinity may be a public health
issue. The Project Sponsor believes that there will
be no similar pollution of the river water by
discharges from the power station, as all the
wastes to be discharged into the river will be
treated to the applicable regulatory standards.
nevertheless, the Project Sponsor has agreed to
specific suggestions that a fisheries survey be
undertaken up to 1000 m upstream and 1000 m
downstream of the MPSA to demonstrate
compliance.
details of the monitoring that will be undertaken
are outlined in the Environmental Action Plan
(section 6).
ongoing throughout the
operational life of the
power station
4. land compensation and
employment
several groups were identified within the Project
Sponsors RAP for supplemental assistance due
in part to land taking.
the Project Sponsor has reached an
understanding with the Construction Contractor
for employment up to 200 PAPs, over a one year
period, during the construction phase.
the Project Sponsor is also providing vocational
skills training to the potential candidates for jobs at
the construction works as well as in other non-
project areas to improve their livelihoods (section
5.4.5.4).
ongoing until December
2002
December 2001
Ongoing until 2002
5. gated entrance and
salary
the Project Sponsor requested the BPDB to open
a gate at the northwest corner of the MPSA for
access of the villagers from Dhudghata,
Kurbanpur, Panchani, Char Goaldi, and other
villages lying on the northern side of the back.
channel, coming to the Meghnaghat Site for work.
the request was rejected by the BPDB on the
grounds that the Meghnaghat power stations will
collectively be KPIs and to ensure their security,
no access for general public can be permitted.
the Construction Contractor sets the salaries of
workers depending on their skills and demand-
supply in the local labour market.
no further action
6. local improvements
elementary school
the Project Sponsor made this commitment
provided there is available free land for location of
the school in Islampur Village (Table 7.1). As most
of the villagers at Islampur are either landless or
to be determined
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Table 7.3: In-Country Review Issues and Project Response
Review Issue Project Response Target Completion Date
possess limited land (received from the
government under resettlement programme which
prohibits further donation of such land for other
purposes), the Project Sponsor is looking for land
owned by the government for site of the school.
school construction will follow immediately once
sufficient free land (approximately 0.6 acres) is
confirmed.
access road
the Project Sponsor made this commitment
provided there is available land for location of the
access road to Islampur Village (Table 7.1).
road construction began in March 2001 partly on
the existing village track (hallot) and partly on
public land. The total quantity of land required is
approximately 1.0 acres if the road is terminated
at the nearest end of Islampur Village
June 2001
inter-village road
this was a suggestion from the local public in a
PCDP meeting, for which the Project Sponsor did
not make any commitment.
once the access road to the village of Islampur is
completed, it will serve the purpose of the inter-
village road demanded.
no further action
7. potable water
drinking water construction of the wire fence along the demised
corridor by the PAPs was finished in February
2001. When this work was awarded to the PAPs,
they were shown the location of the potable water
supply. As the demised corridor is 860 meter long,
the PAPs may have faced some difficulties in
carrying drinking water to the work site, which in
turn could have lead them to record this complaint
in order to avoid this issue in the future, the
Project Sponsor will ensure, via the Construction
Contractor, that all workers at the project site have
access to drinking water close to their work place.
on-going
tube wells the Project Sponsor has no immediate plans to
take up more projects under their Social
Responsibility Programme. However, the Project
Sponsor may consider such plans in the future
once the commitments made in the EIA and RAP
are successfully implemented and if it is
determined that such tube wells would provide
safe drinking water.
to be determined
8. canals
site preparation was the responsibility of the
BPDB and as such the Project Sponsor cannot
assume responsibility for this request.
No further action
In addition to these follow-up activities, the Project Sponsor has also committed to several other activities
based upon preliminary reviews by the project lenders as noted in section 5.4.5.4. Specifically, the
Project Sponsor will:
Comment [gc1]: Tajul please ensure the
validity of this comment.
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continue to expeditiously pursue the BPDB to increase compensatory levels to those PAPs who
have been impoverished by the land taking associated with Phase I of the MPSA and inform
IDCOL of the results of those investigations ;
building upon Figure 4.2, provide an updated land-use map that will be annually revised to
illustrate land-use changes in the vicinity of the Meghnaghat area. As requested, the Project
Sponsor will submit the land-use map to the DOE to assist in the issuing of environmental
clearances for new industries and commercial complexes in the Meghnaghat area. The map may
also be used by the DOE to regulate any changes in the areas land-use characteristics (e.g.,
from its present industrial and commercial characteristic to mix zone due to the establishment of
new residential colonies by private entrepreneurs); and
provide assistance to Titas for the preparation of their full EIA report for the gas pipeline and
associated facilities.
7.4.7 Construction Phase Consultations
During construction of the power station, the Project Sponsor is planning to continue to receive advice
from the project stakeholders through the CLO. The CLO will serve as a point of contact between the
Project Sponsor and the local communities and function as a channel to communicate local concerns to
the Project Sponsor during the construction period. The CLO will also be involved with consultations on
possible solutions to remedy any issues that may arise.
Phase I and II consultations, public review of the EIA report (dated September 2000), and other
disclosure activities have provided specific contact points and persons in the project area that will be
useful for the CLO. The CLO will also take responsibility for working with any NGOs and community
groups that bring project related issues before the Project Sponsor.
7.4.8 Operation Phase Consultations
The Project Sponsor will continue its contact with project stakeholders through the CLO during the initial
period of operation and for as long as this seems an effective two-way channel for communication. By this
time, as a long-term presence in the locality, the Project Sponsor will be developing additional informal
contacts. In time, the Project Sponsor may develop other local relationships and channels of
communication, which could benefit the local area. This may include the modalities by which the Project
Sponsor continually develops its social responsibility programs.
7.4.9 Integration of Public Consultation Findings into EIA
As illustrated in Appendix M3, there are some issues that will have to be addressed during project
implementation. These issues have been taken into consideration by the Project Sponsor in power station
design, impact assessment, and specification of and commitment to impact mitigation measures.
Chapters 5 and 6 indicate what actions/measures will be taken to address specific public issues.
7.5 Disclosure Plan
The PCDP was provided to most of the stakeholder groups noted in Table 7.1. This included the area
political and administrative leadership, interested entities in GOB, and NGOs. In addition, socio-economic
surveys were carried out in the Villages of Islampur, Ganganagar, Dhudghata, Kurbanpur, Char Goaldi,
and Panchani. In each case, contact with local persons resulted in communications about the project and
avenues were opened to communicate comments and concerns to the EIA study team.
Locally, the most extensive period of consultation to date occurred during preparation of the draft EIA and
the subsequent Phase II meetings. Considerable contact with the project area population also occurred
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during fieldwork for the social impact assessment component of the EIA. The most intensive consultation
occurred with those groups directly impacted, fisherfolk and the villagers of Islampur and Ganganagar,
who reside closest to the project site.
7.5.1 Information Materials
To assist with the dissemination of information, throughout the life of the project, the following materials
may be produced in bulk for provision to the public and/or selected stakeholder groups as part of the
information disclosure process:
pamphlet on the project: this document (i.e., a non-technical summary in Bengali) will provide
simplified, but accurate information about the project, its environmental and social impacts (e.g.,
during construction and operation), and planned mitigation activities. As much as possible, the
pamphlet will use pictures and cartoons to illustrate information.
updated EIA report: upon request, copies of the non-technical summary of the updated EIA will be
made available to the concerned ministries and agencies of the GOB, regional political and
administrative leadership, and those NGOs with a significant presence in the project region that are
also concerned with EIA issues.
Locations will be provided where all interested groups may also review copies of the updated EIA
report. Copies of the updated EIA would be in addition to those provided to the DOE, IDCOL, and
ADB as part of the processes of project approval and certification.
Copies of the updated EAP (subject to negotiations of the investment agreement among ADB, IDCOL,
and the Project Sponsor) will be distributed to the DOE as well as the project lenders.
7.5.2 Resources and Responsibilities
In order to facilitate its own involvement in the consultation and disclosure process, the Project Sponsor
will engage a CLO to serve as its point of contact with the community. The CLO will be the main point of
contact with the community and PAPs. This appointment will be made prior to implementation of
construction phase PCDP activities, so that the CLO can assist the Project Sponsor in organizing
meetings with the PAPs (e.g., on the revised RAP), among other tasks.
Since public consultation and disclosure at the local level emerged in part from the process of preparing
the EIA, the Project Sponsors environmental consultants organized the initial small group meetings with
the most vulnerable groups. Continued involvement with these groups will give the CLO strong familiarity
with local issues, groups, and leaders. This will enable the CLO to take over responsibility for managing
the task of public consultation as the project moves through the construction phase and into the operation
phase.
7.5.3 Grievance Mechanisms
The Project Sponsor recognises the need to maintain a clear channel through which project stakeholders
can express their grievances with assurance that these will be heard and addressed by project managers.
For the purposes of the power station, any individual or group that feels aggrieved by some project
activity will have the right to attend the regularly scheduled meetings with the CLO to present their
grievance either verbally or in writing. The CLO will pass the grievance on to the appropriate individual
within the Project Sponsors organisation.
In the first instance, if the Project Sponsor cannot resolve the complaint within one month, attempts to find
a solution by activating traditional methods of mediation in the community should be initiated; usually by a
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respected elder. In the event that an individual or a group still feels its grievance is being ignored, or
should unresolved tensions between the power station management and the local community over an
issue persist, the two sides could invoke a mediation panel. Should this occur, the three-person mediation
panel would consist of an appointed member by each side to the dispute, as well as a third jointly
appointed member. The mediation panel would attempt to find a solution acceptable to all sides. The CLO
will be responsible for ensuring that the mediation panel is appointed and available for conflict resolution.
In the event that disadvantaged or poor stakeholders (e.g., women) wish to lodge a grievance with the
management of the power station, but are unwilling to attend a meeting of the CLO, they should pass
their grievance to the CLO through the female community organizers of the local NGO.
7.5.4 Reporting
To date, five reports have been prepared as part of the public consultation and information disclosure
methodology adopted for this project, and include:
conceptual design 1997 EIA report (Appendix M2);
PCDP based upon 1997 findings July 1999 report (Appendix M1);
Phase I consultations summarized above and detailed in Appendix M3;
Draft EIA report April 2000 presenting the findings of the environmental and social review of this
project; and
Final EIA report September 2000 outlining the findings of Phase II PCDP activities as well as
the environmental and social aspects of the project.
The results obtained thus far have been reviewed and incorporated into the overall consultation and
disclosure methodology. The Project Sponsor will be responsible for reporting on ongoing consultation
activities and results as part of its annual reporting requirements. This will include the results of
consultation with relevant stakeholders throughout the construction and operation phases of the project.
Reporting on public contact will be included in the annual monitoring reports submitted by the Project
Sponsor to the ADB and the IDCOL where appropriate.
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8. SIGNATURES OF ENVIRONMENTAL PROFESSIONALS
Geoff Carnegie, M.Sc. Robert Turland, M.Des
Project Manager Project Director
Dated this _________ day of ________________, 2001.
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F:\Projects\1999 Projects\99299 - AES MEGHNAGHAT\Draft EIA\Final Version\Updated EIA Report (April, 2001)\Update Report
(Final Version - Black Text).doc