BANGLADESH ECONOMIC ZONES AUTHORITY (BEZA)

PRIME MINISTER’S OFFICE

Environmental & Social

Impact Assessment
Report of Sirajganj
Economic Zone
EIA & SIA of Sirajganj EZ

PREPARED BY

MD. ABDUL QUADER KHAN

SOCIAL AND RESETTLEMENT SPECIALIST
LIST BANGLADESH
OF ABBREVIATIONS
1
BEPZA Bangladesh Export Processing Zones Authority
BEZA Bangladesh Economic Zones Authority
BMD Bangladesh Meteorological Department
BOD5 Biochemical Oxygen Demand
BOQ Bill of Quantities
BOT Build, Operate and Transfer
BRTA Bangladesh Road Transport Authority
CAGR Compounded Annual Growth Rate
CETP Central Effluent Treatment Plant
CNG Compressed Natural Gas
DoE Department of Environment
dB (A) Decibel Unit (Amplitude)
DPP Development Project Proposal
ECC Environment Clearance Certificate
ECR Environment Conservation Rule
EHS Environmental, Health and Safety
EIA Environmental Impact Assessment
ESMF Environmental and Social Management Framework
EMP Environmental Management Plan
EMS Environmental Management System
EPC Engineering, Procurement and Construction
EPZ Export Processing Zone
ESC Environment and Social Cell
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESO Environmental and Safety Officer
EU European Union
EZ Economic Zone
FABR Fluidized Aerobic Bio Reactor
FGDs Focus Group
Discussions FDI Foreign Direct Investment
FTE Full Time Equivalent
GCF Gross Capital Formation
GDP Gross Domestic Product
GRC Grievances Redress Committee
GRM Grievances Redress Mechanism
GVA Gross Value Added
HFL Highest Flood Level
ICR Implementation Completion Report
IDA International Development Association
IECs Important Environmental Components
IEE Initial Environmental Examination
ILO International Labour Organization
IUCN International Union for Conservation and Nature
IDC Interest During Construction
MIS Management Information Systems
2
MSL Mean Sea Level
MLD Million Liters per
Day MFL Maximum Flood Level
MSW Municipal Solid Waste
NERP Northeast Regional Water Management Project
NOx Oxides of Nitrogen
NGO Non-Government Organization
NPV Net Present Value
OP Operational Policy
O&M Operations and Maintenance
PAP Project Affected Person
PEP Project Entitled Person
PD Project Director
PCU Passenger Car Unit
PFR Pre-Feasibility Report
PPP Public Private Participation
PSDSP Private Sector Development Support Project
PSIG Private Sector Investment Guidelines
PAU Project Affected Units
RAF Risk Assessment Framework
RAP Resettlement Action Plan
RMG Ready Made Garments
RSRP Resettlement and Relocation Programme
RSPM Respiratory Suspended Particulate Matter
RU Resettlement Unit
SEZ Sirajganj Economic Zone
SIA Social Impact Assessment
SPV Special Project Vehicle
STP Sewerage Treatment Plant
SPM Suspended Particulate Matter
SWM Solid Waste Management
ToR Terms of Reference
TDS Total Dissolved Solids
US United States
VOC Volatile Organic Compounds
WTP Water Treatment Plant
WQS Water Quality Standards

3
TABLE O F C O N T EN T S

1 Executive Summary ................................................................................................................. 11

1.1 Introduction.......................................................................................................................... 11
1.2 Legislative considerations ................................................................................................... 12
1.3 Project description ............................................................................................................... 12
1.4 Description of the environment ........................................................................................... 13
1.5 Identification and evaluation of potential impacts ............................................................... 14
1.5.1 Construction stage impacts .................................................................................................. .14
1.5.2 Operation stage imacts......................................................................................................... 14
1.6 Alternative Analysis .............................................................................................................15
1.7 Mitigation measures.............................................................................................................. 15
1.8 Environmental Management plan (EMP) ........................................................................... .. 1 5
1.9 Environmental Monitoring and institutional development ................................................. ..1.6
1.9.1 Pre-construction stage monitoring....................................................................................... .. 16
1.9.2 Construction stage monitoring ...............................................................................................16
1.9.3 Operation stage monitoring ................................................................................................. .16
1.9.4 Institutional arrangement .................................................................................................... 1 .6
1.10 Public consultations.............................................................................................................. .16
1.11 Summary............................................................................................................................... 17
2 Introduction.................................................................................................................................. 1 8
2.1 Background........................................................................................................................... 18
2.2 Scope of the study ................................................................................................................ 18
2.3 Methodology Adopted ......................................................................................................... 19

3 Applicable Environmental Regulatory Framework......................................................................22

3.1 National Environmental Policy, 1992 .................................................................................22
3.2 National Environmental Management Action Plan, 1995....................................................22
3.3 National Conservation Strategy, 1992.................................................................................. 23
3.4 Relevant National Legislation ..............................................................................................24
3.5 Ecologically Sensitive/ Protected Areas near the project region ......................................... 28
3.5.1 Ecologically sensitive areas...................................................................................................28
3.5.2 Protected Areas .....................................................................................................................29
3.6 Statutory Environmental Requirements for the project ........................................................32
3.6.1 GoB requirements .............................................................................................................. 32
3.6.2 WB requirements ................................................................................................................ 34

3.6.3 Concordance Analysis for Project Requirements ................................................................34

4
4 Project description ....................................................................................................................... 35
4.1 Introduction To Sirajganj EZ (SEZ) .................................................................................... 35
4.2 Site and surroundings ........................................................................................................... 37
4.3 Land Use Plan ...................................................................................................................... 38
4.4 Infrastructure requirement ................................................................................................... 38
4.4.1 Basic infrastructure Requirement .........................................................................................39
4.4.2 Environmental infrastructure .................................................................................................40
4.5 Man power ........................................................................................................................... 45
4.5.1 Construction stage................................................................................................................. 45
4.5.2 Operation stage .................................................................................................................... 45
5 Description of the environment ................................................................................................... 47
5.1 General ................................................................................................................................. 47
5.2 Project Influence Area ......................................................................................................... 50
5.2.1 Determining factors for the project influence area .............................................................. 51
5.3 Physical Environment .......................................................................................................... 51
5.3.1 Atmosphere & Climate .................................................................................................... 51
5.3.2 Land condition ................................................................................................................. 53
5.3.3 Water resources ......................................................................................................................54
5.4 Biological Environment........................................................................................................60
5.4.1 Ecology......................................................................................................................... 60
5.4.2 Aquatic Flora.................................................................................................................60
5.4.3 Aquatic Fauna ...............................................................................................................61
5.4.4 Terrestrial Flora ............................................................................................................62
5.4.5 Terrestrial Fauna...........................................................................................................62
5.4.6 Protected Areas ............................................................................................................ 62
5.5 Natural hazards and risks ......................................................................................................62
5.5.1 Seismic Effects ............................................................................................................ 62
5.5.2 Cyclones and Storms ................................................................................................... 63
6 Identification and evaluation of Potential Impacts .......................................................................64
6.1 Pre-Construction stage environmental impacts.................................................................... 64
6.1.1 Natural flow stopped due to filling of water bodies ..................................................... 64
6.1.2 Loss of Trees ................................................................................................................ 64
6.1.3 Risk due to Earthquake................................................................................................. 65
6.2 Construction stage environmental impacts .............................................................................65
6.2.1 Disruption of earth Surface .......................................................................................... 65
6.2.2 Soil erosion and siltation .............................................................................................. 65
6.2.3 Surface water and ground water pollution .....................................................................65
5
6.2.4 Traffic flow congestion .................................................................................................65
6.2.5 Air quality ......................................................................................................................66
6.2.6 Noise pollution ............................................................................................................. 66
6.2.7 Water resources .............................................................................................................66
6.2.8 Solid waste disposal.......................................................................................................67
6.2.9 Bridge structures ........................................................................................................... 67
6.2.10 Flora and fauna ............................................................................................................. .67
6.2.11 Historical and cultural monuments ............................................................................... 67
6.3 Operation stage environmental impacts.................................................................................67
6.3.1 Air Quality ....................................................................................................................68
6.3.2 Dust............................................................................................................................... 68
6.3.3 VOCs ............................................................................................................................68
6.3.4 Exhaust Gases ...............................................................................................................68
6.3.5 GAS-based power plant ................................................................................................69
6.3.6 Noise pollution ............................................................................................................. 69
6.3.7 Traffic flow/congestion ................................................................................................. 70
6.3.8 Water Pollution ............................................................................................................. 70
6.3.9 Solid waste.................................................................................................................... 72
6.3.10 Odour............................................................................................................................ ..73
6.3.11 Flooding ........................................................................................................................ 73
6.4 Evaluation of Impacts ........................................................................................................... .73
7 Analysis of Alternatives ..................................................................................................................74
7.1 The No Build scenario ..............................................................................................................74
7.2 Consideration of alternatives ....................................................................................................74
7.2.1 Alternative sites .............................................................................................................74
7.2.2 Site Analysis ................................................................................................................. 74
7.2.3 Socio-environmental considerations............................................................................. 75
7.2.4 Alternate production techniques for textile dyeing ...................................................... 78
8 Mitigation and enhancement measures .........................................................................................79
8.1 Mitigation measures.............................................................................................................. 79
8.2 Enhancement measures ........................................................................................................ .79
9 Environmental management plan (EMP) ....................................................................................... 93
9.1 Objective................................................................................................................................93
9.2 Environmental management measures proposed ................................................................. 93

9.3 Specific management plan .............................................................................................................93

9.3.1 storm water management plan........................................................................................93

6
.
9.3.2 Wastewater management plan ..........................................................................................94
9.3.3 Solid waste management plan ........................................................................................97
9.3.4 Traffic management .......................................................................................................98
9.3.5 Landscaping/greenery ....................................................................................................98
9.3.6 Occupational Health & Safety Management Plan ....................................................,..98
9.3.7 Industrial risks and contingency plan ......................................................................... 100
9.3.8 Appropriate contingency and emergency response measures..................................... 100
10 Environmental monitoring and Institutional development ....................................................... ..102
10.1 Monitoring plan .................................................................................................................. .102
10.1.1 General Features ...........................................................................................................102
10.2 Institutional arrangement .................................................................................................. …104
10.2.1 Roles and Responsibilities ............................................................................................105
10.2.2 Training ...................................................................................................................... ..106
10.2.3 Environmental Specifications .................................................................................... ..106
10.2.4 monitoring Program ................................................................................................... ..106
10.2.5 Reporting systemand record keeping .......................................................................... 111
10.2.6 Environmental audit .................................................................................................... 113
10.3 Implementation Schedule and Cost Estimates..................................................................... 113
10.3.1 Implementation Schedule ............................................................................................ 113
10.3.2 Cost Estimates ............................................................................................................. 113
11 Public Consultation ...................................................................................................................... 115
11.1 Objectives ............................................................................................................................ 115
11.2 Identification OF stakeholders ..............................................................................................115
11.3 Community concerns on project intervention ...................................................................... 116
11.4 Future consultation and disclosure plan ............................................................................... 116
12 Conclusions and recommendations .............................................................................................. 118
12.1 Key conclusions .....................................................................................................................118
12.2 Recommendations ................................................................................................................ 119

7
Social, Gender and Resettlement Issues……………………………120-142

Annex 1 – Environmental Clearance from the DoE

Annex 2 – Consolidated Environmental Standards
Annex 3 – Water Balance Scheme for the project
Annex 4 – List of Flora and Fauna Species
Annex 5 – Borrow Pit Guidelines
Annex 6 – Environmental Clauses for the bid documents
Annex 7 – Impact Assessment Matrix
Annex 8 – EMP Implementation Schedule

8
LIST O F FIGURE

EXHIBIT 1 LAND USE DISTRIBUTION AT THE SITE ...... ... .... ... .... ... ... .... ... .... .... ... ... .... ... ... .... ... .... ... .... ... .... ... ..12
EXHIBIT 2 UTILITY DEMAND STIMATION.... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... ....13
EXHIBIT 3 PROPOSED ZONES IDENTIFIED UNDER SDSP. .... ... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ... ..18
EXHIBIT 4 OVERVIEW OF NATIONAL LEGAL INSTRUMENTS. ... .... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... ... ....27
EXHIBIT 5 ENVIRONM ENTA LLY SENSITIVE AREAS IN BANGLADESH ...... ... .... ... ... .... .... ... ... .... ... .... ... ....28
EXHIBIT 6 NOTIFIED & PROTECTED AREAS OF NGL A D E SH .. ... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ..30
EXHIBIT 7 PROTECTED AREAS OF BANGLADESH (SOURCE: DEPARTMENT OF FOREST) ...... ... ... .... ..31
EXHIBIT 8 STEPS FOLLOWED FOR ENVIRONM ENTAL CLEARANCE FOR RED CATEGORY PROJECT.... ...... .... .33
EXHIBIT 9 Concordance Analysis of EIA Requirements -------------------…..-.... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... .34
EXHIBIT 10 PROPOSED MASTER PLAN FOR SIRAJGNANJ ..... ... .... ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... .36
EXHIBIT 11 SITE PHOTOGRAPHS ........ ... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... ... ...37
EXHIBIT 12 LAND USE DISTRIBUTION AT THE SITE ....... .... ... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ..38
EXHIBIT 13 INDUSTRIAL LAND-USE MIX ..... ... .... .... ... .... ... ... .... ... .... ... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... 39
EXHIBIT 14 ROAD BUFFER REQ U IR E M E N T S ..... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ..39
EXHIBIT 15 WATER DEMAND ESTIMATION STANDARDS ...... .... ... .... ... ... .... .... ... .... ... ... .... ... .... ... ... .... ... .... ..40
EXHIBIT 16 WATER CONSUMPTION PATTERN (FRACTION OF TOTAL DEMAND)... .... ... ... .... ... .... ... .... ..40
EXHIBIT 17 WATER CONSUMPTION PATTERN – POTABLE VS. NON-POTABLE ........ ... ... .... ... .... ... .... ... .41
EXHIBIT 18 WATER DEMAND JECT IO N S .... ... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... .... ... .... ... ... .... ... ....41
EXHIBIT 19 STORAGE RESERVOIR SIZE ESTI M A T IO N ...... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ... .... ... .... ... .... ... .41
EXHIBIT 20 ALTERNATIVES OF TREATMENT OF WATER ..... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... .... ... ... .... ..42
EXHIBIT 21 SCHEMATIC OF WATER TREATMENT SYST E M .. .... ... .... ... ... .... ... ... .... .... ... .... ... .... ... ... .... ... .... ...43
EXHIBIT 22 WASTE WATER ESTIM A T I O N ... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ..43
EXHIBIT 23 SOLID WASTE CONSTITUENTS ...... .... ... ... .... .... ... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ..44
EXHIBIT 24 SOLID WASTE GENERATION ASSU M PT IO N S ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... ... .... ... ... ...44
EXHIBIT 25 SOLID WASTE GENERATION ESTIMATION ..... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... .... ... ... .... ... ... ..45
EXHIBIT 26 MAN POWER FOR ADMINISTRATIVE LEV E L ... ... .... ... .... ... ... .... ... .... ... .... ... ... .... ... .... ... ... .... ... ... ...45
EXHIBIT 27 MAN POWER FOR M AINTENANCE OF VAEIOUS ENVIRONM ENTAL INGRASTRUCTURE……..46
EXHIBIT 28 SCOPING MATRIX..………………………………………………………... ... ... .... ... .... ... ... .... ... ... .. 48
EXHIBIT 29 ENVIRONM ENTA L ATTRIBUTES AND FREQUENCY OF MONITORING…….. ... .... ... ... .... .. 49
EXHIBIT 30 AT A GLANCE RAJAPUR UP OF BELKUCHI & SAIDABAD UP………….……. ... ... .... ... .... ... 50
EXHIBIT 31 PROCEDURES FOR DETERMINING VARIOUS AIR QUALITY PARA M E T E R S.. .... ... ... .... ... ...52
EXHIBIT 32 AIR QUALITY RESULTS AROUND MEPZ AREA ...... ... .... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... ... ..53
EXHIBIT 33 PHYSIOGRAPHICA L MAP OF BANGLADESH ..... ... ... .... ... .... ... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ...54
EXHIBIT 34 FLOOD PRONE AREAS OF BANGLADESH ....... ... .... ... .... ... ... .... ... ... .... ... .... ... ... .... ... .... ... ... ... . ... .. 56
EXHIBIT 35 EATHQUAKE & FLOOD PRONE AREAS OF BANGLADESH ........ ... .... ... ... .... ... .... ... ... .... ... .... ... . 63

9
EXHIBIT 36 FLOW CHART FOR COMPOSITE TEXTILES ...... ... .... ... ... .... ... .... ... .... ... .... ... .... ... .... ... .... ... ... .... .. 71
EXHIBIT 37 SUMMARY OF SITE CONSTRAINTS AND CORRESPONDING DESIGN ASPE C T .. ... ... .... ... 75
EXHIBIT 38 ENVIRONMENTAL QUALITY ST ANDARDS CONSIDERATION FOR ENGINEERING DESIGN ................................... 75

EXHIBIT 39 MITIGATION MEASURES ....... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ... .... ... ... .... ... .... ... ... .... ... ... .... ... .... . 92
EXHIBIT 40 SEWAGE COLLECTION & TRANSPORT NETWORK DESIGN CRITERIA ....... ... .... ... ... .... ... 94
EXHIBIT 41 RAW EFFLUENT CHA RA CT E RI ST IC S ... .... ... ... .... ... .... ... .... ... .... ... .... ... ... .... ... ... .... .... ... ... .... ... .... .. 94
EXHIBIT 42 TREATED EFFLUENT CHARACTERISTICS ...... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ........................... 95
EXHIBIT 43 RAW EFFLUENT CHA RA CT E RI ST IC S ... .... ... ... .... ... .... ... .... ... .... ... .... ... ... .... ... ... .... ... .... ... ... .... ... ... 96
EXHIBIT 44 TREATED EFFLUENT CHARACTERISTICS ...... ... .... ... .... ... ... .... ... .... ... ... .... ... .... ... .... ... ... .... ... .... ..96
EXHIBIT 45 EFFLUENT COLLECTION & TRANSPORT NETWORK DESIGN ITERI A . .... ... .... ... ... ....................96
EXHIBIT 46 INTEGRATED SOLID WASTE MANAGEMENT METHODOL.. ... ... .... ... .... ... ... .... ... ... .... ... .... ... 97
EXHIBIT 47 EMP IMPLEMENTATION AND ORGANISATION STRU C T U R E ....... ... .... ... .... ... .... ... ... .... ... .... 104
EXHIBIT 48 MONITORING PROGRAM DURING PROJECT CYCLE ....... .... ... ... .... ... ... .... ... .... ... ... .... ... ... .... 110
EXHIBIT 49 REPORTING SYSTEM ...... .... ... ... ..... ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... . 112
EXHIBIT 50 TYPICAL RECORD KEEPING REQ U I R E M E N T S ..... .... ... .... ... ... .... ... .... ... ... .... ... ... .... ... .... ... ... ... 113
EXHIBIT 51 EMP BUD G E T .. ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... .... ... ............. 114
EXHIBIT 52 ENVIRONM ENTA L CONCERNS/ISSUES OD SURROUNDINGS … . .... ... .... ... .... ... ... .... .... .... 116

10
CHAPTER # 1
EXECUTIVE SUMMARY
1.1 I NT RODUCT IO N

The Bangladesh Economic Zones initiative is a part of the vision 2021/MDG. As part of the initiative, a ECONOMIC
ZONES ORDINANCE WAS FORMULATED IN 2007-08 which is approved by the Government in 2010. Further,
Support to Capacity Building of Bangladesh Economic Zones Project assigned a Social Specialist (Consultants)
– to carry out the Resettlement and EIA/SIA of five sites to be developed as Economic Zones. The Sirjganj
Economic Zone Project (SEZ) is one of the four sites selected for the study.
This report summarizes the environmental and social impacts associated with the Sirajganj EZ Project proposed to
be located at Rajapur Union of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila of Sirajganj
district . The assessment of impacts has been based on the design of the project proposed. The EIA/SIA is done in
accordance with the environmental assessment requirements of the WB Safeguard Policies (OP 4.01, 4.12) and
the Environment Conservation Rules (ECR), 1997 under the Environment Conservation ACT, (ECA) 1995 and its
subsequent amendments, Government of Bangladesh. The Project is classified as “Category A” by the World
Bank.
The scope for the Environment and Social Impact Assessment is as follows:
 A general description of the proposed sub-project and existing physical, environmental, biological
and socio-economic conditions;
 Consultations with stakeholders involving affected people in identifying the
social/resettlement and environmental issues;
 Identification and assessment of the potential impacts associated with infrastructure development
and industrial units’ activities within the study area on the natural and human environment; and
 Identification of the means of mitigating negative impacts and development of an Environmental
Management Plan (EMP) including mitigation measures for negative impacts, measures for
pollution control and environmental monitoring.
For the EIA study, the following methodology is adopted:
Collection and review of documents relevant to Sirajganj Economic Zones reconnaissance, field visit to site
and neighborhood areas ;
 Continuous interaction with design consultants
 Stakeholder consultations
 FGDs
 Environmental data collection and analysis
 Detailed legislative review
 Identification, prediction and evaluation of significant/potential impacts
Formulation of Environmental Management and Monitoring Plan

11
1.2 L E GI S L AT I V E CO NSI D E R ATIONS

The proposed project should comply with the relevant legislation and planning requirements of Bangladesh.
Furthermore, the safeguard policies of the World Bank/any development partner also need to be followed (As
required )
Key provisions of the same have been discussed in the report. Relevant Policies, Strategies and Plans (National
Environmental Policy 1992, NEMAP 1995, NCS 1992) of the Government have been discussed to make the
intervention in line with the Government Policies and Guidelines (DoE, EIA Guidelines for Industries). The National
Environmental Quality Standards and International Standards have been assessed to make sure that the project
interventions are consistent with those standards.
As per WB environmental categorization, the OP 4.01 (Environmental Assessment) is triggered by the project and
therefore requires detailed EIA including specific EMP.

1.3 PROJECT DESCRIPTION

Considering the growing demand of foreign investors for industrial plots and experience from successful
implementation of Dhaka, Chittagong, Comilla, Adamjee, Mongla and other Export Processing Zo nes (EPZs),
Bangladesh Economic Zone Authority (BEZA) plans to develop an EZ at Sirajganj Several sites were identified
initially as potential EZ for the project. After a site visit on May 2011 by BEZA, a site having an area of approx.
1035. 94 acres at western site of Bangabandhu Bridge was finalized.

Based on the market study and assumptions related to the commercial positioning of the zone, the land use pattern
in terms of industry mix was proposed by the consultants. The land use pattern is summarized in the following
figure :

A. Industries %
Knitting 500.00 44.02
Spinning 300.00 26.41
RMG 97.94 8.62
B. Utilities %
Customs, Security, Admin, entrance plaza & Social 25.00
infrastructure 2.20
Essential staff quarters 15.00 1.32
Road 70.00 6.16
Greenery 103.00 9.07
Warehouse 10.00 0.88
Gas Power Plant 15.00 1.32
Total 1,135.94 100.00
Figure 1 : Land Use Distribution at the Site
The general internal infrastructure and utilities envisaged for the Sirajganj EZ are:
 Site grading, boundary wall
 Road
 Storm drainage
 Power supply
 Street lighting
 Bridge
The environment-related infrastructure designed includes:
 Water supply & treatment system
 Sewage collection, treatment and recycle

12
 Effluent Collection and Treatment System
 Solid waste management system

The onsite infrastructure was designed based on the fact that the EZ would be developed in phases, for optimum
project implementation & financial returns. Normative estimation of the demand for utilities etc. yielded estimates as
summarized in the following figure :

Utility Aspect Projection ( Ultimate )

Power Demand 60 MVA
Water Demand 12.84 MLD
Traffic Volume 12300 PCU/day
Effluent Generation 3 MLD
Sewage Generation 4 MLD
Solid Waste Waste Generation 80.5 TPD
Figure 2 : Utility Demand Estimation

The design of onsite project infrastructure components and also the project cost estimation was carried out based on
the aforementioned utility demand estimation projections. Also, the development of the overall EZ is likely to
happen over two phases.

1.4 DE S CRI P T I O N OF T HE EN V I RONMENT

The baseline data has been compiled for: Land Environment; Water Environment; Air Environment; Noise
Environment; Ecological Environment and Socio-economic Environment. Primary data related to environmental
attributes like air, noise level and water quality was collected through field studies. Information on other aspects
was obtained from field observation as well as secondary sources.

Land Environment
Parameters involved in land environment are land use/land cover pattern, physiography, geology and
minerals, soils, and seismicity.

The existing land use of the proposed Sirajganj EZ site is mostly dominated by low lying agricultural lands followed
by surface water body of canals and Jomuna river channels. Most of the land is single crop agricultural land and
rest is double cropped. The proposed site is located on the flood plain of Jamuna. Proposed site is located
between western site of Bangobondu Multipurpose Bridge. Sirajganj Town is located North- west of the proposed
project site The topography of the land varies from -2.363 to +5.765 m with respect to the Mean Sea Level (MSL)
with moderate slope. The site is situated near the Jomuna Flood Plain. The dominant soil texture is sandy loam.
The soil of the area is grey loam on the ridges and grey to dark grey clays in the basins. The dominant general soil
type is non-calcareous grey flood plain soil. The area falls under Earthquake Zone II as per the NBC (National
Building Code) of Bangladesh
Water Environment
The water bodies within the site are used for irrigation and drinking water supply as well as for inland river
transport. The pollution level of water in the river is low as ascertained from the water sample analysis results.
Therefore, although development of the EZ might lead to increase in the pollution levels, they are expected to be
within the prescribed limits.
However, contamination of ground water may be a significant problem. Development of industries in the region
might lead to contamination of ground water which would disturb the drinking water supply to the nearby
population. Rain water harvesting and ground water recharge structures have been proposed to ensure that
the quality of ground water is maintained.

13
Air Environment
The climate of the study area is humid and tropical. A hot and humid pre-monsoon from March to mid-May, a
prolonged southwest monsoon or rainy season from mid-May to September, a pleasant post-monsoon or retreating
monsoon from October to November and a cold pleasant winter from December to February are the characteristics
of the climate. Summer runs concurrently with the later part of the pre-monsoon season and continues
throughout the monsoon season.
Air quality standards in the region are found to be within the prescribed limit. However, with several manufacturing
industries being planned in the zone, emissions from the industries may lead to pollution of the ambient air quality.

Noise Environment
Existing sound levels were found to be exceeding the normal limits. The reason for that is the existence of the
industries as well as other commercial activities in the nearby region. Therefore, it is envisaged that mitigation
measures for preventing noise pollution would be required for the region

Ecological Environment
The ecosystem that evolved on the Jamuna floodplain and the Jamuna River is very important from biodiversity and
economic point of view. This ecosystem supplies huge amounts of freshwater fish products
Rajapur and Saidabad Union constitute a part of the Jamuna floodplain ecosystem and are inhabited by many
important freshwater plants and fauna species. The channels of the Jamuna River and associated Jamuna Flood
Plain are the habitat of many species of commercial freshwater fishes, native waterfowl and migratory birds.
The proposed project site does not fall under the jurisdiction of any of the protected or sensitive areas in
Bangladesh.

1.5 I D EN T I F I CAT I ON A ND E V AL U AT I O N O F P OT E NT I AL I M P ACT S

The primary function of an environmental impact assessment study is to predict and quantify the magnitude of
impacts, evaluate and assess the importance of the identified changes and formulate plans to monitor and mitigate
the actual changes. Environmental impacts could be positive or negative, direct or indirect, local, regional or global,
reversible or irreversible.
Impacts Identification: T he potential impacts of the project on the environment can be in different phases
of the project cycle viz. location, construction and operation. The type and magnitude of the impacts, however
depends on the specific attributes of the given environment.
OUT OF THE TOTAL LAND, APPROXIMATELY 10% (103.59 ACRE) IS IN THE FORM OF OPEN WATER BODIES
(RIVER/CANAL). Out of the remaining (932.35 acre) lands, 30 acres is homestead, 2.00 acres is common property
and 900.35 acre is agricultural land. A total of 815 households, One Government Primary School, Two mosque,
Two Madrasa, 02 non- government primary school will be affected by the project. There is 10 commercial and
business enterprise within the proposed project area.

1.5.1 CONS T RUCT I ON S T A GE IMPACTS

During the construction phase, IMPACT ON FAUNA IS EXPECTED TO BE THE MOST SIGNIFICANT IMPACT
WHICH COULD BE IRREVERSIBLE. Other major impacts during construction would be noise, air and water
pollution. These will need to be mitigated properly through good construction practices that are compliant with
international standards.

1.5.2 O P E RA T I O N S T A GE IMPACTS

Only yarn and fabrics are expected to be the water-polluting units. Other industries are assumed to be only
formulation (pharmaceuticals), apparel making (leather and jute) etc. and they do not produce any effluents. The
major environmental components that are expected to be adversely affected by the activities of the project are water
quality and ambient noise conditions. The EZ has been planned in such a way as to consider these impacts and
14
reduce them to a minimum. For waste disposal, a separate area has been identified where a CETP has been
proposed to treat the untreated effluent to meet ‘zero discharge’ standards i.e. no treated/ non- treated water and
solid waste generated from the CETP will be let out to areas surrounding the EZ. As per the impact matrix, three
parameters (surface water, noise, and odour) reach scores in the range of 72 to -96 which indicate major and
irreversible impact, if not properly mitigated. It should be noted that parameters in the impact matrix relate to the
impacts, assuming no mitigation
Also, NO CUMULATIVE IMPACT IS EXPECT ED TO BE CREAT ED, although there are few industrial settlements in
the nearby region.

1.5.3 AL T E RNA T I VE ANALYSIS

Due to land scarcity in the country, seeking an alternative site for establishing an industrial zone is quite difficult.
Also, land acquisition is a lengthy and complex procedure under the existing land acquisition law. Further, the
project conceptual development over alternative sites is quite difficult because delay in overall land acquisition
process might create social conflicts and risks for the project.
This site has been selected by BEZA and some initial planning for land acquisition is in process. Part of this
land is Government ‘khas’ land and the remaining needs to be taken from public. As per plot schedule provided by
BEZA, the total amount of land to be acquired for the project is 1035.94 acres
To minimize displacement and other adverse impacts on the settlements and privately owned land, the project is
planned to be implemented mostly in paddy land. A total of 815 households, One Government Primary School,
Two mosque, Two Madrasa , 02 non- government primary school will be affected by the project. About 10% (103.59
ACRE of the total land is open water bodies belonging to GoB.

1.7 M I T I GAT I ON M E AS UR E S
To avoid and minimize the impacts resulting from the activities of the project, measures and management
plans, which are essential to mitigate the impacts discussed above, have been proposed. These are based
upon appropriate technological design, improvements or adjustments, and policy including good site
operational practices etc. The overall strategy has the following sequence:

 Impact avoidance: Changing project location, design and construction methods to avoid impacts.
 Impact minimization: Where impacts cannot be avoided, implementing mitigation measures to
reduce the impact to acceptable levels.
 Compensation: Arranging compensation where impacts cannot be avoided or sufficiently
mitigated.
 Enhancement: Measures, which, at insignificant cost to the project, give appreciable developmental
benefits.

The mitigation plan has been recommended to highlight the procedures to avoid/minimize / control the impacts
arising out of different project phases i.e. pre-construction, construction and operation, the plan is elaborately
described as matrix format in the report.

1.8 E NV I RO NM E NT A L M A NAGE M E NT P L AN (EMP)

The EMP is based on five major principles:

 The POLLUTER PAYS for pollution and prevention of pollution
 The DEPART MENT OF ENVIRONMENT (DOE) IS TO PLAY A CENTRAL ROLE in the
environmental safeguarding of the project - regulation, supervision and enforcement.
 Environmental SAFEGUARDS TO BE INCORPORATED FROM THE INCEPTION of all
activities.
 PRIVATE SECTOR DEVELOPMENT FOR EXECUTION AND IMPLEMENTATION of
environmental safeguard related activities.

15
 All activities undertaken within the framework of the PSDSP or subsequent
developments are to be reviewed for their environmental impacts, and, when required, they need to
be included in relevant EFFECTIVE ENVIRONMENTAL MANAGEMENT PLANS aimed at off-
setting, preventing, or mitigating any such negative impacts.
Certain important and specific management plans with their respective action procedures for carrying out the
overall EMP effectively are enumerated separately in the report.

1.9 E N VI RO NM E NT A L M ON I T O RI NG AND I N ST I T UT I O N A L D EV E L OPM E N T

1.9.1 P RE- CO NST RUCT I O N S T A GE M O NI T ORI NG
Compliance monitoring during the pre-construction stage from the environmental perspective would
consist of the following components:
 Checking that the project’s design incorporates appropriate measures to avoid or minimize
negative impacts
 Incorporation of appropriate protective clauses in the contract documents that are to be followed by
the developer(s
1.9.2 CO NS T RUCT I O N ST A GE M O NI T ORING
Compliance monitoring during the construction stage comprises:
 Developer’s compliance with environmental clauses in their day-to-day activities
 Implementation of site clearance activities after completion of work
1.9.3 O P E RAT I O N S T AGE M O NI T ORI NG
Operations stage monitoring would involve the following:
 Periodic monitoring and checking of environmental parameters within the EPZ Inspection of
individual units to check whether the units follow the prescribed environmental and
social norms or not
The rationale for the reporting system is based on accountability to ensure that the measures proposed as part of
the Environmental Management Plan get implemented in the project.

1.9.4 I N ST I T U T I ONAL A RRA NG EM ENT

The implementation of the EMP will be done by the project developer in case of the project being developed
by a SPV and supervised by an Environment and Social Cell. Otherwise, the present BEZA structure with an
additional Environmental and Social Cell has been recommended. The following key entities will be involved in the
EMP implementation:
o Project Director/GM
o Environmental and Social Cell (ESC) Supervision Consultant
o Supervision Consultant
o Developer

1.10 P UBL I C CO NSU L T AT I ONS

As per the requirements of World Bank guidelines, public consultations were undertaken to seek opinion and
suggestions from various stakeholders that will provide inputs required for designing, construction and other
implementation related issues of Sirajganj EZ Project.
The consultation program has three components as under:
 Identification of key stakeholders
 Consultation with all key stakeholders
 Public access to the outcome of the EIA Process and further information about the
project

16
1.11 S U M M ARY
On critical review of the potential environmental impacts, the specific mitigation and monitoring measures proposed
and the benefits described, it was found that the project is not expected to lead to any long term irreversible
adverse impacts on the environmental quality and resources. The findings further suggest that major environmental
components adversely affected during implementation of proposed EZ would be: loss of water bodies, trees, socio-
economic environment, hydrology/drainage, back water effect, erosion, industrial effluent, and pollutant emissions
to air, noise / vibration, accidental risk, occupational health and safety. T he potential negative and long term
problem could arise if the new bridge is incorrectly sized, leading to flooding and erosion. This could be avoided by
USING A HYDRAULIC MODEL during the design process.
INDUSTRIAL EFFLUENTS FROM INDIVIDUAL PROCESSING UNITS COULD BE A MAJOR SOURCE OF
ADVERSE IMPACT during operational phase of the proposed project. This might create long term and irreversible
effect to a certain degree on the receiving environment, if no mitigation measures are adopted. It is
recommended that all industrial effluents be collected and conveyed through closed pipes to the CETP which will
ensure zero discharge treated effluent by way of recycling.

Having reviewed all the potential environmental impacts and following the recommended mitigation measures as
per this EIA, the proposed Sirajganj EZ Project is expected to proceed without having any unacceptable
environmental impacts.

17
2. INTRODUCTION
2.1 BACKGROUND

Economic Zones (EZs) have been set up in the country to promote exports and these have been relatively
successful especially in sectors such as textiles. This is largely attributable to availability of serviced land,
infrastructure and logistics. In addition, there is also an authority controlling the sector – the Bangladesh Economic
Zones Authority (BEZA).
However, the overall impact of EZs has been limited. The spillover effects into the local economy are also felt
to be limited. Further, the EZs have been developed solely by the public sector, whose resource limitations constrain
further growth.
To overcome some of the shortcomings of the EZ sector, a new Economic Zones regime was contemplated by
the Government. These would actively encourage private participation, cater to both exporters as well as the
domestic market and have world class standards of infrastructure, environmental and social compliance.
Towards this end, an Economic Zone ordinance was finalized and passed by the interim administration. The
ordinance of BEZA already approved by the Government in 2010. The PSDSP program is one of the key
initiatives designed to further the objective of EZ development.

Further, Bangladesh Economic Zones Authority appoint a Project Director for Support to Capacity Building of
Bangladesh Economic Zones Authority. Project also appointed a Social Specialist – to carry out the Social and
Environmental activities. The Sirajganj EZ is one of the 5 sites selected for the study, the details of the four sites is
as follows:
Location Area (Acre ) Proposed
Industries /
Companies
Mirshorai,Chittagong 6615 .12 Multiproduct
Anwara, Chittagong 611.47 Shipbuilding
Sherpur, Moulovibazar 352.89 Multiproduct
Mongla, Bagerhat 203 Multiproduct
Sirajganj 1041.43 Multiproduct
Figure 3 : Proposed Zones identified by BEZA
This EIA/SIA will examine the aspects of the project activities, which are likely to interact with and affect the
surrounding environment and the community. The EIA and SIA report provides an Environmental Management Plan
(EMP) and Social Screening issues along with specific mitigation measures with a view to reduce and/or control the
level of adverse impacts upon the environment as well as to enhance measures for positive impacts resulting from
the proposed project activities.

2.2 S CO PE OF T HE ST UDY

The scope of the report covers the environmental legislative, regulatory & policy guidelines and considerations
relating to the implementation of the proposed EZ including the following:
 Describe the proposed project and associated works together with the requirements for carrying out
proposed development;
 Identify and describe the elements of the environment likely to be affected by the proposed
developments;
 Establish the baseline environmental and social scenario of the project area
 Identify and quantify pollution sources and determine the significance of impacts on sensitive
receptors;
 Identify, predict and evaluate environmental and social impacts expected during the
construction and operation phases of the project;
 Assess the opinion of the public/stakeholders observed in the consultation in identifying the
environmental issues;

18
 Develop mitigation measures so as to minimize pollution, environmental disturbance and
nuisance during construction and operation of the development;
 Design and specify the monitoring requirements necessary to ensure the implementation and the
effectiveness of the mitigation measures suggested; and
 Work out the cost of environmental mitigation and monitoring requirements

2.3 M E T HODOL O GY A DO P T E D

The methodology used for this study is based on the procedures described in EIA guidelines for industries
published by DoE of the GoB as well as the guidelines embodied in World Bank’s safeguard policies.
The main objectives of EIA are to :
 Identify the project or activity and the environment in which it will be implemented i.e. describe
proposed new activities;
 Predict the impacts of each activity on the different components of the environment i.e. relate the
activities to planning regulations;
 Evaluate the significance of predicted impacts and develop alternatives i.e. analyse primary and
secondary environmental impacts: These are physical, ecological , social as listed in the ‘Impact
Matrix’ for environment;
 Formulate the basis for Environmental management plan together with monitoring program and
controlling mechanism to protect local environment i.e. EIA methodology enables a participatory
planning activity between industrial enterprise, government and community.
 Communicate these impacts to decision–makers and affected communities and generate
courses of action to reduce the impacts;
The overall activities of the EIA study include the following:
 Kick-Off meeting with BEZA Officials: The study started with a kick- off meeting between the EIA/SIA
Consultants and BEZA Officials in order to obtain project background, present status, sources of secondary
data/reports, guidance, etc. and to finalize the work plan.
 Collection and review of documents: Project Proposal of ‘Northern Economic Zone which is conducted by
Industrial Development Company Ltd.. Several other documents were reviewed. The details are provided in the
references
 Site reconnaissance, field visit to site and neighborhood areas: The EIA team undertook reconnaissance and
field visits to the study area of Sirajganj EZ area to observe the site- specific environmental concerns and to
get perception within the vicinity of the area. During site visits the team addressed the following issues:
o Hydrological features of the area;
o Land use and settlement pattern;
o Aquatic and terrestrial flora and fauna;
o Endemic, rare and threatened species;
o Presence of sensitive features, reserve forest, wildlife sanctuary, religious
o structures etc. within and along the proposed EPZ area;
o Public utilities/facilities;
o Baseline Conditions
o Effluent discharge route
 Stakeholder Consultations: EIA Consultants held consultations with:
Board of Investment
Bangladesh Economic Zones Authority
Department of Environment
Local administrative representatives
Local leaders, educated/business group etc
Project Affected Persons

19
Environmental Data Collection and Analysis: Samples of water, air quality and noise level were collected
from pre-determined sampling stations with subsequent analyses of various environmental quality
parameters for baseline data generation.
Detailed Legislative Review: The applicable guidelines of GoB/World Bank were reviewed. This review
addressed social and environmental policies and requirements at following levels:
o National Legislation
o World Bank Safeguards Policy and guidelines relevant to the study

Deskwork for identification, prediction and evaluation of significant/potential impacts was carried out
with the collected information and data through usages of ‘Impact Matrix’. Thereafter, possible mitigation
measures to reduce/control negative impacts and enhancing measures for positive impacts have been
identified.
Formulation of Environmental Management Plan for implementation of the proposed
Sirajganj EZ.

20
CHAPTER # 2
REPORT LAYOUT
Chapter 2 of the report is an Introduction. It gives an overview of the objective, and scope of study and
Methodology. The legal/ policy frameworks along with environmental standards are summarized in Chapter 3. In
Chapter 4, a concise documentation is given on the proposed project activities and facilities including project
features. Chapter 5 summarizes the environmental baseline data on physical, ecological and socioeconomic
parameters. Chapter 6 highlights anticipated potential positive and adverse environmental impacts of the project.
Environmental impacts due to the proposed park activities have also been quantified in this Chapter. Analysis
of alternatives to the project has been presented in Chapter 7. An environmental strategy to offset/mitigate the
probable adverse impacts has been outlined in Chapter 8. Chapter 9 provides recommendation for environmental
management plan aimed at minimizing the negative environmental impacts of the project. Environmental monitoring
requirements for effective implementation of mitigating measures during development as well as operation of the
project have been delineated along with requisite institutional arrangements for their implementation in Chapter 10.
Chapter 11 summarizes the consultation with interested parties and the general public and Chapter 11 Socio
economic condition of project area.

21
CHAPTER # 3
THE LEGAL/ POLICY FRAMEWORKS ALONG WITH ENVIRONMENTAL STANDARDS
3. AP P L I CA BLE E N VI RO N M E NT AL REG UL AT O RY F RAM EWO RK

The Government has developed a policy framework that incorporates environmental considerations
into all economic development planning. The key policy documents are listed below:

o National Environmental Policy, 1992

o National Environmental Management Action Plan (NEMAP), 1995
o National Conservation Strategy, 1992

3.1 N AT I ON AL EN V I RONM ENT A L P O L I CY , 1 992

The Bangladesh National Environmental Policy sets out the basic framework for environmental action together
with a set of broad sectoral action guidelines. Key elements of the policy are:
o Maintenance of the ecological balance and overall progress and development of the country
through protection and improvement of the environment;
o Protection of the country’s assets, properties and resources against natural disasters;
Identification and regulation of all types of activities which pollute and degrade the
environment;\
o Identification and regulation of all types of activities which pollute and degrade the environment;
o Ensuring sustainable utilization of all natural resources;
o Promoting active association with all environment related international initiatives.

The environmental policy requires the following specific actions with respect to the ‘Industrial’
sector:
o To phase in corrective measures in polluting industries;
o To conduct Environmental Impact Assessment (EIAs) for all new public and private industrial
developments;
o To ban, or find environmentally sound alternatives for, the production of goods that cause
environmental pollution; and
o To minimize waste and ensure sustainable use of resources by industry.

Under the National Environmental Policy, Department of Environment is directed to review and
approve all environmental impact assessments.

3.2 NAT I ONAL E NV I RONM ENT AL M A NAG E M E NT ACT I ON P L AN , 1 99 5

The National Environmental Management Action plan (NEMAP) is a wide ranging and multi- faceted
plan, which builds on and extends the statements set out in the National Environmental Policy. NEMAP
was developed to address issues and management requirements and set out the framework within
which the recommendations of the National conservation strategy are to be implemented.
NEMAP has the following broad objectives:
 Identification of key environmental issues affecting the country;
 Identification of actions necessary to halt or reduce the rate of environmental degradation;
 Improvement of the natural environment; Conservation of habitats and bio-diversity;
 Promotion of sustainable development; and Improvement of the quality of life of the people.

22
3.3 NA T I ONA L CONS E RVA T I ON S T RAT E GY , 1 99 2

The National conservation strategy provides recommendations for sustainable development in the industrial
sector as follows:
 All industries shall be subject to EIA and adoption of pollution prevention/control
technologies shall be enforced;
 Hazardous or toxic materials/wastes shall not be imported as raw materials for industry;
 Import of appropriate and environmentally sound technology shall be ensured; and
 Dependence on imported technology and machinery should gradually be reduced in favor of
sustainable local skills and resources.

23
3.4 RELEVENT NATIONAL L E G I S L A T I O N

The following exhibit presents an outline of the National legal instruments that will have relevance to the proposed EPZ project with respect to the
environment considerations.

Act/Rule/Law/Ordinance Responsible Agency- Key Features-Potential Applicability project/Time Whether Triggered for the Frame
Ministry/Authority for Clearance and Responsibility

The Environment Department of Declaration of Ecologically Critical Areas; Obtaining Yes/2 Months/BEZA
Conservation Act, 1995 and Environment Environmental Clearance Certificate
subsequent amendments in Ministry of Environment and Regulation with respect to vehicles emitting smoke
2000 and 2002 Forest harmful for the environment
Regulation of development activities from
environmental perspective;
Promulgation of standards for quality of air, water, noise, and
soils for different areas and for different purposes;
Promulgation of acceptable limits for discharging and emitting
waste;
Formulation of environmental guidelines relating to control
and mitigation of environmental pollution, conservation and
improvement of environment

Environment Conservation Department of Declaration of ecologically critical Area; Requirement

Rules, 1997 and subsequent Environment of Environmental Clearance
amendments in 2002 and Ministry of Environment and Certificate for various categories of projects;
2003 Forest Requirement for IEE/EIA according to the
appropriate category of the project;
Renewal of the environmental clearance certificate
within 30 days after the expiry;

24
Act/Rule/Law/Ordinance Responsible Agency- Key Features-Potential Applicability project/Time Whether Triggered for the Frame
Ministry/Authority for Clearance and Responsibility

Provision of standards for quality of air, water & sound and

acceptable limits for emission/discharges from vehicles and
other sources
Environment Court Act, 2000 Judiciary GOB has given highest priority to environment No
and subsequent amendments Ministry of Environment pollution and passed ‘Environment Court Act 2000 for
in 2002 & Forest completing environment related legal preceding effectively

The Vehicle Act, 1927 Bangladesh Road Transport Exhaust emission; Vehicular air and noise; Road safety; Yes/Regulatory only
The Motor Vehicles Authority (BRTA Licensing
Ordinance, 1983
The Bengal Motor Vehicle
Rules, 1940
The Brick Burning Ministry of Environment Requires a license from the MoEF; Restricts brick burning Yes/Regulatory only
(Control) Act, 1989 & Forest with fuel wood
The Brick Burning Control of brick burning
(Control) Amendment Act,
1992

The Removal of Wrecks and Bangladesh Water Removal of wrecks and obstructions in inland No
Obstructions in inland Transport Authority Navigable Waterways
Navigable Water Ways
Rules
1973

Water Supply and Sanitation Ministry of Local Management and Control of waste supply and sanitation in Yes/Regulatory only
Act, 1996 Government, Rural urban areas.
Development and
Cooperatives

25
Act/Rule/Law/Ordinance Responsible Agency- Key Features-Potential Applicability project/Time Whether Triggered for the Frame
Ministry/Authority for Clearance and Responsibility

The Forest Act, 1927 and Ministry of Environment and Reserve Forests; Protected Forests; Village No
subsequent amendments in Forest Forests
1982 and 1989

The Private Forests Ordinance Regional Forest Officer Forest Conservation of private forests and for the afforestation on No
Act, 1959 Department wastelands
Bangladesh Wild Life Ministry of Environment and Preservation of Wildlife No
(Preservation) Act, 1974 Forest Sanctuaries, parks,
Bangladesh Wild Life No reserves
Advisory Board

The Protection and Ministry of Fishery Protection and Conservation of fishes in Government owned No
Conservation of Fish Act water bodies
1950 subsequent
amendments in
1982

Natural Water Bodies Rajdhani Unnayan According to this Act, the character of water bodies i.e. rivers,
Protection Act 2000 Kartipakkha/Town Development canals, tanks, or floodplains identified as water bodies in the Yes/Regulatory only
Authority/Municipalities master plans or in the master plans formulated under the laws
establishing municipalities in division and district towns shall
not be changed without approval of the concerned ministry.

The Embankment and Ministry of Water Resources An Act to consolidate the laws relating to embankment and Yes/Regulatory only
Drainage Act 1952 and FCD drainage and to make better provision for the construction,
maintenance, management, removal and control of
embankments and water courses for the better drainage of
lands and for their protection from floods, erosion and other
damage by water
Antiquities Act 1968 Cultural Ministry of Affairs This legislation governs

26
Act/Rule/Law/Ordinance Responsible Agency- Key Features-Potential Applicability project/Time Whether Triggered for the Frame
Ministry/Authority for Clearance and Responsibility

preservation of the
No national cultural heritage,
protects and controls ancient
monuments, regulates antiquities
as well as the maintenance,
conservation and restoration of
protected sites and monuments
controls planning, exploration and
excavation of archaeological sites

The Building Construction Ministry of Works An Act to provide for the prevention of haphazard Yes/Regulatory
Act construction of building and excavation of tanks which are only
1952 (with amendments) likely to interfere with the planning of certain areas in
Bangladesh
The Land Acquisition Act, Revenue Department Current GoB Act & guidelines, relating to acquisition of land Yes/8-12
1894 and The Acquisition months*/BEPZA
and Requisition of Immovable Depending on quantity of land to be
Property Ordinance 1982 and acquired
subsequent amendments in
1994, 1995 and 2004
The Factories Act, 1965 Ministry of Labour This Act pertains to the occupational rights and safety of
Bangladesh Labour Law, factory workers and the provision of a comfortable work Yes/Regulatory
2006 environment and reasonable working conditions. only

Figure 4 : Overview of National Legal Instruments

27
3.5 E COL O GI CA L L Y S E NS I T I V E/ P RO T E CT ED A REAS NE A R T HE P ROJ ECT REG I ON

3.5.1 E COL OGI CA L L Y S E NS I T I VE AREAS

Ecologically sensitive areas as defined by the World Bank (OP 4.04) are areas that may contain unique features,
maintain key natural processes, support endangered, endemic or threatened plants or animals and their habitats, or
provide breeding areas for wildlife. Some ecologically sensitive areas are natural, while others may have been
significantly altered by certain human activities.
Criteria given by the World Bank for Ecologically sensitive areas, and the corresponding areas in Bangladesh, are listed
in the exhibit below under categories A-E. Areas that are socio-culturally sensitive are listed under categories F and G.
The Environment Conservation Act, 1995 and the Environment Conservation Rules, 1997, also refer to Environmentally
Sensitive Areas (called Ecologically Critical Areas in the legislation). According to this legislation, environmental
protection is deemed particularly relevant in Ecologically Critical Areas, which are defined by the Government as areas
where degradation of the environment has reached or threatens to reach a ‘critical’ state. Specifically, under the
Environment Conservation Act and Rules, the Government will take into special consideration areas such as
human settlements, ancient monuments, archeological sites, forest sanctuaries, national parks, game reserves, wildlife
habitats, wetlands, mangroves, forested areas, biodiversity areas, and other similar areas. Environmentally sensitive
areas, category-wise in the country, are presented in exhibit below:

Category Environmental Sensitive Location in Bangladesh

Areas
A Areas that provide protection to Forests on steep watersheds generally these areas
steep slope Protected Areas, especially occur in the Chittagong Hill Tracts
in watershed areas, against erosion
B Areas that regulate and purify Wetlands - 10 More-or-less permanent wetlands
water flow such as rivers, beels, haors, baors, dhours and
djheels, containing water at the peak of the dry
season; & wetlands included in the Directory of
Asian Wetlands

C Areas that provide conditions Mainly Forest Reserves (especially the Sunderbans)
essential for the perpetuation of and important wetlands (listed in Directory of Asian
species of medicinal and genetic Wetlands) but also unusual habitats such as St
conservation value Martin's Island (coral reef)

D Sites that maintain conditions vital for Mainly Forest Reserves (especially the Sunderbans)
the perpetuation of species that and important wetlands (listed in Directory of Asian
enhance attractiveness of the Wetlands) but also unusual habitats such as St
landscape or the viability of protected Martin's Island (coral reef)
areas
E Sites that provide critical habitat that Freshwater and coastal wetlands, sites recorded in the
threatened species use for breeding, Directory of Asian Wetlands
feeding or staging
F Areas of cultural or historical Graveyards, tombs, forts, mosques, temples, churches
significance etc
G Areas that are densely populated and All Urban centers
are important for human habitation

Figure 5 : Environmentally sensitive areas

28
3.5.2 PROTECTED AREAS

Protected Areas’ in Bangladesh cover an area of 2,43,435 hectare which accounts for 16% of the total area managed by the
forest department and almost 2% of total area of Bangladesh. It includes 8 national parks, 7 wildlife sanctuaries, 1 game
reserve and 5 other conservation sites.

Protected Areas include Wildlife Sanctuary, National Park and Game Reserve. Their definitions in the Bangladesh Wildlife
(Preservation) Order, 1973 (henceforth Wildlife Order) is as follows:

Wildlife Sanctuary means an area closed to hunting, shooting or trapping of wild animals and declared as such under Article
23 by the government as undisturbed breeding ground primarily for the protection of wildlife inclusi ve of all natural resources
such as vegetation soil and water (paragraph) (p) of Article 2).

National Park means comparatively large areas of outstanding scenic and natural beauty with the primary object of protection
and preservation of scenery, flora and fauna in the natural state to which access for public recreation and education and
research may be allowed (paragraph) (p) of Article 2).

Game Reserve means an area declared by the government as such for the protection of wildlife and increase in the
population of important species wherein capturing of wild animals shall be unlawful (paragraph) (c) of Article 2)•.

Article 23 of the Wildlife Order has provisions for declaration of Protected Areas and also has regulations prohibiting activities
in the Protected Areas.

Sl. No. National Parks Location Area (ha.) Established

1 Bhawal National Park Gazipur 5022 11/5/1982

2 Madhupur National Park Tangail/ Mymensingh 8436 24-2-1982

3 Ramsagar National Park Dinajpur 27.75 30-4-2001

4 Himchari National Park Cox's Bazar 1729 15-2-1980
5 Lawachara National Park Moulavibazar 1250 7/7/1996

6 Kaptai National Park Chittagong Hill Tracts 5464 9/9/1999

7 Nijhum Dweep National Park Noakhali 16352.23 8/4/2001

8 Medhakachhapia National Park Cox's Bazar 395.92 8/8/2008
9 Satchari National Park Habigonj 242.91 15-10-2005
10 Khadimnagar National Park Sylhet 678.8 13-04-2006
11 Baroiyadhala National Park Chittagong 2933.61 6/4/2010
12 Kuakata National Park Patuakhali 1613 24-10-2010
13 Nababgonj National Park Dinajpur 517.61 24-10-2010
14 Singra National Park Dinajpur 305.69 24-10-2010
15 Kadigarh National Park Mymensingh 344.13 24-10-2010
16 Altadighi National Park Naogaon 264.12 24-12-2011
17 Birgonj National Park Dinajpur 168.56 24-12-2011

29
B) Wildlife Sanctuaries :

Sl. No. Wildlife Sanctuaries Location Area (ha.) Established

18 Rema-Kalenga Wildlife Sanctuary Hobigonj 1795.54 7/7/1996

19 Char Kukri-Mukri Wildlife Sanctuary Bhola 40 19-12-1981

20 Sundarban (East) Wildlife Sanctuary Bagerhat 31226.94 6/4/1996

21 Sundarban (West) Wildlife Sanctuary Satkhira 71502.1 6/4/1996

22 Sundarban (South) Wildlife Sanctuary Khulna 36970.45 6/4/1996

23 Pablakhali Wildlife Sanctuary Chittagong Hill Tracts 42087 20-9-1983

24 Chunati Wildlife Sanctuary Chittagong 7763.97 18-3-1986

25 Fashiakhali Wildlife Sanctuary Cox's Bazar 1302.43 11/4/2007

26 Dudpukuria-Dhopachari Wildlife Sanctuary Chittagong 4716.57 6/4/2010

27 Hajarikhil Wildlife Sanctuary Chittagong 1177.53 6/4/2010

28 Sangu Wildlife Sanctuary Bandarban 2331.98 6/4/2010
29 Teknaf Wildlife Sanctuary Cox's Bazar 11615 24-03-2010
30 Tengragiri Wildlife Sanctuary Barguna 4048.58 24-10-2010
31 Dudhmukhi Wildlife Sanctuary Bagerhat 170 29-01-2012
32 Chadpai Wildlife Sanctuary Bagerhat 560 29-01-2012
33 Dhangmari Wildlife Sanctuary Bagerhat 340 29-01-2012
34 Sonarchar Wildlife Sanctuary Patuakhali 2026.48 24-12-2011
35 Nazirganj Wildlife (Dolphin) Sanctuary Pabna 146 1/12/2013
36 Shilanda-Nagdemra Wildlife (Dolphin) Sanctuary Pabna 24.17 1/12/2013
37 Nagarbari-Mohanganj Dolphin Sanctuary Pabna 408.11 1/12/2013
Other Conservation Sites
C Name Location Area (ha.) Established
1 National Botanical Garden Dhaka 84.21 1961
2 Baldha Garden Dhaka 1.37 1909
3 Madhabkunda Eco-Park Moulavibazar 265.68 2001
4 Sitakunda Botanical Garden and Eco-park Chittagong 808 1998
5 Dulahazara Safari Parks Cox's Bazar 600 1999
6 Modhutila Eco-Park Sherpur 100 1999
7 Banshkhali Eco-Park Chittagong 1200 2003
8 Kuakata Eco-Park Patuakhali 5661 2005
9 Tilagar Eco-Park Sylhet 45.34 2006
10 Borshijora Eco-Park Moulavibazar 326.07 2006

Protected Area Covers 10.72% of Total Forest Area ,

Figure 6 : Notified & Protected Areas of Bangladesh

30
Figure 7: Protected areas of Bangladesh (Source: Department of Forest)

The proposed Sirajganj EZ site does not fall under the jurisdiction of any of the protected or sensitive areas.

31
3.6 ST AT UT O RY EN VI R ON M EN T AL REQUI RE M EN T S F OR T HE P ROJ ECT

3.6.1 G O B RE QUI RE M ENTS

Bangladesh is a signatory to a number of International Treaties and Conventions, which require safe protection of the
environment from degradation and environmental concerns of global scale, protect workers against hazards arising from
occupational exposure to harmful substances and agents in the working environment. Section 12 of the Environment
Conservation Act (ECA) stipulates "No industrial unit or project shall be established or undertaken without obtaining
environmental clearance from The Director General of the Department of Environment (DG, DoE) in the manner prescribed by
the ECR 1997". T he Department of Environment (DoE), which is a statutory body under the Environment Conservation Act, is
responsible for reviewing and evaluating the IEE and EIA of various types of development projects in Bangladesh.

Environmental Clearance: The Department of Environment (DOE), the technical arm of the Ministry of Environment
and Forest (MOEF) is the enforcement agency. Depending upon location, size and severity of pollution loads,
projects/activities have been classified in ECR,’97 into four categories: Green, Orange A, Orange B and Red
corresponding respectively, to nil, minor, medium and severe impacts on important environmental components (IECs).
Categorized industries are listed in Schedule 1 of ECR’ 1997. It is to be noted that the list of industries under Green,
Orange – A, Orange – B and Red categories is not updated since 1997.
Since the proposed EZ (as industrial estate) falls under red category (described under Item 39, Schedule -1, page 3121 of
ECR –97), IEE and EIA have to be conducted as mandatory requirement. As per the provisions of the ECR’ 97 (Section 7
and subsection 4 of SRO 197), the Director General of the Department of Environment can accord Environmental Clearance
for the project without site clearance. This section 7 and subsection 4 also provides provision for submitting EIA report
based on an approved TOR of comprehensive EIA as an alternative to IEE. Procedural steps to be followed for obtaining
Environmental Clearance Certificate (ECC) in connection with establishing industrial estate project (under Red Category)
from DOE is outlined in the Exhibit below. The snapshot of relevant DOE related form has been annexed to this report.
For Sirajganj EZ, Bangladesh Economic Zone Authority (BEZA) will be responsible for obtaining the ECC. Necessary actions
will include:

Liaison with DoE to confirm the submission requirements;

Preparation of all required documentation, including any approvals required from other agencies;
Submission of the application to DoE in a timely manner, such that no delay occurs to the award of contracts for
construction;
Attendance at meetings with the DoE;
Undertaking any further actions as required by DoE prior to issue of the ECC

32
RED CATEGORY PROJECT

Issuance of Site
Clearance , IEE, Within 60
NOCs and working Days
Others from date of
Supporting
To prepare and submit the
application to the DG, Within 15
DOE, for the working days
exemption of the site from date of
clearance procedure;

M ay start land and Submission for

infrastructural approval of the EIA
development a nd ETP Des i gn

Approval of EIA & ETP Design

within 60 days of Submission

Ins tallation of ETP / Implementation of

a l l neces s a ry mi ti ga ti on mea s ures
whi ch i s ci ted i n the EIA Report

Apply for ECC

Issuance of ECC within 30

days

Project Starts

Renew ECC every years 30 days before date

of expire

Figure 8: Steps Followed for Environmental Clearance for Red Category Projects

Source: Guide to the Environmental Conservation Act 1995 and Rules 1997, Prepared by Bangladesh Centre for
Advanced Studies, 1999.

33
3.6.2 WORLD BANK/DONOR REQUIREMENTS

Environmental Assessment is one of the safeguard policies of the World Bank. It is used in the World Bank funded projects
to examine the environmental risks and benefits associated with the Bank lending operations.
The Bank's environmental assessment procedures are described in Operational Policy (OP)/ Bank Procedure (BP) 4.01.
This policy is considered to be the umbrella policy for the Bank's "safeguard policies" which among others include: Natural
Habitats (OD 4.04); Pest Management (OP 4.09); International Waterways (OP 7.50); Indigenous People (OP 4.10); and
Involuntary Resettlement (OP 4.12). In the World Bank operations, the purpose of Environmental Assessment is to
improve decision-making and to ensure that project options under consideration are sound and sustainable.
According to WB criteria, a proposed project is classified as Category A if it is likely to have significant adverse
environmental impacts that are sensitive, diverse, or unprecedented. On the other hand a proposed project is classified as
Category B if it’s potential adverse environmental impacts on human populations or environmentally important areas —
including wetlands, forests, grasslands, and other natural habitats — are less adverse than those of Category A projects.
These impacts are site-specific; few, if any of them, are irreversible; and in most cases migratory measures can be designed
more readily than for Category A projects.
As per WB environmental categorization, the proposed Sirajganj EZ project triggers OP 4.01 (Environmental
Assessment) and requires detailed EA including specific EMP.

3. 6 . 3 CO N CO RDA N CE A NA L YS I S F OR P RO J E CT RE QUIREM ENTs

3.6.3.1 EIA REQUIREMENTS
In order to ensure that the proposed project has addressed the requirements of the GOB and World Bank Group (WBG),
an analysis has been undertaken to examine the concordance of policies, procedural issues, and guidelines of the two:
Issue World Bank Guidelines Bangladesh Rules
Environmental Quality Standards 1 3
EHS ECR
Project Description OP 4.01 3
EIAGFI
Physical Resources OP 4.01 EIAGFI
Ecological Resources OP 4.01 /OP 4.04 EIAGFI
Socio-Economic Development OP 4.01 EIAGFI
Quality of Life and Cultural Values OP 4.01 /OP 4.11 EIAGFI
Anticipated Environmental Impacts OP 4.01 EIAGFI
Mitigation OP 4.01 EIAGFI
Monitoring OP 4.01 EIAGFI
Compensation OP 4.01 Not specified
Disclosure OP 4.01 Not specified
Resettlement OP 4.12 EIAGFI
Site Selection OP 4.01 EIAGFI
Alternatives OP 4.01 EIAGFI
Cost Benefit Analysis Not specified EIAGFI
Figure 9: Concordance Analysis of EIA Requirements

3.6.3.2 ENVI RONMENTAL STANDARDS AND GUIDELINES

All parameters of effluent, gaseous emission, noise, solid waste, hazardous waste, etc. shall be within the limits as
prescribed in the Environment Conservation Rules, 1997 and the World Bank guidelines/global best practices (annexed to the
report). The stringent of the two shall apply.

34
CHAPTER # 4
PROPOSED PROJECT ACTIVITIES AND FACILITIES
4. PROJECT DESCRIPTION
4.1 I NT RO DUCT ION T O SIRAJGANJ EZ

Considering the growing demand of foreign investors for industrial plots and experience from successful
implementation of Dhaka, Chittagong, Comilla, Adamjee and other Export Processing Zones (EPZs), Bangladesh
Economic Zones Authority (BEZA) plans to develop an EZ at Sirajganj for creation of employment at Northern area of
Bangladesh .
Several sites were identified initially as potential candidates for the project. After a joint site visit on 2nd November
may 2011 by BEZA, a site having an area of approx 1035.94 acres at Sirajganj was finalized.
The identified site is adjacent to the Dhaka- Sirajganj highway, at the western end of the Bangobondu Multipurpose
Bridge. The site lies between Tangail and Sirajganj, with an approximate distance of 130 km from Dhaka. The location
of proposed site is shown in Figure below.

The layout of the site is planned keeping specific activity areas integrated with the ambient environment. The entire
built environment is planned to be developed in tune and harmony with nature. Layouts of industrial land parcels
are schematically planned so as to relate better with the existing and proposed landscape. The exhibit below shows
layout master plan of the proposed Sirajganj Economic Zone.

35
Figure 10: Master Plan of Sirajganj EZ

36
4.2 S I T E A N D SU RROUN DI N G S

The existing land use of proposed site is mostly dominated by low lying agricultural lands followed by surface
water body of canals and Jamuna River channels A total of 815 households , One Government Primary School,
Two mosque, Two Madrasa , 02 non- government primary school will be affected by the project. The overall site is 8-
10 feet lower than the flood level and inundates for almost 5 months in a year.
A 40 feet wide National Highway (Dhaka-Siragjang highway) Northern side of project, Jamuna river passes by the
eastern boundary of the site.
Physiographically, the proposed site is located on the flood plain of the Jamuna. Sirajganj Sadar Upazila is located at
24.4583°N 89.7000°E, as is the site. On the eastern side is the Jamuna river and on the western side is Sirajganj-
Belkuch Highwa. Bangobondu Multpurpose Bridge located North-East site of proposed project area.

Figure11: Site Photographs

37
4.3 L A ND U SE PL A N

Based on the market study of the target industries to be established at this zone, the industrial land use pattern was arrived
at. The industry mix thus obtained was further combined with the supporting infrastructure land utilization, to arrive at the
overall land use pattern. The following exhibit captures a snapshot of the land use pattern considered for the design

A. Industries %
Knitting 500.00 44.02
Spinning 300.00 26.41
RMG 97.94 8.62
B. Utilities %
Customs,Security, Admin, entrance plaza & Social 25.00
infrastructure 2.20
Essential staff quarters 15.00 1.32
Road 70.00 6.16
Greenery 103.00 9.07
WareHouse 10.00 0.88
Gas Power Plant 15.00 1.32
Total 1,135.94 100.00
Figure 12 : Land Use Distribution at the Site

Knitting

44.02
Spinning

100.00 RMG
26.41

Customs,Security, Admin,
8.62 entrance plaza & Social
infrastructure
2.20
Essential staff quarters
1.32 0.88 9.07 6.16 1.32

Figure : 13 Industrial Land-use Mix

4.4 I NF RAS T RUCT URE REQUI REM ENT

The infrastructure requirement for the proposed Sirajganj EZ has been broadly classified into the following two heads:
Basic Infrastructure: It includes construction material, site grading, boundary wall, roads, storm
drainage, power supply, street lighting, bridge etc.
38
Environmental Infrastructure: It comprises of water supply and treatment system, sewerage collection,
treatment and recycling, effluent collection and treatment system and solid waste management system

4.4.1 BAS I C I NF RAS T RUCT URE RE QUI REM ENT

In this section, we highlight the major basic infrastructure requirements for the Sirajganj EZ from the
environmental perspective.

4.4.1.1 CONSTRUCTION M ATERIAL

The major materials required for construction of the proposed project are steel, cement, bricks, metal, flooring
tiles/stones, wood, sanitary and hardware items, electrical fittings, water, etc. All the materials to be used in the
proposed project will be as per the national building code specifications.
4.4.1.2 SITE GRADING

It is recommended to carry out site grading works for the entire site area. The topography survey provides essential
inputs to this exercise. To maintain the existing water bodies as well as to ensure prevention of water logging/ inundation
at the site, filling of a part of the site area has been envisaged. The master plan drawing depicts the conserved water
body within the site.
It is recommended to have the finished ground level of the EZ above the maximum flood level at the site.
4.4.1.3 STORM WATER DRAINAGE
T he area under study is proposed to be leveled by filling. It is planned to collect the storm water flow at low-lying areas
within the site. Roads and drains within the individual plots of the industrial zone are recommended to be provided by the
user industry.
The storm water is proposed to be discharged at strategic locations on the river nearby, considered in the design of the
storm drainage network. The proposed drainage system would be designed to cater to the surface runoff within the
project area by gravity flow. Drains are proposed to be provided on both sides of the roads on site.
Closed rectangular drains are adopted for the surface run off collection for the reasons of easy maintenance and land
optimization. The entire zone area is designed to be covered under this collection system. Drains are designed on both
sides of the road. Foot path is planned on top of the drain slab. RCC box culverts of suitable sizes are designed for road
crossings. Rainwater harvesting structures are envisaged along the drain.

4.4.1.4 BUFF ER REQUIRMENTS

Buffer areas are areas between the roadside and the construction of the units in the plots. They consist of a green buffer
and a physical buffer. The green buffer is meant for tree planting / turf and small ancillary structures. Within the physical
buffer, driveways, car / lorry parks, and other ancillary structures can be developed. The buffer requirements vary
depending on the width of the road along which the buffer is designed. The exhibit below captures a snapshot of the
buffer requirements designed for the Sirajganj EZ

Road Width (m) Green Buffer (m) Physical Buffer (m) Total Buffer (m)
30 6 6 12
24 4 4 8
22 4 4 8
18 4 4 8
15 2 2 4

Figure: 14 Road Buffer Requirements

39
4.4. 2 EN VI RO NM E NT A L I NF RAS T R UCT URE

4.4.2.1 WATER SUPPLY AND TREATMENT SYSTEM

Presently, in and around Jamuna, underground water is the main source of water. Samples from Sirajganj Sadar Upazila
show a considerable amount of variation in arsenic concentration level in the site proximity. According to the
environmental provisions, surface water can be utilized from the Jamuna River for the EZ. By developing an intake well
followed by proper treatment, the river water can be utilized for potable water consumption.

Water requirement of 60 m 3 per day per hectare has been considered for the processing industries i.e. Knitting
manufacturing industry, as per the prevailing standards for these industries. 50% of the requirement is considered for
various processes involved during manufacturing and the balance 50% has been considered for drinking, sanitary and
other purposes within the industry.

Demand requirement of 60 m 3 per day per hectare has been considered for other industries, utilities, amenities,
institutional areas and 368 m 3 per day per hectare for public green, and roads which are the norms as per the
International Standards.
The water requirement for management accommodation is arrived at based on the total population which has been
calculated based on the allocated area, floor area ratio, maximum allowed built-up area, population density and water
demand per capita at the rate of 135 LPCD (Litres Per Capita Per Day) as per the BNBC (Bangladesh National Building
Code). The summary of the assumptions is shown in the following exhibit.

Description LPCD Cu.m/ ha/ day

Knitting 60
Spinning 60
RMG 36
Staff Quarter 135

Figure 15 : Water Demand Estimation Standards

Water losses occur in the distribution and transmission network. T he percentage of loss depends on the pipe material,
jointing system, etc. As this is a complete loss, it is recommended to be kept below 10% of the total demand, by
implementing efficient network design and construction as well as operation

Potable water has been considered to be used for bathing and washing, cooking and drinking. Non potable water has
been considered to be used for gardening, cleaning and toilet flushing. The water consumption pattern assumed is as in
the exhibit below

Bathing and Washing clothes 47%

Cooking, drinking and washing vessels 23%
Gardening and cleaning 9%
Toilet flushing 21%

Figure 16 Water consumption pattern (fraction of total demand)

For areas other than hospital and management quarter area (no bathing and washing facility)
Potable Water 44%
Non Potable Water 56%
40
For Hospital and management quarter area (bathing and washing facility envisaged)
Potable Water 70%
Non Potable Water 30%

Figure 17 Water Consumption Pattern – Potable vs. Non-potable

The following figure presents the water demand projection carried out for the Sirajganj EZ. It may be noted here that

Non -
Total Area Water Loss@ Total Potable Potable
Water Demand, 10% water water water
Demand, Cum/Day Cum/day demand demand demand
cum / Cum / Cum / Cum /
A. Industries % ha in % day day day

Knitting 500.00 44.02 60 12,145.00 1,214.50 13,359.50 9,595.00 3,760.00

Spinning 300.00 26.41 60 7,287.00 728.70 8,015.70 5,757.00 2,256.00

RMG 97.94 8.62 36 2,378.96 237.90 2,616.86 1,879.47 736.51

B. Utilities - - - - -

Customs, Security,
Admin, entrance
plaza & Social 25.00 60.73
infrastructure 2.20 36 607.25 667.98 479.75 188.00
Essential staff
quarters 15.00 1.32 135 364.35 36.44 400.79 287.85 112.80

Road 70.00 6.16 1.8 1,700.30 170.03 1,870.33 1,343.30 526.40

Greenery 103.00 9.07 1.8 2,501.87 250.19 2,752.06 1,976.57 774.56

Warehouse
10.00 0.88 36 242.90 24.29 267.19 191.90 75.20

Gas Power Plant 15.00 1.32 432.84 364.35 36.44 400.79 287.85 112.80

Total 1,136 100 799 27,592 2,759 30,351 21,799 8,542

the firefighting demand has been considered as one time usage driven, and therefore not been considered for daily
water demand estimation. The water balance chart for the project has been annexed to the report.
Figure 18 Water demand projections
Based on the estimates of water demand, the following water treatment, storage and distribution infrastructure
is proposed for the EZ.
Underground storage reservoirs (sumps) are recommended for water storage, including water stored for firefighting
demand. The following exhibit captures a snapshot of the recommended capacity of such storage reservoirs.
Description Capacity in cu.m.
Potable Water Non Potable Water
Ground level storage reservoir 15000 & 100 10000 & 2550
Elevated storage reservoir 725 & 150 625 & 155
Figure 19 Storage Reservoir Size Estimation

41
4.4.2.2 WATER PUM PING STATION

Water pumping station for potable and non-potable water is required for pumping clear water from the underground
storage tank to respective elevated water tanks. Elevated tanks are proposed in order to cater to the entire area
and their size is planned to be proportionate to the demand. The water supply scheme including distribution is planned
to be designed and based on the assumptions set out below.
The peak flow factor is assumed to be 2.0. Minimum residual pressure at the inlet of the underground sump of each
plot is assumed to be 7 m equivalent. The pipe material is assumed to be DI / HDPE.
4.4.2.3 ELEVATED ST ORAGE TANK

T wo hours storage requirement is proposed for the elevated level storage tank

4.4.2.4 WATER DI ST RIBUTION NETWORK

It is proposed to provide separate water distribution network for potable and non potable supply. Four elevated level
service reservoirs (ELSR) are proposed to be provided for potable and non potable water for the entire

4.4.2.5 T REAT MENT OF WATER

Information from the socio-environmental baseline study reveals that there is a relatively high content of arsenic in the local
water. The water treatment system is thus recommended to treat water towards removal of the arsenic content.

The figure below enunciates the various alternatives possible for treatment of water.

Figure 20 Alternatives of Treatment of Water

The system selected shall ensure that the quality of water is within the acceptable drinking water
standards. T he arsenic removal shall be accomplished through the following process:
Coagulation/Microfiltration
Fixed Bed Adsorption Technologies
Coagulation/Filtration
Based on the above, the water treatment system with coagulation followed by filtration is recommended to
encompass:
Primary treatment
Aerator
Flash Mixer
Clarifloculator
Secondary Treatment
Rapid Sand Filter
Filtered Water T ank
Sludge handling Thickener , Auxiliary units: as required
A schematic diagram of the system is shown in the exhibit below :

42
Figure 21 Schematic of Water Treatment System

4.4.2.6 EFFLUENT, SEWERAGE AND SULL AGE SYSTEM

The domestic sewage and sullage to be generated has been assumed to be 90% of the domestic water consumption in
addition to infiltration of 10%. Based on the general wastewater generation pattern, the amount of wastewater
generated in domestic premises is classified in the exhibit below

Description %
Fraction Bath/ Shower & Laundry 55%
Hand Basin, Kitchen 10%
Toilet 35%
Figure 22 Waste Water Estimation

Waste water generation from bath / shower etc. in the EZ is expected to be relatively insignificant. Also, based on the water
consumption by the industrial sub-zones within the EZ, normative indications towards the effluent generation were utilized to
estimate the effluent generation.
It may be noted here that considering optimal land usage and viability aspects of industrial land use mix, only the yarn and
fabric industries are assumed to be polluting units. The other industries are assumed to be only formulation (in case of
Pharma), apparel-making (in case of Leather and Jute) etc. and not producing any effluents.

4.4.2.7 SOLID WAST E GENERAT ION

On a normative basis, the components of the solid waste considered for the project are summarized in the
following exhibit.
Solid waste component Constituents

Domestic waste Kitchen and wood waste, plastic, paper, floor

sweepings, etc
Industrial waste Sludge generated during production process, effluent
treatment waste, chemical waste including hazardous
and toxic waste, burnt fuel solid waste, oil slurry, packing
waste etc.

Road, garden & foliage waste Leaves, branches, plants, road sweepings

43
etc
Construction waste Earth, asphalt, concrete, brick, plaster, wood, glass,
stones etc.

Bio – Medical Waste from the health care

facility.
Exhibit 23 Solid Waste Constituents

The solid waste generation rates of industries and other areas vary to such an extent that exact quantification of solid waste
generation is not feasible at this point. However, an attempt has been made to quantify & qualify the solid waste that
may be generated from various components of the EZ.
The total quantity of solid waste to be generated from the EZ depends on various factors such as:
T ype of occupants and their occupancy ratio
Processing methods, efficiency & capacity
Preparatory losses of each type of industries
Critical process requirements
T ype & quality of raw materials to be processed & the consumables
T otal manpower required for the industries and the likely domestic waste generated.
The total population as per the assumptions considered earlier is taken into consideration for the waste generation
estimation. Further, as quantification of solid waste is not an exact science and no data is available for municipal solid
waste generation within an EZ, estimation of solid waste generation was carried out based on norms. The following exhibit
captures a snapshot of the norms adopted for solid waste generation estimation

Project component Project component Rationale

Industries 150 kg / acre/day Considered including packing materials, street

& floor sweepings, part of industrial waste etc
will contribute to this higher generation rate
All other areas 100 kg / acre/day Considered including food waste &
others
Roads 25 kg / acre/day Considered as sweeping waste,
foliage waste etc.
Greenery, utilities 150 kg / acre/day Considered including packing materials, street &
floor sweepings, part of industrial waste etc will
contribute to this higher generation rate
Exhibit 24 Solid Waste Generation Assumptions

Based on the above, the solid waste quantity estimation has been carried out, the snapshot of which is depicted in the
following exhibit

44
Total solid
Total Solid waste
waste
A. Industries Area Generation
Generation
Faction Acre/day
Tons/day

Knitting 500.00 44.02 150.00 75.00

Spinning 300.00 26.41 150.00 45.00

RMG 97.94 8.62 150.00 14.69

B. Utilities -
Customs, Security, Admin, entrance 25.00 2.20 75.00 1.88
plaza & Social infrastructure

Essential staff quarters 15.00 1.32 100.00 1.50

Road 70.00 6.16 100.00 7.00

Greenery 103.00 9.07 25.00 2.58

WareHouse 10.00 0.88 75.00 0.75

Gas Power Plant 15.00 1.32 75.00 1.13

Total 1,136 100 900 150
Figure 25 Solid Waste Generation Estimation

4. 5 M A N POWER

4. 5 . 1 CONS T RUCT ION ST AGE

It is estimated that almost 6970 gross person-years of employment could be created during the construction phase

4. 5 . 2 O P ERA T IO N ST AGE

The total man Power requirement for administrative level and maintenance of various environmental infrastructures
during operation stages are presented in the following two figure

Employee Level Staff Employed

Top management 5
Senior Management 4
Middle Management 10
Lower Level 16
Secretarial 15
Total 50

Figure 26 Man Power for Administrative Level

45
Tim
Designation Nos/ Sirajganj
e
STP STP WD WDS /
shift S/ CETP-1 CETP-2 SWM Total
1 2 WTP
WTP
G 4
Plant in charege Shift 1 1 1 1 1

3 shift 21
Shift Operators 21 1 3 3 3 3 3 3 3

Relievers 4 1 1 1 1 1 4

Helpers 3shifts 1 3 3 3 3 3 3 3 21
Relievers 1 1 1 1 4
Mechanic G shift 1 1 1 1 1 1 1 2 8
Electrician G shift 1 1 1 1 1 4

Misc. labour for

2 2 1 1 2 2 15 25
cleaning

Lab Chemist G shift 1 1 1 1 4

Plumber 3 3 6
Reliever 2 2

Bill collectors 4 4

Tractor driver 4 4

Front end loader

4 4
driver

SWM collection
10 10
team

Watch & Ward 3 3 3 3 3 3 3 21

Watch & Ward –

1 1 1 1 4
reliever

Exhibit 27 Man power Requirement for maintenance of Various Environmental Infrastructure

46
CHAPTER # 5
ENVIRONMENTAL BASELINE DATA ON PHYSICAL, ECOLOGICAL AND
SOCIOECONOMIC PARAMETERS
5 DE SC RI PT I O N OF T HE EN V I RON M ENT

5. 1 GE NE RAL
The primary objective of the study of existing environmental parameters is to provide an environmental baseline with
which potential impacts from the construction and operation phases of the proposed project can be compared.
Identification of environmental parameters, data collection and impact predictions form the core of Environmental
Impact Assessment exercise. A scoping matrix has been formulated to identify the attributes likely to be affected due to
the proposed project and presented in the exhibit below.
Baseline data includes inventory of physical, ecological and socio-economic parameters. Covering these aspects, data
has been compiled for:
 Land Environment (physiography, geology, seismology and soils); Water
Environment (water resources, water quality);
 Air Environment (meteorology, air quality);
 Noise Environment (noise levels); Ecological Environment
 Socio-economic Environment
Baseline data for the study area was collected using the following methods:
 Previous studies and literature review
 Site Reconnaissance and Field Visits
 Organizational Visit
Public
 Consultations Field
 Studies Laboratory
 Analyses Preparation of Maps

S Important Likely Impacts

N Environmental
Components
(IECs)
Natural Environment
1 Hydrology/Flo Hydrological impacts include sedimentation, submergence of
oding structures, bank erosion, and damage in the surrounding
area
2 River erosion Because of the construction activities in the site and possible
and siltation obstacles to the flow of river, there could be impacts on the
flow of river and sediment carrying capacity of the river.
3 Drainage The approach road may have negative impact on local
Congestion drainage pattern especially since the proposed site is located
in a flood plain.
Ecological Environment
1 Aquatic Ecology Fish spawning, Fish Nursery, Cage Culture fishing and Pen
Culture (Katha fishing) are dominant in the region. Project
development may lead to disrupt fish migration, fish

47
spawning and nursing ground and also the aquaculture
activities by the local people.
2 Agriculture Agricultural land will be converted to industrial land cause
agricultural production loss and soil quality degradation
3 Tree In order to implement project components, trees have to be cut. On
Cutting/plantation the other hand, opportunity for tree plantation arises due to the project
and associated green belt and open
spaces
4 Wild Life Construction activities may create disturbance for aquatic
and terrestrial wildlife. However, terrestrial wild animals are
rare in the region.

Environmental Pollution
1 Water Quality During construction:
Surface run off from project site, Oil/fuel and waste spills, sewage
discharge from labour camps and site office
During Operation:
Waste Water Discharge, Discharge of Sewage, Oil/fuel and waste
spills.

2 Noise Pollution During Construction:

Noise due to operation of various equipment/generators and
due to increased vehicular movement, pile driving
During Operation:
Noise from the industries, vehicle movement and generators.
3 Air Pollution During Construction:
Dust generation from construction activities, air pollution
due to increased vehicular movement, fugitive emissions from
various construction equipment
During Operation:
Air emissions occurring from the industrial units engaged in
the production of manufacturing goods
4 Soil Pollution Accidental spillages of toxic chemicals such as fuel,
lubricants and solvents may pollute soil
5 Socioeconomics Pre-Construction Stage
Loss of Land
Loss of structures
Loss of income
Construction Stage
Increased Job Opportunity
Increased Commercial activities
Operation Stage
Multiproduct sector enhancement
Increased commercial activities
Increased Job opportunities

Exhibit 28 Scoping Matrix

48
The methodology adopted for data collection is highlighted wherever necessary and the frequency adopted for data
collection for environmental attributes is summarized in the following exhibit.

SL No Attribute Parameters Freq Sour

uenc ce
y
LAND ENVIRONMENT
1 Soil Soil - Literature
Characteristics review
2 Geology Geological - Literature
Status review
3 Seismology Seismic - Literature
Hazard review
WATER ENVIRONMENT
4 Water Quality Chemical One Field studies
parameters seas and Laboratory
on Analysis
AIR and NOISE
5 Ambient Air Quality SPM,SO2, NOX One Field studies
Season and Laboratory
Analysis
6 Metrology Temperature , Data BMD/Literature
Rainfall, Wind review
Speed
7 Noise Noise levels in One Field
db Season Studies
Ecological Environment
8 Ecological Aspects Flora,Fauna, Threaten Socio Economic Socio
Species Aspects Economic
Aspects
9 Socio economic Aspects Socio economic Field Literature Studies and
characteristics of the review
affected area

Figure : 29 Environmental Attributes and Frequency of Monitoring

49
5. 2 P RO JE CT I NF L U E NCE AR E A
For the purpose of the EIA study, the Project Influence Area (impact zone) for the proposed Sirajganj
Economic Zone confines within a radius of 2 km from the proposed project boundary since the nature of the
project is such that most of the potential impacts are most likely to occur within this area as shown in the
following exhibit.
The baseline information is collected for the identified influence area, where proposed project area is considered
as the core zone with respect to the peripheral zone. Information for most of the environmental parameters and
features was collected for this zone. However, general information of a larger area has been gathered from the
secondary sources to compare the zone with on a broader scale.
SL Features/
Attributes Direction Distance
No. Remarks
1 Bangobandu Multripurpose Bridge North east Adjacent Major Bridge
2 Sidarbad Power Plant North east Adjacent Power Plant
3 Dhaka Rajshashi Highway North Adjacent Major Road
4 Belkuchi-Shragjang Approach Road West 1 KM Major Road
5 Jamuna River East Adjacent River
6 Shomeshpur Bazar North 2 Km Market
7 Randounipur Bazar North 3 Km Market

At a glance Rajapur UP of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila

Rajapur Number Belkuchi Number

Name 2 No Rajapur Union Number of HHs 7426
Area 6945 Number of voters 31460
Population 47596 Number of Mouza 23
Number of Village 33 Number of Village 37
Number of Mouza 5 Number of Bazar 05
Bazar 2 Number of High School 02
Transformation from CNG/Rickshaw/Bus Number of Gils High School 01
Sodor Upzila
Literacy Rate 40.99% Number of Government Primary 11
School
Government Primary 12 Number of Non-Government 10
School Primary School
Non-Government 05 Number of Public Health 01
Primary School Primary School
High School 03 Public Library 02
Madrasa 14 Kinder Garden 02
Chairman Md. Ataur Rahman Lillah Boarding 05
Important religious 02 Ebtedaiyee Madrasa 04
places
RAJAPUR UP SAIDABAD UP

Figure : 30 At a glance Rajapur UP of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila

50
5. 2 . 1 DE T ERM IN I NG F A CT ORS F O R T HE P RO JE CT INF LUENC E AREA

Factors that were considered in determining the project influence area-

Construction Stage
 Noise Pollution
 Nuisance dust – PM10, ,SPM, Dust etc.
 Traffic congestion
Operation Stage
 Environmental Pollutant- liquid discharge/effluent outlet/ discharge outlet/ point
 Air Emission dispersion Noise and Vibration
Others
 Load on infrastructure/ utilizes facilities- road, building, gas , electricity, water
 Location of affected communities those who are using water body as source of drinking
water
 Location of ultimate recipients of above issues (surrounding villagers)
The methodology adopted for determining the influence area was:
 Impact prediction
 Physical observation of surrounding settings
 General information on the site and surrounding collection
 Mapping/overlay the project influential area over base map
Further information was gathered on the existing physical environment including meteorology, geology, topography,
soils, hydrology and drainage, surface water quality, air quality and noise levels. The following sub-sections
elaborate the findings in this regard.

5. 3 P HYS I CAL E NV I RONM ENT

Following sub-sections detail out the current status of various environmental parameters in the study area

5. 3 . 1 A T M OSPHE RE & CLI M ATE

The climate of Belkuchi and Sirajganj Sadar Upazila follows the sub-tropical monsoon climate of Bangladesh.
North- west monsoon dominates the rainy/summer season and north-east monsoon drives the dry/winter season.
Rainfall in the project area varies considerably depending on the season. The annual rainfall measured at Sirajganj
averaged 1610 mm over the period 1990-2014. On an average, 60 to 70% of the annual rainfall of the project area
occurs in the months of May, June, July and August. The post-monsoon or transitional season, October to
November, is warm and humid with unstable atmospheric conditions that induce local thunderstorms due to
the influence of cyclones from the Bay of Bengal. The cool dry season during December-March, is sunny with
infrequent rainfall that is normally within three percent of the total annual rainfall. The pre-monsoon season between
April-May is hot and is characterized by thunderstorms called
‘Nor-westers’, with heavy rainfall. The most important climatic events of the project area are the onset and
withdrawal of the monsoon. The Bangladesh Meteorological Department (BMD) was contacted to obtain specific
meteorological data pertaining to the project area and its surroundings. The nearest meteorological observation
station is based at Sirajganj, about 20 km away from the proposed area. The meteorological data have been
considered in the engineering and design aspects such as the zoning & relative positioning of industrial clusters
within the area.

51
5.3.1.1 TEMPERATE
The exhibit below shows the average maximum and minimum temperature for the year 2005 to 2007. average
maximum temperature is 34.6 °C in April and the average minimum temperature for three years was 11.9 °C in
January .

5.3.1.2 RAINFALL
Rainfall varies considerably with a peak of 987 mm
achieved during September 2007. The minimum rainfall
recorded was zero mm in December 2005 and January
2006.

5.3.1.3 HUM IDITY AND WIND

Humidity levels are consistently very high during the monsoon season,
and drop significantly for a relatively short period at the end of the
dry season. Sunshine levels are low during the monsoon, but are
consistently high from November to May. It is reported that wind
speeds are at a maximum level in the early part of the monsoons, but drop substantially by the beginning of the dry season.
Wind direction is mainly from north to north-west during the dry season and from south to south-east during wet season.

5.3.1.4 AIR QUALIT Y

The Department of Environment (Rajshahi Division) does not have any record on regular air quality monitoring program
for ambient condition or emission for the project area.
Ambient air quality measurements are essential to provide a description of the existing conditions, to provide a baseline
against which changes can be measured and to assist in the determination of potential impacts of the proposed EZ on air
quality.
In order to establish baseline air quality, air quality analysis was performed. The air quality assessment involved the
determination of ambient levels of Suspended Particulate Matter (SPM), Oxides of Sulphur (SOx) and Nitrogen (NOx).
Air samples were collected from the site for a standard continuous 8-hour run using pre-calibrated High Volume Sampler.
The following exhibit presents the air quality sampling locations

Parameter Testing Procedures

SPM Gravimetric method using High Volume Sampler
NO x Absorption in dilute Sodium Arsenite Solution
SO 2 Absorption in Potassium tetrachloromercurate solution
Figure 31 Procedures for Determining Various Air Quality Parameters

52
Test results are presented below and were observed to be within acceptable ambient standards (except the value of SPM
which is slightly higher) as specified in Environmental Quality Standards for Bangladesh as well as WHO standards. The
value of SPM exceeded the allowable limits probably due to the presence of dustiness adjacent to the bank of river.

SPM SO 2 NOx BD WHO

(µg/m3) (µg/m3) (µg/m3) Guidelines2(µg/m3) Guidelines3 (µg/m3)
215.9 Not Detected 20.5 SPM- 200 (8 hrs) _
SO2- 365 (24 hrs) 20 (24 hr mean)
SO2- 80 (annual)
NOx – 100 (annual) 40 (annual)

Figure 32 : Air Quality Results around SEZ Area

Note: Air Quality tests performed at Department of Environment Laboratory, Dhaka Division

5. 3 . 2 LA ND CO ND I T IONS
Following sub-sections describe the existing land condition in the study region.

5. 3.2.1 GEOLOGY

5.3.2.1 PHYSIOGRAPHY
Sirajganj site is located on the flood plain of the Jamuna. Sirajganj Sadar and Belkuchi Upazlia is located in
Sirajganj district . On the eastern side is the Jamuna river and on the western side is the Belkuchi-Sirajganj access
road. The Northern side is the Dhaka –Sirajganj highway and Southern side of project is Belkuchi Upazila. Sirajganj town
is located north-west side of the proposed project site. The project is located western side of Bangabondu Multipurpose
Bridge.

5.3.2.2 SOIL T YPE AND QUALITY

The soils of the project area have been deposited by the Jamuna River on its flood plain, or on the river channel as
channel bar deposits during the Holocene and Quaternary Periods. Frequent shifting of channels resulted in the
formation of lenses and inter–tonguing in both surface and subsurface sediments. At present, surface sediment of the
proposed project site is mostly sandy clay with considerable amount of sand just below the surface. Soil of the area is
grey loam on the ridges and grey to dark grey clays in the basins. The dominant general soil type is non-calcareous
grey flood plain soil. T op soils are strongly acidic and sub-soils slightly acidic to slightly alkaline. General fertility level is
medium with low nitrogen and organic matter

53
Figure 33 Physiographical Map of Bangladesh

5. 3 . 3 WA T ER RE S OUR CES

5.3.3.1 BASIC HYDOLOGY

The Brahmaputra-Jamuna is the second largest river in Bangladesh and one of the largest rivers in the world,
flowing through Tibet, China, India and Bangladesh. Actually Jamuna is the downstream course of the
BRAHMAPUTRA which took place after the EARTHQUAKE and catastrophic FLOOD between 1782-1787. Presently the
Brahmaputra continues southeast from Bahadurabad (Dewanganj upazila of Jamalpur district) as the OLD
BRAHMAPUTRA and the river between Bahadurabad and Aricha is the Jamuna, not Brahmaputra. The Hydrology
Directorate of the BANGLADESH WATER DEVELOPMENT BOARD (BWDB) refers to the whole stretch as the
Brahmaputra-Jamuna.
Average annual flow at Bahadurabad is estimated to be 501 million acre-feet. August has always been the month
when widespread flooding has been most likely. Floods from May to July are usually due to the Brahmaputra -
Jamuna and Meghna. From August to October due to the combined flows of those river and the Ganges. As a rule,
the flow of the Brahmaputra-Jamuna is more erratic than that of the Ganges. The gradient of the Jamuna averages
1:11,850 which is slightly more than that of the Ganges. The Jamuna discharges a large volume of water and at the
same time brings in huge amounts of SEDIMENTs. During the rainy season it brings down something like 1.2 million
tons of sediment daily, and the annual silt runoff at Bahadurabad is estimated at 735 million tons.

54
Recently a 4.8-km long bridge has been constructed over the Jamuna for linking the eastern and western parts of
Bangladesh. The eastern edge of BANGABANDHU JAMUNA MULTIPURPOSE BRIDGE lies in Bhuapur upazila of Tangail
district and the western end in Sirajganj Sadar upazila of Sirajganj district. Apart from quick movement of goods and
passenger traffic by road and rail, it has facilitated transmission of electricity and NATURAL GAS , and integration of
telecommunication links. The bridge was opened for traffic on 23 June 1998. A considerable volume of river training
work was done to keep the river within the bridge instead of a flood-width of 14 km at the bridge site. During the dry
season, water levels can be as low as 0.52 m above sea level, while during the monsoon season water levels can
be much higher causing the Jamuna to overflow onto the low-lying floodplains.
The highest flood levels were recorded at the Jamuna hard point (about 11 km north –west of
the project site) during the monsoon of 1998, 1988 and 1974 when flood elevations o f +27m ,
+6.55 m and + 6.19 m PWD were noted respectively. At the same gauging station, the lowest
elevations of 0.0 m PWD in the year 1994 and 0.2 m PWD in the year 1982 were recorded.

Average Weather in Tangail for August

Average Weather in Tangail for July

Sunlight 10 hours a day Sunlight 7 hours a day

Coldest July temperature 22°C Coldest August temperature 24°C
Coldest daily temperature 23°C Coldest daily temperature 24°C
Warmest daily temperature 28°C Warmest daily temperature 28°C
Warmest July temperature 34°C Warmest August temperature 37°C
Discomfort* High Discomfort* High
Morning Humidity 76% Morning Humidity 79%
Evening Humidity 68% Evening Humidity 71%
Rain in July 1262 mm Rain in August 758 mm Sourc
Wet days for July 14 days Wet days for August 17 days e:
http://
www.weatherforecastmap.com/bangladesh/tangail/

55
Figure 34. Flood level map of Bangladesh

56
5.3.3.2 RIVER NET WORK
The study area possesses the following sections of the rivers and adjacent floodplains: Jamuna
River (West)
5.3.3.2.1 JAM UNA RIVER

The Jamuna River is one of the three main rivers of Bangladesh. It is the main distributary channel of the
Brahmaputra River as it flows from India
to Bangladesh , Length: 205 km,
Basin area: 47,000 km², Source:
Chemayung-Dung glacier, Country:
Bangladesh, Bridges: Jamuna Bridge,
Cities: Mymensingh, Pabna, Tangail.

This river drains the northern and a part

of the southern slope of the Himalayas.
Its basin area is
nearly 570,000 km2 , and it is the
highest contributor of fresh water into
the estuary – more than 60%
annually. Compared to the Ganges
River, human interventions are
insignificant in the Brahmaputra/Jamuna
basin. The flow hydrograph for the
Jamuna shows that the average peak
(70,000 m3/s) of the river occurs in
July/August and the average minimum
flow (4,200 m3/s) occurs in
February/March. Long-term observation
of discharges suggests an apparent
(although not significant) trend of
increase in the flow volume. Since the
seventies, very high variability has been
apparent in the annual peak discharges,
though the reasons for this trend are not
yet clear. This has an impact on the Meghna Estuary, especially in terms of increasing fresh water flows during the
wet season.

Brahmaputra/Jamuna is the largest source of sediment in the Meghna Estuary. The Bhadurabad station, situated
about 240 km upstream of Chandpur in the northern limit of the Meghna Estuary, is the only sediment gauging
station in the Brahmaputra/Jamuna River in Bangladesh. Time-series (although not continuous) sediment
measurements since 1964 are available at this gauging station. The bed materials in the Brahmaputra/Jamuna
River comprise fine sand of an average grain size of 0.20 mm, which become gradually finer downstream. The
suspended mode of sediment transport is the dominant process in the river. 1/3 of this sediment consists of fine
sand and the rest silt and clay. Nearly 500 to 600 Mtons of sediment input is found at Bahadurabad. It has been
found that the sand fraction of the sediment has decreased considerably over time, which indicates that there is
variation in sediment input in the estuary with time. This is assumed to be the result of the Assam Earthquake in
1950, during which a huge amount of sediment was produced and transported to the estuary through the
Brahmaputra/Jamuna River. The high accretion rate in the Meghna Estuary during the last 50 years is probably
related to the extra sediment produced by the earthquake

57
5.3.3.2.4 F LOOD PLAINS

Jamuna (Young Brahmaputra) Floodplain an alternative name used for the mighty Brahmaputra river, because
the Jamuna channel is comparatively new and this course must be clearly distinguished from that of the older one.
Before 1787, the Brahmaputra's course swung east to follow the course of the present Old Brahmaputra. In that
year, apparently, a severe flood had the effect of turning the course southward along the Jenai and Konai rivers to
form the broad, braided Jamuna channel. The change in course seems to have been completed by 1830. Due to
the upliftment of the two large Pleistocene blocks of the Barind and Madhupur, the zone of subsidence between
them was turned in to a rift valley and became the new course of the Brahmaputra as the great Jamuna. Both the
left and right banks of the river are included in this sub-region. The Brahmaputra-Jamuna floodplain again could be
subdivided into the Bangali-Karatoya floodplain, the Jamuna-Dhaleshwari floodplain, and diyaras and chars.

The right bank of the Jamuna was once a part of the Tista floodplain, and now through the Bangali distributary of
the Jamuna is a part of the bigger floodplain. Several distributaries of the Jamuna flow through the left bank
floodplain, of which the dhaleshwari is by far the largest; this floodplain is sub-classed as the Jamuna-Dhaleshwari
floodplain. The southern part of this sub-region was once a part of the Ganges floodplain. Along the Brahmaputra-
Jamuna, as along the ganges, there are many diyaras and chars. In fact, there are more of them along this channel
than in any other river in Bangladesh. There is a continuous line of chars from where this river enters Bangladesh
to the off-take point of the Dhaleshwari. Both banks are punctuated by a profusion of diyaras. The soil and
topography of chars and diyaras vary considerably. Some of the largest ones have point bars and swales. The
elevation between the lowest and the highest points of these accretions may be as much as 5m. The difference
between them and the higher levees on either bank can be up to 6m. Some of the ridges are shallowly flooded but
most of the ridges and all the basins of this floodplain region are flooded more than 0.91m deep for about four
months (mid-June to mid-October) during the monsoon.

The project area falls under the Jamuna flood plain system. All floodplains of the project area are extremely
seasonal. T hese floodplains are fringing type i.e. plain upon which alluvium is deposited in relatively narrow
discrete strips bordering the main river channel.
The schematic diagram of the entire river network system including associated flood plains of the study area
is presented in the exhibit overleaf.

5.3.3.3 DRAINAGE SYSTEM

Jamuna river and its tributaries form the natural drainage

system for the site . The recorded highest peak flow of
Brahmaputra-Jamuna is 98,000 cusec in 1988; the
maximum velocity ranges from 3-4 m/sec with a depth of
21-22m. The average discharge of the river is about 20,000
cusec with average annual silt load of 1,370-tons/sq km.
The average slope of the Jamuna is about 1:11,400;
however, the local gradient differs quite considerably from
the average picture.

Although, Jamuna River provides the major drainage outlet of

the proposed project site, because the site adjacent with the
Jamuna river Sirajganj point

58
5.3.3.4 FLOO DS AND WAT ER LOGGING
According to the local inhabitants, the proposed project site is frequently affected by floodwater.
However, at present, there is a road cum embankment that provides partial flood protection for the area.
Other dynamics like topography and landform indicate that the area is affected by flood. It is to be noted
that the formation level for the Dhaka-Sirajganj Highway (Highway N1) was raised to make it flood proof.
Maximum recorded water level at Sirajganj Hard Point is 6.17 m and estimated water level for 100 years
return period at Bangobondu Bridge is 6.36 m, whereas ground elevation of the area varies between 8 to
10 m. This data may suggest that flooding in the project area is either due to local drainage congestion or
river flooding. There is also a possibility that what the local people consider as flooding from the major river
could, in reality, be local water logging.

5.3.3.5 RIVER EROSION

As we know that Sirajganj is one of the river erosion affected area in Bangladesh and proposed site is
closed with Jamuna river . So, planning stage need to prepared a protection dam for proposed EZ. Last
10 years the river erosion beside Jamuna river has been improved due to Jamuna Multipurpose bridge
project.

5.3.3.6 SURF ACE WAT ER QUALITY

Two major centers of economic activities are located on the river Jamuna: Jamuna Multripupose Bridge
and Bagabari River Port. Bangobondu Multripurpose Bridge is upstream to the proposed EZ site and
Bagabari Reiver Port Authority is downstream to the proposed site. The river receives effluent from major
industrial units as well as domestic and commercial wastes from sirajganj and other smaller
economic/commercial centers and from the rural area, located on its banks. Run off from agricultural fields
containing pesticide and chemical fertilizer residues are also drained into the river.
However, from the river monitoring data available with the DoE, Jamuna River appears to be relatively non-
polluted. The river is in good condition aerobically and there is no problem with septic nature of the river.
Given the large discharge of the river and limited number of industries, the septic nature is not a
major concern for Jamuna.
For the determination of surface water quality, water samples were taken from Jamuna River. Water
samples were collected by using Rutner sampler. T he samples were preserved after collection and
were analyzed for the parameters shown in the exhibit below.
Water samples were collected for the analysis of the following
parameters:
pH: Measured by a digital PH meter
BOD: Measured by Incubation bottles (250-300 ml) & water Bath (thermostatically controlled at 200
C±10 C), (unit: mg/l (5 days))
DO: Measured by Portable Luminescent Dissolved Oxygen Meter
COD Measured with titration against 0.1250N ferrous ammonium sulphate using ferrous indicator.
Oil Measured by Partition Gravimetric methods (unit: mg/l) TSS Measured by Suspended
Solids Meter
TDS Measured by conductivity/T DS meter

5.3.3.7 GROUND WATER

Groundwater is the major source of drinking water in the region. It is also an important source of irrigation
water for the area. The project area has good groundwater potential, as groundwater recharge is not a
59
problem, due to the presence of highly permeable sandy soil. There are sandy aquifers at relatively low
depths. The National Hydrochemical Survey found that the young (Holocene) alluvial and deltaic
deposits are most affected whereas the older alluvial sediments in the north-west and the Pleistocene
sediments of the uplifted Madhupur and Barind tracts normally provide water with low arsenic
content. However, arsenic contamination in groundwater aquifers of the Bengal Basin is not
uniformly distributed, because of lenticular nature of alluvial and deltaic deposits. Some of the wells
may show high concentration of arsenic, whereas some may show very low concentration.
The National Hydro chemical survey found that arsenic concentration in groundwater of Siraganj District
varies from 6-50 µg/l. Samples from Sirajganj Sadar and Belkuchi Upazila show a considerable amount of
variation in arsenic concentration levels. Groundwater samples collected from a tubewell (13 m deep) of
Upazila DPHE of Sirajganj Sadar Upazila showed a value of 31µg/l. However, groundwater samples
collected from a tubewell (24 m deep) at Rajapur had arsenic concentration of 47.9 µg/l. Bangladesh
standard for acceptable limit of arsenic concentration in drinking water is 50µg/l and as per WHO
guidelines, it should be nil.

During consultations in the Rajapur area (adjacent to the proposed Sirajganj EZ site), it was reported by
the villagers that out of 65 tube-wells, only two wells are arsenic affected.

Ground water samples were collected from one tube well at Bangobondu Bridge, about 1.5 km away from
the proposed Sirajganj EZ area. The arsenic level in this sample was found to be nil. One of the reasons
for that can be that the sample was taken from a 380m deep tube well. Low arsenic level in the sample
suggests that the ground water at lower depths is arsenic free and suitable for potable use.

5. 4 BI OLO GI CAL E NV I RON M ENT

The biological component generally refers to flora and fauna, their present status, description and
habitats. The status of the flora and fauna of the study area (both terrestrial and aquatic environments) was
determined by:
Transit walks
Interviews, and
Review of literature relevant to the area
5. 4 . 1 E CO LOGY
Rajapur and Saydabad Union constitute a part of the Jamuna flood plain ecosystem and are inhabited by
many freshwater plants and animal species. The channels of Jamuna River and wetlands of Jamuna flood
plain are habitat to many species of commercial freshwater fishes, native waterfowl and migratory birds.
Jamuna River is also a major route for fish migration and the surrounding canals and floodplains area are
spawning grounds for some commercial fishes

5. 4 . 2 A QUAT IC F LORA

The proposed EZ may have an impact on the aquatic plant species of the area, if appropriate mitigation
measures are not enforced. Although many varieties of aquatic plants can be found in and around the
project area, their diversity and abundance have been reduced and are now mostly restricted to river
systems and wetland regions. Most of the aquatic plant species of the project area and the Jamuna Basin
are sensitive to seasonal water level fluctuations, and regeneration and growth are governed by these
parameters. In the permanent water bodies (‘beels’ - small ponds/lakes; and parts of river channels), plants
can survive and reproduce for the whole year.
Five different types of aquatic flora are found in and around the project area. T hey are:
 Submerged plants;
 Free floating plants;
 Rooted floating plants;

60
 Sedges meadows; and.
 Plants on margins (surrounding higher ground)
Submerged plants are present in the project area, both in ‘beels’ and seasonally flooded areas. Almost all
of these plants are monocotyledons and belong to families like ‘Aponogetonaceae’ and
‘Hydrocharitaceae’. These plants start growing with the rise of water level and sustain as long as water
is present.
Free floating plants are common throughout the project area although they are not among the most dominant
plant communities of ‘beels’ and relatively stagnant parts of the river channels. They are related to families
like ‘Eichhornia’, ‘Azolla’ and ‘Kachuripana’. Many fish ponds are also covered by this type of vegetation.

Rooted floating plants present in the project area include species with dominant families of ‘Nymphaeaceae’
and ‘Menyanthaceae’. They are most common in ‘beels’, old ponds and deeply flooded floodplain portions
of the project area. They are found in shallow parts of ‘beels’ or depressed areas due to inadequate time for
growth. ‘Shapla’ is one of the common plants of this type.

Reed and grasses cover high and medium high land and are not frequently affected by floods. This type of
vegetation consists of plant families like ‘Phrgmites’, ‘Gramineae’. This group of plants consists of both
grass and woody shrubs. ‘Durba’ (Cynodon aciculatus), ‘Kash’ (Saccharum spontaneum), ‘Gagra’
(Xanthium strumarium), ‘Binna ghash’ (Vetiveria zizaniodies) belong to this group of plants and they are
quite common in the project area.

Some of the most common aquatic plants of the project area include ‘Kachuripana’ (Eichhorina crassipes),
‘Makhna’ (Euryale ferox), ‘Shapla’ (Nymphaea nouchali), ‘Janglidhan’ (Hygrohiza aristrata), ‘Boronukha’
(Monochoria hastata) and ‘Binna’ (Vetivera Zizanoides).
A list of common plants including aquatic plants of the project area is presented in the annexure to the report
(Annex 5)

5. 4 . 3 AQUAT I C F A UNA
Fish is the most common aquatic fauna in the project area, in addition to other aquatic animals like crabs
and mollusks. There are also a number of species of reptiles and amphibians like Bibron's softshell turtle
(Pelochelys bibroni), Gangetic gharial (Gavialis gangeticus), Ganges softshell turtle (Aspideretes
gangeticus), Median roofed turtle (Kachuga tentoria) Jerdon's bull frog (Hoplobatrachus crassus), Skipper
frog (Euphlystis cyanophyctis) etc.
Jamuna and its floodplains provide very important habitat for many commercial species of fish. The river is
also a major route of fish migration. In general, there are two groups of freshwater fish species in and
around the project area. T he chief are those that spawn and breed locally in local drainage systems and
floodplains. Their spawning migration start when early flash floods or rain water inundates areas
rich in nutrients creating favorable environmental conditions including expanded areas of aquatic
habitat. This group of fish include Koi (Anabas testudineus), Khalisha (Colisa fasatus), Punti (Puntis
ticto), Shol (Channa striatus), Taki (Channa punctatus) Shingi (Heterpneustes fossilis) etc. Towards
the end of the monsoon, the fish start to return to rivers, streams and other aquatic parts of the
project area. A list of common fish species is enclosed as annexure to the report (Annex 4).

It may be noted here that the zero discharge concept proposed in the engineering & design study
along with appropriate environmental mitigation measures enforced successfully would ensure
minimization of the impact of the proposed project on various environmental components
encompassing the fauna.

61
5. 4 . 4 T ERREST RIAL F LORA

There is no natural hardwood or freshwater swamp forest in the proposed project area. In general, most of
the terrestrial vegetation of the project area is found along roadside and homesteads. T errestrial
vegetation is also found on the high ground of agricultural land and on the side of flood protection
embankments. Common terrestrial plants of the project area include: Narikel (Cocos nucifera), Supari
(Areca catechu), Kala (Musa spp), Ata (Annona squamosa), Kathal (Artocarpus heterophyllus), Aam
(Mangifera indica), Tal (Borassus flabellifer), Simul (Bombax ceiba) Khejur (Phoenix sylvesetris),
Debdaru (Polyalthia lonfifolia), Rain tree (Samanea saman), Koroi (Albizia sp), Gura neem (Melia
sempervirence), Bel (Aegle marmelos), Bansh (Bambusa sp), Pitali (Trewia nudiflora), Painna dumur
(Ficus heterophyllus) etc. A list of common plants, including homestead vegetation is annexed to this
report (Annex 5).

5. 4 . 5 T ERREST RIAL F A UNA

There are very few wild mammals in the project area. The species that are present include small
mammals such as Bengal Fox (Vulpes bengalensis), Common Mongoose (Herpestes edwardsi), Indian
Porcupine (Hystrix indica), etc. Ud Biral (English Name: Indian Otter, Scientific Name: Lutra
pespicillata). Other terrestrial animals like lizard, mouse, rats and bats are also found in the project area.
The chars and the rivers of the project area are visited by different kinds of migratory birds. They
normally use these areas as a temporary habitat. A list of wildlife species of the project area is also
annexed to this report (Annex 4 ).

5. 4 . 6 P RO T E CT ED AREAS
’Protected Areas’ of Bangladesh covers an area of 2, 43,435 hectare, which accounts for 16% of the total
area managed by the Forest Department and almost 2% of total area of Bangladesh. It includes 8 National
Parks, 7 Wildlife Sanctuaries, 1 Game Reserve and 5 other conservation sites.
THE PROPOSED PROJECT DOES NOT FALL UNDER THE JURISDICTION OF ANY OF THE PROTECTED
OR SENSITIVE AREAS OF BANGLADESH.

5. 5 NA T URAL HAZ A RDS A ND RI SKS

Because of the physiography, geography and other natural conditions of Bangladesh, the country is
susceptible towards certain natural hazards and calamities like floods etc. The following sub-sections
describe these in greater detail.
5. 5 . 1 S EI S M I C E F F E CTS
The project site is located in Seismic Zone II, an area classified as having potential for
intermediate intensity earthquakes. This intensity can be up to VII on the Modified Mercalli Scale (MMS) (i.e.
approximately 6.2 on the Richter scale). The basic horizontal seismic coefficient for the zone 2 is 0.15.
However, no major earthquake has been reported in the proposed project site in the recent past. The
project area is not located at the margin of any major plate or at the basin boundary. It is understood that
seismic risk at the project site is moderate and would not pose a major constraint to the development of the
project. The following exhibit shows the earthquakes and seismic risk zoning of Bangladesh.

62
Figure 35 Earthquake zones & flood prone areas of Bangladesh

5. 5 . 2 CYCL ONE S A ND S T ORMS

Cyclones (Kal-Boishakhi) may occur at any time of the year but are most probable and severe around April -
May and October – November.

63
CHAPTER # 6
POTENTIAL POSITIVE AND ADVERSE ENVIRONMENTAL IMPACTS OF THE
PROJECT

6 . I DE NT I F I CAT I ON AND E V A L I UAT I ON OF P O T ENT I AL I M PACT S

The process of identification of potential environmental impacts was initiated by identifying the development and
operational activities resulting from the proposed project as presented in the earlier sections of the report. This
chapter discusses the potential impacts on environment. As far as possible, attempts have been made to
quantitatively predict the impacts due to the proposed project. For non-quantitative impacts, qualitative
assessment has been done.
This section identifies and appraises the negative as well as positive impacts on various aspects of the
environment likely to result from the proposed development. Potential significant environmental impacts from the
development of the project have been identified with respect to the major activities to be carried out which
include:
 Land development
 Infrastructure development
 Operational phase of the project
It is pertinent to mention that the negative environmental impacts listed below are based on the assumption that
no negative impact mitigation measures or benefit enhancement are adopted.
 Land
Environment
 Water Environment
 Air Environment
 Noise Environment
 Biological Environment
 Socio-Economic Environment

The impacts of the above components have been further assessed during various phases of the project cycle
namely pre-construction (planning and design), construction and operation.

6. 1 P RE- CONS T RUCT I ON S T AGE EN V I RO NM E NT A L I M P ACTS

6. 1 . 1 NA T URAL F L OW ST O P PE D D UE T O F I L L I N G O F WA T E R BODIES

As per the survey drawing, a canal is entering into the project site on west corner. T he rain water and m onsoon
season will flow only through this canal. As per the Master Plan, realignment of the canal along the western
boundary to the existing discharge point (river) has been suggested. Due to this, no flooding is expected within the
proposed site or outside the project boundary. Also, the main river course has been retained in order to maintain
the normal water flow during all the seasons. Therefore, the natural water flow is not expected to be restricted due
to the filling.

6. 1 . 2 L OS S OF T REES
The Sirajganj Economic Zone will require removal of 3638 trees of various sizes and about 20
species. The affected people have planted fruit bearing and timber trees beside their houses or on
other high lands.

64
Types of trees Large Middle Small Sapling
Fruit tree 564 480 150 299
Timber 221 524 108 552
Banana 420 400 100 20
T otal 1205 1204 358 871
As per DoE requirement, any tree required to be cut will have to be compensated by provision of
3 saplings for each tree cut.
Figure 35 : Loss of trees

6. 1 . 3 RI S K DU E T O E ART HQUAKE
The project area falls in zone 2, i.e. moderate seismic zones (Z= 0.15) as per the Bangladesh National Building
Code (BNBC). Necessary seismic factors suggested by BNBC shall be incorporated suitably while designing
the structures to safeguard against earthquake risks.

6. 2 CONS T RUCT I ON ST A G E E NV I ONM E NT AL I M P ACTS

Generally, construction impacts are expected to last for a relatively short time period and are expected to
cease soon after the completion of construction. CONSTRUCTION IMPACT S ARE CONSIDERED TO BE
MINIMAL as all the construction works will be carried out within the site boundary on the acquired land and will
be controlled via the mitigation measures defined in this EIA. If the developer does not comply with the
environmental specifications, serious long term environmental problems could emerge.

6. 2 . 1 DI S RUP T I ON OF EART H SURF ACE

According to the preliminary design, the estimated quantities of earth works requirements for 3 m
The Consultants recommend that the developer will take fill material from the designated land and will be carried
by trucks, The developer will be required to submit specific proposals for borrow sources to the Project Director
(Sirajganj EZ) who will check the acceptability of each proposal with advice/assistance from the environment
authority. The developer will be responsible for obtaining all other necessary approvals for the borrow works such
as may be required from landowners, local Government agencies and Government Departments. It is preliminarily
identified that this land can be procured from various areas near Jamuna. All fill material should be free from roots,
sods or other deleterious materials. If all the earth material is brought from an authorized place, NO MAJOR
IMPACT IS EXPECTED T O BE ASSOCIATED WITH THE DISRUPTION OF THE EART H SURFACE.
Guidelines of Borrow Area development and operation have been annexed to this report.

6. 2 . 2 S OI L E ROSI O N AND S I L T AT ION

Soil erosion and siltation of water bodies from clearing and grubbing, storage of filled material, stripping of road
surfaces etc. can have a negative impact on the flow regime and water quality within the Jamuna River adjacent to
the construction site. This could lead to negative impacts such as flow impairment and localized upstream or
downstream flooding (arising from the overtopping of the river bank). However, these IMPACT S CAN BE
CONTROLLED T HROUGH GOOD CONSTRUCT ION PRACTICES.

6. 2 . 3 S URF A CE WAT E R A ND G R OU ND WAT ER P OL L U TION

Loose stockpiles of earth materials and bare top soil can be washed away into the water bodies during heavy
rainfall events. During the construction phase, storm water runoff can carry large sediment loads which increase
turbidity in the adjacent water bodies. T his CAN BE AN IRREVERSIBLE IMPACT , if not mitigated properly.
During construction, oil and grease and hazardous material should be managed properly in designated areas, and
disposed of appropriately. These are, however, MINOR SHORT TERM, REVERSIBLE IMPACT S. The integrity
of ground water quality must be maintained to ensure the long term yield of water suitable for potable supply.

6. 2 . 4 T RAF F I C F L O W CONGE S T I ON
65
The transportation and use of heavy equipment and trucks would be required during construction. Trucks will
transport construction materials and heavy equipment. This could directly impact traffic flow and aggravate
accidental risk along the Dhaka-Sirajganj and village roads, especially at the entrance to the construction site.
This can be a significant impact if not properly managed.

It is recommended that the construction impact mitigation plan of the developer quantify and forecast the impact on
the traffic volumes in Dhaka-Sirajganj road during the construction period. The plan should be approved by the
Bangladesh Road Transport Authority.

6. 2 . 5 AI R QUAL I TY
During construction phase, SPM IS EXPECTED TO BE T HE MAIN POLLUT ANT
ASSOCIATED WITH EART HWORK activities and material handling.
SPM generation due to handling of earth and movement of vehicles would be another source of air pollution. It is,
however, dependent on the moisture content of earth, and the same can be optimized by sprinkling water in
requisite quantity. Impact on air quality is envisaged due to the emission of construction plant, machinery and
transportation.
Due to the above mentioned emissions during construction, it is inferred that minor negative impact on ambient
air quality within a few meters from the source and within the site would occur.
However, appropriate mitigation measures, in the form of good construction practices have been annexed
to this report and the ESMF for the project would need to be followed in order to keep these impacts to a
minimum.

6. 2 . 6 NOI S E P OL L U T I ON

Noise at a construction site varies relative to the particular operation in progress. An operation can
be divided into three consecutive phases:
Ground Clearing
Excavation and Foundation
Erection and Finishing
Construction activities are expected to produce noise levels at source in the range of 75-90 dB (A). It would be
intermittent and decreasing with increasing distance. The impact of noise produced during the construction will,
however, be limited to a distance of about 75 meters at which, the noise level of various equipment will
come down below 55 dB(A). The CONSTRUCT ION ACT IVIT IES WOULD THUS NOT HAVE A
SIGNIFICANT IM PACT ON AMBIENT NOISE LEVELS, but the personnel operating the machines and the
workers stationed close to the machines may get exposed to high levels of noise and therefore proper mitigation
measures should be adopted to avoid any harmful consequences.

6. 2 . 7 WAT E R RE SOU RCES

Water requirement for the construction of the proposed EZ shall be met from tube wells within the premises of
the EZ area. A large number of workers, depending upon the speed and type of construction, would be required
during the peak period of the construction stage. Average estimated requirement of water for various
construction activities would be about 180 kl every day.
The ground water condition is mainly influenced by soil cover, which controls the local vertical rainfall recharge.
The infiltered water has to be stored in the interstitial spaces inside the sandy layer, which again depends on the
primary porosity in sand. T he thickness of the sand layer decides the total ground water storage while the open
pore spaces controls the movement of water in the sub surface.
66
The well inventory and hydrogeological studies in and around the study site indicate that the ground water
potential of Sirajganj EZ is good. Ground water is present in shallow unconfined aquifers as well as deeper
confined acquifers. The subsurface formations comprising semi- consolidated and unconsolidated alluvial
sands form a multi-layered aquifer system which further contributes to the ground water sources of the study
site. The occurrence and movement of ground water is mainly controlled by inter-granular pore spaces in the
unconsolidated to moderately consolidated formations. The general study of the lithology of these areas
reveals that there are alternating layers of sand and clay. At deeper horizons, there is occurrence of fine to
medium grained sand and the thickness of the aquifer is also appreciable
The quality of surface water is acceptable and it is noted that the local villagers use the water from Jomuna River
for domestic purposes.
Groundwater is the major source of drinking water in the region and also an important source of irrigation water
for the area. The study site is blessed with good surface and groundwater sources, as groundwater
recharge is adequate enough due to the presence of sandy soil.
The proposed project site is on the South Eastern side of Dhaka and surrounded by areas with high arsenic
contaminated groundwater aquifers. THERE IS A HIGH PROBABILIT Y OF T HE PRESENCE OF ARSENIC
CONTAMINATED GROUNDWATER AT SHALLOW DEPTH IN T HE STUDY SITE.
Drinking water requirement during the construction period is expected to 100 lpcd (Liters per capita per day),
which will be arranged by the developer. Requirement of water for water closets and urinals for the workers
would be met from the tube well at site. Wastewater generation during construction is assessed to about 80
lpcd, which could cause water pollution, if not treated. NO SIGNIFICANT IMPACT ON THE QUALIT Y OF
WATER RESOURCES IS ANT ICIPATED due to disposal of treated wastewater.

6. 2 . 8 S OL I D WA ST E D I SP OSAL

Inorganic solid waste generated during the construction phase like waste concrete, and mortar, left over
aggregate and debris etc. shall be recycled. Municipal waste from labour camps can lead to land pollution.
Pollution risks may also arise from accidental leakage and spillage of oil or fuel, which may contaminate soil. The
overall IMPACT OF WASTE DISPOSAL DURING CONSTRUCTION PHASE CAN BE SIGNIFICANT AND
HENCE PROPER MIT IGATION MEASURES WOULD BE REQUIRED TO BE FOLLOWED.

6. 2 . 9 BRI DGE ST RUCT URES

Construction of bridge can have serious effects on the area particularly on its hydrology and drainage,
leading to the risk of flooding. THEREFORE, THE DESIGN OF T HE BRIDGE WILL HAVE TO TAKE
INT O ACCOUNT ANY POSSIBLE MODIFICAT ION OR RIVER REGIM E BOT H UPST REAM AND
DOWNSTREAM AND M INIMIZE SUCH MODIFICATIONS AND CONSEQUENT IMPACTS.

6. 2 . 10 F L O RA AND F A UNA

The clearing of vegetation will result in the modification or removal of existing habitats for fauna. No
impact on or encroachment of nature reserves is anticipated, as the project area and its surroundings do not
come under any notified natural reserve.
During the baseline study, some species were found in the project area that are designated as threatened
animals by the IUCN. T hese include Siberian Duck, Ganges River Dolphin etc.

6. 2 . 11 HI ST ORI CA L AND CUL T U RAL M ON UM ENTS

NO HISTORICAL OR CULTURAL MONUMENTS WILL BE AFFECTED/ LOST due to the

construction of the project.

6. 3 OP E RAT I O N ST AG E E N VI RONM ENT AL I M PACTS

67
Operational impacts continue during the life of the project after the completion of construction phase and these
impacts are relatively longer lasting and in some cases permanent.

6. 3 . 1 AI R QUAL I TY
As part of the manufacturing processes of the multi-product industries shortlisted for the project, the
following air emissions are to be generated from the manufacturing operations.
Dust emission from blending of raw cotton/spinning/weaving/knitting manufacturing process
Dust particle may be emitted from formulation and packing material of the
pharmaceutical plant
VOC emission from dye and paint mixing
Exhaust emission from boiler
Diesel Generator
Emission due to Gas based Power Plant

6. 3 . 2 DU ST
Dust emissions would occur during natural fiber and synthetic staple processing and yarn manufacturing. Fiber
(especially cotton) handling and storage are sources of dust, particularly within work areas. Invisible micro dust
particles of fibers escape from the factory, which deteriorate the ambient air quality in terms of Suspended
Particulate Matter (SPM). The pollution of atmosphere by SPM may have the following effects:

 Increased dustiness of the area

 Retarding the growth of the vegetation
 Increased nuisance to the inhabitants
 Increased health hazards to the workers and inhabitants

However, the nature and extent of the effects depend on concentration of particulates and the length of exposure.

6. 3 . 3 V OCS

Emissions of VOCs are related to the use of organic solvents in activities such as printing processes, fabric
cleaning, and wool scouring (e, g. thermo fixation, drying and curing). Another source of emissions is the
evaporation or thermal degradation of chemicals used. THIS CAN HAVE A SIGNIFICANT IMPACT AS
WELL.

6. 3 . 4 E XHAU S T GA SES

Another source of air pollution is the exhaust from the boiler operation. Since the boiler will be operated by
natural gas as fuel, limited air pollution is expected except some effects on the ambient air quality in terms
of thermal pollution through stack effect of the boiler.
All the above IMPACT S WOULD BE CONTAINED WIT HIN THE WORKING ENVIRONMENT within the
plant area and would not affect the area outside the EZ, provided standard mitigation measures have
been applied to control the potential environmental impacts.
Moreover, vehicular emissions will be the major source of air pollution from the Sirajganj EZ area. The
pollutants from vehicular emission would include SPM, RSPM, CO2, NOx and CO. However, AS MOST
OF THE VEHICLES WOULD BE USING CNG, POLLUT ION FROM VEHICULAR SOURCES IS
EXPECTED TO BE LOW. It is recommended that the traffic within the EZ is phased as much as possible
to minimize traffic jams. T he proposed master plan for the development of the EZ considers traffic
movement within the area and has been developed to minimize congestion.
During the baseline survey, NO APPARENT PROBLEM WITH THE AIR QUALITY WAS NOT ICED.
Satisfactory results were obtained which revealed that the ambient air quality (in terms of PM10,
68
SPM, SO2, NOX) is within the acceptable levels as prescribed by the Department of Environment
and internationally accepted guidelines

6. 3 . 5 G AS - BAS ED P OWE R P L ANT

It is proposed to install combined cycle GAS BASED POWER PLANT of 54 MW capacity which is
integrated by two or more thermodynamic cycles of energy to transform the feed energy more efficiently into
work or power. Capacity of the power plant is arrived considering the power requirement as follows:
Electrical Demand Requir 39 MW (assuming with Unity Power Factor)

In the process mentioned above the following units are required for operation of the power
plant with closed cooling water system. AN AREA OF 14.84 ACRES IS EARMARKED WITHIN
THE SIRAJGANJ EZ BOUNDARY FOR POWER PLANT .
 Compressor Gas turbine Steam
turbine
 HRSG (Heat Recovery Steam
Generator)
 Condensation stage (exchanger and a tank)
 Energy generator

6. 3 . 6 NOI S E P OL LUT ION

Major sources of noise pollution expected are:
Yarn processing (texturizing, twisting and
doubling) Woven fabric production
Vehicular traffic
Generator sets during emergency
Gas Based Power Plant

From past experience, it is found that during yarn processing, maximum noise level generated from the
machines is about 99-105 dB(A)9. Therefore, high noise level, causing inconvenience and certain
health impacts related to hearing impairment and other problems for the workers, are expected if no
monitoring, mitigation and enforcement measures are in place. The respective agencies
responsible for such noise generation are envisaged to be monitored by the proposed environmental and
social cell at the site.

The modeling of impacts of noise from generators considering the worst case when all the sets are
running together indicated that the noise level at source would be about 75 dB (A)10. The impact in this
case, without any attenuation at the receptor, is given in the following exhibit. As seen from the exhibit,
noise during operation phase will be less than 55 dB (A) within a distance

69
of 20 m from the source. It can be concluded that noise in the operation phase of the project would have
moderate impact. To keep the noise within allowable limit will be the most challenging issue during
operation period of the proposed power plant project. As per Engine specification, project will generate
noise at a level of 101 dB (A) within 1 meter from aggregate source and 123 dB (A) from Gas exhaust
source. Generated noise from Gas exhaust source shall be minimized at level of 75 dBA in 10 meter
measured at the chimney escape by installing ‘Exhaust Gas Silencer’. EPC Developer must ensure
allowable noise level at boundary wall through proper layout and setting design of machineries.

6. 3 . 7 T RAF F I C F L OW/ CONGE STION

Preliminary traffic flow estimated at the site is about 12,326 PCU/day. Operation of the proposed
EZ and other establishments will result in an increase of traffic at the access and Dhaka-Sirajganj road.
Therefore, there would be a CONSIDERABLE NEGATIVE IMPACT ON THE TRAFFIC
MOVEMENT .
Within the zone, the traffic estimations have been utilized to arrive at the road configuration required in
terms of number of lanes to carry the traffic volume.

6. 3 . 8 WA T ER P OL LUT ION

In the Sirajganj EZ, only yarn and fabrics are water

polluting units. Other industries are assumed to be
only formulation (pharmaceutical), apparel making
(leather and jute) etc. and not producing any
effluents. Yarn and Fabrics, in general consume
large volumes of water. Consequently, these
plants discharge large quantities of effluents and
these effluents normally exhibit polluting
characteristics, unless treated appropriately. The
production process of Composite textiles (Yarn
and fabrics) is depicted in the exhibit below:

70
Exhibit 48 Garment Process flow chart

Exhibit 36 Flow chart for composite textiles

6.3.8.1 PROCESS OF WASTEWATER

Wastewater effluents are related to wet operations, which are integral to the textile manufacturing process.
Process wastewater from textile manufacturing is typically alkaline and has high BOD (from 700 to 2000
mg/l) and COD loads. Pollutants in textile effluents include suspended solids, mineral oils and other
organic compounds, including phenols from wet finishing processes (e.g. dyeing) and halogenated
organics from solvents used in bleaching. Effluent streams from dyeing processes are typically hot and
colored and may contain significant concentrations of heavy metals (e.g. chromium, copper, zinc, lead or
nickel). In a COTTON TEXT ILE DYEING/PRINTING INDUSTRY EFFLUENTS NORMALLY HAVE
HIGH BOD 5 AND SOLIDS CONCENTRATION. If it is a composite/integrated textile mill involving
various processes of desizing, scouring, bleaching, mercerizing and causticizing, dyeing and printing,
about 50 % of the total waste water flow, about 20% of the total BOD, and about 15% of the total
suspended solids would come from the dyeing process alone. For the printing process, corresponding
figures are about 5%, 5% and 2.5% respectively.
No waterborne pollutants originate from the process of weaving since all the operations are mechanical
processes requiring almost no water. Almost, all wastewater generation takes place during the finishing
processes. The following exhibit presents the snapshot of the estimated effluent generation, from the yarn
and fabric industry units in the Zone.
Effluents may be generated from the following production steps:
 Scouring: Fiber (especially wool) scouring involves the use of hot water and detergents to
remove soil, vegetable impurities, grease, and other contaminants from fibers. The scouring
effluent is strongly alkaline, and a significant portion of BOD5 and COD loads from textile
manufacturing arises from scouring processes.
 Desizing: Desizing operations may generate effluents with significant concentrations of organic matters

71
and solids. BOD5 and COD loads from desizing may be significant (35 to 50 percent of the total
load), and COD concentrations up to 20,000 mg/L may be generated.
 Bleaching: Common bleaching reagents include hydrogen peroxide, sodium
hypochlorite, sodium chlorite and sulfur dioxide. Wastewater let out from this process has high BOD, pH
and temperature.
 Mercerizing: Wastewater from this process is highly alkaline. Since this wastewater is normally
reused after recovery of caustic soda there is no constant liquid let out from this process.
 Dyeing: The process varies with the choice of dye, desired color and depth. Reactive dyeing solution
consists of an alkaline solution of the dye. Reactive dyes also react with water in alkaline solution at
elevated temperatures. Depending on the color and depth, generally 10 - 50 gm/liter of common salt and
5 - 20 gm/liter of soda ash is used in the dyeing process. Following the dyeing process the fabric is
washed once with detergent and twice with plain water. Dyeing process effluents are characterized by
relatively high BOD and COD value, the latter commonly above 5,000 mg/l. Salt concentration may
range between 2,000 and 3,000 ppm
 Printing: The wastewater coming out from this process is colored and contains high suspended solids
and BOD5
 Finishing: The quantity of WASTEWATER LET OUT FROM THIS PROCESS IS ABOUT 5 % OF
TOTAL WASTEWATER. The untreated effluent if discharged into surface water bodies causes
rapid depletion of the dissolved oxygen of the receiving streams. The condition is aggravated due to the
settlement of Suspended Solids (SS) and subsequent decomposition of the deposited sludge in an
anaerobic condition. The alkalinity and the toxic substances like sulphide and chromium affect aquatic
life; and also interfere with the biological treatment process. The color often renders the water unfit to
use for some industrial purposes. Only properly treated effluents may be discharged into any water body
or even land; otherwise it may pose a threat to the water quality and aquatic life. Effluent from Dyeing &
Finishing plants may contain heavy metals like Chromium, Copper, Cobalt etc. when mordant azo dyes
are used in the process. The individual units within the EPZ are not expected to use any Azo dyes, so it
is expected that the effluent will not contain any heavy metals.
 Process Cooling Water: In addition to the process liquid waste, certain volumes of liquid wastes mainly
comprising boiler wash water, boiler blow down, jacket water (cooling water) and other occasional
releases are discharged from the individual plant. Generally, this wastewater does not contain any
harmful or toxic elements and requires no special treatment. However, a routine monitoring will be
required for effluents particularly for cooling water (temperature and pH) and for boiler blow down
(concentration factor and pH) before discharging into the environment.
6.3.8.2 SEWAGE
The average DAILY SEWAGE GENERATION FROM THE PROJECT HAS BEEN ESTIMATED TO BE ABOUT
6570 M 3/DAY, which is proposed to be treated through the proposed Fluidized Aerobic Bio Reactor (FABR) or
active sludge process based sewage treatment plant. The treated effluent from the sewage treatment plant will be
used for watering of plants and greenery, in addition to usages that do not involve manual contact with the water.
No significant adverse impact due to this is anticipated.

6.3.8.3 POWER PL ANT

The power plant is not expected to generate any process wastewater, particularly cooling water. Because the main
power block is designed with Closed Cooling Water system. ‘Engine Jacket Water Cooling Circuit’ shall be
replaced when necessary.

6. 3 . 9 S OL I D WA STE
Wastes specific to the textile industry include trials, edge trimmings, cuttings of fabrics, and yarns
and sludge from process wastewater treatment containing mainly fibers and grease. Solid waste generated
in textile industries should be effectively recycled or reused within the process.
It is estimated that about 69 T PD would be generated during the operation phase, which need to be
disposed off effectively.
72
NO NEGATIVE IMPACTS ARE PREDICTED DUE TO SOLID WASTES DURING PLANT OPERATION since handling
and disposal of solid wastes will be carried out in accordance with the solid waste management plan as detailed
in the Engineering Design.

6. 3 . 10 ODO UR
Odour may be generated, particularly in the dyeing and other finishing processes, and use of oils,
solvent vapors, formaldehyde, sulphur compounds etc.
It may also be a problem in the waste disposal area and the area surrounding it. Proper
mitigation measures need to be designed to minimize the impact.

6. 3 . 11 F L O OD I NG

Flooding impacts relate to both flooding of the site by adjacent properties, and flooding of adjacent
properties by the proposed development at the site.
Major portion of the site mainly constitutes low-lying areas due to the Jamuna River crossing the site from
east. The entire site area is well below the Maximum Flood Level of 6.3 m. It is recommended to have the finished
ground level of the EZ above the maximum flood level i.e. 7.3 m to ensure prevention of water
logging/inundation at the site. Also, the river leg flowing through the site has been designed to be retained.

6.4 E V AL UA T I ON OF I M PACTS
Identification and evaluation of potential/significant impacts due to project location, site preparation, construction
and operation of the Sirajganj EZ has been done using an ‘IM PACT ASSESSM ENT M AT RIX ’ for
environmental impact assessment by identifying all stages of activities (construction to operation and
maintenance phase) and assessing the potential impact of each operation upon individual environmental
components.
The impact assessment matrix was developed to quantify the impacts and understand their significance in detail.
Impacts have been rated across five parameters:
Scale of Impact (Rated on a scale from -3 to 3, with -3 being the most negative and 3 being
the most positive)
Probability (Rated on a scale from 0 to 4 with 0 being no probability and 4 being highly probable)
Cumulative Impact (Rated on a scale from 1 to 3)
Permanence (Rated on a scale from 1 to 3)
Reversibility (Rated on a scale from 1 to 3)
It is to be noted that the identification as indicated in the ‘Matrix Rating’ relates to the significance
level of impact, assuring that no negative impacts mitigation or beneficial enhancement are adopted.
Since the proposed EZ is expected to house predominantly textile (Yarn and fabrics manufacturing) industries,
major environmental components that will be adversely affected by activities of the project are water quality and
ambient noise conditions. Other industries are not producing any effluents or noise problems. T he EZ has
been planned in such a way as to consider these impacts and reduce them to a minimum. For waste disposal,
a separate area has been identified where a CETP has been proposed to treat the untreated effluent to meet
‘zero discharge’ standards i.e. no treated/ non- treated water and solid waste generated from the CETP will
be let out to areas/ environmental components surrounding the EPZ. It can be seen from the IMPACT
MATRIX THAT T HREE PARAMETERS (SURFACE WATER, NOISE, AND ODOUR) REACH SCORES IN
THE RANGE OF -72 T O -96 WHICH INDICATES MAJOR AND IRREVERSIBLE IMPACT
Also, NO CUMULAT IVE IMPACT IS EXPECTED to be created, although there are a few
industrial settlements in the nearby region.
During the CONSTRUCT ION PHASE, T HE MAJOR IMPACT IS ENVISAGED TO BE ON FAUNA is
which cannot be reversed. Other major estimated impacts during construction are NOISE, AIR AND WATER
POLLUT ION that will need to be mitigated properly through good construction practices.
73
CHAPTER # 7
ANALYSIS OF THE ALTERNATIVES
7. 1 T HE NO B UI L D SCE NA RIO
From a purely physical environmental point of view, the ‘do-nothing’ scenario is preferable to any project
implementation, since it would avoid creation of any of the adverse impacts associated with the project.
However, the potential socio-economic benefits to the nation would be foregone and industrial growth would
be hampered.
It is, therefore, concluded that the ‘No build’ alternative is not acceptable, and the potential socio- economic
benefits of implementation of such project far outweigh the adverse impacts, all of which can be controlled and
minimized to an allowable level.
7. 2 CONS I DE RAT ION OF A LT ERNAT IVES
7. 2 . 1 A LT ERNAT I VE S ITES
Due to land scarcity in the country, seeking an alternative site for establishing an industrial zone is quite
difficult. Also, land acquisition is a lengthy and complex procedure under the existing Land Acquisition
Law of Bangladesh. Not only that, the project conceptual development over alternative sites is quite
difficult because delay in overall land acquisition process might create social conflicts and risks for the
project.
This site has been selected by BEZA and it has done some initial planning for land acquisition and
general layout planning. Part of this land is Government ‘khas’ land and the remaining needs to be
acquired from public. As per the plot schedule provided by BEZA, the total amount of land to be acquired
for the project is 1035.93 acres.
To avoid and minimize the impacts resulting from the activities of the project, Sirajganj Economic Zone
project is expected to be designed to adopt appropriate technological design, improvements or
adjustments, policy including good site operational practices and applicable ESMF etc.
The overall strategy shall follow the following sequence:
Impact avoidance & minimization
Adequate Compensation where impacts are unavoidable
Enhancement Measures – Employment benefit enhancement
measures proposed by consultant
7. 2 . 2 S I T E A NA LYSIS

The proposed site was assessed based on industrial, locational and infrastructure dynamics in the
region. The key aspects were as follows:
Industrial positioning: The success of an EZ depends on its acceptability by the
potential industries. Considering the same, we assessed the benefits/challenges that industries
may perceive in locating at the proposed site.
Social considerations: The potential of site for industrial development was weighed vis- à-vis
the social impact of the same to develop a holistic perspective of the proposed development.
Infrastructure availability: Considering that infrastructure is one of the key
requirements for industrial development, we assessed the infrastructure scenario in the region to
identify the critical bottlenecks that could be potential hindrances for industrial development.

74
The parameters highlighted above lay the foundation for assessing the potential for industrial development in the
Northern region. The constraints posed by the site conditions and the corresponding design aspects have been
summarized in the following figure

Figure 37 Summary of Site Constraints and Corresponding Design Aspects

7. 2 . 3 S OCI O- E NV I RONM EN T AL CO NS ID E RAT IONS

The baseline study of the socio-environmental aspects with regards to the project site helped in identifying a set of
parameters that would require due consideration while planning the project. The following exhibit captures a
snapshot of these parameters and the corresponding design aspects incorporated in the basic planning study

Further, the environmental quality standards envisaged to be adhered to by the on-site infrastructure, based on the
environmental study are summarized in Figure 38.

75
Parameter World Standards Bangladesh Standards Comment
Ambient Parameter WHO guidelines Parameter BD guidelines No diesel generation sets are
Air (µg/m3) (µg/m3) envisaged to be established at the project
Quality Sulphur Dioxide 20 (24 hr mean) Sulphur Dioxide 365 (24 hour) site. Further, air quality monitoring is
Nitrogen Oxides 40 (annual mean) 80 (Annual) envisaged to be carried out by respective
Suspended 50 (24 hr mean) Nitrogen Oxides 100 (Annual) agencies responsible for operation of
Particulate matter Suspended Particulate matter 150(24 hour) captive power generation units & other air
(SPM 10) (SPM 10) 50 (Annual) polluting components etc.
Suspended 25 (24 hr mean) Suspended Particulate matter 65(24 hour)
Particulate matter (SPM 2.5) 15 (Annual)
(SPM 2.5) Carbon Monoxide 1000 (8 hour)
Carbon Monoxide - Ozone -
Ozone 100 Lead 0.5
Lead 0.5
Ambient Location WBG guidelines dB(A) Location BD guidelines dB(A) No ambient noise polluting project
Noise components are envisaged as a part of the
Standards Day Night Day Night site infrastructure. T he respective agencies
Silent - - Silent 50 40 responsible for such noise generation are
Residential 55 45 Residential 55 45 envisaged to be monitored by the proposed
Commercial 70 70 Commercial 70 60 environmental monitoring agency at
Industrial 70 70 Industrial 75 70 the site

76
Parameter World Standards Bangladesh Standards Comment
Potable Parameter WHO Guidelines (mg/l) Parameter BD Guidelines (mg/l) The water treatment infrastructure at
Water the site has been designed considering
Guidelines the applicable standards.

Parameter WHO Guidelines (mg/l)

Parameter BD Guidelines (mg/l)
pH 6.5-8.5
pH 6.5-8.5
TDS 500
T DS 1000
BOD Nearly 0
BOD 0.2
Turbidity 5 NTU
Turbidity 10 NTU
Fluoride 1.5
Fluoride 1
Nitrite 0.91
Nitrite <1
Sulphide 0
Sulphide 0
Ammonia 1.5
Ammonia 0.5
Chloride 250
Chloride 150-600
Iron 0.3
Iron 0.3-1
Phosphorus -
Phosphorus 0
Arsenic 0
Arsenic 0.05
Effluent Parameter WB Guidelines (mg/l) Parameter BD Guidelines (mg/l) The effluent treatment network and
pH 6-9 pH 6.5-9 system has been designed considering
Suspended Solids 50 Suspended Solids 100 the applicable standards.
BOD5 30 BOD5 150
Total dissolved solids - Total dissolved solids 2100
Waste water flow - Waste water flow 100 l /kg of fabric processed
Total Chromium 0.5 Total Chromium 2
Sulfide 1 Sulfide 2
Phenolic Compounds 0.5 Phenolic Compounds 5
Oil & Grease 10 Oil & Grease 10
Cobalt, Nickel, Copper 0.5 each Cobalt, Nickel, Copper -
77
7.2.4 A LT ERNA T E P ROD UCT ION T EC HNI QUES F OR T EXT I LE D YING
The focus here would be on assessing the main sources of pollution within the industry and suggesting
mitigation measures. To assess the pollution within the industries, a cleaner production audit process will be
carried out with the cooperation of the industries.
A Cleaner Production Audit is a management tool comprising a systematic, documented, periodic and
objective review of a company’s processes, products and operations, designed to identify and provide
information about opportunities to reduce environmental hazard, by reducing the use of hazardous
substances in the product life cycle.
This would focus on the raw materials coming on to the premises, the processes to be undertaken
and the materials (products, by-products and waste) that would leave each factory site. In addition water
quality analysis would be undertaken in the effluent and in the different stages of production, to support the
cleaner production audit process.
In order to reduce waste, many alternative production trials will be carried out to optimize the production
processes. These will include improved housekeeping, training of factory staff, and optimization of dyeing
conditions (changing dyeing parameters and introducing alternative inputs or processes).

78
CHAPTER # 8
MITIGATION AND ENHANCEMENT MEASURES
8. 1 M I T IG A T ION M EA S UR ES

This chapter includes the principles, procedures and mitigation measures that are necessary for ensuring the most
appropriate environmental mitigation and enhancement plans are applied during different stages of project
implementation. T o avoid and minimize the impacts resulting from the activities of the project, measures/management
plans are based on appropriate technological design, improvements or adjustments, noise policy including good site
operational practices etc.
The overall strategy has the following sequence:
IMPACT AVOIDANCE: Changing project location, design and construction methods to avoid impacts.
IMPACT MINIMIZATION: Where impacts cannot be avoided, implementing mitigation measures to reduce
the impact to acceptable levels.
COMPENSATION: Arranging compensation where impacts cannot be avoided or sufficiently
mitigated.
ENHANCEMENT: Measures, which, at insignificant cost to the project, give appreciable social or
developmental benefits.
The mitigation plan has been recommended to highlight the action procedures to avoid/minimize / control the
impacts arising out of different project phases i.e. pre-construction, construction and operation. NO RESIDUAL
IMPACT OF THE PROPOSED MITIGATION MEASURES IS ANT ICIPATED

8. 2 E NHAN CEM E NT M EA S URES

The total construction time frame envisaged for the project is 2 years for Phase 1 with commercial operations
starting in the year 2015. During construction, the project will create some temporary job opportunities. However, the
impact is expected to be of relatively short duration, being restricted locally to the construction period. Although labour
recruitment is the affair of the construction Developer who has the right to determine the selection procedures, but
priority could be given to hire local people/PAPs as far as possible.
The proposed Sirajganj EZ is expected to provide foreign exchange earnings by promoting traditional exports, provide
jobs to alleviate unemployment or under employment problems in the country and assist in income creation, attract
foreign direct investment (FDI) that would act as catalysts for domestic entrepreneurs to engage in production of
textile goods and other products.

79
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
Design and Planning Stage
Loss of Trees As per ESMF Prior to land clearance Resettlement External
Unit Consultant
Loss of Water bodies- a. As per Master plan, the Detailed Design Design BEZA
associate canal has realigned Consultant
along the northern and western
boundary to the existing river. The
main river course also retained in
order to maintain the normal flow of
water during all the season.
b. Alternate water route would be
proposed in the detailed
engineering and design study
phase for overcome affected water
bodies being utilized transportation
by the surrounding communities
Bridge Structure a.The hydraulic design will be Detailed Design Design BEZA BEZA
Design related issue: considered 50 years design flood for Consultant
Sirajganj, including bridge openings, to
Provision of adequate waterway such that no accommodate flash floods and
afflux is created upstream after construction catastrophic events, which typify the
of bridge area.
Provision of adequate vertical clearance for b.Scour protection will be provided
navigation where necessary.
Control of possible bank erosion with proper c. Make sure that the regime waterway
river training works width is not reduced, thus avoiding
Need of higher embankment for bridge additional rise of water level upstream
approaches due to navigational of bridge because of constricted
requirements water way (afflux creation)
d.Hydraulic Model studies may be
necessary
Construction Stage
Land Clearance a. Any debris generated will be Construction site During Construction Developer ESC
disposed of only at designated
sites.
80
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
b. Adequate protection will be
provided to prevent the dispersal
of loose material.
Preservation of Top Soil The filling material will be Construction site During Construction Developer ESC
brought by truck from designated
land.
Transport of construction material to a. All vehicles delivering material to Construction site During Construction Developer ESC
site the site will be covered to avoid
spillage of material
b. All haul roads will be kept
clean and clear of all dust / mud
or other extraneous material
dropped by such vehicles
c. All vehicles used on site for this
purpose will carry currently
valid fitness certificates issued
by the BRTA at all times
and copies of the same
should be submitted to the
Project Director
d. All vehicles used on site for this
purpose should comply with the
pollution norms of ECR 1997.
Storage of Construction Material On Stockpiles of all construction Construction site During Construction Developer ESC
site material will be at least 100m from
watercourses along the expansion
area.
Slope Protection All slope protection measures Construction site During Construction Developer ESC
will be carried out as detailed in
the engineering design
with prior approval of the Project
Director.

Erosion Control Measures Suitable erosion protection Construction site During Construction Developer ESC
measures will be carried out as
detailed in the engineering
design with prior approval of the
Project Director.

81
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
Hot-mix Plants and Batching Plants All hot-mix plants and batching Construction site During Construction Developer ESC
plants will comply with
requirements of ECR emission
control norms (Schedule –11,
ECR).

Contamination of Soils by fuel and a. Vehicle/ machinery and Construction site During Construction Developer ESC
lubricants equipment operation,
maintenance and refueling will
be carried out in such a fashion
that spillage of fuels and
lubricants does not contaminate
the ground
b. Fuel storage and refilling areas
will be located at least 300 m
from all cross drainage
structures and water bodies or
as directed by the site engineer.
At Brick fields/Brick During Construction Developer ESC
Contamination from fuel and a. The work will be carried out in
crushing yards
Lubricants such a manner that pollution of
natural watercourses, ponds and
tanks is avoided.
b. Vehicles, machinery &
equipment maintenance and
refueling will be done in a
manner as specified to prevent
pollution of water.
Impacts of bricks material a) Give preference to local At Brick fields/Brick During Construction Developer ESC
brickworks that have crushing yards
DOE’s approval.
(b) Procure bricks only from brick
kiln using natural gas as fuel.
(c) All bricks delivered to site to
82
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
be accompanied by a certificate
showing that the kiln concerned
has not used fuel wood in their
production.
(d) Developer to use kerosene, gas
or other non fuel wood materials
for heating bitumen and for
domestic purposes

Construction Camp (a) Sufficient measures will be All Construction Worker’s During establishment, Developer ESC
taken in the construction camps, Camps including areas in operation and
i.e. provision of garbage tanks and immediate vicinity dismantling of Camps
sanitary facilities. Waste in septic
tanks will be cleared periodically.
(b) Drinking water will meet
Environment Quality Standards.
(c) Garbage will be collected
in a tank and disposed of
periodically.
(d) Special attention will be paid to
the sanitary condition of camps.
(e) Location of temporary sanitation
facilities must avoid settlements
which are adjacent to the EPZ
boundary.

Construction site During Construction Developer ESC

Dust/Air Pollution a. Locating Hot Mix Plant/s Construction plants, During Construction Developer/ ESC
(HMP) away from habitat. equipment and vehicles Construction
Firm
83
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
b. Locating Concrete batching
plant (CBP) away from
human habitation and water
bodies.
c. Locating HMP and CBP in
downwind direction
(predominant) to the nearby
settlement as far as possible
d. Adequate dust control
devices for HMP and CBP
e. Carrying out routine
maintenance and/ or
replacement of dust control
devices.
f. Carrying out regular
maintenance of plant,
equipment and vehicles
g. Maintaining adequate
moisture in aggregates before
loading and unloading to
feeder bins of HMP to
prevent dust emission.
h. Defining vehicle movement
path inside plant site and
maintaining the movement
path for control of dust
emission.
i. All tippers / dumpers carrying
earth, sand or stone will be
always fitted with tailboards to
prevent spilling.
j. Materials will not be loaded to
a level higher than the side and
tail boards and will be covered
84
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
with a clean tarpaulin in good
condition. The tarpaulin will
be properly secured.
Noise Pollution (a) All vehicles, equipment and Vehicles, Plant and machinery During Construction Developer ESC
machinery used for the project
will comply with the relevant
ECR norms and the relevant BRTA
rules.
(b) Using enclosure for all diesel
generator sets.
(c) Source control through proper
maintenance of all equipment.
(d) Use of properly designed
engine enclosures and intake
silencers.
(e) Construction workers operating
equipment that generates noise
should be equipped with noise
protection. It is recommended that
workers operating equipment
generating noise of ≥80 dB (A)
continuously for 8 hours or more
should use ear muffs. Workers
experiencing prolonged noise level
70 -80 dB (A) should wear ear
plugs.

Water Pollution a. Storage of construction Earthwork and marginal During Construction Developer ESC
material and excavated soil spillage of construction
above high flood level. material causing temporary
b. Strictly avoiding turbidity and suspended solids
cleaning/washing of
construction vehicle in any
water body.
85
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
c. Proper planning of site
clearing and grubbing so as
not to keep the cleared site
before working for long
duration
d. Providing temporary side
drains, sedimentation basin,
as necessary to avoid or
minimize erosion and
prevent sedimentation to
receiving water bodies.
Ground Water Pollution (a) Providing septic tanks for Human wastes and waste During Construction Developer ESC
treating sewage from toilets water at construction camp
before discharging through soak
pits.
(b) Locating soak pits at least 50
m from any ground water
sources.
Land Pollution (a) Collecting kitchen waste in Domestic solid waste and During Construction Developer ESC
liquid waste generated
separate bins and disposing at
of in a pit at designated workers’ Camp
areas.
(b) Collecting plastics in
separate bins and
disposing as specified
Loss of Damage of Vegetation (a) All work will be carried out Site Clearance During Construction Developer ESC
in such a fashion that the damage
or disruption to the flora is
minimal. Only the trees or shrubs
that impinge directly on the
permanent works or necessary
temporary works will be removed
with prior approval from the Site
Engineer.
86
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
Loss, Damage or Disruption to Fauna (a) All works are to be carried out Throughout the construction During Construction Developer ESC
in such a fashion that the damage site
and disruption to fauna is
minimal.
b) Construction workers will be
instructed to protect natural
resources and fauna, including wild
animals and aquatic life.
Hunting and unauthorized
fishing would be prohibited
Traffic Control and Safety The Developer will take all All along the EZ area During Construction Developer ESC
necessary measures for the safety
of traffic during construction and
provide, erect and maintain such
barricades, including signs,
markings, flags, lights and flagmen
as may be required by the Engineer
for the information and protection
of traffic approaching or passing
through the section of the EPZ area
under improvement.
Occupational health and safety of (a) Water supply, sanitation, Construction camp and During Construction Developer ESC
worker drainage and medical health work site
facilities at campsite.
(b) Providing and using PPEs
(c) Using working reverse horn for
all construction equipment and
construction vehicles i.e. tippers,
dumpers, roller, etc.
(d) Providing earth link circuit
breaker (ELCB) for all electrical
connections.
(e) Maintaining first aid at
construction sites.
87
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
(f) Maintaining emergency response
system.
(g) Conducting induction and
periodic training for all workers
and supervisors.
e) Conducting periodic training
for all personnel working at plant
site.

Bridge Construction

Disruption of Navigation and (a)To avoid the

Water navigational disruption
Transport and accidental risk,
adequate navigation
lights, and markings are
to be provided in the
navigation route and
adequate navigational
clearance should be
allowed in the design of
bridge

Degradation of Water Quality if (a)Developer will made provision During Construction Developer ESC
bentonite mud is allowed to enter for disposal of bentonite
water course enriched material from site
in an appropriate manner and in
accordance with the regulations
of the appropriate regulatory
authorities.

Construction of circular cofferdam for (a) The work shall be scheduled During Construction Developer ESC
the foundation of bridge is an issue of and planned to avoid creating
88
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
major concerns as it may block the obstruction and disturbance to
waterway creating obstruction to free migration and spawning of fish
movement of aquaculture including
migratory fish

Noise from pile driving ESC (a) Piles will be designed as cast During Construction Developer ESC
in place

Impact on aquatic ecosystem (a) Mitigation measures will During Construction Developer ESC
include appropriate engineering
design to minimize increases
in suspended solids. This is
particularly important during the
Feb.-March and August to
October fish migration periods.

Post Construction/Operation Stage During Construction Developer ESC

Bridge Structure a. Adequate waterway opening shall be During Construction Developer ESC
of BEZA Hydrology and provided in the design of bridge and
Flood approach roads for defusing impacts
Pattern on regional hydrology
(b) Proper maintenance and monitoring of
bridges/ culverts are
to be ensured during post construction

Industrial Effluent (a) Effluent from individual industry should Individual Plant Throughout Operation Developer ESC
be collected and transported through stage
concealed pipes to CETP which will ensure
zero discharge treated effluent by way of
recycling
(b) No treated/non treated water and solid
waste generated from the CETP should be let
89
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
out to land/drain/existing water sources or
discharged to other areas (Refer: Basic
Planning Study –Sirajganj EZ
(c) The Design Consultant should include the
main mitigation measures in the treatment
process, to ensure that effluent standards meet
National/ international standards

Air Pollution (a) Suitable dust collectors (bag filters)

will be provided at all major emission
sources. Use of masks should be made
compulsory for the workers.
(b) Gas based generator will be used
(c) Boiler/generator will be regularly inspected
to ensure that they are operating efficiently and
emission standards are met
(d) For well dispersion of the hot air from
boiler stack, it is recommended that the
height of the stack chimney should be at least
15.0 m
(e) Installing and modifying equipment to
reduce solvent use
(f) Adopting water based methods for
removing oil and grease from fabric
instead of using volatile solvents

Noise Pollution (a) The workers and employees Individual Plant Throughout stage
Operation Unit ESC
working at the factory premises
should use ear plugs and ear muffs
for protection against the noise
90
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
(b) The individual plant should
carryout regular maintenance of
the equipment to minimize the
noise level
(c) Using enclosure for all generator
sets
Traffic Control and (a) Traffic management plan will be All along the Sirajganj Throughout ESC Supervision
Safety implemented (b) Traffic control measures to EZ Stage Consultant
be enforced strictly. area and surrounding
Domestic Sewage a. Suitable STP with tertiary treatment STP Supervision
Throughout stage ESC
Discharge will be established and treated waste Consultant
water will be used as non potable
water.
b. The Design Consultant should
include the main mitigation measures
in the treatment process, to ensure
that effluent standards meet
National/international standards.
c. Location of STP should avoid
settlements which are adjacent to the
boundary.

Drinking Water (a) Water Treatment System selected will WTP Operation Throughout stage ESC Supervision
ensure that the quality of water is within Supervision Consultant
the drinking water standards.
Solid waste Management (a) Elaborate Solid Waste collection/ MSW, Industrial Waste Throughout Operation ESC Supervision
management mechanism will be (Hazardous/Non Hazardous) Stage Consultant
implemented
(b) Biocomposting facility, sanitary
land filling will be implemented within
the MEPZ area .
c) Observe good housekeeping and periodic
maintenance
Odour a.Installing and modifying equipment to Individual plant (Dyeing and Throughout Operation ESC Supervision
91
Environmental Impact / Issue Mitigation Measures Location/Source Time Frame Responsibility Responsibility
Implementation Supervision
reduce use of odorous chemicals Finishing process) Stage Consultant
(b) Routing of stack emissions through boilers
to reduce odour emissions

ETP The designers should have included the Sludge of CETP, STP and Throughout Operation ESC Supervision
main mitigation measures in the treatment Sanitary landfill area Stage Consultant
process (CETP, STP, Sanitary landfill) to
ensure that odour standards meet National/
international standards

Figure : 39 Mitigation Measures

92
CHAPTER # 9
ENVIRONMENTAL MANAGEMENT PLAN ( EMP) OF THIS PROJECT
9.1 O BJE CT IV E

The Environmental Management Plan (EMP) aims to ensure the compliance of all activities undertaken during
the implementation and the operation of the Sirajganj EZ with the environmental safeguard requirements of the
World Bank and Government of Bangladesh. Furthermore, it aims at integrating the environmental
components of the project with existing initiatives and programs in these fields. T he plan consists of
mitigation, monitoring and institutional measures to be taken during implementation and operation to eliminate
adverse environmental impacts, offset them, or reduce them to acceptable levels. T he plan also includes the
actions needed to implement these measures.
The EMP is based on five major principles:
 The POLLUTER PAYS for pollution and prevention of pollution.
 The DEPARTMENT OF ENVIRONMENT (DOE) IS T O PLAY A CENTRAL
ROLE in the environmental safeguarding of the project - regulation, supervision and
enforcement.
 Environmental SAFEGUARDS TO BE INCORPORAT ED FROM THE
INCEPTION of all activities.
 PRIVATE SECTOR DEVELOPMENT FOR EXECUT ION AND IMPLEMENT ATION
of environmental safeguard related activities.
 All activities undertaken within the framework of the PSDSP or
subsequent developments are to be reviewed for their environmental impacts, and,
when required, they need to be included in relevant EFFECTIVE ENVIRONMENT AL
MANAGEMENT PLANS aimed at off-setting, preventing, or mitigating any such
negative impacts. Satisfying the environmental safeguard requirements is a condition
for the proposed activities to be implemented.

9. 2 E NV I RONM EN T AL M AN AG E M E NT M E AS URE S PROPOSED

Exhibit 54 summarizes the potential impacts which are to be controlled, the mitigation measures which are to be
adopted, and the indicated time frame for implementation and responsibility for ensuring the management plans
are efficiently implemented.

9. 3 S P ECI F I C M AN AG EM E NT PLAN
Certain important and specific management plans with their respective action procedures for carrying out the overall
EMP effectively are enumerated as follows

9. 3 . 1 S T O RM WAT E R M ANA GE M EN T P LAN

The proposed drainage system is designed to cater to the surface runoff within the project area by gravity
flow. Drainage system is designed in order to meet the stream invert level at the corresponding location. T he
different types of drainage systems are:
 Open drain with brick wall - trapezoidal, rectangular, semi-circular
 Open drain with RCC wall - rectangular, semi-circular
 Closed drain with RCC wall - rectangular
Closed rectangular drains are adopted for the surface run off collection for easy maintenance and land
optimization. The entire zone area is designed to be covered under this collection system. Drainage system is
designed on both sides of the road. Foot path is planned on top of the drain slab. RCC box culverts of
suitable sizes are designed for road crossings. Rainwater harvesting structures are envisaged along the drain.

93
The storm network with discharge point is shown in the exhibit below.

9. 3. 2 WA S T EWA T E R M A NA GEM E N T P LA N

9.3.2.1 SEWAGE T REAT MENT SYSTEM

The objective of the sewerage & sullage treatment system is to cater to the anticipated peak discharge
requirements and to treat the waste as per the required discharge standards. Although grey water
(sullage) is potentially different from the sewage and requires different treatment system if it is to be used in an
optimal manner, the sullage quantity estimated at the project site is insignificant. In light of this, it is
recommended that sewage and sullage be treated together at the Sirajganj EZ STP (sewage treatment plant)
facility.

Based on the estimation of sewage generation at the project site, this section concentrates on the qualitative
aspects of the sewage treatment system and alternatives recommended for the same.
The total capacity of the sewage treatment plant is 6.57 MLD of sewage per day.

9.3.2.2 SEWAGE COLLECT ION NET WORK DESIGN

The design criteria considered for the design of the sewage treatment system are summarized in the following
figure.
Demand 6.57
Working hours per day 24
Pipe material NP2 RCC for all areas except road crossing
NP3 RCC for road crossing
Pipe roughness coefficient 140
Peak Flow Factor 2.00 for contributory population up to 50,000
Formula used to calculate friction loss Hazen Williams

Infiltration 10%
Minimum self cleansing velocity 0.6 m/s
Figure 40 Sewage Collection & Transport Network Design Criteria
The raw effluent characteristics taken for design basis are as follows:
Parameters Unit Value
Ph - 6.0-7.5
Suspended Solids mg/l 150
Biological Oxygen Demand mg/l 300
Chemical Oxygen Demand mg/l 900
Oil and Grease mg/l <50
Bacteriological Count mpn/ 100ml 107-108
Figure 41 Raw Effluent Characteristics
Treated effluent characteristics taken for setting objectives of design are given in the following
exhibit below.
Parameters Unit Value
Ph - 6.0-7.5
Suspended Solids mg/l Less than or Equal to 20
Biological Oxygen Demand mg/l Less than or Equal to 20

94
Parameters Unit Value
Chemical Oxygen Demand mg/l Less than or Equal to 100
Oil and Grease mg/l Tarces
Bacteriological Count mpn/ 100ml Less than 103

Figure 42 Treated Effluent Characteristics

The treatment system for the proposed ST P is as
follows:
 Primary Treatment
 Bar Screening: Large debris entering into the system prevented with a bar
screen installed
 Collection sump: The effluent from the bar screen chamber is let out into the
collection sump

 Secondary Treatment
 Fluidized Aerobic Bio Reactors (Phase I & II): The reactor is filled with high
quality self-supporting cylindrical shaped poly-Propylene. Bacterial growth is
generated by providing compressed air in the reactor and gets attached on
the PP media to form fixed film. Here the BOD, COD, organic pollutants get
digested easily
 Clarifier (Phase I, II): Treated water and sludge gets separated
 Tertiary System
 Disinfection: Sodium Hypo Chlorite is dosed before filtration for disinfection
 Dual media filtration: It is used as polishing unit for the removal of
suspended solids, color, odour, chlorine etc.

9.3.2.3 RECOMMENDED SEWAGE T REAT MENT PLANT

Since the sewage generated is of domestic nature and the cost of land is very high, fluidized aerobic bio reactor
system is considered as the primary and secondary treatment systems in order to optimize land usage at the
site. It is also proposed that the tertiary treatment system consist of lagooning followed by filtration with
chlorination for disinfection. Sludge handling system can consist of thickener and centrifuge. The thickened/ dried
sludge is recommended to be handled by the secured landfill/ composting facility.

9.3.2.4 EFFLUENT COLLECT ION AND T REAT M ENT SYSTEM

It is proposed to collect the industrial effluent from the polluting industry sub zones of the EZ through suitable
effluent networks and discharge into one location within the earmarked area for common effluent treatment
plant (CETP).

The tentative quality of the raw effluent is given below based on the available data from the industry. It is
expected that the treatment of the effluent shall meet “zero discharge” concept. The zero discharge concept
means no treated / non treated water and solid waste generated from the CETP should be let out to land /
drain / existing water sources or discharged to other areas. It is also envisaged that at least 85% recovery of
the waste water for recycling usage for the process industry will be achieved. The tentative raw effluent and

95
treated effluent characteristics are given below.
Parameters Influent
pH 10-11
Total Dissolved Solids (T DS), mg/l 6000-9000
Suspended Solids (SS), mg/l 150-300
Biochemical Oxygen Demand (BOD), mg/l 300-600
Chemical Oxygen Demand (COD), mg/l 1200-1700
Figure: 43 Raw Effluent Characteristics

The estimated quantity for yarn manufacturing industries is approx. 0.97 MLD and for fabric
manufacturing industries is approx. 0.88 MLD. Central effluent treatment plants of appropriate
capacities are therefore recommended for the corresponding industrial sub zones.
Treated effluent characteristics taken for setting objectives of design are given in the following
Figure.

Parameter Treatment
pH 7-7.5
Total Dissolved Solids (TDS), mg/l Less than 200
Suspended Solids (SS), mg/l Nil
Biochemical Oxygen Demand (BOD), mg/l Nil
Chemical Oxygen Demand (COD), mg/l Less than 10
Hardness, mg/l Less than 5
Turbidity, NTU Less Than 1
Oil & Grease, mg/l Nil
Figure 44 Treated Effluent Characteristics

The design criteria considered for the design of the effluent collection network have been
summarized in the following exhibit.

Demand 6.57
Working hours per day 24
Pipe material NP2 RCC for all areas except road crossing
NP3 RCC for road crossing
Pipe roughness coefficient 140
Peak Flow Factor 2.00 for contributory population up to 50,000
Formula used to calculate friction loss Hazen Williams
Infiltration 10%
Minimum self cleansing velocity 0.6 m/s
Figure 45 Effluent Collection & Transport Network Design Criteria

9.3.2.5 T REAT M ENT AND RECYCLING SCHEM E

The treatment scheme depends upon the raw water quality and also the technology provider. One of the
treatment scheme followed in the textile industry is pre-treatment followed by membrane treatment process.
T he tertiary treated water is recommended be used as non- potable water. Excess treated water is
planned to be disposed to the water body passing through the site, only after ensuring that the treated
water meets the required norms.
Since the treatment scheme depends on the treatment technology, it is proposed that a suitable party is
96
brought on board for design, detailing, fabrication, erection, testing, commissioning, operating and maintaining
of effluent treatment system for obtaining the treated water effluent quality from the raw effluent quality with
zero discharge concept.
9. 3 . 3 S O LI D WA S T E M AN A G EM E N T PLAN
Solid waste management system at the Sirajganj EZ site has been recommended so as to
reduce/recycle to the maximum extent and effectively manage/treat the solid waste at the site. The role of
integrated solid waste management is to reduce the quantity of solid waste disposed of to land by recovering
materials and energy from solid waste as depicted in Exhibit 63.
In order to maximize the utility of the solid waste management system, source segregation should be
made mandatory and due care should be taken while planning the collection, transportation of waste within
the EPZ area. Users should be asked to segregate their waste in the following categories and put in color
coded bins
 Bio-degradable waste
 Non-biodegradable waste other than industrial / hazardous
 Construction debris, street sweepings etc.
From the above, only bio-degradable waste & construction debris etc. can be treated with the
integrated solid waste treatment facility.
The entire solid waste at the Zone is planned to be collected and disposed off to the composting plant and
landfill site identified within the EZ. An area is earmarked for development of STP (sewage treatment plant),
composting plant and secured landfill within the EZ to handle the solid waste generated by the zone
operations. Since the non hazardous industrial waste and non biodegradable municipal waste are
expected to be relatively limited, it is proposed to dispose both the non hazardous industrial waste and
non biodegradable municipal waste in the secured landfill

Figure 46 Integrated Solid Waste Management Methodology

97
9. 3 . 4 T RAF F I C M AN AGE M E NT

Based on the traffic flow estimation carried out for the project site, the road design was developed. Further, in
the detailed design phase, the following practical operational aspects of traffic management were considered:
 Avoidance of direct intersection of major on site roads. For added safety;
 Incorporation of adequate green buffer along the roads, to ensure effective
usage of the sidewalks by the employees of the zone.
It is also recommended that ingress / egress points be set back at least 30 m from the road junction. The
Sirajganj EZ Authority should consider enforcing on street parking of containers and trailers along the major
roads. All design elements relating to landscape and signage are coordinated to reinforce a sense of harmony
for the Sirajganj EZ.
Large billboards for advertising should be discouraged. Reasonable dimensions for logo and / or company name
signs range between 3.0 m to a maximum of 6.0 m in length. The EZ Authority should establish a colour
scheme and a set of predetermined standard signage design guidelines, along with a set of street name
signboards, which will set the pace for the Sirajganj EZ.

9. 3 . 5 L AN DS CAP I NG/ GRE EN E RY

Extensive landscaping shall be one of the most important features of this EZ. A total of 100.35 acres of land is
designated for green space which meets the minimum requirement of 10%. Essentially, the public open spaces
within Sirajganj EZ are centered in the following locations:
Green landscaped zone at the entrance plaza
Green belts on the edge of the boundary
Green belts at selected pockets
Green belts around the water bodies
Green buffer all along the HT (high tension) power line
In order to create a high-quality built environment for people to work, in addition to the public parks and open
spaces, guidelines are recommended to be developed to ensure that there is sufficient greenery within the
individual factory plots in the respective industrial zone. Mandatory areas for landscaping and greenery
within the factory plots, facing the road are proposed. In the exhibit below, we present the proposed Greenery of
the Sirajganj Economic Zones area.
The greenbelt development/plantation in the Sirajganj EZ area will not only function as landscape features
resulting in harmonizing and amalgamating the physical structures of proposed buildings with surrounding
environment but will also acts as pollution sink/noise barrier. It will check soil erosion, make the ecosystem more
diversified and functionally more stable, make the climate more conducive and restore balance.

9. 3 . 6 OCCUP AT I ONAL HEA L T H & S AF E T Y M ANA GE M EN T PLAN

Sirajganj EZ Authority would be committed to protect the existing conditions of the surrounding
environment, health, safety and hygiene of employees, workers, Developers, and sub- Developers
within the project area during construction and operational phase on the basis of IFC/World Bank Guidelines as
well as code of practices will also be in compliance with GOB guidelines/requirements.

These guidelines apply to intermittent, temporary and permanent places of work and activities undertaken by
Developers’ workforce, suppliers’ people and employees of the Sirajganj EZ project.

98
An Occupational Health, Safety and Hygiene Management Plan/ System shall be established, operated and
maintained for overall project. It is the responsibility and duty of the employer to ensure healthy and safe
working conditions. A fully transparent OHSMP is a powerful tool towards fulfilling the objectives.
Meaningful participation by workers and employees is required for optimum results and these could be
obtainable through efficient awareness building and training program among the workers and employees

The initial system of assessment should include the needs for risk reduction and management
related to HIV/AIDS at the place of work. The contents of the OHSMP manual is prepared from ILO-
OHS 2001 and outlined in brief at below ;

1. Occupational Health, Safety and Hygiene Policy

Management’s supports and direction
2. Organizational Framework of the OHSMP (Safety Organization) Staffing of OHSMP
 Operating procedures
 Training program on all topics of OHSMP System documentation
 Communication
3. OHSMP Objectives
Realistic and achievable participation of all by supervision
4. Risk and Hazard Prevention
 Prevention and control measures
 Emergency preparedness/ awareness and response
 Procurement (tools, equipment, services Developers, etc.)
5. Performance Monitoring, Investigation and Reporting
 Hazards and natural calamities prevention measures
 Ambient working environment
 Work related injuries, ill health, diseases and on-going incidents
 On-going Medical and safety monitoring program for all workers and employees
6. Evaluation
 Feedback
 Corrective measures
 Action plan

In-line with the aforesaid salient features of management plan referred in IFC/WB guidelines, Sirajganj
EZ Authority has prepared their Action Plan Manual on the above subject.
In fulfillment of Commitment on execution of this particular project and in response to EIA Study,
Sirajganj EZ Authority will conduct its project activities in a manner so as to minimize environmental
and human health and safety impacts and to provide project area free from recognized safety hazards and risk
as far as practicable.

In addition to cited action plan, provisions will be incorporated in the operation policy manual for protecting
OHS, electric shock and hearing impairment to the workers/ employees, health and life insurance system to
be introduced in contractual agreement as per procedure laid down in DOE’s Rules of GOB and WB.
In fact Sirajganj EZ Authority will comply with all applicable safety, health and environmental laws and regulation
prescribed by Department of Environment (GOB) and IFC/World bank. The Authority will also monitor and
assess performance in Health, safety and environmental protection from major impacts.
The EZ Authority will also impart training needed for human, environmental and physical resources and project
protection.
The Authority always encourages timely communication of health, safety and environmental risks between
employees/workers and their Developer.

99
Subject matter statement within box-umbrella referred in Exhibit 65 reflects the expectation and requirement of
all employees, workers and Developers of the proposed project and they adhere to the adopted principles/
guidelines of OHSMS compliance in their performance of their respective job responsibilities.

9. 3 . 7 I ND US T RIA L R IS K S A ND CO NT INGE N CY PLAN

Potential sources of risks and emergencies to be envisaged during the operation of the
industries in the Sirajgain EZ are presented below.

Risks Emergencies
Fire & Explosion Emergency shutdown systems

Failure of key controls, of Fire-fighting devices

power sources or of services

Structural failures Emergency evacuation procedures

Work site injuries First aid equipment & personnel Specialist

medical treatment

Spills and unplanned release Systems and procedures for

of producer other materials preventing, mitigating & monitoring
environmental effects of emergency actions

Outbreaks of disease Procedures for communicating with authorities

relatives and other relevant parties
Impacts & collisions

Health risks from inhalation of

dust and particulate matter

Noise, odour, dust and vibration

9. 3 . 8 AP P ROPR I AT E C ONT I NG E N CY AND E M ERGE NCY RE SP O N SE M EA SU RES

The individual industrial concerns in the EZ should have the following:

 Alarm systems (Flame arresters, smoke detectors);
 Appropriate fire extinguishers (foam, water hydrants, dry chemical, sand, CO 2
etc.);
 Eye wash and showers, where appropriate;
 First aid equipment;
 Emergency shutdown systems;
 Oil/chemical spill cleanup systems; Emergency evacuation procedures
 A properly coordinated internal and external emergency
response teams;
 A well maintained internal and external communication system;
 Procedures for communicating with authorities relatives and other relevant parties;
Systems and procedures for mobilizing company equipment, facilities and
personnel; Arrangements and procedures for mobilizing third party resources for
100
emergency support.

For the Sirajganj EZ, it is imperative to have the following:

 A well equipped clinic to be manned by doctor and nurses; An ambulance;
 A fleet of firefighting equipment trucks including water hydrants, wheeled extinguishers
and portable hand extinguishers;
 Arrangements for training response teams and for testing the emergency systems
and procedures;
 Communications to other departments and agencies (Fire Brigade, local police
station etc.) with fire fighting and emergency response capabilities;
 Strategic sitting of water hydrants

101
CHAPTER # 10
ENVIRONMENTAL MONITORING AND INSTITUTIONAL DEVELOPMENT
10.1 M O NI T ORIN G P L AN

10 . 1. 1 GE NE RAL F E A T URES

Monitoring is a critical activity with respect to the implementation of the EMP for the Sirajganj EZ. T he primary
purpose of the monitoring plan is to ensure that the environmental objectives set during project preparation are
consistently achieved during project implementation. T he results of the monitoring plan will provide critical
information to influence decision-making during the construction and operation stages. It is expected to provide
information regarding the effectiveness of the mitigation and enhancement measures proposed within the
EMP and suggest further actions that need to be taken to achieve the desired results. Monitoring would include:
 Visual observations
 Selection of site specific environmental parameters;
 Sampling and regular lab analysis of the above selected parameters.

The prime objectives of monitoring are:

 To check whether mitigation and enhancement measures are actually
being adopted, and are proving effective in practice.
 To provide a method whereby impacts which were subjected to uncertainty
at the time of preparation of the EMP, or which are unforeseen, can be
identified and steps can be taken to adopt appropriate control measures.
 To provide information on the actual nature and extent of key impacts and
the effectiveness of mitigation and enhancement measures used on the
project
 To satisfy legal, safeguard and community obligations.

10.1.1.1 C O M P O N E N T S TO BE M ONI T ORED

Monitoring has the following two components:

 COMPLIANCE MONITORING, which checks whether prescribed actions have been carried out,
usually by visual observation and by the use of checklists.
 MONITORING OF EFFECT S, which records the beneficial and adverse consequences of activities
on the biophysical environment. This is often by repeat measurements of a set of objectively verifiable
indicators.

10.1.1.1.1 PRE-CONSTRUCTION STAGE C OMPLIANCE M ONITORING

Compliance monitoring during the pre-construction stage has three components:
 Checking that the project’s design incorporates appropriate measures to avoid or
minimize negative impacts
 Incorporation of appropriate protective clauses in the contract documents that are to be followed by the
Developer

10.1.1.1.2 CONSTRUCTION STAGE COMPLIAN CE M ONITORING

Compliance monitoring during the construction stage comprises:
 Developer’s compliance to the environmental clauses in their day-to-day activities.
102
 Implementation of site clearance activities after completion of work.
The environmental impacts during construction are highly dependent on:

 INCORPORAT ION OF MIT IGATING MEASURES identified in the EMP into bid documents
and specifications
 The Developer’s WORK PRACTICES, especially those related to the storage of
construction materials and cleanliness of the work sites;
 CO-OPERATION BY THE LOCAL AUT HORITIES with the Developer in terms of traffic management
and use of public space and utilities; and
 Project management teams’ strict enforcement of the CORRECT CONST RUCTION
PRACTICES and standards;

Direct monitoring during the construction phase will involve the following activities:

 REVIEW OF DEVELOPER’S PROPOSED DESIGNS and working methods including a

review at project start-up to ensure that the designs and working methods proposed by the
Developers have taken account of the environmental constraints specified in the tender
documents (geotechnical, ecological, safety etc).
 SITE- SPECIFIC REVIEW OF DEVELOPER’S TEMPORARY FACILITIES; involving the
inspection of Developer’s worksites and work camps to ensure that the Developer’s
arrangements regarding temporary facilities are satisfactory.
 REGULAR SIT E INSPECT ION during the construction period, involving scheduled and
unannounced inspections to ensure that the stipulated procedures as defined in the ESMF and
this EMP are being followed by the Developer(s). This monitoring will require the completion of
systematic observations of site activities using checklists to be developed by Sirajganj EZ
authority or the supervising consultants.
 INSPECTION OF T HE CERT IFICATE OF SITE CLEARANCE and restoration,
to ensure that actual restoration has taken place, e.g., the temporary works have
been adequately & appropriately disposed of etc.

The above monitoring system will be fully controlled by the EZ Authority.

10.1.1.1.3 OPERATION STAGE COMP LIANCE MONITORING

Operation compliance monitoring involves following

activities:
 Periodic monitoring and checking of the environmental parameters within the EZ
 Inspection of the individual units to check whether the units follow the prescribed
environmental norms or not.

103
10 . 2 I N ST I T U T I ONAL A RRA NG EM E NT

The implementation of the ESMP will be done by the project Developer in case of the project being
developed by a SPV. Otherwise, the present BEZA structure with an additional Environmental and Social
Cell and Resettlement Unit is recommended. T he organization structure for both the above
alternatives is shown in the exhibit below ;

BEZA/DEVELOPER

Project Director /GM

Sirajganj EZ

Supervision Consultant

Resettlement Unit Environmental & Social Developer

Cell

Resettlement Specialist Environmental

Specialist

Figure 47 : EMP Implementation and Organization Structure

The following key entities will be involved in the EMP implementation:

 Project Director/GM(Sirajganj EZ)
Environmental and Social Cell (ESC)
Resettlement Unit
The Supervision Consultant
Developer

104
10 . 2. 1 RO L E S AND RE SP O N SI BI L I T IES

The Project Director of the Sirajganj EZ with the assistance of ESC will be responsible for ensuring overall
compliance of safeguard measures and will be reporting to the regulatory bodies and donor agencies certifying
that relevant environmental safeguard measures have been complied with during the project implementation.
The Project director will undertake implementation of the environment measures and will conduct a periodic self-
audit. T he roles of others involved in the implementation of the EMP will be as follows:

10.2.1.1 E N VI R O NM E N T AND SOCIAL CELL

The ESC of will be responsible for effective monitoring of the EMP. For this purpose, provisions have been
made in the ESMF towards training for the capacity building of ESC staff. Its primary objectives would be as
follows:
 Ensuring implementation of the EMP throughout the project implementation period
 Ensuring integration of the EMP into the project design and implementation plans through bid
documents
 Monitoring implementation of the mitigation measures
 Assisting the construction engineers at site by providing appropriate environmental and social
compliance advice and solutions
 Preparing training materials and implementing program in collaboration with the supervision
consultant
 Preparing regular periodic progress reports on the implementation of the EMP
 throughout the project implementation period.
 Preparing budget and maintaining records of expenditure
 Maintaining a log of public complaints and the action taken
 Coordinating the process of environmental clearance for units

10.2.1.2 SUPERVI SION CONSULTANT

The supervision consultant will be appointed by the EZ authority and will liaise with ESC to ensure that the
Developer complies with the requirements of various environmental safeguard measures through supervision,
monitoring and reporting on the same. Efforts must be made by the consultant to ensure that environmental
mitigation and good-construction-practices are not only considered but actually implemented as integral
component of each civil activity. Implementation of environmental safeguard measures needs team effort and
the team leader will delegate the responsibilities to each member of the supervision team with respect to their
core responsibilities. Besides, the team leader of the supervision consultant will nominate a senior level
engineer for being directly responsible for implementation of stipulated safeguard measures, to establish
accountability. He will provide guidance to the field staff of the consultant and Developer for implementing
each of the activities as per the EMP. He will review Developer’s EMP, traffic management plan and
safety plan. He will be responsible for record keeping, providing instructions through the Engineer for corrective
actions, ensuring compliance of various statutory and legislative requirements and assist Engineer for
submitting reports to ESC. He will maintain a close coordination with the Developer and ESC for successful
implementation with the environmental safeguard measures.

10.2.1.3 DEVELOPER

To ensure that the EMP is properly implemented, Developer is required to nominate a Senior Engineer /
Manager as Environmental and Safety Officer (ESO) from the commencement to completion of the project. It is
recommended that the personnel to be nominated as ESO should have experience on implementation of
environmental and safety measures. The responsibilities of ESO will include the following:
 Discussing various environmental issues and environmental mitigation, enhancement and
105
monitoring actions with all concerned directly or indirectly
 Preparing EMP, traffic management plan and safety plan as part of their work Program
 Ensuring compliance with the EMP stipulations and conditions of statutory bodies
 Ensuring timely procurement of materials that are included in the Bill of Quantities relating to
environmental mitigation and enhancement measures
 Conducting periodic environmental and safety training for site engineers, supervisors and
workers
 Preparing registers for material sources, labour, pollution monitoring results, public
complaints and other issues
 Preparing monthly reports on the status of implementation of safeguard measures

10 . 2. 2 T RAI NI NG

The training program should equip the members of the Environment and Social Cell (ESC) and Resettlement
Unit, who will be directly involved in the planning, design and implementation of the project, to understand and
appreciate the ESMF requirements and to monitor the implementation of the project EMP.
It is recommended that an environmental orientation workshop is conducted. The purpose of this workshop
can be to discuss the environmental impact aspects as stipulated in contract, and the data collection,
implementation, best practices, supervision and reporting & MIS mechanisms. A follow-up training
program should be conducted for reviewing the implementation status, constraints, shortcomings etc. and to
improve implementation. It is also suggested that Developers are required to conduct routine training program
for their own staff to ensure that environmental and safety measures are complied with. A workshop for the
tenant units describing various environmental aspects is also recommended

10 . 2. 3 E NV I RONM EN T AL SP E CI F I CAT IO NS

Environmental specifications to be included in the technical specification of bid documents are

annexed to the report (Annex 5).

10 . 2. 4 M O NI T O R I NG PR OG RAM

The monitoring program for the various performance indicators of project stage wise is shown in
the following Figure.

106
Environmental Aspect Monitoring Parameter Frequency Location Responsibility
Implementation Supervision
Pre Construction Stage
Fisheries Study to Fish monitoring(5 km upstream and Once External ESC
establish baseline downstream) Consultant
Fish Catch monitoring
(surrounding area)
Katha ((pen Culture) fishing
Fish landing center (fortnightly)
Captive fisheries (Cage culture and
aquaculture
Limnobiological monitoring
Tree Removal Monitoring all prescribed mitigation During tree removal and site Developer ESC
measures in Mitigation Table clearance operations
Construction Stage
Surface Water Quality pH, Turbidity, Temperature, DO, Pre monsoon and Post monsoon Jamuna river and associate Developer ESC
BOD5, COD, TSS, T DS, oils and canal passing adjacent to
greases the SEZ area, bridge site
Pre monsoon and Post monsoon Tube well near
Drinking Water Quality pH, fecal coliforms, Fe, Chloride, construction camp Developer ESC
Arsenic
Air Quality SPM, SOx, NOx Pre monsoon and Post monsoon (8 Near Hot Mix Plant, near Developer ESC
hours continuous for two days) settlement area

107
Environmental Aspect Monitoring Parameter Frequency Location Responsibility
Implementation Supervision
Noise Level Measurement of noise dB(A) Quarterly (during day time) and Near residential area, Developer ESC
whenever any complain is received institutional area and ,
about disturbance due to silent zone within 1 km
construction noise from the EPZ boundary,
bridge site
River Erosion and Site Inspection Continuously Jamuna river and Developer ESC
siltation associate canal passing
adjacent to the SEZ
area, bridge site
Navigation Site inspection During monsoon Bridge site Developer ESC
Hydrology and flood Site inspection during flood Weekly during flood Jamuna river and Developer ESC
pattern associate canal passing
adjacent to the SEZ
area, bridge site
Occupational health Check of personal protective Weekly Construction Site Developer ESC/DoE
equipment (PPE) for workers at
the sites
Check if Health, First-Aid
facility, and staff trained in First Aid
are available at the sites Check if
medical checkup of
workers is on going
Operation Stage
Post Fisheries Same indicators as done during pre- During first year External ESC
Monitoring constructions Consultant

108
Environmental Aspect Monitoring Parameter Frequency Location Responsibility
Implementation Supervision
Industrial Effluent pH, Color, DO, BOD5, COD, TDS, TSS, Samples of effluent to be collected Raw effluent and Treated ESC Supervision
Oil & grease, heavy metals before it is entered into Effluent Consultant
(chromium, copper, cobalt, nickel, CETP and after treatment
zinc, cadmium etc.)
Domestic Waste Water pH, Turbidity, Temperature, DO, Before and after treated water Raw Sewage and Treated ESC Supervision
BOD5, COD, TSS, TDS, Coliform (Quarterly) sewage Consultant
count
Drinking Water Quality pH, fecal coliforms, Fe, Chloride, Monthly Treated water from WTP ESC Supervision
Arsenic Consultant

Noise Level Measurement of noise dB(A) Quarterly (24 hours) and Four corners of the site ESC Supervision
whenever any complain is boundary, at 200 m and Consultant
received about disturbance due 300 m from the following
to noise level locations: (i) residential, (ii)
institutional (school,
mosque), (iii) silent
(hospital) area
Air Quality SPM, SOx, NOx Quarterly (8 hours continuous for Boundary of the Generator, ESC Supervision
two days) and at 200 m and 300 m Consultant
from the following
locations: (i) residential, (ii)
institutional (school,
mosque), (iii) silent
(hospital) area

109
Environmental Aspect Monitoring Parameter Frequency Location
Responsibility
Implementation Supervision
Odour Sludge Annually and whenever any CETP and STP ESC Supervision
complain is received about Consultant
disturbance due to odour
problem
Land fill monitoring Landfill gas, Leachate, Odour Annually Landfill Site/Composting ESC Supervision
plant Consultant

Stack Emission SPM, SOx, NOx Annually (24 hrs average ) Boiler, Power Plant ESC Supervision
Consultant

Re-vegetation Program Select healthy sapling to confirm Quarterly As per Master Plan MEPZ ESC
(Green Belt) survival rate Authority
Monitoring plantation procedure
Growth
Figure : 48 Monitoring Program during Project Cycle

110
10.2.4.1 EFFECTS M ONIT ORING
The effects and results (beneficial/ adverse), arising out of the establishment of the EZ, should be monitored based on the
parameters described in the ‘Monitoring and Evaluation Framework’ in the ESMF. Parameters across seven components,
based on the sustainability framework, have been identified – these would help in efficient monitoring of impacts and
results.
It is understood that the Department of Environment (DoE) is under-staffed and is therefore not able to monitor and strictly
enforce the regulations. It is recommended that the supervision consultant appointed by the SIrajganj EZ Authority to
supervise/monitor the work of ESC on all the environmental aspects as detailed in the EMP.

10.2.4.2 L ABORATORY SUPPORT SERVICES

The EZ authority would require a well-equipped and on-site analytical laboratory with modern instruments. The laboratory
shall be used for routine physical and chemical analysis of liquid effluents and potable water. The laboratory shall also
observe gaseous pollutant discharge in connection with stack emission and air quality, noise level monitoring, quality and
quantity measurement and regular analysis of solid waste.
The EZ authority would require a well-equipped and on-site analytical laboratory with modern instruments. The laboratory
shall be used for routine physical and chemical analysis of liquid effluents and potable water. The laboratory shall also
observe gaseous pollutant discharge in connection with stack emission and air quality, noise level monitoring and
regular analysis of solid waste.

10 . 2. 5 REP ORT I NG SY S T E M A ND RECO RD K EE P I NG

The rationale for the reporting system is based on accountability to ensure that the measures proposed as part of the
Environmental Management Plan get implemented in the project.
Reporting system for the suggested monitoring program operates at two levels:
1) Reporting for environmental condition indicators and environmental management indicators
2) Reporting for operational performance indicators at the Project Director/GM
( Sirajganj EZ)/ESC level
Monitoring involves regular checking of the environmental management issues detailed in the ESMF and in this EMP and
to ascertain whether the mitigation measures are achieving their objectives with the progress of the works. It provides the
necessary feedback for project management to keep the program on schedule will still achieving the expected outcomes.
The Developer, Supervision Consultant and Project Director/GM (Sirajganj EZ)/ESC will operate the reporting system for
environmental conditions and environmental management indicators. The reporting system is presented Exhibit 69 to
ensure timely and effective implementation of the ESMP.

This reporting will be as follows:

 Reporting by the Developer to the SC
 Reporting by the SC to ESC
 Reporting by ESC for the information of all interested parties

111
ITEM Developer ESC and Supervision Donor BEZA
RU Unit Consultant

Implementation Supervision Reporting Oversee Report to Desired

to Project Compliance donor(s) Supervision
Director/ Monitoring
GM (EPZ)

Construction Stage
Initial Site Before the start Regular Quarterly Quarterly Half yearly
Observation of of work
construction
site and camp
Pollution As required As required Quarterly Quarterly After Half yearly
Monitoring Monitoring

Tree Cutting Weekly Weekly Monthly Quarterly Half Yearly Yearly

Operation stage
Pollution As per After T wice
Monitoring monitoring Monitoring during
program operation
phase
Green Belt Quarterly Half Yearly
Program Yearly

Figure 49 Reporting System

Record keeping is an important management tool for ensuring sustainable operation of the proposed project. Records should
be maintained for regulatory, monitoring and operational issues. Typical record keeping requirements for the proposed facility
is summarized in the following exhibit

Parameter Particulars
Waste Water  Daily quantity of treated sewage received
 Daily quantity of treated effluent disposed
 Quantity and point of usage of treated wastewater
 Result sheet of Treated Wastewater quality

Solid Waste Handling and  Daily quantity of waste received
Disposal  Daily quantity of treated and recycled waste
 Daily quantity of waste sent for landfill

Regulatory Licenses  Site Clearance and Environmental Clearance Certificate

(Environmental) from DoE

Monitoring and Survey  Records of all monitoring carried out as per the finalized
monitoring protocol
Accident reporting  Date and time of the accident
 Sequence of events leading to accident
 Chemical datasheet assessing effect of accident on health and
112
environment
 Step to prevent recurrence of such events
 Emergency measures teken

Figure 50 Typical Record Keeping Requirements

10 . 2. 6 E NV I RO NM EN T AL A U DIT
To assess whether the implemented EMP is adequate or not, annual third party environmental audits will be conducted.
These audits will be followed by corrective action plan to correct various issues identified during the audits.

10 . 3 I M P LE M EN T AT IO N SC HED ULE A ND C OST ES T IM ATES

10 . 3. 1 I M PL EM E NT AT IO N S CHE D ULE
The Following are the key activities, which are to be performed at different phases of the project, as
per the requirement of this EMP.
 Obtaining site clearance from DoE and approved T oR for Environmental Impact Assessment (EIA)
study
 Allocating budget for environmental management
 Engaging construction supervision monitoring consultants
 Nominating environmental and safety officer of Developer
 Review and approval of Developers’ EMP, traffic management and safety plan
 Finalizing site/s and layout plan for construction camp incorporating environmental requirements
 Tree removal
 Implementation of mitigation and enhancement measures
 Environmental Pollution Monitoring
 Training
 Re-vegetation (Green Belt) Program
The EMP implementation schedule, along with the responsibilities for each of the above- mentioned activities is annexed
with the report.
It is also recommended that environmental safeguard measures may be included as an item for pre-bid meeting so that
Developers can raise queries on the same, if any
10 . 3. 2 CO ST EST IM AT ES
The budget for implementing various activities and mitigation measures proposed in this EMP has been estimated and
the details are given in Exhibit 71. The total budget for implementing the EMP has been estimated as USD 0.42
million. T his EMP budget will form part of the total project budget. T he cost of environmental infrastructure
implementation such as traffic management, water treatment, sewage treatment, solid waste management, development of
green belt area are considered to be a part of the project itself and their costs have been included in the project
cost. Cost of environmental protection works, which will be implemented by the Developer, shall be considered incidental
to the corresponding item of civil work for which Bill of Quantities will be given in the bid document and no separate
payment shall be made.
Sl Budget Head Unit Amount Reference to Overall Project
No (Million Taka) Budget Head
1 ESC Operational Budget Part of the Sirajganj EZ
a. Staff Salary establishment budget
b. Transportation Cost
2 Baseline Fisheries Study
a. Preconstruction LS 10 Part of the Study

113
b. Post Construction (during first LS 8
year)
3 Environmental Auditing LS 1.00 Part of the Technical Audit
consultant Fees Consultancy Budget. Estimated
budget considered two audit
program (one for construction
period and one for operation)
4 Environmental Mitigation / Not considered. Will be Part of the
Enhancement Project Cost, Civil BOQ item cost,

5 Environmental Laboratory Set up LS 10.00 Part of the Environmental

including equipment procurement for management budget
Monitoring (including heavy metal)
(Laboratory consumables,
maintenance, vehicles and running
cost for 1 year, other machineries for
longer term)

6 Environmental and social T raining LS 2.00 Part of the overall T A / Training

budget
7 Stakeholder Consultation LS 1.00 Part of the overall T A
Total 32.00
Contingencies @ 10% 3.200
Total (in million Taka ) 35.20
Total ( in million USD ) 0.50
Figure 51 : EMP Budget

Currency Conversion rate: USD 1 = BDT 70 (Other environmental infrastructure costs have been considered
separately)

114
11 P UBLI C CO N SULT AT I ON
Public Consultation is a tool for managing two-way communication between the project sponsor and the public. Its goal is
to improve decision-making and build understanding by actively involving individuals, groups and organizations with a stake
in the project. This involvement will increase a project’s long-term viability and enhance its benefits to locally affected
people and other stakeholders.
As per the requirements of World Bank guidelines this consultation process is undertaken to seek opinions and
suggestions from various stakeholders that will provide inputs required to designing, construction and other implementation
related issues of Sirajganj EZ Project.
11 . 1 OBJE CT I VES
Engaging with stakeholders from the very initial stage – as a part of core business strategy – enables a proactive
cultivation of relationships that can serve as “capital” during challenging times and to confirm long term cooperation.
Key objectives of stakeholder consultation and participation at this stage of the project cycle and considering the community
situation were limited to:
Rapport Building
Understand the stakeholders attitude towards SEZ Project as well as perception and concerns
Disseminate information about proposed project interventions
Collect qualitative information on present livelihood system, extent of project affect and their views,
expectations and suggestions on livelihood restoration
Identify impacts issues that not been considered Develop
mitigation and design enhancement measures. Establish an
information discloser channel
Perceive ‘How communities expect Project authority in developing relationship and maintaining
throughout the project life’.
Priority and objectives also varied according to the stakeholders’ interest/stake with the Sirajganj
EZ Project.

11 . 2 I D EN T I F I CAT I O N OF S T AK EHOL DERS

Through a systematic process the following stakeholders have been identified for consultation.

Public Sector
Board of Investment (BOI)
Bangladesh Economic Zones Project
Bangladesh Export Processing Zone Authority (BEPZA)
Department of Environment(Department of Environment)
Deputy Commissioner, Sirajganj
Upazila Nirbahi Officer (UNO), Belkuchi and Sirajganj Sadar
District LA office , Sirajganj
Chairman and Word Members of Rajapur Union of Belkuchi Upazila
Chairman and Word Members of Saidabad Union of Sirajganj Sadar Upazila
Department of Fisheries
Department of Agriculture Extension
Private Sector
Word Commissioners, former Union Chairman and word members of the study area
Farmers, landowners, fishermen, Katha Fishing ground owner, and pond owner of the study area
PAPs of Saidabad and Rajapur Union
Non-Government Organizations
Local and national active NGOs of the study area ( MMS & NDP)
115
11 . 3 COM M UNI T Y CO NCE RN S O N P RO JE CT I N T E RVE NT I ON
The following exhibit summarizes only the environmental concerns/issues of surrounding communities that were
raised and discussed.

Issues Participants Discussion

Use of surface Villagers of Rajapur and The canal at the southern side of Dhaka-Sirajganj
water Saidabad UP Highway ( West site of Bangobondu Multipurpose
Bridge) the proposed area is being used as
source of drinking, bathing, washing water for
people of Saidabad Union .
The people of Rajapur Union using Jamuna river
fresh water as bathing, washing and agriculture.
They requested to keep the canal undisturbed
for their use, if it is disturbed, piped water
supply facilities to be provided though they are
living beyond the project boundary.

Affected people of the During construction and operation of the project people will have
Noise villages surrounding the to face noise pollution. The project will try to minimize the thing.
project

Proposed Gas During consultation, participants informed that authority of

Pipeline Village of Masumpur Porchimpnchall Gas company planed to construct a high
interception of the pressure gas pipeline from Sirajganj to proposed site which shall
site intersect the site at north-east. Sirajganj EZ authority should
take necessary action to revise the alignment of the proposed
gas pipe line immediately.

Compensation for Pond owners, Katha Ponds are on private land and Katha or Cage fishing practices
fish, pond and fishing and Cage fishing are in the river. People take lease space in the river from the
open water owners, boat men, GoB for Katha or Cage fishing. The pond owner will get
bodies. fishermen, laborers compensation for land, digging cost, fish stock etc. The Katha
fishing and Cage fishing will be paid compensation for the
existing fish stock and lump sum as business restoration grant.
The boatmen and wage laborers associated with the Katha
fishing will duly be paid grants as per policy of RAP. People
demanded open water bodies to be kept undisturbed so that
fishermen can earn their livelihood.

Figure 52 : Environmental concerns/issues of surrounding communities

11 . 4 F U T URE C O NS UL T AT I ON A ND D I SCL OS URE P L AN.

To encourage participation, regular consultations are planned with beneficiary communities to share project
related information and to provide a feedback mechanism for these communities to voice their concerns
and issues in all stages of the Sirajganj EZ project. BEZA will be responsible to carry out continued
consultation with and information dissemination to the key stakeholders.

116
117
12 C O NCL USI O N S AN D RE CO M M E NDAT I ONS

12 . 1 K E Y CON CLUSI O NS
Sirajganj EZ is located west site of Bangobondu Multipurpose Bridge , with an approximately distance of 130 km
from Dhaka and 10 km from Sirajganj. A land parcel spanning approximately 1035.94 acres has been identified by
BEZA for development of an EZ in the northern part of Bangladesh. The identified site is adjacent to the Dhaka-
Sirajganj highway, at the western end of Bangobondu Multipurpose Bridge.
This EIA report is a legal requirement for obtaining Environmental Clearance Certificate from the Department of
Environment (DoE) for implementation of Sirajganj EZ. The information and data presented in this EIA are based upon
the field visit Report and specific data obtained and gathered from relevant organizations/institutions, field survey and
public consultation meetings in the study area in line with the Environmental Guidelines for Industries published by
DoE of the GoB as well as the guidelines embodied in WB’s Environmental and Social Safeguards Policies.
On critical review of the potential environmental, the specific mitigation and monitoring measures proposed and
the benefits described, the project is not expected to lead to any long term irreversible adverse impacts on the
adjacent environmental quality and resources. The findings further suggest that major IECs adversely affected during
implementation of proposed EPZ would be: loss of water bodies, trees, hydrology/drainage, back water effect, erosion,
industrial effluent, pollutant emissions to air, noise / vibration etc. T he potential negative and long term problem
could arise if the new bridge is incorrectly sized leading to periodic catastrophic flooding and erosion. This could be
avoided by USING HYDRAULIC MODEL during the design process.
INDUSTRIAL EFFLUENT S FROM INDIVIDUAL PROCESSING UNITS COULD BE A MAJOR SOURCE OF
ADVERSE IMPACT associated with the operational phase of the proposed Sirajganj EZ. This may create long term
and irreversible effect to a certain degree on the receiving environment, if no mitigation measures are adopted. It is
recommended that all industrial effluents be collected and transported through concealed pipes to the CETP which
will ensure zero discharge treated effluent by way of recycling.
Traffic congestion is also expected to increase in the region. Therefore, construction of new roads and proper
traffic channeling and monitoring would be required to ease the congestion. The proposed EZ is also expected to
provide foreign exchange earnings by promoting traditional exports; provide jobs to alleviate unemployment or
under employment problems in the country and assist in income creation, attract foreign direct investment (FDI) that
would act as catalysts for domestic entrepreneurs to engage in production of textile goods and Multi Products.
Most of the potential impacts are expected to be short-term and minor in nature. Therefore, the anticipated adverse
effects could be controlled/minimized or eliminated through adoption of suggested mitigation measures and
implementation of the Environmental Management Plan during construction, operation and maintenance phases of the
project.
Since the Project sponsor, namely BEZA, shows a positive approach towards environmental management and safety
standards in-line with their environmental policy and management plan, it is expected that Sirajganj EZ will
provide necessary resources to the proposed Environmental and Social Cell (ESC) such as proper technical
personnel to make the ESC an accountable and responsible institution for successful implementation of the
recommended EMP.

In the view of keeping surroundings of the project environmentally friendly, the Sirajganj EZ authority should ensure
the practice of proper implementation of an Operation and Maintenance Manual together with an
Environmental Pollution Abatement and Mitigation Measures Plan, regular and effective monitoring of
environmental quality parameters as indicated in this EIA report. The amount of residual environmental damage due
to the project would be directly related to how well the EZ authority meets its environmental responsibility, and how it
uses the EMP and enforces the Developers’ compliance with the EMP and the monitoring program.
However, no development project could be expected without any adverse impact on environment
aspects. The beneficial impacts on the nation as well as human beings would only be meaningful and the
development would only be sustainable if the impacts are minimized through proper management and taking
appropriate control measures as proposed and recommended for this project. All this would need extreme care and
118
subsequent monetary involvement, and EZ authority should take these into consideration.

Finally, having reviewed all the potential environmental impacts and following the recommended
mitigation measures as per this EIA, it is expected that the proposed EZ with operate within the internationally
accepted environmental norms.

12 . 2 REC OM M EN DAT I ONS

Based on the above study, the following recommendations are made:

 The open water bodies should be kept intact so that fishermen can earn their livelihood from the river
as they are doing now
 In light of the loss of water bodies currently being used by the surrounding communities for water
consumption, it is proposed that alternate source of water be developed by the BEZA outside the project
boundary for this purpose
 Detailed baseline fisheries study will be necessary to evaluate exact impact on fish and fisheries resources
within and adjacent demarcated area
 Mathematical and physical modeling study to be conducted at the Sirajganj EZ site to confirm the
hydrological and flood impact during the detail design stage

 Immediately after commencement of acquisition process, the EZ authority should apply to the Department of
Environment for a SITE CLEARANCE CERTIFICATE by submitting IEE report and approval of ToR for EIA
Study

 BEZA to facilitate design, detailing, fabrication, erection, testing, commissioning, operating and
maintaining of EFFLUENT TREATMENT SYSTEM for obtaining the treated water effluent qual ity from
the raw effluent quality with zero discharge concept
 Sirajganj EZ authority and DoE should MONITOR THE ENVIRONMENTAL COMPLIANCE of
 EPZ on a regular basis and in accordance with the ESMF & ESMP

 Textile and dyeing industries should ADOPT ENVIRONMENTALLY RESPONSIBLE PRODUCTION

TECHNIQUES
 It is also recommended that environment compliance issues are INCORPORATED UPFRONT INTO THE
CONTRACTUAL DOCUMENTATION while issuing licenses to operate within the zone

119
CHAPTER # 11
Social, Gender and
Resettlement Issues

120
1.1.1 I NTRODUCTION

Social and gender aspects and resettlement issues are crucial in the planning and implementation of any
development project. On the one hand, EZs require land acquisition which will cause loss of property, homestead
and livelihood sources and on the other hand they will provide significant opportunities for economic
activities, commerce and trade. These are likely to have an impact on landownership, poverty issues, food security,
economic status, social status and gender relations. T he social and gender aspects and the resettlement issues
presented here, cover the impact of the proposed EZ on the EZ itself and on adjacent areas. T hese are based on
the current socio-economic scenario of the locality and take into account whether the proposed project is going to
affect lives, livelihoods, structures, institutions, historic sites, ethnic and religious minority people and resettlement
matters of the displaced population for the proposed EZ.
1.1.2 METHODOLOGY
 Review of relevant documents and data including World Bank policies related to social, gender and
resettlement aspects and the Bangladesh Government Acts.
 Meeting with concerned agencies.
 Reconnaissance field visit.
 Public consultation within the project area and adjacent areas.
 Preparation of the review report including secondary and primary data and incorporation of feedback.

1.1.3 SECONDARY DATA COLLECTION AND LITERATURE REVIEW

The literature review is carried out to identify the current socio-economic scenario of the EZ and adjacent areas
and the Project Affected People (PAP). This will provide the basis in formulation of the RAP (Resettlement Action
Plan). However during the feasibility stage, a further review will be conducted on social, economic and legal issues
relevant to the project.

The following activities have been undertaken:

 Data were collected from secondary sources comprising demographic composition, occupational status and
sources of livelihood, educational status, household structures, and access to basic physical facilities.
 An assessment of all legislation including World Bank Policies and those of the Bangladesh
 Government was done.
 A list of social, cultural, religious and academic institutions and sites was done.
 An information gap analysis and identification of the areas where further field work was done.

1.1.4 DONOR POLICIES AND ACTS AND REGULATIONS OF BANGLADESH GOVERNMENT

The World Bank's environmental and social safeguard policies: The World Bank's environmental and social
safeguard policies were analyzed. These are a cornerstone of its support to sustainable poverty reduction. The
objective of these policies is to prevent and mitigate undue harm to people and their environment in the
development process. T hese policies provide guidelines for World Bank and borrower staff in the identification,
preparation and implementation of programs and projects.

Safeguard policies have often provided a platform for the participation of stakeholders in project design and
have been an important instrument for building ownership among local populations. T he following policies and
legislation were reviewed:

 World Bank OP 4.12 Requirements for Involuntary resettlement

 World Bank Gender Policy: OP 4.20 - Gender and Development (Revised March 2012)
 Specific Funding Requirement of the World Bank Policy OP 4.10.
 World Bank policy on Physical and Cultural resources: OP4.11
 Bangladesh Government Acquisition and Requisition of Immovable Property Ordinance, 1982

121
1.1.5 PUBLIC CONSULTATION IN PROJECT AREA AND ADJACENT AREAS
A participatory approach is an essential part of projects dealing with development in order to ensure sustainable
development. Participation of local people and other stakeholders enables different socio- economic interest groups
in enhancing their capabilities to play an effective role in development initiatives. It also ensures commitment and a
sense of ownership of various stakeholders beyond local people and direct project beneficiaries. Government
agencies, people’s representatives, professional groups and voluntary groups including NGOs and community-
based organizations, could be actively engaged to share responsibility in key decisions. It also enriches
project planners with local/indigenous knowledge.

1.1.6 FIELD VISIT TO THE SIRAJGANJ EZ

Meetings were held with the DC at the Sirajganj District and Bulkuchi and Sirajganj Sadar UNO and other
government officials, Upazila chairman of Sirajganj Sadar , Belkuchi in Sirajganj Sadar UNO office.

Consultations were conducted with local people including homestead owners, private land owners, fishermen,
shopkeepers and restaurant owners and workers, women, school going children and local small traders.

Table 4.2.2.3-1: Consultations at site

Date Stakeholders Location No of persons
2th July 2013 Interviews with the DC and Sirajganj 4 Person
ADC and other District
government officials
25th July 2013 Youth, students, fishermen, Rajapur UP 26 fishermen, 3 van pullers, 9
van pullers, shop owners shop owners, 18 youth
29th July 2013 Affected households. Nakkata 17 homestead owners’ place,
Government 18 children in the adjacent
Primary School area, 2 women

11-14 February, Youth, students, fishermen, Saydabad Union Several spot discussions
2014 van pullers, shop owners, with
Affected households. many locals and to be
affected people in their
11-14 February, Survey on population homestead
Affected area by DC Whole areaand shops
covered
2014 composition, HH, & shops office
structures, institutions,
ponds, trees
15-20 May, Survey on population Affected area by DC Whole area covered
2014 composition, HH, & shops office
structures, institutions,
ponds, trees
1.1.7 BACKGROUND, GEOGRAPHIC AREA AND LOCATION

Sirajganj district was formerly a sub-division of Pabna zila. It was made full-fledged zila as a part of up-gradation
programme of Sub-divisions to zilas. During the reign of Nawab Alivardi Khan Sirajganj became the commercial
centre of Bengal. He flourished this commercial centre further for steady supply of papers to different parts of the
country by transferring a group of highly skilled people in making hand-made papers (generally known as Tulat
kagas) from central Asia to this place. Their descendants are still in Kalia and Kandpara mauzas adjacent to
Sirajganj town. He also gave the name of this place as “Sirajganj” after the name of his beloved grandson
Sirajuddowla, the last independent Nawab of Bengal.

122
The zila is bounded on the notrth by Bogra zila, on the east by Tangail and Manikganj zilas, on the south by
Manikganj and Pabna zilas and on the west by Natore and Bogra zilas. It lies between 24º01’ and 24º47’ north
latitudes and between 89º15’ and 89º59’ east longitudes. The total area of the zila is 2,402.05 sq. km.

1.1.8 ANNUAL AVERAGE TEMPERATURE

Maximum 34.6°C, minimum 11.9°C; annual rainfall 1610 mm.

1.1.9 MAIN RIVERS

Jamuna, Baral, Ichamati, Karatoa and Phuljuri. About 10% area of the CHALAN BEEL is located in the TARASH
upazila of this zila.

1.1.10 ARCHAEOLOGICAL HERITAGE AND RELICS

Tomb and mosque of Khawja Pir Saheb of Enayetpur (Chauhali), tomb of Hazrat Abdul Ali Baki Shah Sharif Jindani
(R) of Naogaon (Tarash), homestead of Behula (Tarash), Shiva Mandir (Tarash), Rabindra Kuthi Bari (Shajadpur),
Akhra of Sri Sri Maha Pravu, Gopinath Bigraha, Kalika Devi Bigraha, Joysagar (Raiganj), Protap Dighi (Raiganj),
Elliot Bridge or Lohar Poll (iron bridge, built in 1893), Makkahaulia Mosque (fifteenth century, Ullahpara), Nabaratna
Mandir (Ullahpara).
Historical Events: In 1922, many people were killed and wounded when police opened fire on an assemblage of
people gathered at Salanga Hat (as a part of the Khelafat and non cooperation movement) under the leadership of
Maulana Abdur Rashid Tarkabagish. This is known as Salanga Movement or 'Salanga Genocide'. In 1942
Mohammad Ali Jinnah came to Sirajganj to attend the All India Muslim League Conference; Mahatma Gandhi and
Subas Basu came to Sirajganj to attend the convention of the Brahmo Samaj in 1928. The Hindu -Muslim Pact of the
Swaraj Party, headed by Deshbandhu CHITTA RANJAN DAS, was adopted in the Conference of the All India
Congress Party held in 1924 at Sirajganj. National Poet KAZI NAZRUL ISLAM came to Sirajganj in 1932 to preside
over the Conference of the Tarun Muslim. AK FAZLUL HUQ laid the foundation stone of Sirajganj Degree College in
1940. During the War of Liberation a battle was fought between the freedom fighters and the Pak army at Naogaon
of Tarash upazila in which the Pak army was defeated and about 150 members of the Pak army were killed. During
11 to 14 December a battle was fought between the Pak army and the freedom fighters at Shailabari in which Pak
army was defeated. Sirajganj was liberated on 14 December 1971.

1.1.11 MAIN CROPS

Paddy, jute, wheat, mustard seed, sugarcane, onion, garlic, potato, sweet potato, chilly and ground nut. Extinct or
nearly extinct crops Indigo, tobacco, local varieties of aus paddy, china, kaun, varieties of dal (pulse).

1.1.12 MAIN FRUITS

Mango, jackfruit, black berry, papaya, guava, coconut, palm, date, olive, bel, tetul and banana.

1.1.13 INFORMATION ON SIRAJGANJ AND THE EZ AREA

The following section provides the current socio-demographic and economic conditions of the people of the EZ
area of Boyra Masum and Baro Beruakarua Mouza of Rajapur Union of Belkuchi Upazila and Khasbaroshimul,
Chockboyra, Birhati, Saydabad and Ponchoshona Mouza of Saydabad Union of Sirajganjg Sadar Upazila

The EZ is a small part of the Boyra Masum and Baro Beruakarua Mouza , Khasbaroshimul, Chockboyra, Birhati,
Saydabad and Ponchoshona Mouza and population density in this part is much less compared to the Mouza’s
overall population. The EZ covers government land and part of the adjacent area Jamuna River. From the
consultation with local people during the field visits, and the field survey it is found that 815 households (HH)
will be affect and that the number of people living in the proposed EZ area is 4000 The survey covered a l l
o f M o u za b u t some portion of these wards may not fall under the EZ as they live in fringe too, thus
number of real affected households and people may be less. During the site visit, it appeared that they are
among the most poverty stricken families, mostly fishermen or old aged people once were involved in
agriculture in field and living in ‘kutcha’/ Tin shed houses.

123
Figure 4.2.3-1: Conceptual Diagram Showing EZ Location in Sirajganj District

Sirajganj District

Belkuchi
Sirajganj
Upazila
Sadar
Rajapur UP Saydabad Khasbaroshimul,
Chockboyra, Birhati,
Boyra M asum and Baro UP
Beruakarua M ouza Saydabad and
Ponchoshona Mouza

The socio-demographic data in this section presents details of the EZ area to provide an idea of the locality
and the people who will be effected by the proposed EZ.

Table 4.2.3-1: Land distribution of Sirajganj EZ

1. Existing land 1041.43 Acre

2. Private land 55.50 Acre
3. Public land 985.93 Acre

1.1.14 AT A GLANCE BELKUCHI UPAZILA

BELKUCHI UPAZILA
CENSUS RESULTS AT A GLANCE Items Zila Upazila
2011 2001 2011 2001
Population (Enumerated)
Both Sex 30,97,489 26,93,814 3,52,835 3,02,678
Male 15,51,368 13,97,863 1,79,738 1,60,265
Female 15,46,121 12,95,951 1,73,097 1,42,413
Urban 3,76,432 2,29,106 75,364 0
Other Urban 60,145 92,147 0 20,328
Rural 26,60,912 23,72,561 2,77,471 2,82,350
Annual growth rate 1.38 1.76 1.52 2.13
Sex Ratio
Total 100 108 104 113
Urban 103 110 108 0
Other Urban 99 111 0 119
Rural 100 108 103 112
Households (HH)
Total 7,14,971 5,62,708 74,450 57,666
Urban 84,287 46,953 16,229 0

124
Other Urban 14,887 19,490 0 3,748
Rural 6,15,797 4,96,265 58,221 53,918
Average HH Size
Total 4.31 4.78 4.72 5.30
Urban 4.39 4.86 4.60 0
Other Urban 4.01 4.69 0.00 5.30
Rural 4.31 4.78 4.75 5.21
Area sq. km 2402.05 2497.92 158.87 164.29
Area sq. mile 927.43 964.45 61.34 63.43
Density per sq. km 1290 1842 2221 1842
Density per sq. mile 3340 4771 5752 4771
Urbanization (% ) 14.09 11.93 21.36 6.72
Literacy (%)
Both Sex 42.1 40.6 45.7 47.0
Male 45.1 45.5 48.2 51.5
Female 39.0 35.4 43.1 42.0
School Attendance (5 to 24 years) (%)
Both Sex 50.5 41.7 46.7 42.3
Male 53.5 45.1 47.5 43.2
Female 47.6 38.2 45.9 41.3
Population (Adjusted)
Both Sex 32,20,814 28,18,278 3,67,337 3,16,255
Male 16,13,173 14,62,455 1,87,137 1,67,452
Female 16,07,641 13,55,823 1,80,200 1,48,803
Geographic Unit
Upazila/Thana 9 9 - -
Union 82 79 6 6
Mauza 1,300 1,467 94 108
Village 2,016 2,024 131 143
Paurashava 6 4 1 0
Paura Ward 60 42 9 0
Paura Mahalla 160 117 14

Area and Location: The upazila occupies an area of 158.87 sq. km. It lies between 24°13' and 24°22' north latitudes
and between 89°37' and 89°47' east longitudes. The upazila is bounded on the north by Kamarkanda upazila, on the
east by Tangail Sadar and Kalihati upazilas of Tangail zila, on the south by Shahjadpur and Chowhali upazilas and on
the west by Ullahpara and Kamarkhanda upazilas.

1.1.15 AT A GLANCE SIRAJGANJ SADAR UPAZILA

Items Zila Upazila

2011 2001 2011 2001
Population (Enumerated)
Both Sex 30,97,489 26,93,814 5,55,155 4,84,170
Male 15,51,368 13,97,863 2,79,113 2,53,050
Female 15,46,121 12,95,951 2,76,042 2,31,120
Urban 3,76,432 2,29,106 1,58,913 1,28,144
Other Urban 60,145 92,147 8,287 7,007
Rural 26,60,912 23,72,561 3,87,955 3,49,019
Annual growth rate 1.38 1.76 1.36 2.21
Sex Ratio
Total 100 108 101 109
Urban 103 110 102 109
Other Urban 99 111 105 113
Rural 100 108 101 109
Households (HH)

125
Total 7,14,971 5,62,708 1,25,485 99,769
Urban 84,287 46,953 35,556 26,525
Other Urban 14,887 19,490 1,886 1,423
Rural 6,15,797 4,96,265 88,043 71,821
Average HH Size
Total 4.31 4.78 4.38 4.85
Urban 4.39 4.86 4.37 4.81
Other Urban 4.01 4.69 4.38 4.84
Rural 4.31 4.78 4.39 4.86
Area sq. km 2402.05 2497.92 320.15 325.78
Area sq. mile 927.43 964.45 123.61 125.78
Density per sq. km 1290 1842 1734 1486
Density per sq. mile 3340 4771 4491 3849
Urbanization (% ) 14.09 11.93 30.12 27.91
Literacy (%)
Both Sex 42.1 40.6 48.0 47.4
Male 45.1 45.5 50.1 51.0
Female 39.0 35.4 45.8 43.6
School Attendance (5 to 24 years) (%)
Both Sex 50.5 41.7 54.3 41.6
Male 53.5 45.1 57.0 44.2
Female 47.6 38.2 51.7 38.9
Population (Adjusted)
Both Sex 32,20,814 28,18,278 5,78,583 5,07,722
Male 16,13,173 14,62,455 2,90,897 2,65,355
Female 16,07,641 13,55,823 2,87,686 2,42,367
Geographic Unit
Upazila/Thana 9 9 - -
Union 82 79 10 10
Mauza 1,300 1,467 187 217
Village 2,016 2,024 294 299
Paurashava 6 4 1 1
Paura Ward 60 42 15 15
Paura Mahalla 160 117 50 52

1.1.16 Total number of Household, population and structure of residence

Name of area Total Total Village Mouza Bazar

HH population
Rajapur UP 6945 47596 33 5 2
Saydabad UP 7426 31460 37 05 2
Total 14371 79056 70 10 4

1.1.17 TOTAL NUMBER OF INSTITUTIONS IN EZ AREAS

Institution type Educational Institutions Religious Institutions Social Graveyard

Institute

Primary High Collage Madras Mosque Temple Church Pagoda

School school a s

No 2 - - 1 2 1 2

1.1.18 TYPE OF OWNERSHIP OF LAND

(i) Water bodies, Baluchar (sandy islands): the major part of the water body belongs to the
government and only a very small area of such land belongs is in private ownership
126
(ii) All lands are compensated at double the current market price. Compensation for homesteads will be
twice the current market price. Actual current market price of trees will be provided.
For livelihood loss, payment for sources of income and relocation costs will be provided

Due to the location of the Sirajganj EZ, the population of Sirajganj district will be benefit from the high number of
industrial jobs created there

1.1.19 POPULATION OF RAJSHAHI DISTRICT AND DIVISION

 Population in Sirajganj District: 7,616,352 (male-3,838,854, female-3,777,498)

 Population living in rural areas in Sirajganj : 4,463,723

 Population in Rajshahi Division: 28,423,019 (Male: 1, 39, And 33,314, female: 14,489,705)
 Population living in rural areas: 21,517,539
Due to the location of the Sirajganj EZ, the population of Sirajganj , Tangail, Pabna, Natore and Bogra districts will
benefit from the high number of industrial jobs created there.

2.0 SOCIO-ECONOMIC BACKGROUND OF PROPOSED SITE

2.1 POPULATION DISTRIBUTION

For a better understanding of the Union and locality the following section provides information on Rajapur and
Saydabad UP . In Rajapur of Belkuchi and Saydabad of Sirajganj Sadar Upazila, the total number of households is
14371 with a total population of 79056. Maximum number of people ara floating population in the proposed
project area . T he population density (per sq.km) in the Union is 2221.The following population composition and
information on the households are based on the Union population.

2.2 POVERTY INFORMATION

There is no data directly indicating poverty in the latest Census. But the data on occupation, education and
household types are presented to give an idea of the socio-economic condition of the locality.
From these variables, the area seems impoverished and very few well-off families live in the proposed area. But in
the Upazila there are several structures and buildings and institutions which are presented in the report.

2.3 THE NUMBER OF PEOPLE NOT ATTENDING SCHOOL

More than 20 % of the population aged 7 and above, which is not attending at school . Thus, employment of
parents is expected to contribute to higher attendance of children, including girls, at schools and overall higher
education for all.

2.4 EMPLOYMENT STATUS

There is a huge gap in male-female employment. In the job seeking category 93 are males and 44 are females.
Most of the women are involved in household work.

2.5 WOM EN’ S EM POW ERM ENT

Since women are mostly in the household work category. T hus, employment opportunities for women
created by the proposed EZ, directly or indirectly, in Sirajganj is expected to provide them with a better socio-
economic status and empowerment.

127
2.6 OCCUPATION

Table 4.2.5-3: Field of Activity by the People Living in the EZ

Among the employed population, 474 males and 37 females work in agriculture. In fisheries 40 males and 23
females are employed. 37 males and 2 1 females work in the service sector. T he employment status clearly
shows that the majority are dependent on agriculture related activities. Fewer than 100 people are involved in
industry, an insignificant percentage of the population.

During consultation with local people, it appears that as a whole, in terms of occupation, this is a predominantly
fisheries based area.

2.7 HOUSEHOLD STRUCTURE

Most of the houses are kutcha (76.4%) followed by Jhupri/ straw-shed (16.3%). Only 3.2% are pucca and 4.1% semi-pucca.

2.8 SANITATION FACILITIES

Sanitary water sealed toilets: 5.2%; Sanitary non water sealed toilets: 41.6%; non-sanitary toilets:
47%, no toilets: 6.1%.

The household pattern, sanitation facilities and behaviour show a grim picture of poverty in the proposed EZ area.
The majority of the population (around 83%) live in kutcha and temporary straw- shed houses. People using
sanitary toilets is only 5.2%. Due to the sea-side location, salinity is also a problem for pure drinking water.

2.9 TOTAL NUMBER OF STRUCTURES

The socio-cultural institutions of Sirajganj Sadar and Belkuchi Upazila , Rajapur and Saydabd UP are presented
below. Though the proposed EZ area is part of the Rajapur and Saydabd UP, not all of these institutions fall under
the EZ proposed area, thus the number of affected institutions is less than these. Therefore, an inventory and
population census is done in the area which is presented in earlier section.

a. Homestead: T he number of total households in project area about 875, the total population is
4730. During consultation, we were informed that the proposed EZ area will be in the seaside area where
the population concentration is very low and around 574 HH will fall under the EZ area. People living in
these households will be affected and will need resettlement and compensation. The houses are scattered
and mostly kutcha .

b. Business centres, bazaar, shops etc.: T here are also a few shops and restaurants which are mostly small and
kutcha and tin-sheds. T here are a few trees around the homestead and the roadside bust mostly small and
newly planted. In the resettlement compensation package, all of these are included. Details of these are
provided in the budget analysis section of this report.
c. Primary Schools: 2
d. Mosques: 2
e. Dakhil madrashas-1
f. Forkania madrashas-1
g. Health centres: None in project area
k. Graveyards: 1
l. NGOs: MMS , NDP , Shushilan has micro-credit and awareness raising programs.

Although in the consultations during field visits, local people, mentioned no higher academic or social institutions
within the EZ area, the UNO of Sirajganj Sadar and Belkuchi provided the list of institutions in Rajapur and
Saydabd UP. If any academic or religious institutions fall under the EZ area, proper compensation and replacement
cost will be provided after consultation of local authorities and local residents.

128
2.11 OVERALL SOCIAL IMPACT

Regarding social indicators, the following are likely to have impact on the social lives of the local population
due to EZ:

Table 4.2.8-1: Overall Social Impacts with Strategies for Mitigation

Issues Impact Strategies for Risk mitigation

Poverty Through industrialization and related trades, Skill training programs by relevant
Alleviation and diversification of livelihood will occur for all Government agencies and
Diversification in strata of people. Diverse livelihood option for the NGOs will be needed for efficient
livelihood locals and better wages for the employees of the utilization of this huge manpower.
industrial zone will reduce poverty for many poor
households and will contribute to reducing the
poverty level in the locality.
This EZ will have garments , spinning , and
knitwear will create approximately 1,72,000
workers (374 workers per hectare).

Food security With increased income the families will be able to Better livelihood options and food
ensure food security for themselves. As current security should be ensured for the
earnings are not enough for the small farmers and 815 HH s who will be displaced and
fishermen to ensure food security for their families the most impoverished fishermen’s
or a standard livelihood, they prefer a better families.
livelihood and secure earning options. Preferences of the males and
females of displaced HHs in job
opportunities created by the EZ.
Issues Impact Strategies for Risk mitigation
Awareness and Better access to health facilities and better Issue of health hazards caused
accessibility communication and access to health services is by the EZ industries to be identified.
regarding health: expected. Housing patterns and WATSAN If there is any, steps need to be
behaviour which is very poor at current stage are taken to prevent and minimize
expected to be much better due to affordability of such
better housing, sanitary toilets and attitudinal hazards
change due to increased earning and industrial .
zone lead urban atmospheres.
Education for Due to the establishment of the EZ and better During construction and until the
children economic changes in the locality, the child EZ becomes operational, children’s
including Girls’ education rate is likely to increase leading to a safety needs to be ensured.
Education Local community needs to be
reduction in children’s informal or agriculture based
labour. sensitized and NGOs can be
engaged with them.
Access to civic Civic life for the overall communities will be 815 HHs will be displaced,
amenities and better due to the modern facilities and better compensation package should be
communication communication. Industrialization will ensure better ensured to be sufficient for a better
livelihood and increase ability to access better livelihood and living.
civic facilities. However, due to the EZ
construction overall traffic may be congested over
the years.
Social mobility With improved employment opportunities and Special compensation package or
increased and secured income, priorities in job opportunities for the
impoverished people will be able to move up to the most impoverished needed so that
social ladder. they don’t become more vulnerable
due to higher income level of
others.
129
Women’s Women are mostly in household work category. Measures should be taken to
empowerment Thus, employment opportunities for women ensure
created by the proposed EZ directly or indirectly women of the households who are
are expected to provide them with better socio- losing livelihood opportunities do
economic status. Through employment; women not face vulnerable situations of
will be empowered economically by being self- losing livelihood options of their
reliant and may become more socially aware. This HH head or themselves.
could lead to their having more decision making
power in their respective families and
communities.
This will also encourage the parents to send their While dealing with land transfer and
children to schools and withdraw them from wage compensation, the gender issue
earning activities. At the same time girl’s should be taken care of sensibly as
education due to parents’ better economic women in Bangladesh do not
condition and awareness will prevent early and usually possess land in their names
child marriage as girls’ education will but in the male household members’
automatically retain them in school increasing names. If cash compensation is
social awareness and reducing pressure marrying given, it could be also in joint
them off at an early age. account transfer, so women are not
deprived of any benefit and also do
not bear the loss alone. With female
headed households, a special
package canofbemales
Preferences provided.
and females in
job opportunities created by the EZ.

At the macro-level, employment opportunities, social and economic commitment of development efforts and
public-private partnership will be the outcomes of the project.
More detailed consultation at the EZ site and adjacent areas may be needed to assess detailed socio- cultural
effects.
2.12 RESETTLEMENT ISSUES AND PLAN
The policy objective conforms to that of the government, to reduce poverty and meet the Millennium Development
Goals (MDGs). The basic policy is to avoid land acquisition as much as possible. The guiding principles are:

to minimize and mitigate adverse impacts;

to ensure compensation payment according to the World Bank OP 4.12 and GoB rules and
regulations;
to establish a grievance redress mechanism with representatives from stakeholders to suggest
institutional and monitoring arrangements for compensation payment.

2.13 PEOPLE LIKELY TO BE AFFECTED

The people who will be removed from their homesteads will have to be provided with financial compensation as
there is no government fallen/khas land available near the site or in the Upazila. It is not possible to accommodate
these people within the EZ site due to shortage of land.

All lands are compensated by double price of current market price. Compensation for homesteads will be 2 times
current market price. Actual current market price of trees will be provided. For the livelihood loss, payment for
sources of income and relocation costs will be provided. The private land owners will be compensated according to
standard provisions.

The proposed industries here are Garments and Knitwear industries, requiring huge number of workers at
different levels. This EZ will have garments , knitwear’s , spinning and textile and will create 172,000 workers
(374 workers per hectare). As the EZ will provide job opportunities with standard wages, the overall population,
including the poor population, will benefit from that immensely. T he project can make provision the affected farmer,
small businessman, labourers to be given priority in employment and recruitment in the EZ, so that a better
livelihood is ensured for them. The most impoverished section of the population, women and vulnerable people,
130
could be given priority and a special package of compensation to restore or initiate their sustainable livelihood in
case they are not capable of taking jobs.

The fishermen and farmer in the EZ area and nearby locality will benefit from greater job opportunities. At the
moment, they can only catch fish from the river for 4 months of the year and it is not plentiful. They often have to
risk their lives. Many of them have lost heir investments through river errisoin . Thus, economic activities in the
locality will bring more opportunities and diverse and secure livelihood options for them.
During the consultation with the local poorest people including farmar , labours , fishermen, shopkeepers,
unemployed youth and students living inside and adjacent areas, all opined that the EZ will bring more economic
benefits to the population of the EZ and adjacent areas as there are no industries established or income generating
activities currently undertaken. The poorest strata of the population of the locality, fishermen and unemployed
women will benefit from the EZ.

However while the construction activities go on, including the establishment of the EZ, widening roads and
seaside dam improvement with dykes, outside workers are likely to be present in the locality for a long
period. Thus, necessary measures needed to be taken to prevent any harassment or violence against women and
public health related problems including HIV-AIDS.

Detailed survey and consultation on socio-economic conditions and land ownership and asset ownership patterns
of PAPs at the EZ site needed for efficient and effective resettlement actions. Further consultation in EZ adjacent
areas may be needed before and during implementation of resettlement and establishment of EZ for ensuring
best possible socio-economic effects of the EZ.

2.14 ESTIMATED EMPLOYMENT CREATION

Employments of Sirajganj is estimated from an average employment of each industrial sector estimated from the
existing industry in Bangladesh and some industries which doesn’t exist in Bangladesh was estimated from
industries of Asian countries. Based on the planned land use of Sirajganj, the estimated employment created will
be 1,72,000 workers. The total employment of direct and indirect employments may reach 1,72,000 workers
within 7-10 years.
Table 4.2.7.2-1: Employment Estimate for Sirajganj Economic Zone

Industry & Com Land Area (Ha) Employment /Ha Employments

Knitting 202 500 101172
Spinning 121 300 36422
RMG 40 798 31629
Customs, Security, Admin, 10.1 25 253
entrance plaza & Social
infrastructure
Essential staff quarters 6.1 25 152
Road 28.3 2 57
Greenery 41.7 50 2084
Warehouse 4.0 20 81
Gas Power Plant 6.1 25 152
Total 460 1745 172000

131
Sector wise % of Employment Generation:

70.00 58.82
60.00
50.00
40.00
30.00 21.1818.39
20.00
10.00 0.00 0.15 0.09 0.03 1.21 0.05
0.00

2.15 RESETTLEMENT PLAN

As there are various types of household, a detailed survey will be needed to assess the socioeconomic condition
and land and asset ownership patterns before the compensation is provided. Proper consultation needed before
displacing people from their households who need to be re-located, consultation with the local elite, UP chairman
and members, teachers, religious leaders, local administration including UNO need to be included along with the
representatives of the PAPs particularly the ones losing their homesteads needed in the grievance redress
mechanism committees to ensure proper compensation is provided to the genuinely deserving ones and to reduce
tensions and in order to motivate PAPs to move out of their current homesteads on time.

Affected households will be resettled in or adjacent to the EZ area in Sirajganj. The farmers, fishermen and people
from other affected occupational groups will receive compensation for loss of livelihood options and income, with
twice the current market value. Private tree owners will also be compensated.
2.16 COMPENSATION AND ENTITLEMENTS
The affected persons will be compensated for their affected structure, trees, cropping field, ponds and business.
Compensation is based on entitlements including: (i) replacement value for structures, tree, etc. and (ii) other
resettlement assistance as required such as transfer grants, re-installation grant (except replacement value) and
compensation for loss of business/wage due to dislocation. Vulnerable households will be eligible for further cash
assistance for relocation and resettlement to improve their living condition. The entitlements as per loss category
are presented in table below;

2.17 RESETTLEMENT MATRIX AND COMPENSATION PACKAGE

Sl Type of loss Type of compensation suggested

.
1No Homestead Resettlement in EZ area (land for land)
. Cash compensation: twice the current market price and relocation costs who
opt for cash instead of land
Preference in the jobs created by the EZ
Skill training for new livelihood options
2 Private land ownership Cash compensation x 1.5 times of current price
Actual of loss of crops where applicable
Preference in the jobs created by the EZ
Legal owner(s), including mortgagors, as determined by DC during
Compensation under law (CUL) payment, or by court in cases of legal
disputes.
Co-sharers/ to be determined by title deeds/records by DCs.
T ransition allowance (TA) for income loss from productive lands.
3 Shop owners Actual cost of the shops & materials
Relocation costs
Compensation for two months earnings.
132
Preference in the jobs created by the EZ
4 Ponds Cash compensation x 1.5 times of current price
5 Trees Cash compensation x 1.5 times of current price
In case of fruit tress one season of earnings from fruit sale
5 Livelihood loss Preference in the jobs created by the EZ
Compensation of 2 months of earnings and relocation costs
6 Vulnerable groups A special compensation for the most vulnerable people such as female headed
families, people with disability, orphans.
7 Training needs Government’s youth department, Women’s affairs department, NGOs can do
assessment needs assessment on training and provide technical training related
to employment at EZ industries.
8 Temporary/short term Compensation to the affected people
hassle for construction Employ their household members in construction works or other relevant
period works.
9 Social, educational and T he project is avoiding any destruction of such institutions and minimizing
Economic such loss, thus approach roads were carefully designed to avoid loss.
organizations
10 Public property In case any such public property is affected during the construction or
operational phase, these services and facilities will be compensated
and rehabilitated/relocated properly before implementing work.
11 Historical, cultural or None fall in the project area. In case any such sites are affected, relocation
religious sites cost should be paid.
12 Closing/obstructing to Sirajganj EZ is adjacent to the Jamuna River. But the EZ is not closing
accessibility to natural or obstructing access for communication or livelihood to the natural
resources resources as a whole. The dyke for protection of the EZ will be constructed
with a road on top of it. So accessibility to surroundings will be very good. The
dyke will also protect the locality of the fishermen from flood. T here is no
possibility of destroying the access of fishermen to the sea. But, a sea
channel is proposed to bring coal to the power plant inside the EZ. It will be
a shipping line. So the mouth of river Sangu may have limited access for
fishing activities.

Though BEZA is responsible for overall execution and coordination, ensuring GOB's support and timely financial
disbursements of the EZ but land acquisition and resettlement has to be done by the Ministry of Land through the
respective DC office. Thus, complexity of bureaucratic procedure and coordination may happen. Land replacement
costs, dislocation allowance, transfer grants, reconstruction grants, onetime special assistance, income and
livelihood restoration grants will be included in the compensation package so that the economic condition of PAPs
will be improved.
The Project construction activities will require many unskilled labourers and skilled staff for earthwork in
the EZ development, approach roads, offices and management work. Provision should be made in the contract
with the contractors for employment of qualified PAPs and their dependents in the recruitment of local labour,
including affected women. Employment in the project construction will act as an added source of income and
livelihood restoration of the PAPs.
Land replacement costs, dislocation allowance, transfer grants, reconstruction grants, onetime special assistance,
income and livelihood restoration grants will be included in the compensation package so that the economic
condition of PAPs will be improved.
The Project construction activities will require many unskilled labourers and skilled staff for earthwork in
the EZ development, approach roads, offices and management work. Provision should be made in the contract
with the contractors for employment of qualified PAPs and their dependents in the recruitment of local labour,
including affected women. Employment in the project construction will act as an added source of income and
livelihood restoration of the PAPs.

133
Table : Institutional Responsibilities in Resettlement Process
Related Activities and Responsibilities Responsibility
A. Preparation of Updated RAP
Preparation of land acquisition plans BEZA/RU/Eng Firm
LA process and land acquisition DC/BEZA
Recruitment of ERS and NRS BEZA/RU/WB
Recruitment of Implementing Agency BEZA/PIU
Design and reproduction of RAP Information Brochures BEZA/RU/NRS
Disclosure and public consultations BEZA/RU/IA
Selection of members for resettlement advisory bodies BEZA/RU/IA
Design and carry out census for joint inventory of losses RU/IA
Market survey on prices of lands, structure, crops and trees. IA/PVAT
Establishment of unit prices PVAT/RU
Processing the Census and socioeconomic data of APs IA/NRS
Assessing AHs to be relocated and any vulnerable APs IA/RU
Determination of entitlements and consultations with individual APs RU/IA
Consultation of Draft RAP to EA, APs and stakeholders ERS/RU
Incorporate suggestions and finalizing the RAP ERS
Review and concurrence of RAP SS(National)/WB
B. RAP Implementation
Mobilization of GRC RU/IA
Establishment of internal monitoring and hiring of EMA MOHW/DCs/PIU
Budget approval for compensation and resettlement PIU
Release of funds for compensation BEZA/RU
Filing and resolution of complaints APs, RU/GRCs/IA
Assess needs, identify sites and develop relocation sites RU/IA/APs
Consultation with APs on schedule of clearing the lands RU/IA
Clearing of lands APs
Confirmation of “No Objection” for the award of civil works contract WB
Relocation and livelihood restoration assistance IA/RU/LIRP
C. Monitoring and Evaluation
Internal monitoring RU/ERS/NRS/IA
Independent external monitoring and evaluation EMA/WB

134
Figure: Procedure of Determining Valuation of Property

Identification of Alignment
and Affected Property by RU

PVAT members
RU (PIU,BEZA) PVAT to Collect Information
IA Representative
DC Representative

Conduct PVS for Land, Sub-Register Office for the then

Key Informants Structure, Trees Recorded Value of Land
Potential Buyer
Potential Seller
Deed Writer
Religious Leader
Local Elites
CRO for approval of Prepare Mouja wise existing
Unit Rate Replacement Value/Unit Rate

Implementing
Agency for
Preparing Budget

135
2.18 GRIEVANCE REDRESS
A grievance redress mechanism should be developed prior to the compensation provided and during the
resettlement period.

T he land acquisition and resettlement will be done during mid-2014 to early 2016. A local body incorporating
the Local Governance (LG) representatives and the government administration at the local level, with a cell
at central level, could be established to take care of this.

T he aggrieved person will apply to GRC (Grievance Redress Committee). The grievance redressing
mechanism is shown in the following figure. GRC will review the application and if the application is under
arbitration then it will be referred to the DC. If the application is not under arbitration then the grievance will
be settled by RAP policy. If the application is rejected then the person can apply to the district judge for legal
settlement.

It should be remembered that grievance redress is a very time consuming matter and should be given
priority so that the minimum possible time is required for it.

2.19 DISCLOSURE OF INFORMATION

According to WB OP 4.12, people’s participation in the project planning and implementation phase is
essential. People have the right to information what is going to happen in their surroundings. They must be
informed about the positive and negative impacts of the proposed project and their opinion, suggestions and
feedback must be incorporated in the project design. People living in the EZ area, where embankment
improvement with dykes and super dykes will be undertaken, must be informed so that they can take
protective measures for their safety, or can get compensation for the loss of their structures. Consultation
was done with various stakeholders in the EZ area and adjacent areas for initial assessment of the
positive and negative effect of the EZ.

2.20 INSTITUTIONAL ARRANGEMENTS AND PROBLEMS RELATED TO IT

T here may be problems regarding institutional arrangements among several government departments
involved in the EZ implementation. Lack of manpower, lack of training, lack of coordination, administrative
problem for transfers, trust building and rapport with local people are the major problems which may be
faced during implementation of the project.

During consultation with the relevant stakeholder government agencies, it appeared that while the PPP
agency had some considerable amount of money to undertake new ventures, due to lack of
experience, in practise, the money could not be spent. Also the regulatory frameworks and
coordination are mentioned as major obstacles.

Government Ministries and agencies likely to be the stakeholders are, among others : the Prime Minister’s
Office, the Ministry of Finance (Finance Division and Economic Relations Division), the Ministry of Land, the
Customs Authority, the Board of Investments (BOI), Bangladesh Economic Zone Authority (BEZA),
Bangladesh Export Processing Zone Authority (BEPZA),the Ministry of Industries, the Ministry of Commerce,
the Ministry of Power, Energy and Mineral Resources, the Ministry of Communications, the Ministry of
Water Resources, the Ministry of Railways, the Ministry of Law, the Ministry of Environment and
Forest. More consultations are needed in this regard.

136
Resettlement Unit (RU) for BEZA

Deputy
Social/Resettle BEZA
Commissioner
ment Project
Specialist Director

INGO/IA

An INGO needs to be involved in the process of resettlement for transparency and effect land
acquisition and resettlement and grievance redress process for timely completion of this phase to
move on to construction of EZ and allocation of industrial plots.

2.21 CONSULTATION WITH LOCALS

A participatory approach is an essential part of projects dealing with development in order to ensures
sustainability. Participation of local people and other stakeholders enables different socio-economic interest
groups in enhancing their capabilities to play an effective role in development initiatives. It also ensures
commitment and a sense of ownership of various stakeholders beyond the locals and direct project
beneficiaries. Government agencies, people’s representatives, professional groups and voluntary groups
including NGOs and community-based organizations, could be actively engaged to share responsibility in
key decisions. It also enriches project planners with local/indigenous knowledge.

As part of the public consultation of social, gender, and resettlement issues, we carried out a series of
consultations with people from a range of categories within the proposed EZ and the nearby areas including
proposed approach roads. These meetings were heled from March 2011 to June 2014. Meetings were held
with relevant government officials. Consolations took the forms of individual interviews, focus group
discussions – mostly informal, in project area.

Consultations were done with the locals including farmaer, fishermen and, labourers, youth and children. In
the consultation, various stakeholders mentioned the positive impact of the EZ on the lives and livelihoods
of the people of that area or adjacent areas. T hey consider that in the current scenario of the
unemployment and low return from agriculture and fishing, low food security is a problem. T hey perceive
that industrialization in the EZ will enhance job opportunities and income and will have positive impacts on
poor people by various occupational and income generating opportunities even in addition to the EZ
employment. The probable offshoots of the EZ would be tourism, small trading, suppliers of raw materials to
the related small factories, better transportation and transportation related business, women’s
entrepreneurship and children’s education.

Issues covered in Consultation:

During consultations, issues covered are current socio-economic conditions of the population living inside the
EZ area and the locality, women’s employment, children’s education and health facilities; how EZ will affect
the lives and livelihoods of the people living inside and adjacent areas, what are the expected prospects
for socio-economic development in the area due to the EZ and if there is any probable negative problems
related to the establishment of the EZ, what should be the resettlement compensation and grievance redress.

137
2.22 SWOT Analysis for Sirajganj Economic Zones

Strengths
 Si te is l ocated by the side of the 60 ft. wi de Dhaka- Sirajganj Highway , 130
KM to Dha ka international airport and 375 KM to Chi tta gong port . • Resettlement of 815 HHs
 Ra ilway s tation only 1 KM would be a challenge,
strong monitoring needed.
 Cl os est with Bangabandhu Mul tipurpose Bri dge • Inadequate institutional
 Ba ga bari River port within 40 KM . In future have a chance to establish river support and coordination
port wi th zone among the government
 Ja muna River within 1 KM . La rge wa ter body available southern part of ministries and agencies.
zone • PPP is not well
 Gros s a rea 1041.43 a cre (Khas land 985.93 a cre a nd 55.50 pri va te Land practiced yet, needs
 Si te is especially s uitable for knitwear , ga rments and pharmaceuticals motivation and good
coordination.
 Empl oyment creation is expected to be 80,000 workers
• Local investors and traders
 230 KV s wi tching power station within 1 KM from the site may like small scale risk free
 Ga s supply s ource available within 1 KM industries, needs motivation.
 The l and is plain a nd high. only 3m ea rth filling is required • Political changes and red tape.
 Res ource development -80000 workers employment opportunities. • Social bottlenecks-
 Own Ri ver port will be developed for EZ i n future resistance form sections of
communities & landowners
 Ga rments , knitwear a nd RMG i ndustries s uitable for l arge no. of
in developing EZ.
empl oyment.
 Sui table for na ti onal i nvestors a s competitive and high demand of
knitwear and garments abroad
• Increa s ed urba n fa ci l i ti es a nd connecti vi ty to the ci ty of Si ra jga nj

Sirajganj EZ

Opportunities Threat
 Lack of co-ordination between
relevant government ministries and
 To use EZ to catalyze agencies.
infrastructure development.  Land will be acquired by Land
 To increase investment in a demand ministry, other development activities
driven, labour intensive way in a done by several other ministries
country experiencing unemployment in  Lack of experience and success in PPP
rural areas. may risk the project or slow it down.
 To organize industrial zone for  Labour cost competitiveness but
best management and least health and conforming with more restrictive labour
environmental hazards. laws.

138
World Bank Policy on Involuntary Resettlement, Gender and Indigenous/Tribal Population

2.23 WORLD BANK OP 4.12: REQUIREMENTS FOR INVOLUNTARY RESETTLEMENT

T he primary objective of the World Bank policy on ‘Involuntary Resettlement’ is to explore all alternatives to
avoid or at least minimize involuntary resettlement. Where resettlement is unavoidable, the resettlement
activities should be conceived and executed as sustainable development programs, providing sufficient
resources to enable affected persons to share in project benefits and assisted in their efforts to improve their
livelihood and standard of living, or at least to restore them to pre-project level. The policy also requires that
affected people are meaningfully consulted and should have opportunities to participate in planning and
implementing resettlement programs. The policy applies to the taking of land and other assets when
involuntary resettlement results in the loss of shelter, the loss of all or part of productive assets, or access to
them and the loss of income sources or means of livelihood, with or without physical displacement.

Measures required ensuring that resettlement has a positive outcome include:

Providing Project-affected persons with options;
 Permitting their participation in planning and selecting these options;
 Prompt compensation at full replacement cost for losses;
 Choosing relocation sites that provide, at a minimum, the same benefits as the sites they
replace;
 Providing allowances and other assistance to make a smooth transition after displacement;
 Identifying vulnerable groups and providing and special assistance to these groups; and,
 Implementing an institutional structure that supports the process to a successful and
World Bank policy on Involuntary Resettlement requires payment of compensation and other
assistance to project affected people before they are displaced from their existing locations. Further, the
policy requires income rehabilitation assistance to those affected severely due to the loss of their productive
assets or loss of incomes and livelihood.

Absence of legal title does not exclude individuals from the eligibility to receive compensation and/or other
assistance. The displaced or affected population eligible for compensation for losses include: those who
have formal legal rights to land or other assets and those who initially do not have formal legal rights to land
or other assets but have a claim to legal rights based upon the laws of the country. The policy also requires
that those without legal title should be given assistance to meet the objectives of the policy. T he genesis of
these rights may come from continued possession of public land where the government has not sought
their eviction. World Bank policy also recognizes that stakeholders who illegally occupy project-affected
areas after established cut-off-date for any components are not eligible for compensation and other
assistance provided that adequate measures are taken for information dissemination to people.

T he gaps in the existing legal framework of Bangladesh and the objectives and requirements of the World
Bank and other multilateral agencies are well recognized. T herefore, institutional or project specific policies
are prepared to address these gaps and to meet the requirements of multilateral agencies in projects funded
by them.
T he gaps in the existing legal framework of Bangladesh and the objectives and requirements of the World
Bank and other multilateral agencies are well recognized. T herefore, institutional or project specific policies
are prepared to address these gaps and to meet the requirements of multilateral agencies in projects funded
by them.
T he following basic categories of issues/impacts are foreseen under this entitlement framework:
a. Loss of land;
b. Loss of structure;
c. Loss of source of livelihood;
d. Loss of access to common resources and facilities;
e. Loss of standing crops, trees and perennial trees; and
f. Loss of public infrastructure.
139
Data on the various land patterns, structures and institutions are provided in the report showing the overall
condition and probable impact of the proposed EZ. In the financial and economic plans, financial
compensation is counted for all the affected households whoever is living inside the proposed EZ
area. From the secondary data it seems there are mostly kuccha and khupri houses in the area of the EZ
site, so the financial compensation along with job opportunities will benefit them compared to the amount of
land they will lose from their possessions and their current livelihood loss. Though there are structures and
institutions and buildings in adjacent areas, if extension or new constructions for transportation are needed,
more consultation will be needed with relevant stakeholders.

2.24 WORLD BANK GENDER POLICY OP 4.20: GENDER AND DEVELOPMENT (REVISED MARCH 2012)

T he objective of the World Bank Gender and Development policy is to assist member countries to
reduce poverty and enhance economic growth, human well-being and development effectiveness by
addressing the gender disparities and inequalities that are barriers to development and by assisting member
countries in formulating and implementing their gender and development goals.

No gender disparity will result from implementation of the proposed EZ. Rather, it will contribute to gender
parity and women’s empowerment by their involvement in the income generation activities and
employment in the industries, compared to the current situation where women are mostly unemployed.
However, a special package should be provided for the female headed households.

While providing compensation money for the households, a joint back account should be opened and money
should be transferred by banks for the purchase of property. If possible, property should be bought in the
name of husbands and wives jointly. While moving to a new place, women may their kin, social networks
and informal economic transactions. Therefore, for the displaced population, special care needs to be taken
to ensure that women are not left vulnerable and without assets. In the case of women having some kind of
income generating activities, livelihood restoration support must be provided.

Regarding poverty alleviation, as previously stated the project will contribute tremendously by creating
jobs particularly for women and the impoverished population. By reducing poverty and contributing to the
solvency of families within the area, it is also expected that education and health will improve. This project
conforms to various MDGs and has no conflict with the World Bank’s aim of poverty alleviation and
development. But the project needs to ensure that the affected people are given priority in employment and
that the most vulnerable people including widows, the old age population, orphans and people with disability
get priority in assistance packages.

2.25 SPECIFIC FUNDING REQUIREMENT OF THE WORLD BANK POLICY OP 4.10

Policy document OP4.10 of the World Bank contributes to the Bank's mission of poverty reduction and
sustainable development by ensuring that any development activity and accompanying processes fully
respects the dignity, human rights, economies and cultures of Indigenous Peoples. Hence, it is a requirement
that all projects which are proposed for financing by the World Bank are assessed to see whether the policy
needs to be triggered keeping in mind the geographic location, nature and scope of activities.

T he policy requires client governments to seek broad community support of Indigenous Peoples through a
process of free, prior and informed consultation before deciding on development projects affecting
Indigenous Peoples. T he policy requires that Indigenous Peoples benefit from the commercial
development of natural resources. T he Project must include measures to (a) avoid potentially adverse effects
on the Indigenous Peoples’ communities; or (b) when avoidance is not feasible, minimize, mitigate, or
compensate for such effects. World Bank-financed projects are also to be designed and structured in a
manner to ensure that Indigenous Peoples receive social and economic benefits which are culturally
appropriate and gender and inter-generationally inclusive.

140
2.26 WORLD BANK OP/BP 4.11: PHYSICAL AND CULTURAL RESOURCES
The objective of OP/BP 4.11 on Physical Cultural Resources is to avoid, or mitigate, adverse impacts on
cultural resources from development projects that the World Bank finances. Cultural resources are
important as sources of valuable historical and scientific information, as assets for economic and
social development and as integral parts of a people's cultural identity and practises. The loss of such
resources is irreversible, but fortunately, it is often avoidable.

Taking OP 4.11 into consideration the project planning team endeavoured to avoid any such resources being
affected by the project and proposed alternatives to avoid destruction of cultural resources and to minimise the
displacement of physical resources

2.27 LEGAL CONTEXT OF LAND ACQUISITION IN BANGLADESH

Currently the only legal framework that governs land acquisition in Bangladesh is the Acquisition and
Requisition of Immovable Property Ordinance, 1982.However, its provisions are not adequate to address
adverse impacts associated with land acquisition and involuntary displacement and do not fully satisfy the
requirements of the Bank's Operational Policy (OP 4.12) on Involuntary Resettlement or that of the international
practices.

The project proposal follows the World Bank policy OP 4.12 Requirements for Involuntary Resettlement where
there is a gap between the government’s and World Bank’s policy regarding the resettlement issues.

Due to the low lying land, the EZ area is at risk of flooding, during rainy season, for example the site was
affected by the floods of 1988, 1998, 2004, 2011. Therefore, people living in the site area are willing to relocate a
safer site with compensation. Although the site is currently waste land prone to flooding in the time of rainy
season, the construction of a super dyke is planned (7 metres in height, which is 1 metre higher than the
historical record flooding.) surrounding the Sirajganj EZ site. This, plus land-reclamation of 5 metres will turn the
waste land into a safe and valuable water front industrial zone. Many ports and industrial zones in Asia, including
Japan, Korea, China, Philippines and Vietnam were low waste land, but were turned into valuable industrial
zones/ports. T he Sirajganj EZ can convert the current waste land into a valuable water front industrial zone using
the above technical solution. These would make the EZ safe and valuable and also ensure the safety of the
entire community of Sirajganj (population of 259,022 in 49,966 HH living in the Upazila, with including 0000
HH living in rural areas .
2.28 Detailed Information of Land for proposed EZ
Data on this section was collected from the DC, Sirajganj district records. T here may be a small gap in these
details and the land use pattern in the EZ. T his is provided to help in identifying the land details during the land
acquisition and compensation for resettlement.

Upazi l a Name M ouza Name JL NO Khas Land (acre) Pri vate Land
(acre)
Sirajganj Sadar Khas Baro 214 271.35 -
Shim ul
Chak Boayra 215 260.19 -
Birhati 216 13.47 -
Belkuc hi Boyra M asum 16 139.83 -
Baro Bera 17 295.59 -
Kharua
T otal 980.13
Private land for approac h road = 55.50 ac re and
Bangobandu Bridge authority land = 5.50 ac re
= 61.00
Total Land 1041.43

141
RE F ERE N CES
 Bangladesh Proposed Private Sector Development Support Project, Environmental
assessment, Final Report, funded by CIDA, February 2007.
 Environmental and Social Impact report of MEPZ, PwC.
 Bridge Replacement Project (BRP: Interim Guidance Notes on Environmental Management, Health
& Safety, Social & Resettlement), July 2001.
 DHV consultants BV et al.: Nalka – Hatikamrul - Bonpara New Road- Detailed Environmental Study:
Part 5- Environmental Management and Monitoring, RHD, Dhaka, December 1996. Dorsati madani,
 A Review of the Role and Impact of Export Processing Zones, April 1999
 European Commission, 2003b. Integrated Pollution Prevention and Control (IPPC), Reference
Document on Best Available Techniques for the Textile Industry. Seville, Spain

 Environmental Guidelines, Volume 1: Environmental Management in the Roads and Highways

Department, Ministry of Communications, Government of the People’s Republic of Bangladesh,
August 2004.
 Environmental and Social Management Plan for the Network Preservation and Network Improvement
for the Proposed Road Sector Reform Project (RSRP): Ministry of Communications, Road &
Highways Department, Bangladesh, funded by WB, 2007.
 Environmental Management Plan for Padma Bridge Project at Mawa –Janjira Corridor,
Bangladesh Consultants Ltd., April 2006
 Environmental Management Plan for Ganga Bridge at Kachlaghat on Bareilly-Badaun-
Bharatpur Road, Operational Research Group Pvt. Ltd. November 2005
 EIA Final Report, Trade Gate Way Project for Department of State for Trade, Industry and
Employment, Gambia Investment, Promotion and Free Zones Agency, Republic of Gambia,, October
2000
 ESMP, Trade Gate Way Project, for Department of State for Trade, Industry and
Employment, Gambia Investment, Promotion and Free Zones Agency, the Republic of
Gambia, August 2001.
 International Finance Corporation (IFC), Environmental, Health and Safety Guidelines for Textile
Manufacturing, April, 2007
 Ministry of Local Development, Department of Local Infrastructure Development and
Agriculture Roads Rural Access Improvement Project (Final Draft Report), Nepal - Environmental
and Social Management Framework, November, 2004.
 Mouchel et al.: Rehabilitation of Dhaka – Sylhet Road, Volume 2-Consolidated
Environmental Management Plan, RHD, Dhaka, March 1998.
 Northeast Regional Water Management Project (NERP), 1998a, Environmental Impact
Assessment, Final Repot, March 1998
 Northeast Regional Water Management Project (NERP), 1995, Specialist Study Surface Water
Resources of the Northeast Region, Final Report 1995
 RCC Ltd., EIA of proposed Sewing Thread Dyeing & Finishing Plant for American
& Efrid Bangladesh (PVT) Ltd., September 2001.
 RCC Ltd., EMP of Existing Spinning Plant for Padma Textiles Mills Ltd., April 2000
 Strategic Environmental Assessment (SEA) for the EPZ, T EMA, Republic of Ghana, February 2011
 SMEC International (Pty Ltd.), Australia, Environmental Management Plan – Detail
Project Report for the Flyover and Approach Road to the Chittagong Port Terminal
under Chittagong Port Trade Facilitation Project, January 2007.

142