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Initial Environmental Evaluation, Northeast Regional Water Management Plan, Bangladesh Flood Action Plan 6

CHAPTER 11: ENVIRONMENTAL MANAGEMENT PLAN (EMP)

11.1  INTRODUCTION

This chapter is composed of information related to the Environment Management Plan (EMP). An EMP consists of:
  • Environment Protection Plan (mitigation plans and contingency plans). Purpose is to reduce impacts and risks. Issues related to existing legislation, codes of good engineering practice, proponent commitment, and the like are also discussed here.
  • Summary of Residual Impacts and Risks. These are the actual expected impacts and risks of the projects, which will need to be managed, monitored, and reported.
  • Impact Management and Environmental Enhancement (compensation and enhancement plans). Purpose is to balance adverse impacts by providing alternate benefits to adversely impacted persons or biophysical systems.
  • Environmental Effects Monitoring (monitoring plans).
  • Impact Reporting.
Addition sections of this chapter document:
  • Implementation of Environmental Management Plan
    • - Institutional strengthening needs
    • - Training and technical assistance needs
    • - Public participation
    • - EMP Implementation Schedule
    • - EMP Costs
  • Linking With the Project Assessment Process.
The emphasis at the IEE, pre-feasibility, level is on identifying issues and options, to guide the detailed design of specific EMP measures as part of programme and project feasibility studies.

11.2  ENVIRONMENTAL PROTECTION PLAN

11.2.1  Mitigation of Pre-Construction and Construction Phase Impacts
Significant pre-construction and construction activities and impacts are associated with the FCD and river improvement projects.
Land acquisition and site preparation
Land acquisition and site preparation activities and thus impacts occur during the pre-construction phase. For the Regional Plan, the magnitude of these impacts (number of people, hectares of land affected) are small in regional terms, but the impacts can be severe for the particular de facto land and resource users who are affected, including renters, share-croppers, grazers and gleaners, and squatters, with or without legal status.

Impacts can be minimized mainly through careful planning at feasibility and detailed design stages to minimize land use conversion, and to choose infrastructure sites of least value in current use (Shahabuddin, 1994). Residual impacts will require compensation (see below).

Temporary adverse impacts during construction of water control structures
During the construction of water control structures, it appears that temporary adverse impacts on drainage, fish movement, navigation, and road transport are possible. To our knowledge, systematic mitigation measures have never been applied to this type of impact in Bangladesh; they are simply accepted by the receiving communities. Project feasibility studies should investigate these considerations, and if these impacts are significant, detailed mitigation measures proposed.
Dredging and re-excavation spoil disposal
Dredge spoil disposal will be a major issue for the regional drainage improvement projects. If the spoil were simply dumped back in the river, then some of the benefits of the work could be lost. Furthermore, inadequate disposal methods could produce undesirable impacts to fisheries habitat and agricultural land. Formulation of a dredge disposal plans as part of each of the projects having a dredging component will require gathering considerable amount of site-specific primary information which currently unavailable.

Previous experience gained from the Dredged Material Research Program of the US Army Corps of Engineers has shown that:

". . . no single disposal method is necessarily suitable for a given region or project. What is desirable for one project may be completely unsuitable for another, and each project must be evaluated on a case by case basis. Also, each project evaluation must consider long-term as well as short-term disposal needs and possible interactions among projects."
The following comments are intended to illustrate some of the issues that would need to be considered. Much of the general information is summarized from Petersen (1986). The appropriate methods for disposing the spoil will depend on:
  • Quantity of the dredge material;
  • Grain size and organic content;
  • Degree of contamination and its toxicity;
  • Soil permeability and the depth to the water table at the disposal site.
  • Land use in the vicinity of the site and public acceptance of spoil disposal; and
  • Presence of critical habitat or wetlands.
Probably some of the most convenient disposal sites include old abandoned loop cuts and ox-bows that are adjacent to the river channel. These isolated ponds and water bodies would confine the slurry of sediment and water so that most of the solids could settle out before the water spilled back into the river. As the sites were gradually filled in, the newly created land could be used for agriculture or for habitation. However, potential impacts to fisheries would have to be considered.

Land disposal normally involves placing some form of confinement dyke to retain the dredged solids while allowing excess water from the slurry to be discharged from the disposal area. The dredged material is ponded for a period of time until enough of the suspended solids have settled out to meet the required effluent specifications. The return water can then be discharged over a temporary weir back to the river. However, during a site inspection to a BWDB operation, it was observed that no effort was made to confine the spoil. Instead, the slurry was discharged on the land and allowed to spread over a wide area until the water eventually seeped into the ground.

11.2.2  Mitigation of Operation & Maintenance Phase Impacts
Regional hydrology and morphology mitigation measures
River improvement is mitigative of flood control and loop cut impacts on river morphology and water levels.
Fisheries mitigation measures
Fish passes, water retention, bottom-open embankment design, and water control operational measures, including the inclusion of fishermen on project committees, are each mitigative of flood control impacts on fisheries. The Fisheries Engineering Project (other than fish passes) and Fisheries Biological Management may also provide mitigation, but their main thrust is compensation and enhancement (see Section 11.4 below).
Navigation mitigation measures
Boat passes should be provided as part of individual projects' infrastructure where warranted.
Physical maintenance of infrastructure
Maintenance requirements will increase, due to the larger amount of infrastructure in the region and increasing channelization accompanied by higher water levels and velocities on some rivers. Improved maintenance will require greater involvement of local people and local ownership of projects. A local project committee is proposed for each of the Plan FCD projects as a means to achieve these ends. Development of adequate responses will be a challenge.

11.3  SUMMARY OF RESIDUAL IMPACTS

The residual impacts of Plan implementation, reflecting the mitigation measures documented here, are described in Section 9.6.

11.4  IMPACT MANAGEMENT AND ENVIRONMENTAL ENHANCEMENT

11.4.1  Introduction
This section discusses compensation of residual impacts and environmental enhancement. There is no hard boundary between the two: a measure is compensatory if an adverse impact exists elsewhere that it balances, otherwise it is enhancing. General considerations and issues are identified here. Preparation of detailed compensation plans should be included in project feasibility studies as needed.
11.4.2  Compensation of Displacement Impacts
An analysis of land acquisition and resettlement experience and legal arrangements is presented in the FAP 15 final report (1992). The study notes a number of deficiencies in current arrangements and provides a comprehensive set of recommendations for an improved compensation framework. This appears to be the first step in a series of actions that will be necessary to achieve adequate compensation of displacement impacts.
11.4.3  Compensation of Impacts on Regional Stock of Homestead Land
In terms of the total amount of homestead land available with in the region, loss of homestead land to infrastructure construction would be compensated under the NERP initiative Flood and Erosion Affected Villages Development Project (FEAVDEP). This project proposed to use dredge and re-excavation spoil as a resource to construct new village platforms above the level of the monsoon flood in the deeply flooded Central Sylhet Basin. The aim of this project is to raise and enlarge homesteads belonging to families that are vulnerable to flooding and erosion. The most affected victims would be resettled onto new homestead platforms. A typical new village was planned to contain 130 households (700 persons). It was also assumed that the platforms would be constructed up to 5 m above the surrounding floodplain land and each platform would occupy around 2.6 ha for households and 0.65 ha for public land. Therefore, each village platform would require roughly 189,000 m3 of fill material. This volume corresponds approximately to three months operation from an existing BWDB dredger. The proposed work could approximately double the number of village sites along dredged river reaches.

This program of village construction would be a major undertaking, requiring a considerable amount of detailed planning and field work. Additional planning and assessment would be required during feasibility studies and possibly through pilot project investigations. Technical issues such as ensuring the stability of the platforms, and avoiding hazards such as wave erosion and river erosion would have to be addressed. Means for acquiring land and preparing the sites for settlement would also have to be demonstrated. In order to successfully re-settle people into the new villages, it would be important to ensure the sustainability of the new settlements. This implies at a minimum, ensuring their social viability and economic viability. Means for providing adequate project management, and formation of a strong resettlement authority would have to be demonstrated. At this time it is not clear whether the social and resettlement aspects of the work should be carried out as part of each of the river improvement projects separately or under a central separate project such as FEAVDEP.

11.4.4  Fisheries Impact Compensation and Enhancement
Improved fisheries management, including habitat restoration. Poss. dredging designs could be fish friendly (increase habitat).
11.4.5  Navigation Impact Compensation and Enhancement
Overall, the Plan places greater emphasis on drainage improvement than was evident in past water resources development. The projects Dredging for Navigation and Support to Country Boats would act synergistically with the major river improvement (drainage improvement) projects to enhance navigation.
11.4.6  Wetland and Biodiversity Impact Compensation and Enhancement
The Northeast Region Environment Management Research and Education Project (NEMREP) addresses improved wetland management at key sites and threatened community and species recovery. The Flood- and Erosion-Affected Villages Development Project (FEAVDEP) includes afforestation and habitat restoration under village management.
11.4.7  Water Quality Impact Compensation and Enhancement
The Northeast Region Environment Management Research and Education Project (NEMREP) includes actions to reduce regional water contamination from domestic and industrial sources.
11.4.8  Disaster Management
The project Improved Flood Warning addresses management of catastrophic flood risks in the Tripura and Meghalaya piedmont areas. This is a pre-existing (FWO) hazards which does not affect and is not affected by any other Plan projects. [Note that floodplain flooding is not defined as a `hazard' for the purposes of this IEE.]

Disaster planning and other risk management measures for Tipaimukh Dam failure should be dealt with under the auspices of the Joint Rivers Commission.

11.5  ENVIRONMENTAL EFFECTS MONITORING

Monitoring can be effected at a variety of temporal and spatial scales. At the micro end of the spectrum, the Department of Environment makes point measurements of river pollution. Another example of somewhat larger scope is provided by the Project Monitoring Component of NERP Phase I in which biophysical and socioeconomic data was collected for two years in two existing FCD projects (Shanir Haor and Manu River Project). At the opposite extreme, the Bangladesh Bureau of Statistics (BBS) is engaged in ongoing collection of national data.

To monitor the effects of Plan implementation, it would be desirable to:

  • Upgrade existing national monitoring systems (BBS, BFRSS, DOE). Recommendations on this are beyond the scope of NERP, however
  • Incorporate appropriate monitoring measures into each Plan FCD project, as an integral part of the project operation and management activities of the local project committees, with external technical assistance as needed. Detailed designs should be developed as a part of feasibility studies.
  • Incorporate appropriate monitoring into each non-FCD project. Detailed designs should be developed as a part of feasibility studies.
  • Design and institute specialized new monitoring systems and activities in specific areas where these are needed. One such system which has been identified by NERP is the need for all floodplain infrastructure development (embankments, closures, roads, bridges, culverts, etc.), by all agencies and local communities, to be centrally logged. This would allow observed river morphology changes to be understood, and in some cases, diagnosed before they occur.

11.6  IMPACT REPORTING

The levels at which reporting would be done parallel the monitoring levels: national, Plan FCD and non-FCD project, and by specialized monitoring system. The existing and likely near-term future institutional framework all but ensures that such reporting will be on an ad hoc basis, that is, with reference to particular donor conditionalities and executing agency guidelines.

11.7  IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT PLAN

11.7.1  Public Participation
Under the Pilot Project to Institutionalize Public Consultation, and as an integral part of individual FCD project study and implementation, ongoing public participation activities would be carried out, building upon the public consultation activities described in Chapter 5, and on the FPCO guidelines for public participation.
11.7.2  Institutional Strengthening, Training, and Technical Assistance Needs
BWDB can and should be expected to acquire the institutional and technical capabilities required to incorporate EMP measures which are integral to the activities which it performs or for which it has responsibility. These and other areas would be addressed under the project BWDB Strengthening. EMP related strengthening of other national institutions such as DOE is necessary but beyond the scope of this study, though the institutional initiatives addressing biodiversity and surface water quality strategic planning would partially address EMP capabilities in these areas.
11.7.3  EMP Implementation Schedule
Detailed schedules for implementation of the wide range of EMP measures discussed above will be dictated by the phasing of Plan implementation (given that there is mitigation, compensation, and enhancement between and among Plan projects) and by individual projects' detailed schedules, developed during feasibility.
11.7.4  EMP Costs
Some costs associated with Plan implementation clearly should be counted as EMP costs. Other Plan components have both a primary developmental function and an environmental management function (e.g. major river improvement). Keeping this in mind, EMP costs could include any or all of the following (overall total US$361.3 million, 34% of total Plan costs):

EMP study and implementation costs included in Plan FCD initiatives' budgets: US$42.7 million.

Total costs of Plan non-FCD projects which mitigate, compensate, enhance, or monitor environmental components subject to potentially adverse impacts from Plan FCD projects: US$239.2 million.

River improvement project costs (exclusive of EMP costs quoted above): US$75.9 million

Total costs of institutional strengthening projects not already included: US$3.4 million

A detailed breakdown is shown in Table 11.1.

11.8  LINKING WITH THE PROJECT AND PLAN ASSESSMENT PROCESSES

The results of an environmental impact assessment of a project need to be transferred or linked to the overall project assessment process. The goal is to make to sure that environmental concerns are given due weight in deciding whether a project warrants investment.

The tool used by NERP, and more broadly by the FAP, is the multi-criteria analysis. This is to include quantitative and qualitative indicators of all important environmental and economic impacts and criteria.

Explicit MCAs were included in the final chapters of most of the project pre-feasibility studies.

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