51236-001: SASEC Third Bangladesh India Electrical Grid … · 2019-07-05 · CCTV – closed-circuit television ... 2.9 Comparison of Environmental Safeguard Principles between ADB

Initial Environmental Examination

June 2019

Bangladesh: SASEC Third Bangladesh-India Electrical Grid Interconnection Project

Prepared by Power Grid Company of Bangladesh Limited, Government of Bangladesh for the Asian Development Bank.

CURRENCY EQUIVALENTS (as of 04 June 2019)

Currency unit – taka (Tk)

Tk1.00 = $0.012 $1.00 = Tk.84.52

ABBREVIATIONS

AC – alternating current ADB – Asian Development Bank AEZ – agro-ecological zone APs – affected persons BBS – Bangladesh Bureau of Statistics BMD – Bangladesh Meteorological Department BtB – Back-to-Back CCTV – closed-circuit television CEGIS – Center for Environmental and Geographic Information Services DC – direct current DoE – Department of Environment DPP – development project proposal ECA – Environment Conservation Act ECC – environmental clearance certificate ECR – environment conservation rules EIA – environmental impact assessment EMF – electromagnetic field EMI – electromagnetic Interference EMoP – environmental monitoring plan EMP – environmental management plan ESMS – environmental and social management system GIS – gas insulated switchgear GoB – Government of Bangladesh GPS – global positioning system GRC – grievance redress committee GRM – grievance redress mechanism HES – health environment and safety HV – high voltage HVDC – high voltage direct current HYV – high yielding variety IA – implementing agency IBA – important bird area ICNIRP – International Commission on Non-Ionizing Radiation Protection IEC – important environmental component IEE – initial environmental examination IESC – important environmental and social components ISC – important social component IUCN – International Union for the Conservation of Nature JTT – joint technical team KBA – key biodiversity area LGI – local government institutions LV – low voltage MoEF – Ministry of Environment and Forest MP – Murat of Potash

MPO – master plan organization NCA – net cultivable area NGO – non-governmental organization NWRD – National Water Resources Database OHL – overhead line OHS – Occupational Health and Safety PAPs – project affected persons PD – project director PDB – Power Development Board PGCB – Power Grid Company of Bangladesh Limited PGCIL – Power Grid Corporation of India Limited PMU – project management unit PPE – personal protective equipment PSMP – power system master plan RoW – right of way RP – resettlement plan SF6 – sulfur hexafluoride SLD – Single Line Diagram SPS – Safeguard Policy Statement TL – transmission line TSP – triple superphosphate UP – Union Parishad

WEIGHTS AND MEASURES

C cm ha Kg km kV kW Lakh/lac m mm MT MW

– – – – – – – – – – – –

degree celsius centimeter hectare kilogram kilometer (1,000 meters) kilovolt (1,000 volts) kilowatt (1,000 watts) 100,000 meter millimeter metric ton megawatt

GLOSSARY

Aman Ambient Air Aquatic Bangla

– – – –

Group of rice varities grown in the monsoon season and harvested in the post-monsoon season. This is generally transplanted at the beginning of the monsoon from July-August and harvested in November-December. Mostly rain-fed; supplemental irrigation needed in places during dry spell. Surrounding air Growing or living in or near water Bengali language

Baseline (or existing) Conditions

– The ‘baseline’ essentially comprises the factual understanding and interpretation of existing environmental, social and health conditions of where the business activity is proposed. Understanding the baseline shall also include those trends present within it, and especially how changes could occur regardless of the presence of the Project, i.e. the ‘No-development Option’.

Beel – A ‘back swamp’ or depression can be either perennial or seasonal Biological Diversity

– The variety of life forms, the different plants, animals and microorganisms, genes they contain and the ecosystems they form. It is usually considered at three levels: genetic diversity, species diversity and ecological diversity

Boro Fauna

– –

A group of rice varieties sown and transplanted in winter and harvested at the end of the pre-monsoon season. These are mostly HYV and fully irrigated, planted in December-January and harvested before the onset of the monsoon in April- May. Process in which wind and water removes materials from their original place; for instance, soil washed away from an agricultural field

Flora – All of the plants found in a given area Habitat – The natural home or environment for a plant or animal Important Environmental Component

– These are environmental components of biophysical or socioeconomic importance to one or more interested parties. The use of important environmental components helps to focus the environmental assessment

Khal Kharif Kharif-I Kharif-II

– – – –

Small channel, canal Pre-monsoon and monsoon growing season. Cropping season linked to the monsoon between March-October, often divided into kharif-1(March-June) and kharif-2(July-October). Name of cropping season that covers pre-monsoon periods; i.e., March to June. Name of cropping season that covers monsoon period; i.e., July to October.

Mouza – A Bangla word for the smallest government administrative area corresponding to village revenue unit

Public Consultation Stakeholders

– Those who may be potentially affected by a proposal, e.g. local people, the proponent, government agencies, NGOs, donors and others, all parties who may be affected by the Project or to take an interest in it

Rabi Taka

– –

Dry agricultural crop growing season; mainly used for the cool winter season between November and February. Unit of Bangladeshi currency

Terrestrial – Living on land Thana – Sub-district level of government administration, comprising several

unions under district Union – Smallest unit of local self-government comprising several villages Upazila – Sub-district name. Upazila introduced in 1982 Zila – Bengali word for district

NOTE In this report, "$" refers to United States dollars.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

TABLE OF CONTENTS

Executive Summary…… ………………………………………………………………………………... i 1 Introduction ............................................................................................................................... 1

1.1 Background ................................................................................................................... 1

1.2 Objectives of the Initial Environmental Examination .................................................... 3

1.3 Study Area .................................................................................................................... 3

1.4 Scope of Work............................................................................................................... 8

1.5 Methodology .................................................................................................................. 8

1.6 Secondary Data Collection ........................................................................................... 8

1.7 Primary Data Collection ................................................................................................ 9

1.8 Structure of the Report .................................................................................................. 9

2 Policy, Legal and Administrative Framework ......................................................................... 10

2.1 Overview ..................................................................................................................... 10

2.2 Procedure for Obtaining Site/Environmental Clearance ............................................ 10

2.3 Organization Related with Enforcement of Environmental Standards ....................... 11

2.4 National Legislation Relevant to Environment ............................................................ 12

2.5 Policy Related with Energy Development ................................................................... 15

2.6 Compliance with International Requirements ............................................................. 16

2.7 Compliance with ADB Safeguard Policy Statement, 2009 ......................................... 18

2.8 Compliance with PGCB Health Environment and Safety Requirements ................... 20

2.9 Comparison of Environmental Safeguard Principles between ADB and Bangladesh 20

3 Description of the Project ....................................................................................................... 24

3.1 Rationale ..................................................................................................................... 24

3.2 Project Components ................................................................................................... 24

3.3 Project Location .......................................................................................................... 24

3.4 Detailed Project Description ....................................................................................... 29

3.5 Components of Construction Works ........................................................................... 36

3.6 Project Related Documentation, Funding, Land Acquisition ...................................... 37

3.7 Civil Construction Works ............................................................................................. 39

4 Baseline Information ............................................................................................................... 40

4.1 Physical Environment ................................................................................................. 40

4.2 Environmental Quality ................................................................................................. 61

4.3 Agriculture ................................................................................................................... 65

4.4 Biological/ Ecological Environment ............................................................................. 69

4.5 Socio-Economic Environment ..................................................................................... 80

5 Anticipated Environmental Impacts and Mitigation Measures ............................................... 91

5.1 Introduction ................................................................................................................. 91

5.2 Analysis of the impacts ............................................................................................... 91

5.3 Possible Hazards ...................................................................................................... 110

6 Analysis of Alternatives ........................................................................................................ 123

6.1 Constraints in Analysis of Alternatives ..................................................................... 123

6.2 Implications of Site selection for the Substation ....................................................... 123

7 Information Disclosure, Consultation and Participation ....................................................... 124

7.1 Consultation with Stakeholder .................................................................................. 124

7.2 Project Stakeholders ................................................................................................. 125

7.3 Methodology .............................................................................................................. 125

7.4 Tools and Process Used ........................................................................................... 125

7.5 Summary of Focus Group Discussion on Environment ........................................... 126

8 Grievance Redress Mechanism ........................................................................................... 130

8.1 Objectives of Grievance Redress Mechanism.......................................................... 130

8.2 Guidelines to Redress Grievances ........................................................................... 130

8.3 Complaints and Grievance Mechanism .................................................................... 131

8.4 Grievances Redress Committees ............................................................................. 131

8.5 Scope and Jurisdiction of GRC ................................................................................. 132

8.6 Grievance Redress Process ..................................................................................... 132

8.7 Approval of GRCs and Entitlements of GRC Members ........................................... 134

8.8 Grievance Redress Monitoring ................................................................................. 134

9 Environmental Management Plan ........................................................................................ 135

9.1 Environmental Management Plan ............................................................................. 135

9.2 Monitoring Tasks and Activities ................................................................................ 145

9.3 Budget for the Environmental Management Plan (EMP) ......................................... 151

9.4 Environmental Management Responsibilities (PMU and Contractors) during Construction .................................................................................................................................. 152

9.5 Environmental Protection Plan (Contractors) ........................................................... 152

9.6 Monitoring Plan ......................................................................................................... 153

10 Conclusion and Recommendation ................................................................................... 158

10.1 Conclusion ................................................................................................................ 158

10.2 Recommendations .................................................................................................... 159

Annex 1 ........................................................................................................................................ 160

Environmental Audit for Comilla 230/132 kV Substation ............................................................. 160

1. INTRODUCTION .............................................................................................................. 160

1.1 Background ............................................................................................................... 160

1.2 Environmental Compliance Audit ................................................................................... 160

1.3 Method and Approach .................................................................................................... 162

2. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK ................................................. 162

3. SITE BASELINE INFORMATION, AUDIT FINDINGS AND REMEDIAL ACTIONS ........ 163

4. CORRECTIVE ACTION PLAN (CAP) .............................................................................. 165

5. CONCLUSION AND RECOMMENDATION .................................................................... 165

Annex 2. Ancillary information on the site and existing transmission lines. ............................... 168

LIST OF TABLES Table 1.1: Area within Comilla District Table 2.1: Environmental Laws, Regulations and Standards of Bangladesh

Table 2.2: ADB’s Environmental Safeguards Categorization and Requirements

Table 2.3: Comparison of Environmental Safeguard Principles

Table 3.1: Scope of Work of the Project Table 3.2: Project Related Activities

Table 3.3: Estimated Cost of the Project (Bangladesh side) Table 3.4: Mode of Financing with Source in BDT Lac and USD

Table 3.5: Mode of Financing w/ Source in BDT Lac / USD million $

Table 4.1: Present land use of the study area

Table 4.2 Value of air quality parameters at selected locations in the study area

Table 4.3: Water Quality Assessment Details

Table 4.4: Surface Water Quality of the Study Area Comilla

Table 4.5: Ground Water Quality

Table 4.6: Drinking Water Quality

Table 4.7: Standards of Noise Levels for Different Zones of Bangladesh

Table 4.8: Daytime Noise Levels of the Study Area of Comilla

Table 4.9: Standard values under section 80(1) (i) of the National Environment Act, Cap 153 and regulation 16 of the National Environment (Noise Standards and Control) Regulations, 2003

Table 4.10: Existing cropping pattern in the study area

Table 4.11: Detailed information on the proposed HVDC Station area (agricultural production) Table 4.12: Area and location of Bio-ecological zones within the HVDC Station area

Table 4.13: Crop area, yield and crop production in the study area

Table 4.14: Seed and Labor used in the study area

Table 4.15: Detailed information on Fertilizer and Pesticides application in the study area

Table 4.16: Detailed information on the proposed HVDC Station area (agricultural production) Table 4.17: Area and location of Bio-ecological zones within the HVDC Station area

Table 4.18: IUCN status of fish species

Table 4.19: Administrative location of the study area and area coverage (in %) by Mouza

Table 4.20: Total Population, Sex Ratio and Household Size

Table 4.21: Labor availability and wage rate in the study area

Table 4.22: Land price for a specific location

Table 4.23: Land Ownership in the study area

Table 5.1: Parameters for Determining Magnitude

Table 5.2: Criteria for Determining Sensitivity

Table 5.3: Significance of Impact Criteria

Table 5.4: IECs on physical and water resources and their rationale

Table 5.5: IECs on Land and Agricultural Resources and their Rationale

Table 5.6: IECs on Fisheries Resources and their Rationale

Table 5.7: IECs on Biological environment and their Rationale

Table 5.8: ISCs on Socio-Economic Resources and their rationale

Table 5.9: Impacts in different phases of Construction and Mitigation

Table 5.10: Impacts Mitigation Matrix

Table 5.11: Possible Hazards Associated with the Project Table 5.12: Location, Date, Time and Device Specifications for the Investigation

Table 5.13: ICNRIP (2010) vs. Bheramara Measured (including meter accuracy) for Electric and Magnetic Field

Table 5.14: Data Captured for the Electric and Magnetic Field Investigations

Table 7.1: Location of Consultation and Discussion

Table 7.2: Major Problems and Suggested Solution by the Stakeholders

Table 8.1: Grievance Resolution Process

Table 9.1 EMP for Physical Environment and Water Resources

Table 9.2: Environmental Management Plan for land and agriculture resources

Table 9.3: Environmental Management Plan for Fisheries resources

Table 9.4: Environmental Management Plan for Biological Environment Table 9.5: Management Plan for Socio-economic Resources

Table 9.6 Environmental Monitoring Plan for Physical and Water Resources

Table 9.7: Environmental Monitoring Plan for land and agricultural resources

Table 9.8: Environmental Monitoring Plan for Fisheries Resources

Table 9.9: Environmental Monitoring Plan for Biological Environment Table 9.10: Monitoring Plan for Socio-economic Resources

Table 9.11: Budget for EMP and EMoP

Table 9.12 A summary matrix table for monitoring the activity of contractors that is to be submitted to PGCB

LIST OF FIGURES Figure 1.1: Base map of the proposed project site

Figure 1.2: Base map (Google Earth) of the proposed project site in close view

Figure 1.3: Base map of the proposed project site

Figure 1.4: Base map of the proposed project site showing 5 km radius study area

Figure 2.1: Process of Obtaining Environmental Clearance for Orange B Category

Figure 3.1: Tentative Land Area of Different Components of the HVDC Station in Blocks and the Respective Land Requirements of Each Block

Figure 3.2: Satellite Capture and Marking of the Acquired 16 ha Land and Location of the 230/132kV Substation on 6 ha Land. Also it is showing the tentative land area allotment for the aforementioned segments/ blocks of the 400kV HVDC BtB Station

Figure 3.3: Proposed Project Line of the HVDC BtB Station from Surjamaninagar (Tripura, India) to Comilla (Bangladesh) Figure 3.4: Tentatively Proposed HVDC Station Blocks inside the Acquired Land (Blocks Not Drawn to Scale) Figure 3.5: Single Line Diagram of the Project from MAINBUS-I and II of Surjamaninangar (Tripura, India) to Comilla (Bangladesh): Line 1 and 2 Features of the Existing 230/132kV Substation

Figure 3.6: Single Line Diagram of the Debpur 230/132kV Substation, Comilla Civil Structures for Equipment Housings, Control Room and Other Facilities

Figure 3.7: Location of the 230/132kV substation Control Room

Figure 3.8: Inside the 230/132kV substation Control Room

Figure 4.1: Monthly Cumulative Rainfall at Comilla BMD station

Figure 4.2: Monthly average rainfall at Comilla BMD station from 2015 to 2017

Figure 4.3: Monthly maximum and minimum Temperature at Comilla BMD station

Figure 4.4: Monthly average maximum and minimum temperature at Comilla BMD station from 2015-17

Figure 4.5: Monthly Relative Humidity at Comilla BMD station

Figure 4.6: Monthly maximum, average and minimum relative humidity at Comilla BMD station from 2015 to 2017

Figure 4.7: Monthly average evaporation rate at Comilla BMD station

Figure 4.8: Monthly average sunshine hours per day at Comilla BMD station

Figure 4.9: Monthly Average Sunshine hours per day at Comilla BMD station from 2015 to 2017

Figure 4.10: Monthly variation of average wind speed at Comilla BMD station

Figure 4.11: Monthly variation of average wind speed at Comilla BMD station from 2015 to 2017

Figure 4.12: Tectonic Map of the Study Area

Figure 4.13: Seismic Map of the Study Area Figure 4.14: Monthly Water Level Analysis at Gobindapur station of Gomti River

(Station ID-112, 1923-1979) Figure 4.15: Average Monthly Variations of Ground Water Table (1977-2013) Figure 4.16: Water Logging near the Study Area

Figure 4.17: Map showing the Project Area and the Main Proposed Canal. Figure 4.18: Layout Map of Proposed canal in the Study Area

Figure 4.19: Agro-ecological Zone of the study area

Figure 4.20: Land use in the study area

Figure 4.21:Seed bed of HYV Aman in the study area

Figure 4.22: Present condition under the HVDC Station area

Figure 4.23: The culture pond in the project area

Figure 4.24: Bio-ecological Zone of the Study Area

Figure 4.25: Agricultural land of Project area

Figure 4.26: Agricultural land of Study area

Figure 4.27: Avifauna of Project area (Drongo) Figure 4.28: Insect at project area (Dragonfly) Figure 4.29: Roadside vegetation at Project area

Figure 4.30: Roadside vegetation in the Study area

Figure 4.31: Homestead vegetation at Study area

Figure 4.32: Jaintarkhal at Study area

Figure 4.33: Aquatic flora at Project area

Figure 4.34: Aquatic bird and amphibianin the Project area

Figure 4.35: Birds flyways around the world

Figure 4.36: Distribution of households by household members

Figure 4.37: Age Structure of the study area

Figure 4.38: Literacy rate in the study area

Figure 4.39: Treatment Facility of the study area

Figure 4.40: Employment status by population

Figure 4.41: Field of Activity in the study area

Figure 4.42: Distribution of houses by type of housing structure

Figure 4.43: Sanitation facilities by households

Figure 4.44: Source of Drinking Water Figure 7.1: Some Photographs of Consultations

Figure 8.1: Grievance Redress Flow Chart

EXECUTIVE SUMMARY 1. Bangladesh is striding towards becoming a middle-income country by 2021 and power is the prime mover in that uphill national effort. Consequently, demand for electricity is growing very fast. In order to meet this emergent electricity demand, the Government of Bangladesh (GoB) has prioritized the energy projects. In this regard, Power Grid Company of Bangladesh Limited (PGCB) has taken up a Project to construct a High Voltage Direct Current (HVDC) Back-to-Back (BtB) Station at Comilla to import 500 MW Power from Tripura (India). In this regard, PGCB intends to construct a new HVDC Station at Comilla for evacuation of high voltage electricity. The GoB, PGCB, and Asian Development Bank (ADB) will jointly provide financial assistance for this Project. 2. The power will be transported over a 400kV transmission line. The project will construct a 400 kV HVDC BtB station, which will be converting this 400 kV AC to 400 kV DC and then to 230 kV AC, so that it can be connected to the 230 kV National Grid of Bangladesh. The construction of the proposed new 400 kV HVDC BtB Station in Comilla will bolster the National Grid of Bangladesh by importing 500MW power. It may be noted here that an HVDC system has the advantage of connecting two independent systems with different electrical parameters by means of converter valves, thus making the power supply a more reliable one. The project will help cover the ever-growing electricity demand of the Eastern Region of Bangladesh. 3. A 10.6 km transmission line in India to transport electricity from India to Bangladesh will be constructed by the Power Grid Corporation of India Limited (PGCIL). This line does not depend exclusively on the proposed ADB project as this line will cater to power demand of Tripura state, improve the grid reliability and provide alternate evacuation path to OTPC Palatana generation (726 MW). 4. The project is located in agricultural area. No ecologically sensitive areas or national protected areas are marked in the project area. There is no significant adverse impact to the proposed project area. The project is categorized as B for environment as per ADB’s SPS 2009. Proposed Category B projects require an Initial Environmental Examination (IEE). According to the Environment Conservation Act 1995 and Environment Conservation Rules 1997, amended in December 2017, transmission lines (lower than 50 km) and substation related projects are regarded as an ‘Orange B Category’ project that require an IEE to get ‘Site Clearance’ from the Department of Environment (DoE). In this regard, PGCB has conducted an IEE study for the Project with assistance from Centre for Environment and Geographic Information Services (CEGIS), one of the top organisations to conduct environmental impact assessment domestically. The clearance was issued by DoE on 7th April 2019. 5. The study area of the Project is located in the eastern region of Bangladesh, comprising four Mouzas of Burichang Upazila under Comilla District, with the total size of 79 hectares, while the project area is 39.519 acres (16 ha), which has already been acquired (exclusively water-logged rice-growing land, with no houses). The study has been done based on both primary and secondary data. A composite and interdisciplinary approach has been developed for this study, based on the guidelines of DoE and that of ADB’s SPS 2009. The approach includes world standardized ad-hoc methods, application of expert judgment, a systematic and sequential approach of impact identification, spatial analysis through application of remote sensing and Geographic Information System (GIS), including public participation. 6. A scoping process was followed for identifying Important Environmental and Social Components (IESCs), which are likely to be impacted by interventions at the project. Impacts to ecological resources will be minimal and localized in all phases of the project because there is no ecological environmentally sensitive areas. There are 283 households in the study area, where 1,404 people are currently living, including 726 males and 678 females. The main ethnic communities of the Comilla district are Chakma, Tripura and Marma. According to the BBS 2012 data, there are 484 Chakma, 318 Tripura and 191 Marma communities living in this region. There are no indigenous people involved in the study area.

ii

7. HVDC Electromagnetic Field (EMF) was measured in September 2018 at a similar BtB station in the western district of Kushtia, Bangladesh–the Bheramara 2x500MW 400 kV HVDC BtB Station, which is in operation. The maximum figures for both electric field and magnetic field are far below the limits, which indicate that during the operation phase of the project, the potential EMF impacts are not expected to be significant. 8. During the consultation process, the proposed HVDC BtB Station project interventions, as well as its impacts, were discussed with local people. In the consultation process, the stakeholders got involved with the study consultants in reforming/developing the project interventions, considering the local needs and aspirations in line with the problems and solutions suggested by them. The proposed interventions, findings of the IEE, and the EMP were shared with the project stakeholders to obtain their perceptions, views and feedback on the probable changes likely to happen within the project area. 9. During the Stakeholder Consultation Meeting, the project and its related activities as well as several issues with reference to the project were discussed. It was found that the people of the area showed an overall positive attitude towards the proposed project; in general, as they realise that implementation of this project would play a great role for development of the region, as well as the country. 10. The EMP was prepared to include mitigation, enhancement, compensation, monitoring and contingency plans for managing the consequences of the project interventions in the pre-, during, and post-construction phases of the project implementation. The main impacted factors will be on air, water, noise and waste which will arise limited to construction phase. PGCB will ensure the EMP implementation with secured budget of Tk.93.50 lac (0.115 million, 1 USD = 83.85 BDT, 20 May 2019). The EMP will ensure that the project is implemented safely and in an environmental-friendly manner. 11. Mitigation will be assured by the Environmental Monitoring Plan (EMoP) which will also help in detecting changes taking place during, as well as after, establishing the BtB Station so that necessary steps can be taken to rectify defects or deficiencies, if any. The EMoP focuses on implementation of the mitigation/enhancement measures during the pre-construction, construction and post-construction stages with a budget of Tk. 21 lac (0.025 million, 1 USD = 83.85 BDT, 20 May 2019). The project management unit (PMU) will carry out the detailed supervision and environmental monitoring tasks under the overall supervision of the Project Director. 12. Therefore, this project is unlikely to cause significant adverse impacts. The potential adverse impacts that are associated with design and construction can be mitigated to standard levels without difficulty through proper engineering design and the incorporation or application of recommended mitigation measures and procedures. Based on the findings of this IEE, the classification of the Project as Category ‘B’ is confirmed. It is concluded that the proposed project should proceed, with appropriate mitigation measures and monitoring programs identified in the IEE.

1 Introduction

1.1 Background

1. Bangladesh is heading towards becoming a middle-income country by 2021 and power is the prime mover in that uphill national effort. The Power Grid Company of Bangladesh Limited (PGCB) has, therefore, taken up a Project to construct a High Voltage Direct Current (HVDC) Back-to-Back (BtB) Station at Comilla to import 500MW power from Tripura (India). The Government of Bangladesh (GoB), PGCB, and Asian Development Bank (ADB) will jointly provide financial assistance for this Project. 2. In a broader perspective, the GoB has made power sector development a priority for supporting the fast-economic growth. The government has committed to a massive initiative to build a nationwide transmission and distribution network with the aim of providing electricity for all by 2021. As per the Power System Master Plan (PSMP) 2016,1 a transmission system capable of supplying 40,000 megawatts (MW) of electricity throughout the country is expected to be completed by 2030. 3. Bangladesh’s power supply has not been able to keep pace with the rapid growth in demand, and consumers have experienced frequent power outages. As of June 2017, the total nationwide dependable grid-connected peak demand was 9,479 MW, against an unconstrained demand of 12,644 MW, indicating that about 3,200 MW of the power demand was met by supply from captive generation and load shedding. On average, over 1,000 MW of load shedding occurs during summer. Electricity demand is projected to grow by more than 10 percent per year over the medium term. The PSMP 2016 has projected that demand will rise to more than 50,000 MW by 2041.2 4. The shortage of electricity and poor quality of electricity supply from the aged and low capacity grid network severely impact industry and service sectors, which account for a major share of growth in the economy. According to the latest 2013 World Bank Enterprise Survey,3 Bangladesh businesses on average suffered power outages for 840 hours per year, resulting in an output loss of approximately 3% of gross domestic product. The availability and reliability of power is hence a key constraint to job creation and poverty reduction. 5. In line with the above stated goals, the government envisages to obtain financial support from ADB for the proposed HVDC BtB Station with the size of 16 hectaares at Comilla (Bangladesh) for 500 MW from Tripura (India) with the main objective of the Project is to evacuate high voltage power imported from India and strengthen the national grid network of PGCB to ensure power supply reliability in the north-eastern region of Bangladesh. 6. PGCB is a state-owned power transmission company in Bangladesh, and it is responsible for operation, maintenance and development of the power transmission system at 132 kV and above. PGCB has experience in the development, operation, and maintenance of 400 kV transmission lines with several operational lines including installation and operations of 2 such 500MW HVDC stations currently in operation at Bheramara, Kustia of Bangladesh and importing power from India. Thus, PGCB is capable of executing this project, which will be taking advantage of existing transmission line infrastructure in both Bangladesh and India (160 MW of power is already imported from India to the Comilla sub-station). This line will be entering at the planned 400 kV HVDC BtB Station through the 400 kV OHL Entry with the help of a 400 kV Gas Insulated Switchyard (GIS) (controlled from the Control Room).

1 Power System Master Plan 2016, Power Division, Ministry of Power Energy and Mineral Resources, supported by, Japan

International Cooperation Agency (JICA), September 2016. Documents reviewed in the PSMP indicate that the sector has not been subject to SEA.

2 The Bangladesh Power Development Board estimates that load shedding at peak time in 2017 was about 250 MW.

2

3 Enterprise Surveys data for Bangladesh 2013; http://www.enterprisesurveys.org/

3

1.2 Objectives of the Initial Environmental Examination

7. Essentially, implementation of any project can have both negative and positive impacts on the surrounding environment, depending on environmental sensitivities and the design of responsive mitigation measures. 8. Environmental impacts include physical, ecological and socio-economic impacts. This impact assessment was carried out to prevent and reduce potential adverse impacts to an acceptable level, and to enhance the positive impacts linked with the implementation of the project. 9. A rapid environmental assessment checklist for the project was prepared to determine potential adverse environmental and social impacts during project design and planning, construction, operation and maintenance phases of the substation and transmission line projects. It was also to identify, if there was any environmentally/biologically sensitive area located within the project area. 10. This project is categorized as an Environment B project, based on the rapid environmental assessment and the ADB Safeguard Policy Statement (SPS) 2009. For Category B projects, the environmental impacts are less adverse (than category A projects), site specific, and mostly reversible. 11. An Initial Environmental Examination (IEE) is required to address the anticipated impacts and to suggest appropriate mitigation measures. This IEE report was prepared following the requirements of the ADB’s SPS 2009. The project site has been acquired and its boundaries already marked (as of October 31, 2018), with the project components clearly identified (no environmental re-categorization of the project is expected). 12. In fine, the overall objective of the study was to identify the current environmental and social baseline of the project area and the important environmental and social components of the same which may be impacted by the project intervention. Identifying mitigation measures to minimize the adverse impact including any residual impacts of the project. 13. This study has been done through conducting primary and secondary baseline surveys and preparing the environmental management and monitoring plans including a cost estimate for implementation of these plans. 1.3 Study Area

14. The study area of this Project is located in the North-Eastern Region of Bangladesh. Four (4) Mouzas of Burichang Upazila under Comilla District with a total size of 79 ha are recognised as the study area (Table 1.1).

Table 1.1: Area within Comilla District Districts Upazila Union Mouza

Comilla Burichang Mainamati Debpur Harindhara Purba Sharippur Mainpur

15. The location of the project area is shown in Figure 1.1, Figure 1.2 and Figure 1.3, while Figure 1.4 shows the study area.

4

5

Figure 1.1: Base map of the proposed project site4

4 Note that the connector path from Harindhara to Debpur, running through the project site, will be replaced with a new

better quality road immediately north of the site (already partially completed).

6

Figure 1.2: Base map (Google Earth) of the proposed project site in close view

Figure 1.3: Base map of the proposed project site

7

Figure 1.4: Base map of the proposed project site showing 5 km radius study area

8

1.4 Scope of Work

16. According to the Environment Conservation Act (ECA 1995) and Environment Conservation Rules (ECR 1997) (Amended in December 2017) Power Transmission Lines (lower than 50 km) fall under ‘Orange B Category’ which requires an IEE to get a ‘Site Clearance Certificate’ from the DoE. Accordingly, PGCB has conducted an IEE Study for obtaining a ‘site clearance certificate’ from the DoE, as well as to fulfil the requirements of ADB. The clearance was issued by DoE on 7th April, 2019. 17. Thus, the scope of work for the IEE Study essentially includes the following:

• Review of relevant documents and data/information from secondary sources, and identification of gaps to be filled from environmental screening done during field surveys.

• Conduct an environmental baseline survey for providing a description of the environmental baseline (data on physical, ecological and socio-economic characteristics of the project sites, along with areas of influence).

• Collect information on environmentally sensitive features at project sites, as well as within the project influence area and select environmental and social components likely to be impacted by the Project;

• Conduct public consultation to obtain peoples’ perception about the Project and potential impacts through arrangement of consultations with the local people, especially project affected persons, to find out their opinions about the sub-projects as well;

• Work out a comparative analysis of alternatives to the proposed sub-projects following Initial assessment and evaluation of impacts;

• Identify and assess potential environmental impacts due to implementation of the project and develop possible mitigation measures.

• Develop an Environmental Management Plan (EMP), including Environmental Monitoring Plan (EMoP), and institutional arrangements for successfully implementing the mitigation and enhancement measures including a budget for implementation arrangement of the management and Monitoring Plan

• Prepare an IEE Study Report in accordance with the ADB SPS 2009 and the national regulations of the government and assist the project proponent in obtaining a ‘Site Clearance Certificate’ from the DoE.

1.5 Methodology

18. The IEE is usually used to estimate the potential environmental impacts of a proposed project, based on available preliminary information and information readily acquired through rapid environmental surveys. This study has been conducted in accordance with the ADB SPS 2009 and other relevant national/international laws and treaties applicable to the proposed project. This IEE report has been prepared based on the secondary and primary data/information that was collected and analysis of potential project/environment interactions. 1.6 Secondary Data Collection

19. The review of secondary sources and informal initial field investigations were undertaken to prepare a preliminary assessment of the physical and social environment, biodiversity, and conservation significance of the identified project area. The preliminary literature reviews also assisted in identifying data gaps which could be addressed with collection of additional primary information through field surveys.

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20. Relevant data/information was collected from various government and non-governmental organizations, especially related to site aspects, climate (weather), topography, geology, water bodies, surface/ground water quality, ecology/biology, socioeconomics, and other aspects. Previous environmental site studies, where available, were reviewed, as well as relevant articles and web sites. 1.7 Primary Data Collection

21. Primary data/information included data collected during the field surveys and observations, and discussions with stakeholders, such as community representatives and Project Affected Persons (APs) at key project locations and in the project influence area (PIA). The main purpose of this approach was to obtain a clear impression on the people’s perceptions of the project and its environmental impacts and possible mitigation measures.

22. The primary data on environmental and socioeconomic aspects of the project area were collected during July and August 2018 by the safeguard survey team of CEGIS to comprehensively evaluate the existing project area environmental baseline conditions. The status of flora and fauna within the project area was determined by reviewing the literature relevant to the area, as well as observations and surveys at the project sites. ADB safeguard specialists also visited the site. 23. The field survey team used a combination of desk studies, field investigations, census data, structured interviews, focus group discussions, maps, and reports to generate the data required to describe the existing environment. Samples of Environmental Parameters were collected and tested onsite and in the laboratories of repute. The results were analyzed to assess and for keeping records for reference in future. Further, after having comments and obtaining the test results for the physical environment i.e., air, soil, noise and water etc. some of these, as available, have been incorporated in the report. 24. The potential impacts including residual impacts, if any, due to the construction and operation of the project were identified. Local knowledge about the ecosystem and problems associated with the project activities were carefully recorded through public consultations and used in the impact assessment and to develop the EMP. Formal public consultations, as well as informal ones, involving local villagers and affected persons were carried out during the field survey. 1.8 Structure of the Report

25. The report has been structured in compliance with the requirements. Chapter 1: Providing introduction presenting a brief overview of the assignment along with its background, objectives, scope of work, etc. Chapter 2: Policy, Legal and Administrative Framework, Chapter 3: Description of the Project describes the proposed interventions including background, project category, and the need for the project, location, size and magnitude of operations. Chapter 4: Description of Environment (Baseline Data): Chapter5: Anticipated Environmental Impacts and Mitigation Measures, Chapter 6: Analysis of Alternatives, Chapter 7: Information Disclosure, Consultation and Participation, Chapter 8: Grievance Redress Mechanism, Chapter 9: Environmental Management Plan and finally the Report is rounded up with Conclusion and Recommendations in Chapter 10.

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2 Policy, Legal and Administrative Framework

2.1 Overview

26. The Environment Conservation Act (ECA 1995) and Environment Conservation Rules (ECR 1997) (Amended in December 2017) Power Transmission Lines (lower than 50 km) fall under ‘Orange B Category’ which requires an IEE to get Site Clearance Certificate and Environmental Clearance Certificate from the DoE. 27. PGCB, as the project proponent, is responsible for carrying out the IEE studies of the proposed project. Therefore, it has the responsibility to administer the environment assessment process with the consultants, review the findings, and submit the documents to the DoE for review. A key requirement of the IEE for projects classified in the orange categories is an EMP. The function of the EMP is to enable PGCB to show the DoE how it will deliver the environmental performance assessed in the IEE (for which DoE approval is sought). The EMP should describe the management responsibilities, mitigation measures as well as the institutional arrangements, and explain how monitoring will be carried out. 28. Possession of clearances from the DoE does not relieve the developer of a project from the requirement to comply with other environmental regulations. The Bangladesh National Environment Quality Standards for industrial effluents have been set and compliance with them are mandatory. There are also statutory instruments that are applicable to power development projects, which are not primarily environmental but help to mitigate environmental impacts. Compliance with such statutory instruments is mandatory. 2.2 Procedure for Obtaining Site/Environmental Clearance

2.2.1 Requirement for IEE Reports

29. All industries and projects in the Orange B must conduct IEEs, which help in understanding the potential extent of environmental changes of the project. Figure 2.1 shows the process of obtaining the environmental clearance for Orange B category projects. ECC-Environmental Clearance Certificate. NOC- No Objection Certificate

“Orange - B” Category

• Feasibility report for the project

• IEE report

• EMP Report

• NOC from local authority

• Pollution minimization plan

• Outline of relocation plan

Application to DoE

Issuance of site clearance within

60days

Submit ETP design for approval

Issuance of ECC within

30 days

Apply for ECC

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Figure 2.1: Process of Obtaining Environmental Clearance for Orange B Category 30. The IEE process helps in determining ways to mitigate negative impacts by considering available information, past experiences, and standard operating practices. The steps for conducting IEEs are as follows:

• Collection of baseline information with respect to a project and the environmental setting of the project and its site.

• Setting of boundaries of an IEE by identifying the significant issues. • Impact assessment suggesting mitigation measures, development of an EMP, and

discussion of alternative sites for the project or other project modifications. • In the event the IEE of the project or industry reveals that further investigation is required to

be carried out, the sponsors will have to conduct a detailed EIA.

2.2.2 Procedure

31. The project proponent applies to the DoE in the prescribed format for site or environmental clearance after completing the IEE report. The application for environmental clearance for the project classified in the Orange category should be accompanied by the following documents:

• Feasibility Study Report of the industry (project) • IEE report including EMP • No Objection Certificate (from the local authorities concerned) • Pollution minimization plan, including emergency plan for mitigation of adverse

environmental impacts • Outline of relocation plans (where applicable) • Other information as deemed necessary

32. The ECR 1997 gives the Director General of the DoE the discretion to issue an environmental clearance directly without issuing any site clearance to any industry or project, if the Director General finds an appropriate reason for doing so. The project will ensure that this clearance is in place prior to site works. 2.3 Organization Related with Enforcement of Environmental Standards

33. Roles and responsibilities of various Ministries and Departments involved in the enforcement of environmental requirements are described below.

2.3.1 Ministry of Environment and Forest

34. The Ministry of Environment and Forest (MoEF) is the key Ministry in Bangladesh for all matters relating to national environmental policy and regulatory issues. Realizing the ever-increasing importance of environmental issues, the MoEF replaced the Ministry of Agriculture and Forest in 1989 and is at present a permanent member of the Executive Committee of the National Economic Council. The National Economic Council is the major decision-making body for economic policy issues and is also responsible for approving all public investment projects. The MoEF oversees the activities of the following technical and implementing agencies:

• DoE • Forest Department • Forest Industries Development Corporation

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2.3.2 Department of Environment

35. The Government adopted the Environmental Pollution Control Ordinance in 1977 to expand the scope of environmental management and to strengthen implementation powers. The ordinance established an Environmental Pollution Control Board, which formulates policies and proposes measures for their implementation. In 1982, the Board was renamed as the Department of Environmental Pollution Control. Six divisional offices were established in Dhaka, Chittagong, Khulna, Barisal, Sylhet and Rajshahi. 36. A special presidential order renamed the Department of Environmental Pollution Control as the DoE and placed it under the newly formed MoEF in 1989. The DoE is a department of the MoEF and is headed by a Director General. The Director General has complete control over the DoE. The power of the Director General, as given under the Environment Conservation act, is outlined as follows:

• The Director General has the authority to stop activities considered harmful to human life or the environment. The operator has the right to appeal and procedures are in place for this. However, if the incident is considered an emergency, there is no opportunity for appeal.

• The Director General has the authority to declare an area affected by pollution as an ecologically critical area. The DoE governs the type of work or process within that area.

• Before undertaking any new development project, the project proponent must take an environmental clearance from the DoE.

• Failure to comply with any part of the Environment Conservation Act 1995 may result in punishment by a maximum of 5 years’ imprisonment or a maximum fine of Tk100,000, or both.

2.3.3 Forest Department

37. This department under the MoEF is responsible for the protection and management of all reserve forests in the country. Department personnel extend down to the union level in areas where there are reserved forests areas. The department has recently started some agro-forestry programs and its officers are also responsible for the protection of wildlife in the forests.

2.3.4 Other Related Organizations

38. There are several other organizations, which have certain social and environmental functions. These organizations include:

• Ministry of Land: Land Reform and Land Acquisition Directorate • Ministry of Water Resources: Bangladesh Water Development Board • Ministry of Fisheries and Livestock: Directorate of Fisheries • Ministry of Labour and Employment (OHS and labor issues) • Ministry of Power and Energy (supply and safety guidelines)

2.4 National Legislation Relevant to Environment

2.4.1 Environmental Policies and Acts

39. National strategies, policies, acts and rules related with the environment include the following:

• Environment Pollution Control Ordinance, 1977 • Environmental Quality Standards for Bangladesh, 1991

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• National Conservation Strategy 1992 • Environment Policy (1992) • National Environment Management Action Plan 1995 • Environment Conservation Act (ECA 1995) • Environment Conservation Rules (ECR 1997) • Bangladesh Labour (Amendment) Act (#30, 2013) • Electricity (Amendment) Act 2012.

2.4.2 Other Environmental Related Legislations, Rules and Policies

40. In addition to the environmental policies and regulations, the following rules and regulations, listed in Table 2.1, which will be checked for compliance to help maintain a sustainable environment and safe working conditions (during project construction and operation).

Table 2.1: Environmental Laws, Regulations and Standards of Bangladesh

Year Title Objectives and Relevance to Project

1885 The Telegraph Act (Act XIII of 1885) Under the law sections 10-19, specifies parameters and obligations for government-built transmission lines throughout the country.

2013 Bangladesh Labour (Amendment) Act (#30, 2013)

Amends and clarifies appropriate working conditions in all sectors and the rights of workers regarding safe working conditions.

1910 The Electricity Act (Act IX of 1910) Under the law section 51, government-built transmission lines throughout the country, with specific parameters and obligations noted.

2012 Electricity (Amendment) Act 2012

Among other things, specifies conditions of distribution, sale, and use of electricity, including related generation and transmission infrastructure, and obligations regarding the need for preservation of the environment, and associated protection and safety clauses.

1950 East Bengal Protection and Conservation of Fish Act

Requirements and actions for protection and conservation of fish in Bangladesh.

1985 The Protection and Conservation of Fish Rules

Prevention of harm to fisheries resource and fisheries habitat in coastal and inland waters.

1958 Antiquities Act Protection and preservation of archaeological and historical artifacts, if found during project construction.

1965 Factories Act Industrial workers' health and working conditions (now better addressed by the new Labour Act).

1982 Acquisition and Requisition of Immovable Property ordinance

The Acquisition of Immovable Property Rules, 1982 (No. S.R.O. 172-U82) The government adopted these rules in exercise of the powers conferred upon by section 46 of The Acquisition and Requisition of Immovable Property Ordinance, 1982 (Ordinance No. II of 1982). Not directly relevant to this project, as no structures are to be removed except a very small bridge on the site cross-over road).

1990 Bangladesh standard specification for drinking water

Formulation and revision of national standards (inasmuch as the sub-station will continue to require access to safe drinking water).

1860 The Penal Code

This contains several articles related with environmental protection and pollution management (it is considered over-riden by the latest laws and regulations in the last 20 years governing environmental management).

1996 Building Construction (Amendment) The Rules are more comprehensive for taking care of the

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Year Title Objectives and Relevance to Project

Act and Building Construction Rules present circumstances and issues of building, such as the new sub-station.

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2.5 Policy Related with Energy Development

2.5.1 The Electricity Act (1910) and Electricity Rules (1937)

41. Under the act, any person can obtain a license to supply electricity and lay down or place electric supply lines. The licensee can open and break up the soil and pavement of any street, railway or tramway and can lay down any line or do other work near other utility services (gas, telecommunication, water, sewer, etc.), provided prior permission is taken from the respective authority, as stated in Sections 12-18 of the Act. 42. According to Section 19 (1) of this act, the licensee shall give full compensation for any damage, detriment or inconvenience caused by, or anyone employed by, that licensee. 43. Sub-section (1) of Section 51 of the Electricity Rules, 1937 advises that the licensee should take precautions in laying down electric supply lines near or where any metallic substance or line crosses to avoid electrocution.

2.5.2 The Telegraph Act (1885)

44. Under Sections 10-19, Part III (Power to place Telegraph Lines and posts), and the government could build towers on public land without giving any land compensation. But the amendment in the ACT made in February 2018 provided for payments of compensation and framing of rules for such payments is under process.

2.5.3 The Power Policy (1995)

45. As with the Petroleum Policy, this is presently an integral part of the National Energy Policy (1996). It has different policy statements on a whole range of issues including demand forecasts, long-term planning and project implementation, investment and lending terms, fuel and technology, power supply to the west zone, isolated and remote load centres, tariffs, captive and standby generation, system loss reduction, load management and conservation, reliability of supply, system stability, load dispatching, institutional issues, private sector participation, human resource development, regional/international cooperation, technology transfer and research program, and environment policy and legal issues. 46. As the proposed project is a power transmission project, all necessary requirements mentioned above will be adopted for the project.

2.5.4 The Energy Policy (1996; updated 2004)

47. The first National Energy Policy of Bangladesh was formulated in 1996 by the Ministry of Power, Energy and Mineral Resources to ensure proper exploration, production, distribution, and the rational use of energy resources to meet growing energy demand sustainably. The policy was updated in 2004 in response to rapid global and domestic change. The updated policy includes additional objectives namely to ensure environmentally sustainable energy development programs, to encourage public and private sector participation in the development and management of the energy sector, and to electrify the entire country. The policy highlights the importance of protecting the environment by requiring an IEE for any new energy development project for transmission of electricity through OHL of lower than 50 km, in length.

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2.5.5 The Industrial Policy (1999)

48. The National Industrial Policy (1999) aims to ensure a high rate of investment by the public and private sectors, a strong productive sector, direct foreign investment, development of labor intensive industries, introduction of new appropriate technology, women's participation, development of small and cottage industries, entrepreneurship development, high growth of exports, infrastructure development, and environmentally sound industrial development. The World Trade Organization guidelines have been proposed to be followed in the Industrial Policy.

2.5.6 Building Construction (Amendment) Act (1990) and Rules (1996)

49. The first Building Construction Act dates back to 1952. The earlier Government Buildings Act (1899) exempted certain buildings and land that belonged to or were occupied by the government and situated within the limits of a municipality, from the municipal building laws. The 1990 Act supersedes the provision of Municipal Building Laws to regulate the creation, recreation, construction, alteration, or maintenance of buildings within the limits of any municipality. The East Bengal Legislative Assembly promulgated the Building Construction Act (1952) on 21 March 1953 as the East Bengal Act II of 1953 in response to the need to regulate haphazard construction of buildings. The act was framed to allow streamlining of planned development and implement government beautification programs. 50. An important modification to the 1953 act was added through an ordinance titled, "the Building Construction (Amendment) Ordinance, 1986” (Ordinance. No. LXXII of 1986). Later in 1987, the ordinance was adopted for enactment as "The Building Construction (Amendment) Act, 1987” (Act No. 12 of 1987). 51. An authorized officer is empowered through this amendment so that he/she can take necessary action to prevent unauthorized construction or to remove such construction without intervention of the court. 52. The act was further amended in 1990 allowing power to issue limited sanctions to cut down or raze any hill within the area to which this act applies. 53. To support the implementation of the provisions laid down in the Building Construction Act, 1952, the government made the Building Construction Rules, 1953. The Imarat Nirman Bidhimalas (1984) superseded these rules. Later in 1996, the government framed the Imarat Nirman Bidhimalas (Building Construction Rules, 1996). The rules are more comprehensive and more relevant to present circumstances and issues of building construction and other related development activities. 2.6 Compliance with International Requirements

54. Bangladesh has acceded to, ratified, or signed a number of major international treaties, conventions and protocols related to environment protection and conservation of natural resources.

2.6.1 Rio Declaration

55. The 1992 United Nations Conference on Environment and Development adopted the global action program for sustainable development called ‘The Rio Declaration’ and ‘Agenda 21’. 20 Principle 4 of The Rio Declaration, to which Bangladesh is a signatory, states that “in order to achieve sustainable development, environmental protection should constitute an integral part of the development process and cannot be considered in isolation from it”.

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2.6.2 Convention on Biological Diversity (1992)

56. The Convention on Biological Diversity, Rio de Janeiro, was adopted on 5 June 1992 and entered into force on 29 December 1993. Bangladesh ratified the Convention on 20 March 1994. This is the overarching framework for biodiversity and the signatories are required to develop a National Biodiversity Strategy and Action Plan that incorporates the articles of the Convention into national law and statutes. 57. Obligation has been placed on state parties to provide for environmental impact assessments of projects that are likely to have adverse effects on biological diversity.

2.6.3 Wetlands of International Importance as Waterfowl Habitat (1971)

58. The Convention of Wetlands of International Importance as Waterfowl Habitat (1971) is also known as the Ramsar Convention. It was adopted on 2 February 1971 and entered into force on 21 December 1975. Bangladesh ratified the Convention on 20 April 2002. The Convention provides a framework for national action and international cooperation for the conservation and wise use of wetlands and their resources. There are 127 parties with 1,085 wetland sites designated as ‘Wetlands of International Importance.’ 59. This is an intergovernmental treaty, which provides the framework for international cooperation for the conservation of wetland habitats. Obligations for Contracting Parties include the designation of wetlands to the “List of Wetlands of International Importance,” the provision of wetland considerations within their national land use planning, and the creation of natural reserves. 60. Bangladesh has two Ramsar sites: parts of the Sundarbans Reserved Forest (Southwest of Bangladesh) and Tanguar Haor (Northeast of Bangladesh). The proposed project will not have any effect on these two Ramsar sites.

2.6.4 United Nations Framework Convention on Climate Change

61. The Kyoto Protocol to the United Nations Framework Convention on Climate Change was adopted in 1997 and requires developed countries and economies in transition, listed in Annex B of the Protocol, to reduce their GHG emissions by an average of 5.2% below 1990 levels. Article 12 of the Kyoto Protocol provides for the Clean Development Mechanism (CDM). According to CDM, projects are eligible to earn Certified Emission Reductions (CERs) if they lead to “real, measurable, and long-term” GHG reductions, which are additional to any that would have occurred without the CDM project.

2.6.5 UN Convention on the Law of the Sea, Montego Bay (1982)

62. This Convention was adopted on 10 December 1982 at Montego Bay, Jamaica. Bangladesh has ratified this Convention. The main objectives of the convention are:

• To set up a comprehensive new legal regime for the sea and oceans, as far as environmental provisions are concerned, to establish material rules concerning environmental standards as well as enforcement provisions dealing with pollution of the marine environment; and

• To establish basic environmental protection principals and rules on global and regional co-operation, technical assistance, monitoring, and environmental assessment, and adoption and enforcement of international rules and standards and national legislation with respect to all sources of marine pollution.

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63. The proposed HVDC BtB Station related equipment and components (such as transformers, switchgears, filters and reactors etc.) transportation, if conducted via sea route, may pose threat due to unforeseen accidental event during the transport of the aforesaid goods and subsequently create marine pollution in the sea hence, this convention may be considered applicable. However, at this moment of time, the equipment and components transportation method has not been decided yet.

2.6.6 Others (Conventions and Agreements)

64. The following conventions and agreements include provisions which may be relevant for environmental management, nature protection, and biodiversity conservation:

• Convention relative to the Preservation of Fauna and Flora in their Natural State (1933); International Convention for the Protection of Birds, Paris (1950);

• International Plant Protection Convention, Rome (1951); • The Convention concerning the Protection of the World Cultural and Natural Heritage, Paris

(1972) has been ratified by 175 states. This defines and conserves the world’s heritage by drawing up a list of natural and cultural sites whose outstanding values should be preserved for all humanity. Of the 730 total sites, there are currently 144 natural, 23 mixed, and 563 cultural sites that have been inscribed on the World Heritage List (distributed in 125 State parties);

• Convention on International Trade in Endangered Species of Wild Fauna and Flora, Washington (Convention on International Trade in Endangered Species, 1973): This provides a framework for addressing over-exploitation patterns which threaten plant and animal species. Under the Convention on International Trade in Endangered Species, governments agree to prohibit or regulate trade in species which are threatened by unsustainable use patterns; and

• Convention on the Conservation of Migratory Species of Wild Animals, Bonn (1979, Amended 1988): This provides a framework for agreements between countries important to the migration of species that are threatened.

2.7 Compliance with ADB Safeguard Policy Statement, 2009

65. ADB's environmental and social safeguards form the cornerstone of its support to inclusive economic growth and environmental sustainability in Asia and the Pacific. In July 2009, ADB's Board of Directors approved the new Safeguard Policy Statement (SPS) governing the environmental and social safeguards of ADB's operations. The objectives of the SPS are to avoid, or when avoidance is not possible, to minimize and mitigate adverse project impacts on the environment and affected people. Objectives also include helping borrowers strengthen their safeguard systems and develop the capacity to manage environmental and social risks. 66. The key safeguard areas which must be addressed are (i) environmental; (ii) involuntary resettlement; and (iii) indigenous peoples.

• ADB’s environmental safeguards emphasize development and implementation of a comprehensive EMP. Key elements of EMP are mitigation measures, monitoring programs, budgets, and institutional arrangements for implementation. In addition, the environmental assessment process emphasizes public consultation, information disclosure, and consideration of alternatives.

• Further, ADB adopts a set of specific safeguard requirements that borrowers or clients are required to meet in addressing environmental and social impacts and risks associated with a specific project. ADB will not finance projects that do not comply with its SPS, nor will it finance projects that do not comply with the host country’s social and environmental laws and

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regulations. The SPS applies to all ADB-financed and/or ADB-administered sovereign and non-sovereign projects, and their components, regardless of the source of financing.

2.7.1 ADB’s Environmental Safeguard Requirements–Policy Principles

67. Environmental assessment incorporates the following policy principles:

• Projects are screened and assigned to one of the following categories described in Table 2.2 as soon as possible.

• Conduct an environmental assessment for each proposed project. Assess potential trans-boundary and global impacts, including climate change.

• Examine alternatives to the project’s location, design, technology, and components. Avoid, minimize, mitigate, and/or offset adverse impacts.

• Prepare an EMP. • Carry out meaningful consultation with affected people and facilitate their informed

participation. • Disclose a draft environmental assessment report (including the EMP) in a timely manner,

before project appraisal, in an accessible place and in a form and language(s) understandable to affected people and other stakeholders. Disclose the final environmental assessment, and its updates if any, to affected people and other stakeholders.

• Implement the EMP and monitor its effectiveness. Document and disclose monitoring results. • Do not implement project activities in areas of critical habitat, unless (i) there are no

measurable adverse impacts on the critical habitat that could impair its ability to function, (ii) there is no reduction in the population of any recognized endangered or critically endangered species, and (iii) any lesser impacts are mitigated. If a project is located within a legally protected area, should implement additional programs to promote and enhance the conservation aims of the protected area.

• Apply pollution prevention and control technologies and practices consistent with international good practices such as the World Bank Group’s Environmental, Health and Safety Guidelines.

• Provide workers with safe and healthy working conditions and prevent accidents, injuries, and disease.

• Conserve physical cultural resources and avoid destroying or damaging them by using field-based surveys.

68. The project categorization system and the assessment required are described in Table 2.2. The environmental impacts of the proposed project are temporary and reversible. This project is categorized as an Environmental B project. The project will also address the World Bank/IFC EHS guidelines as they apply to transmission lines and associated infrastructure (such as the sub-station).

Table 2.2: ADB’s Environmental Safeguards Categorization and Requirements

Category Definition Assessment Requirement

A A Likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented, and may affect an area larger than the sites or facilities subject to physical works.

Environmental Impact assessment (EIA)

B B Likely to have adverse environmental impacts that are less adverse than those of Category A. Impacts are site specific, few if any of them irreversible, and in most cases mitigation measures can be designed more

Initial Environmental Examination (IEE)

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Category Definition Assessment Requirement

readily than Category A.

C Likely to have minimal or no adverse Environmental impacts.

No environmental assessment is required but the environmental implications of the project will be Reviewed.

F1 Project involves investment of ADB funds to or through a financial intermediary (FI)

FIs will be required to establish an environmental and social management system (ESMS) commensurate with the nature and risks of the FI's likely future portfolio to be maintained as part of the FI's overall management system.

Source: ADB. Safeguard Policy Statement 2009, p. 19.

http://www.adb.org/sites/default/files/institutionaldocument/32056/safeguard-policy-statement-june2009.pdf

2.8 Compliance with PGCB Health Environment and Safety Requirements

69. The PGCB has its own policy and requirements for compliance relating to environment, health and safety issues for its operations. The company is committed to managing its operations in a safe, efficient and environmentally responsible manner. The PGCB's Health Environment and Safety (HES) manuals, guidelines, procedures, and plans are important tools indicating their commitment. HES manuals include:

• Environmental Impact Assessment Module; • Guideline on Integrated Impact Assessment; • Health Impact Assessment Module; and • Social Impact Assessment Module.

70. In addition, the requirement for impact assessment is affirmed in the PGCB's Statement of General Business Principles. The PGCB is committed to:

• Pursuing the goal of no harm to people; • Protecting the environment; and • Managing HES as any other critical business activity.

71. The mandatory company Operations Management System, Environmental Care Element/ Standards, issued in March 1997, refers to Environmental Assessment indicating that "EIA (including a consideration of social impacts) shall be conducted prior to all new activities and facility developments, or significant modifications of existing ones.” 2.9 Comparison of Environmental Safeguard Principles between ADB and Bangladesh

72. Table 2.3 presents a summary comparing the environmental safeguard principles of ADB and the government.

Table 2.3: Comparison of Environmental Safeguard Principles

No. SPS 2009

Government Gaps (if any) Principles Delivery Process

1 Use of Uses sector-specific rapid • ECA 1995 and ECR 1997 No major gaps

http://www.adb.org/sites/default/files/institutionaldocument/32056/safeguard-policy-statement-june2009.pdf

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No. SPS 2009


screening process to determine the appropriate environmental assessment

environmental assessment checklist for screening and assigns categories based on potential impacts: • A -EIA required (irreversible,

diverse or unprecedented adverse environmental impacts)

• B -IEE required • C -no environmental assessment

required but a review of environmental implications

• FI -ESMS required

(amended in 2017) set screening criteria to classify industries /projects based on potential environmental impacts as follows: Green (pollution-free), Orange-A, Orange-B and Red (causes significant environmental impacts).

• The screening criteria are based on project or industry type and do not consider the scale and location. The category determines the level of environmental assessment.

2 Conduct an environmental assessment

• EIA and IEE -Identify potential impacts on physical, biological, physical cultural resources, and socioeconomic aspects in the context of project's area of influence (i.e., primary project site and facilities, and associated facilities)

• ESMS for FIs

• Industry/project category • Green-no environmental

assessment required • Orange-A -no IEE or EIA

required but must provide process flow, lay-out showing effluent treatment plant, etc.

• Orange-B -IEE required • Red -both IEE and EIA are

required

No major gaps

3 Examine alternatives

• Analyze alternatives to the project's location, design, and technology

• Document rationale for selecting the project location, design, and technology

• Consider "no project" alternative

• Regulations (i.e., ECA 1995 and ECR 1997 amended in 2017) do not require specifically the identification and analysis of alternatives

Not required by law but the TOR for EIA to be approved by the DOE now includes a discussion on analysis of alternatives.

4 Prepare an EMP

• EMP to include monitoring, budget and implementation arrangements

• EMP and procedures for monitoring included in the IEE and EIA (i.e., Orange-A, Orange-B, and Red category projects)

No major gaps

5 Carry out meaningful consultation

• Starts early and continues during implementation

• Undertaken in an atmosphere free of intimidation

• Gender inclusive and responsive • Tailored to the needs of

vulnerable groups • Allows for the incorporation of all

relevant views of stakeholders

• Public consultation and participation are not mandatory based on ECA 1995 and ECR 1997 (amended in 2017)

• EIA format required by DOE includes stakeholders’ consultation

Approval of the ToR of EIA by DoE now includes consultation with stakeholders.

6 Timely disclosure of draft

• Draft EIA report posted on ADB website at least 120 days prior to Board consideration (for

• No requirement for public disclosure of environmental reports but DOE posts the

Still no requirement for public disclosure

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No. SPS 2009


environmental assessment (including the EMP)

Category A) • Draft IEE/EARF prior to appraisal • Final or updated EIA/IEE upon

receipt • Environmental monitoring report

submitted by borrowers upon receipt

Minutes of the Meeting on the application for environmental clearance certificate to its website, http://www.DOE-bd.org/minutes.php

of environmental assessment, but the project will be posted to the DoE website, and will be available in summary form at the project site.

7 Implement EMP and monitor effectiveness

• Prepare monitoring reports on the progress of EMP

• Retain qualified and experienced external experts or NGOs to verify monitoring information for Category A projects

• Prepare and implement corrective action plan if non-compliance is identified

• Requires submission of quarterly, semi-annual, and annual reports to ADB for review

• Environmental clearance is subject to annual renewal based on compliance of the conditions set by DOE

No major gaps

8 Avoid areas of critical habitats (use of precautionary approach to the use, development and management of renewable natural resources)

• Provides guidance on critical habitats

• ECA 1995 and ECR 1997 (amended in 2017) identifies ecologically critical areas and the rules to protect them

No major gaps

9 Use pollution prevention and control technologies and practices consistent with international good practices

• Refers to World Bank’s Environmental Health and Safety (EHS) General Guidelines 2007 (or any update)

• If national regulations differ, more stringent will be followed

• If less stringent levels are appropriate in view of specific project circumstances, provide full and detailed justification

• Effluent standards, ambient and emission standards included in ECA 1995 and ECR 1997 (amended in 2017)

• Ambient noise levels included in Noise Pollution Control Rules 2006

No major gaps

10 Provide workers with safe and healthy working conditions; and avoid risks to community health and

• Refers to WB EHS General Guidelines 2007 (or any update)

• Occupational health and safety standards included in the Factories Act 1965, the Bangladesh Labor Law 2006, and the Bangladesh Labor Act 2013.

No major gaps; WB/IFC EHS guidelines will still apply, as per the ADB SPS, and enforcement requirements will be noted.

23

No. SPS 2009


safety.

11 Conserve physical cultural resources (PCR) and avoid destroying or damaging them

• Use of field-based surveys and experts in the assessment

• Consult affected communities on PCR findings

• Use chance find procedures for guidance

• Preservation and protection of cultural resources are within the Antiquities Act 1968.

No major gaps

12 Grievance redress mechanism

• Establish a grievance redress mechanism

• Grievance redress mechanism is not mentioned in ECA 1995 and ECR 1997 (amended in 2017)

Not required by regulation in Bangladesh

ADB = Asian Development Bank, DoE = Department of Environment, EARF = Environmental Assessment and Review Framework, ECA = Environment Conservation Act, ECR = Environment Conservation Rules, EHS = Environmental Health and Safety, EIA = Environmental Impact Assessment, EMP = Environmental Management Plan, ESMS = Environmental and Social Management System, FI = Financial Intermediary, IEE = Initial Environmental Examination, NGO = Non-governmental Organization, PCR = Physical Cultural Resources, ToR = Terms of Reference, WB = World Bank. Source: ADB.

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3 Description of the Project

73. This chapter, as a part of the IEE report for this project, provides an overall picture of the project by describing the rationale of the project, the major components of this project, the project implementation cost, and the electrical and civil works associated with this project. 3.1 Rationale

74. Considering the power scenario of Bangladesh, GoB has taken a number of initiatives to enhance the power status. Importing from neighbouring India is one such effective endeavour. The proposed 400 kV HVDC BtB Station will bolster the National Grid of Bangladesh by importing 500MW power from the neighbouring Tripura and Assam provinces of India. An HVDC system has the advantage of connecting two independent systems with different electrical parameters by means of converter valves, thus making the power supply a more reliable one. Injection of 500MW power into the grid will alleviate the power stress and satiate the growing electricity demand of the Eastern Region of the country. The technology is rather new to Bangladesh, as this project will be only the third such project, all operated by PGCB. 3.2 Project Components

75. As shown in Figure 3.1 & 3.4, the major components of the construction of this 400 kV HVDC BtB Station are listed below:

• 400 kV and 230 kV GIS • 400 kV and 230 kV Overhead Line (OHL) Entry • 400 kV and 230 kV Shunt Reactor and Filters • 400 kV Valve Hall • 400 kV and 230 kV Control Rooms • Storage

76. Two transmission line terminations as part of the project are listed below (shown in Figure 3.3).

• Termination at Surjamaninagar (India, at existing sub-station) – 300m 400 kV Line at 400 kV OHL Entry (existing)

• Termination at North Comilla (Bangladesh, adjacent to existing sub-station) – 200m 132 kV Line at 132 kV Bus (existing)5

3.3 Project Location

77. The project site with a size of approximately 16 ha is adjacent to a 230/132 kV substation in Burichang Upazila of Comilla, which is approximately 6 ha and situated at 23°30'32.22''N and 91°06'06.66''E beside the Comilla-Sylhet Highway. The acquired land falls in the Harindhara Mouza and the Purba Sharippur Mouza of Burichang Upazila, situated at 23°30'42.09''N and 91°06'13.14''E has a lot shape of a pentagon as shown in Figure 3.2. HVDC Station Operation 78. The 500MW power will be transported using a Double Circuit 400 kV AC OHL to enter at the planned Station through the 400 kV OHL Entry with the help of a 400 kV GIS (controlled from the Control Room). The 400 kV AC will then be entering the Valve Hall through Filters and Reactors for compensation and smoothing, before being converted to 400 kV DC and subsequently again

5 The existing transmission lines near and crossing the India-Bangladesh border, including the locations of all

transmission towers, are shown in Annex 2. The existing transmission line corridor and towers will be used for this project, with just two towers added adjacent to the North Comilla sub-station.

25

converted to 400 kV AC and then stepped down to 230 kV AC. The output from the Valve Hall will be put through 230 kV Filters and Shunt Reactors to filter out lower order harmonics and add reactive power, respectively. In the final segment, the output from the AC side filters and shunt reactors will be connected to the 230 kV AC OHL entry and controlled through the 230 kV GIS. The HVDC station is phase matching between the two asynchronous grids of Bangladesh.

(Blocks Not Drawn to Scale)

Figure 3.1: Tentative Land Area of Different Components of the HVDC Station in Blocks and the Respective Land Requirements of Each Block

Note: These preliminary numbers will be revised during the actual designing phase of the station, which will include the layout diagram of the plant from the designing and planning team of PGCB (but all components will still be within the designated site boundary.

400 kV GIS and 400 kV OHL Entry

400 kV Filter and Shunt Reactor

400 kV Filter Valve Hall and Control Room 400 kV Filter

230 kV Filter and Shunt Reactor

230 kV OHL Entry

230 kV GIS Store

26

(Source: Google Earth)

Figure 3.2: Satellite Capture and Marking of the Acquired 16 ha Land and Location of the 230/132kV Substation on 6 ha Land. Also it is showing the tentative land area allotment for the aforementioned segments/ blocks of the 400kV HVDC BtB

Station.

27

79. The proposed project line of the HVDC BtB Station from Surjamaninagar (Tripura, India) to Comilla (Bangladesh) is shown in Figure 3.3 below.

Figure 3.3: Proposed Project Line of the HVDC BtB Station from Surjamaninagar (Tripura, India) to Comilla (Bangladesh)

28

Figure 3.4: Tentatively Proposed HVDC Station Blocks inside the Acquired Land (Blocks Not Drawn to Scale)

29

3.4 Detailed Project Description

Scope of Work for this HVDC BtB Station Project 80. The scope of work of the project primarily consists of two Transmission Line Terminations and one 500MW 400 kV HVDC BtB station. The detailed information is listed in Table 3.1 below.

Table 3.1: Scope of Work of the Project

A Transmission Lines Terminations6 Length (Km)

1 Termination of Surjamaninagar (India) – 400 kV Line at 400 kV OHL Entry

0.3 400 kV at the sub-station site

2 Termination of North Comilla (Bangladesh) – 132 kV Line at 132 kV Bus

0.2 132 kV at the sub-station site

B HVDC Station Works 16 ha (see Figure 3.4)

1 Establishment of 400 kV Level in GIS at 230/132 kV substation along with 500MW 400 kV HVDC BtB Station

500MW 400/230 kV HVDC BtB Station

400 kV GIS Line Bays: 2 nos (within project footprint at Surjamaninagar)

132 kV Line Bays: 2 nos (within project footprint at north Comilla sub-station)

Project Related Activities 81. The project related activities can be subdivided into three phases: 1) pre-construction; 2) construction; and 3) post-construction. Most of the pre-construction activities are administrative works such as project proposals, project planning, project team selection, etc. Most of the activities during construction are related to construction activities, keeping track of the project and activities such as land filling (for building platform), and foundation works, etc. Most of the post-construction activities are related to operation and maintenance of the station, administrative activities, and maintaining occupational health and safety plans.

82. Table 3.2 below lists all the project related activities categorized under the three phases of the project.

Table 3.2: Project Related Activities

Components Activities

Pre-Construction During Construction Post Construction

Complete Project

• Comprehensive project proposal

• Detailed project planning

• Project funding and land acquisition

• Project team selection

• Tender documents preparation

• Consultant recruitment

• Project documentations • Construction works

• Project operation and maintenance records, update documentations, etc.

6 The existing India-Bangladesh cross-border transmission line will be used for this project, so just the terminations

are needed.

30



• Contractor and manpower recruitment

Transmission Line Terminations

• Planning of Right of Way (RoW) for the lines

• Sourcing and procurement of components (lines, insulator discs, spacers, terminations etc.)

• Stringing of Lines from Towers to OHL Entry following appropriate techniques and safety measures

• Maintenance of lines and their components (insulators discs, spacers, terminations, guy-wires etc.) following appropriate techniques and safety measures

HVDC Station

• Soil Investigation, designing and planning of the station

• Site clearance and other project related documentation preparations

• Health and Safety Management Plan

• Designing and planning of the HVDC Station

• Sourcing and procurement of components (construction materials, electrical components, miscellaneous components)

• Contractor and manpower recruitment

• Establishment of onsite facilities for construction engineers and workers

• Health and safety implementation

• Establishment of temporary access track (through the existing subs-station entry from the Sylhet-Comilla highway)

• Transport of equipment and materials for construction works

• Construction equipment and material storage

• Civil construction works following appropriate procedures and safety measures

• Land Development: i.e. soil test, landfilling, leveling etc.

• Foundation works; i.e., Earthwork, treatment, backfilling Reinforced Cement Concrete etc.

• Main structure i.e. Beams and pillars, brickwork, woodwork, aluminum works, cementing, plastering and painting etc.

• Facilities and utilities; i.e., electric wiring, water and sewerage, sanitary, lighting, ventilations, air circulation, air cooling etc.

• Boundary and fencing works

• Operation and Maintenance of the station

• Occupational Health and Safety Management

31



• Foundation works for heavy components such as transformers, reactors, capacitors, towers, etc.

• Storage for electrical components

• Electrical installations following proper techniques and guidelines, following safety measures

• Power terminations for electrical components such as switchyard, transformers, reactors, capacitors, OHL terminations etc.

• Protection, control, measurement, monitoring, communication wiring/ cable connections, etc.

• Communication setup and commissioning of the station following appropriate techniques and guidelines; following safety measures.

• Communications testing for control, measurement, data recording, data trending, security system, etc.

• Testing and commissioning of electrical components after installation.

• Record of construction activities, track of timeline, mitigation measures of unforeseen requirements and activities, change of planned budget, change of contractors, subcontractors, works, etc.

Source: PD office, 2018

General Layout of Facilities and Project Plan 83. Electrical Design of the HVDC BtB Station -The electrical design of the HVDC BtB station has not been finalized yet. The final design will be available once the layout plan is completed.

32

Single Line Diagram (SLD) 84. The SLD of the HVDC Station from the Comilla side has been prepared by PGCIL as shown in Figure 3.5 below.

Figure 3.5: Single Line Diagram of the Project from MAINBUS-I and II of Surjamaninangar (Tripura, India) to Comilla (Bangladesh): Line 1 and 2 Features of the

230/132kV Substation

HVDC Project Related Changes and Development 85. The proposed New Control Room will have access to a fibre optics network through which the 230kV panels of the 230/132kV substation will be controlled. It is proposed that only the 230kV control system of the current substation will be moved to the new Control Room, but the actual physical panels of 230kV will remain in the current substation and will be controlled through the fibre optics network from the New Control Room. The 132kV control panels and control system will remain in the control room of the current 230/132kV substation. The new control room will have a Substation Automation System in place to control the Switchyard Protective Relays (SPRs) automatically during normal operation.

86. Any old components of the 230kV control panel will be properly stored on-site for later disposal (since Bangladesh does not yet have e-waste treatment facilities) and replaced by new components, of suitable compatibility with the new control system.

33

87. The two control rooms will also have a local communication system through intercom for instant conversation between engineers appointed in the two control rooms.

88. The SLD of the current substation is given in Figure 3.6.

Figure 3.6: Single Line Diagram of the Debpur 230/132kV Substation, Comilla Civil Structures for Equipment Housings, Control Room and Other Facilities

34

Control of 230kV Lines for the 230/132kV Substation 89. The location of the 230/132kV Substation control room is shown in Figure 3.7 below. The inside of the control panel is shown in Figure 3.8 below.

Figure 3.7: Location of the 230/132kV substation Control Room7

Figure 3.8: Inside the 230/132kV substation Control Room

Associated Facility 90. Construction of the 10.6 km long 400 kV OHL on the India side for 500 MW power transfer from Surajmaninagar (Tripura, India) to Comilla will be constructed by Power Grid Corporation of India Limited (PGCIL). As shown on Figure 3.9 (red arrow portion), viability and existence of this line does not depend exclusively on the proposed ADB project as this line will cater to power demand of Tripura state, improve the grid reliability and provide alternate evacuation path to OTPC Palatana generation (726 MW). 91. As per the ADB’s SPS 2009, associated facilities: a. that are not funded as part of the project (funding may be provided separately by the borrower/client or by third parties); b. whose viability and existence depend exclusively on the project; and c. whose goods or services are essential for successful operation of the project. 92. Thus the 10.6 km line does not qualify as “Associated facilities”. 93. However, initial screening of environmental risks has been conducted. As per the preliminary assessment through the integrated biodiversity assessment tool (IBAT), no ecologically/environmentally sensitive area or forest land is found to be directly or indirectly impacted by this 10.6 km line. 94. PGCIL is the first EA conducting the project funded by ADB applying India’s country safeguard system to identify and manage the safeguards issues. Agency-level assessment of PGCB’s Environmental and Social Policy confirmed its consistency with ADB’s SPS 2009. It is expected that the due diligence and environmental management plan developed by PGCIL (for the Surjamaninagar sub-station modifications will comply with ADB’s SPS 2009 as well. As a good practice, PGCB could request PGCIL to confirm and provide information that the 400 kV OHL complies with the Government of India rules for obtaining the mandatory Forest and Environmental clearances as and when requested by PGCB and ADB.

7 See Annex 1 for the environmental audit of the existing sub-station.

35

Figure 3.9 Comilla Connection

36

3.5 Components of Construction Works

Gas Insulated Switchyard (GIS) 95. The key design consideration of the station includes GIS technology8 for switching and connecting to the bus bars. The GIS based switchyards have their pros and cons over Air Insulated Switchyards. The design will incorporate ideas as to enhance the pros and reduce the cons of the switchyard. Valve Hall 96. The Valve Hall will house the converter that would convert the incoming 400 kV AC to HVDC and then to 230 kV AC. The Valve Hall will have a proper air circulation and air-cooling system in the housing. Adequate lighting will ensure easy maintenance, when required. Filter Reactors, Capacitors and Transformers 97. The filter reactors and capacitors in series and shunt at 400 kV and 230 kV ends will work as current smoothing and for lower order harmonic filtering purposes. The filter reactors and capacitors will be properly mounted on steel structures bolted on the foundation beneath them. The same consideration will be taken for transformers, as the dimensions and weights of such heavy equipment will be of importance. Protection and Control 98. The protection and control system will be fully automated. The automated system will be inside housing; i.e., the control room with adequate lighting, air circulation, and temperature controlled (~20°C) at all times. The station will have a reliable control system, chosen carefully from a list of contractors bidding for component supply. The control system will have easy access and evacuation in case of an emergency. The control room will also have monitoring screens of different facilities through Closed-Circuit Television (CCTV) cameras. Overhead Line (OHL) Entries 99. The OHL Entries will be placed where access to the transmission lines from the towers will be easy and obstruction free. No. of Towers and Safe Clearance Height 100. It is planned that approximately 2 towers will be installed under the 0.5 km OHL of the project, but this number will be finally decided after the detailed route survey (where the new terminations from the existing adjacent towers make most sense, in terms of orientation to the new sub-station infrastructure; however, they will be very close to the project footprint). Further, OHL from tower to tower is always designed avoiding homesteads to cross over, rather in crossing the rural roads safe clearance heights will be maintained as: Approx. 6m -7m (for 132 kV TL); Approx. 8m -9m (for 230 kV TL) and Approx. 11m (for 400 kV TL). (Source: PGCB). In any case, there is plenty of scope to position the new termination towers in farmland away from houses or trees (see Annex 2). Other Components and Works 101. The project will be based on a turnkey handover. As such, transportation, installation, testing and commissioning of the electrical components will be completed by the vendor. All components will be procured from companies with good reputations.

8 SF6 gas is used, which is non-toxic, but it has a high GHG value, so leakage must be avoided.

37

102. The supplier will make sure the components are properly installed and not damaged during the installation process. Any component that may be damaged during installation or due to transportation to the facility will be rejected and will be replaced by the supplier. Electrical Work 103. Electrical works of the HVDC Station will be of two types. The first will be high voltage (HV) power terminations, and the second will be low voltage (LV) electric connections, such as wiring for measurement, control, and communication, etc. High Voltage Power Terminations 104. The power wiring and connections will include connecting electrical components such as transformers, bus bars, switchyards, circuit breakers, isolators, relays, solid state thyristors, filter capacitors, filter reactors, lightning arresters, etc. Low Voltage Electric Connections 105. Miscellaneous wiring includes instrumentation, measurement and control circuit connections, automation wiring, grounding, and shielding. 106. Some installations, primarily indoor ones or those required to support structures will require completion of associated civil structures. The guidelines for such are mentioned under the civil works in this chapter. All equipment (indoor and outdoor) will be installed as per the specifications and standards provided with the respective equipment. 107. All of the HVDC station components and equipment will be procured from foreign countries. Therefore, there will be minimum domestic resource utilization. Only local materials like bricks, sand, cement, rods, etc. will be used for constructing the facilities. There is a brick kiln (and associated sand quarry) immediately across the highway from the current North Comilla sub-station. Sand and bricks, as needed, can be accessed from there, as well as from the project site (sand).

3.6 Project Related Documentation, Funding, Land Acquisition

108. The project related documentation and administrative works will be completed by PGCB with the help of the consultants and any vendors/ suppliers, construction contractors selected for the project, as per requirements at different phases of the project, for the successful completion of the project. Land acquisition has already been completed and for this the Project Affected People (PAPs) have already been compensated. Project Cost

• The Exchange Rate used in Table 3.3 to 3.4 below is as of November 05, 2017. (1.0 USD (United States Dollar) = 80.90BDT (Bangladesh Taka)

• The estimated cost in BDT Lac (0.1 Million) of the project is given in the Table 3.3 below.

Table 3.3: Estimated Cost of the Project (Bangladesh side)

Source Amount (BDT Lac) Amount USD (mil $)

Government of Bangladesh (GoB) 25,251.11 31.212

Project Aid 101,979.02 126.056

38

Power Grid Company of Bangladesh (PGCB)

6,996.28 8.648

Others 0.00 0.0009

Total 134,226.41 165.916

Sources: Development Project Proposal (DPP), PD Office, PGCB, 2017

109. The modes of financing along with the source of financing in BDT Lac are listed in the Table 3.4 below:

Table 3.4: Mode of Financing with Source in BDT Lac and USD

Source GoB (FE)10 PA (DPA)11 PGCB Others Total PA Source

1 2 3 4 5 6 7

Mode

Loan/Credit 10,100.44 $12.485m

(0.00)

101,979.02 $126.055m

(0.00) 0.00 0.00

112,079.46 $138.540m

(0.00)

Expected from ADB

Grant 0.00

(0.00) 0.00

(0.00) 0.00 0.00

0.00 (0.00)

Equity 15,150.67 $18.728m

(0.00)

0.00 (0.00)

0.00 0.00 15,150.67 $18.728m

(0.00)

Others (PGCB)

0.00 (0.00)

0.00 (0.00)

6,996.28 $8.648m

0.00 6,996.28 $8.648m

(0.00)

Total 25,251.11 $31.213m

(0.00)

101,979.02 $126.055m

(0.00)

6,996.28 $8.648m

0.00 134,226.41 $165.916m

(0.00) Note: For GoB, Loan is 40% and Equity is 60%. Sources: DPP, PD Office, PGCB, 2017

110. The year-wise estimated cost in BDT lac is given in Table 3.5 below.

Table 3.5: Mode of Financing w/ Source in BDT Lac / USD million $

Financial Year GoB (FE) PA

PGCB Others Total RPA DPA12

1 2 3 4 5 6 7

2018-19 55.30

$0.068m 0.00

9900.87 $12.238m

759.37 $0.939m

0.00 10715.54 $13.245m

2019-20 15890.93 $19.643m

0.00

56013.77 $69.238m

1993.48 $2.464m

0.00 73898.18 $91.345m

2020-21 9304.88

$11.502m 0.00

36064.38 $44.579m

4243.43 $5.245m

0.00 49612.69 $61.326m

Grand Total 25251.11 $31.213m

0.00 $0.00m

101979 $126.055m

6996.28 $8.648m

0.00 $0.00m

134226.4 $165.916m

Sources: DPP, PD Office, PGCB, 2017

9 No funding to be provided for the India component. 10 Foreign Exchange 11 Reimbursable Project Aid 12 Direct Project Aid

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3.7 Civil Construction Works

Civil Works 111. The following civil works are expected to occur during the construction phase of the project. The civil works are not listed chronologically as some of the works may overlap with others. 112. Civil works will include: site clearing; setting up a worker camp (for up to 300 workers, although half of these may be local workers) within the current perimeter of the sub-station and new sub-station footprint (see Annex 2); establishing the staging area for equipment and materials; construction of sub-station components; ongoing site maintenance; testing of operational aspects of equipment and new facilities; construction of the tower for linking the existing transmission line to the new sub-station; and, string the line for that connection.

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4 Baseline Information

113. Information on the baseline environmental status of the project area is required for the impact assessment process, to assess and predict the possible environmental consequences of the project interventions. Based on the existing environmental scenario, the potential impacts of subprojects were identified and accordingly an environmental management plan was prepared (see subsequent sections of this IEE). The baseline environmental conditions will help in comparing and monitoring the predicted negative and positive impacts resulting from the project during the pre-construction, construction and operation phases. The impact assessment focused on the direct adverse changes that might be caused by project activities, including effects on the quality of habitats, flora, fauna and humans, socio-economic conditions, current use of land and resources, climate change aspects, physical and cultural heritage properties and biophysical surroundings. The baseline condition of water resources, agriculture, fisheries, ecological resources and socio-economic conditions prevailing in the study area has been established by collecting data from secondary as well as primary sources. The secondary sources included: Bangladesh Water Development Board (BWDB), National Water Resources Database (NWRD), Bangladesh Meteorological Department (BMD), and Bangladesh Bureau of Statistics (BBS). Primary data were collected during the field visits to the study area. 114. The baseline environment is discussed in three broad categories: (i) Physical Environment which includes factors such as topography, geology, earthquake risk, climate, hydrology/drainage, and environmental pollution; (ii) Biological Environment, which includes flora, fauna, Protected Areas, wildlife sanctuaries, forest reserves, and the general ecosystem; and, (iii) Socio-economic Environment, which includes anthropological factors like demography, income, land use, land requirements and infrastructure through secondary data and field studies within the possible impact area (project influence area) for various components of the environment; physical, ecological/biological, and socio-economic parameters. Focus group discussions were carried out in the project impact areas to investigate local environmental conditions, issues, and possible impacts. 4.1 Physical Environment

115. Physical Environment: The physical environment is an important determinant of the environment. The term Physical Environment means the material and tangible conditions in which we live. The baseline conditions of the physical environment of the study area, in terms of meteorology, seismicity, and environmental qualities (water quality, noise quality and air quality), are presented in the following sections.

4.1.1 Meteorology

116. Meteorological information on different parameters, i.e., rainfall, temperature, relative humidity, wind speed, evaporation and sunshine hours have been collected from the BMD station of Comilla. The following sections will provide a clear understanding of the meteorology of the study area.

41

Rainfall 117. The rainy season is significant in the study area in comparison to other districts of the country. November to February are the driest months of the year, with negligible rainfall and while June to September are the wettest months, with highest rainfall intensity. Analysis of the rainfall records of the last 65 years (1948-2013) at Comilla Station shows that the study area received a monthly maximum rainfall of 1,045 mm, which was recorded in July 2002. The collected BMD data are presented in Figure 4.1 below. The figure shows that significant rainfall occurs during the months of May to October (the monsoon), while rain is very insignificant during the months of December to February. The bar graph shows that the highest and lowest values of maximum rainfall are observed during the months of July (1,045 mm, as noted above) and January (52 mm), while the line graph illustrates that the highest and lowest values of average rainfall are observed during the months of July (446 mm) and January (7 mm), respectively.

Figure 4.1: Monthly Cumulative Rainfall at Comilla BMD station

42

118. Monthly average rainfall from 2015 to 2017 has been analysed in Figure 4.2 which shows that rainfall is maximum on July (22.08 cm) and minimum on January (0.02 cm).

Figure 4.2: Monthly average rainfall at Comilla BMD station from 2015 to 2017

0.020.93

3.38

7.61

9.2210.31

22.08

10.66

8.91

4.61

2.18 1.85

0

5

10

15

20

25

Ra

infa

ll (

cm)

Month

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

43

Temperature 119. There is a variation of temperature all the year round, but not so widely in the study area. The temperature data of Comilla Station for the last 65 years (1948-2013) shows that the monthly maximum temperature varies from 31.7°C (January) to 41.8 °C (April). April is the warmest month, whereas the monthly minimum temperature varies within the range of 5.3°C (January) to 18.3°C (September), and January is the coldest month in the study area. The highest maximum temperature ever recorded in the last 65 years is 41.8 °C (April 2001), while the lowest-ever recorded minimum temperature is 5.3°C, recorded in January 1979. The monthly maximum and minimum temperatures in the last 65 years (1948-2013) are presented in Figure 4.3 below.

Figure 4.3: Monthly maximum and minimum Temperature at Comilla BMD station

120. The monthly average maximum and minimum temperature from the last 3 years (2015 to 2017) has been analysed in Figure 4.4. It shows that temperature is at a maximum in March to May and a minimum in November to January. The maximum temperature varies from 25.6 to 33.3oC, whereas the minimum temperature fluctuates within 13.5 to 26.30oC.

Figure 4.4: Monthly average maximum and minimum temperature at Comilla BMD station

from 2015-17

0

5

10

15

20

25

30

35

40


Te

mp

era

ture

(0C

)

Month

Maximum Temperature Minimum Temperature

44

Humidity 121. Relative humidity is the ratio of the partial pressure of water vapour in an air-water mixture to the saturated vapour pressure of water at a prescribed temperature. The value depends on temperature and the pressure of the system of interest. As the temperature of the atmosphere increases, vapour carrying capacity of air increases, and thus the atmospheric vapour pressure also increases. The monthly maximum, average and minimum relative humidity at Comilla Station for the last 65 years (1948-2013) are presented in Figure 4.5. 122. Figure 4.5 shows that the monthly average relative humidity in the study area varies seasonally from 72.9% (February) to 87.6% (July). The most humid months are May to October (relative humidity greater than 80%, and varying from 82 to 88%), while during January to March it remains lowest within a range from 27.4 to 33.9%. The line graph of average relative humidity demonstrates a significant fluctuation as relative humidity values start to increase from April due to the increase in atmospheric water vapours coupled with temperature rise. Relative humidity rises above 85% in the monsoon (June to September) and starts decreasing in the post-monsoon season, following the monsoon rainfall.

Figure 4.5: Monthly Relative Humidity at Comilla BMD station

45

123. Monthly maximum, average and minimum relative humidity data have been analyzed from 2015 to 2017, indicating that maximum relative humidity is almost 100% and minimum relative humidity varies within 18 to 57%. Also, average relative humidity ranges in between 75 and 87% (see Figure 4.6).

Figure 4.6: Monthly maximum, average and minimum relative humidity at Comilla BMD station from 2015 to 2017

Evaporation 124. Water is transformed from the surface to the atmosphere through a process of evaporation. Therefore, evaporation is another important component of the hydrological cycle which influences the overall water balance on the earth’s surface. Historical evaporation data at Comilla Station for the last 25 years (1986-2011) have been collected from the BMD station. These indicate that the average evaporation rate varies from 2.1 (January) to 4.1 (May) mm/day. The variation of the average evaporation rate for the study area is presented in Figure 4.7 below.

Figure 4.7: Monthly average evaporation rate at Comilla BMD station

0

20

40

60

80

100


Hu

mu

dit

y (

%)

MonthMaximum Average Minimum

46

Sunshine Hours 125. Sunshine hour’s data at Comilla Station for the last 30 years (1981-2013) have been collected and analyzed. The monthly average values of sunshine hours in Comilla vary from 4.5 to 7.9 hours/day. The average value of sunshine hours is highest in March (7.9 hr/day) and lowest in July (4.5 hr/day). Figure 4.8 shows that from November to April (except January), the daily average sunshine hours are higher than 7 hours, but due to increased extent of cloud-cover in the monsoon (June to September), the values dropped below 5.5 hr/day.

Figure 4.8: Monthly average sunshine hours per day at Comilla BMD station

126. The monthly average sunshine hours per day from 2015 to 2017 have been analyzed in Figure 4.9, which indicates that sunshine hours are maximum in March and November (7 hr/day) and minimum in June-July (3.3 hr/day).

Figure 4.9: Monthly Average Sunshine hours per day at Comilla BMD station from 2015 to

2017

5.86.4

7.0

6.26.3

5.3

3.3

5.15.0

6.0

7.0

5.1

0

1

2

3

4

5

6

7

8

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov DecSu

nsh

ine

Ho

ur

(hr/

Da

y)

Month

47

Wind Speed 127. The monthly average wind speed in the Comilla region varies from 36 to 201 km/day. The variation of monthly average wind speed is presented in Figure 4.10 below. The figure shows that the average speed of wind is highest in July (201 km/day) and lowest in December (36 km/day).

Figure 4.10: Monthly variation of average wind speed at Comilla BMD station

128. Monthly variation of average wind speed in the last 3 years (2015 to 2017) has been analyzed in Figure 4.11. It indicates that wind speed is highest during the month of April (131.86 km/day), and lowest in November (29.11 km/day).

Figure 4.11: Monthly variation of average wind speed at Comilla BMD station from 2015

to 2017

40.6439.97

50.52

131.86

81.03

94.8896.71

89.55

50.5936.04

34.5029.11

0

20

40

60

80

100

120

140


Win

d S

pe

ed

(K

m/d

ay

)

Month

48

4.1.2 Geology

129. Bangladesh consists of nine major tectonic units namely Himalayan Foredeep, Rangpur Platform, Sylhet trough, Calcutta- Mymensingh Hinge, Bogra Shelf, Faridpur Trough, Barisal Gravity High, Hatiya Trough and Indo - Burma Ranges (Figure 4.12). The study area falls in the Indo - Burman Range as well as the Barisal Gravity High zone. Indo Burman Range 130. The Indo–Burman Range has a complicated and relatively recent tectonic history and lies within the folded hill range of the Chittagong Hill Tracts Region. The relative plate motion between the Indian and Burmese plates has been responsible for the development of the main east-west compression in this region. The area is the natural western extension of the Arakan Yoma anticlinoria. The study area is a part of the Chittagong coastal plain and the greater part of this area is underlain by sediments washed out of the adjoining hill ranges (Source: Brammer, 2012.The Physical Geography of Bangladesh. The University Press Ltd., Dhaka, Bangladesh. Link: http://en.banglapedia.org/index.php?title=Earthquake). Barisal Gravity High 131. The Barisal-Chandpur High is interpreted as a gravity and magnetic anomaly caused by a magmatic body at great depth. This zone is located between the Faridpur trough and Hatiya trough of the Bengal Fore deep. The width of the zone is about 60 km and apparently corresponds to an uplift of the sedimentary cover. A number of gravity anomalies are spread over this zone. A paleo-high stretching from the Barisal-Chandpur High in the NE north east direction has been presumed and the ridge was interpreted to turn south of the Barisal-Chandpur High in a north-south direction, merging with the Ninety East Ridge. There is no definite evidence for existence of such a ridge dividing the Bengal Fore deep into two parts. Patharghata, Laksmipur, Munshiganj, Kamta and Daudkandi are the main anticline structures of this zone.

http://en.banglapedia.org/index.php?title=Earthquake

49

Figure 4.12: Tectonic Map of the Study Area

50

Seismic Classification 132. The HVDC Sub-Station Comilla’s location in the seismic map of Bangladesh has been placed in the Figure 4.13 below. As classified, the project area falls under Seismic Classification Zone II of Bangladesh (earthquakes have been relatively common, on the Indian side of the border, but usually only of moderate size and historically not causing much structural damage in eastern Bangladesh; nevertheless, current building codes addressing seismic risk will be followed).

Figure 4.13: Seismic Map of the Study Area

51

(Source: Banglapedia; Link: http://en.banglapedia.org/index.php?title=Tectonic_Framework).

http://en.banglapedia.org/index.php?title=Tectonic_Framework

52

4.1.3 Water Resources

Surface Water Level 133. Maximum, minimum and average surface water level data have been collected and analyzed for Gobindapur Station (Station ID – 112) which is 1.5 kilometre from the project site. Historical data have been collected from BWDB for the period of 1923 to -1979. 134. From the Figure 4.14 it is shown that the surface water level varies within 4 to 8.5 m with respect to PWD datum. Water level increases about 2-3 meter in the monsoon period (May to October) while average water level ranges within 4 to 7 m PWD at Gobindapur Station.

Figure 4.14: Monthly Water Level Analysis at Gobindapur station of Gomti River

(Station ID-112, 1923-1979)

Groundwater Level 135. Groundwater data at the BWDB observation well COM008 at Burichang Thana (0.5 km from the project site) have been collected for the period from 1977 to -2013 and analyzed. The average monthly data are plotted in Figure 4.15. The figure indicates that groundwater depth varies from 2 to 5 m, going up to 5 m during March-April (end of dry season) and decreasing during August-October (2 m; end of monsoon, indicating recharge).

53

Figure 4.15: Average Monthly Variations of Ground Water Table (1977-2013)

Water Logging 136. The water logging problem is a vital issue for the study area, to be considered in constructing the Sub-Station at Comilla. The adjacent canals of the study area have been filled up and narrowed down due to construction and development activities (such as the Sylhet-Comilla highway) and siltation over the last 10-15 years. According to the perception of local people, siltation at Gomti River, as well as the damaged embankment of the river, is also responsible for water logging in the project area (not that water floods the area from the river, but that monsoon rains do not quickly drain through the old drainage channels and canals, back to the river). As a result, the quick runoff from the high land west and east of the project site accumulates in the area and remains for almost the whole year. The lowest elevation within the project footprint is 9 meters above sea level (asl) on the western edge of the site, and is 11 meters asl on the eastern edge of the site. The surrounding villages are on raised platforms at 13-14 meters asl. The existing sub-station is at 12-13 meters asl. As a result, the natural tendency would be for water to drain to the north-northwest of the site, eventually finding its way to the river in the old canal system (mentioned above). Ideally, a perimeter canal should be constructed and water directed away in this manner, especially as the site will be raised (above expected flood levels) and this will force water within the area between the site and the villages. The borrow pit or channel along the site boundary (required for sand for building up the site elevation) would provide the needed drainage canal to direct water to the north-northwest.

54

Figure 4.16: Water Logging near the Study Area

55

137. In order to construct the Substation at Comilla, it is mandatory to drain out the stagnant water from the project area. To some extent, this will happen when the site is built up (from 9-10 meters asl to at least 12-13 meters asl) with the sand from the perimeter (see GoogleEarth images in Annex 2), with the perimeter (borrow pit, or channel) then forming a drainage ditch. This would direct site drainage to the north and northwest of the site, to the area with the lowest elevation (about 8 meters asl), that eventually connects with khals further north near Fultoli. In this respect, a map showing a proposed canal (about 600 meters long and going through water-logged fields, terminating at the small bridge on the rural road to the northwest) is presented in Figure 4.17, as well as a layout map in Figure 4.17 (and see Annex 2). The layout provided is still a tentative one. Final layout would be provided by the selected turnkey contractor. After finalization of the layout, the required canal would be constructed within the project premises. These should help address water logging in the project area. The proposed main canal would connect the study area to Fultoli Khal at Kushumpur, which drains into the Daudkandi estuarine waters further downstream. This proposed drainage canal has also been supported by the Chairman of Debpur Union, along with the local dwellers. However, since the project site can be built up with sand from the site perimeter and from the brick yard across the highway, the proposed canal is not essential to maintain a dry site (it is, however, proposed to help reduce the persistent waterlogging in the whole area to the northwest, as a CSR-type project that might be funded between local government and the PGCB; the canal would need to be surveyed and built to avoid damage to adjacent rice fields). The pond in the center of the project site (which is not natural) will be retained within the project footprint. Groundwater wells are located in the villages around the project site, about 100-200 meters from the project site perimeter. These would not likely be affected by more channelized drainage in the low areas between the villages, since their dynamic state is more controlled by annual monsoon rains in any case.

56

Figure 4.17: Map showing the Project Area and the Main Proposed Canal.

Figure 4.18: Layout Map of Proposed canal in the Study Area

57

Anticipated Flood Hazard 138. The project site is just about 1 km from the Old Gomti right embankment, which has a chance of bank failure in the future (the Bangladesh Water Development Board is responsible for embankment maintenance and repairs). As a result, flood water could enter into the project area during the monsoon period. However, the villages and roads between the project site and the Gomti River are at 13-14 meters asl (as noted previously) and would provide some flood protection for the project site. Nevertheless, to avoid any damage at the project site, the plinth level of project structures will be elevated to a safe height of at least 1.5m13 above highest flood level (to accommodate possible accelerated risk of flooding due to climate change). This can be achieved by using sand (contained) within the project site to raise the building platforms, prior to pouring cement foundations (this is normal site preparation practice in Bangladesh, especially in waterlogged areas; sand is often pumped from adjacent rivers, which helps reduce river navigation risks). Note: Elevation of the project site above Mean Sea Level is 6.47-6.50 m and Highest Flood Level-8.50m (Ref: Public Works Department)14 Erosion 139. The project area of the Sub Station is almost 1 km from the Gomti River. The banks of the Gomti River suffer from erosion problems annually, mostly in the monsoon and post-monsoon periods. However, due to bank protection alongside the Gomti River, there has been no severe flooding problem (despite the perceived risk identified above). There are currently several transmission towers near the Gomti (on both sides). The closest is 55 meters from the Gomti (right bank) and to date has not been affected by flooding or erosion (see Annex 2). Storm 140. There are some evidences of local seasonal storms, popularly known as nor’westers (Kalbaishakhi). Severe nor’westers are generally associated with tornadoes. According to the local dwellers, the frequency of nor’westers usually reaches a maximum in April, whereas it is low in May and at a minimum in March. Nor’westers and tornadoes are more frequent in the afternoon. Nor ‘esters may occur in late February to April, due to early withdrawal of winter from the Shillong Plateau of India.

4.1.4 Land Type

141. The land type classification is based on depth of inundation during the monsoon season, due to normal flooding on agriculture land. According to the Master Plan Organization (MPO, 1987), five land types (High land, Medium high land, Medium low land, Low land, and Very low land) have been classified in terms of depth of flooding on agricultural land. The entire study area is under medium highland (F1) which is normally flooded between 0-90 cm depth of water continuously more than two weeks to a few months during the monsoon season (Source: Master Plan Organization MPO, Technical Report No-1, 1987 and field observation, July; 2018). Soil Texture 142. Soil texture is an important soil characteristic that determines crop selection, crop production and also field management. It influences many other properties of great significance

13 The earth filling level (benchmark of HVDC station) is 10.5m. The highest flood level is 9.0m. 1.5m extra height will

be maintained beyond highest flood level. This data is collected from Bangladesh Water Development Board. 14 Note that there is a difference of about 1-2 meters between the elevations noted here and those identified on

GoogleEarth, used in previous text. The relative difference between elevations in different areas would still be the same.

58

to land use and management. Soil texture is the relative proportion of sand, silt and clay (in four major textural classes: a) sands b) silts c) loams and d) clays). However, the entire study area is under the clay loam texture (Source: SOLARIS- Soil Resources Development Institute, 2006). This means it is fine sand and clay admixture (from historical floodplain activity). The project site is predominantly rice fields or abandoned plots.15 Land Resources 143. Land comprises natural resources such as soils, minerals, water bodies, and biota. These components are organized in ecosystems which provide a variety of services essential to the maintenance of the integrity of life–support systems and related productive capacity. Agro-Ecological Zones (AEZs) 144. Thirty Agro-ecological Zones (AEZs), 88 sub-regions and 536 units have been identified by adding successive layers of information on the physical environment. These are relevant for land use and assessing agricultural potential in Bangladesh (2012). The study area falls in one agro-ecological zone named Old Meghna Estuarine Floodplain (AEZ-19). Soil characteristics of this AEZ are presented below. 145. This region occupies a large area, mainly low-lying, between a spot south of the Surma-Kusiyara Floodplain and the northern edge of the Young Meghna Estuarine Floodplain. It comprises smooth, almost level, floodplain ridges and shallow basins. 146. Silt loam soils predominate in the highlands and silt clay to clay in low lands. Non-calcareous Dark Grey Floodplain soil is the only General Soil Type of the area. The organic matter content of the soil is low to medium. The moisture holding capacity is medium. Top soils are slightly acidic to or slightly alkaline, but sub-soils are neutral. The general fertility level is medium. The status of potassium is low to optimum. The level of phosphorus is very low. to low, Sulphur is low to medium and Boron status ranges from low to optimum.

15 The presence of rice fields indicates the historical use of pesticides; these either evacuate the area in monsoon flood

discharge or may be retained and eventually mineralized in underlying sediments, depending on the types of pesticides used.

59

Figure 4.19: Agro-ecological Zone of the study area

Land use 147. The study area is 79 ha for the construction of the proposed HVDC Station. Within this the area, net cultivable area (NCA) is 51 hectare (65% of gross area) and the rest comprises aquaculture (6% of gross area), and settlements with homestead vegetation (29% of gross area). The detailed land use of the study area is presented in Table 4.1.

Table 4.1: Present land use of the study area

Land Use Area (Hectare) % of Gross Area

NCA 51 65

60

Aquaculture 5 6

Settlement with homestead vegetation 23 29

Grand Total 79 100

61

Figure 4.20: Land use in the study area16

4.2 Environmental Quality

148. This section provides a baseline scenario on the environmental indicators, i.e., air quality, water quality, and noise levels in the study area. The values of these environmental parameters were collected during the field visit in the study area at Comilla.

4.2.1 Methodology

16 Note that there is a fish pond in the center of the project site. Its historical use is discussed later in this document.

62

149. Potential environmental and social aspects were identified based on-site visits, interviews with affected persons, stake holder engagement, environmental sampling, collection of relevant and secondary data, review of relevant project documents such as feasibility studies, survey reports etc. The significant potential values and information have been reflected in the subsequent parts of this report.

4.2.2 Air Quality

150. The ambient status of seven air quality parameters viz. Particulate Matters(PM), Suspended Particulate Matter (SPM), Sulphur Dioxide (SO2), Oxides of Nitrogen (NOx), Carbon Monoxide (CO) and Ozone (O3) representing the quality of pollution level have been assessed at Debpur Union of the project area (on the perimeter of the project site, at the current sub-station, using 24 hours time frame. Result was calculated using average values of parameters except Carbon Monooxide and Ozone. These two parameters were calculated using 8 hours timeframe). It is observed that the values of parameters in almost all of the points are within the allowable limit as compared to Government of Bangladesh. There is evidence of dust (slightly elevated, compared to the WHO guidelines), which may reflect activities at the current sub-station, as well as the Sylhet-Comilla highway, and the brick kiln immediately across the highway. The measurement results are presented in Table 4.2. Details of air quality results and methodology are given in Appendix III (separate document).

Table 4.2: Value of air quality parameters at selected locations in the study area

Date of Measurement

Location

Concentration present of different parameters in ambient air

(µg/m3) (mg/m3)

PM

2.5

PM

10

SP

M

SO

2

NO

2

O3

CO

08-09/08/2018

Kacharitala, Debpur Union, Comilla.

23º 30´ 32.4´ N17 91º 06´ 09.2´ E

35.1 72.2 123.6 8.2 20.3 21.0 0.72

Bangladesh standard 65 150 200 80 100 235 40

IFC/WB Standard (WHO guideline)

2518 50 230 20 200 100 100

Source: Laboratory analysis, August; 2018 Note: PM2.5=Fine Particulate Matter, PM10= Respirable Dust Content, SPM= Suspended Particulate Matter, NOX = Oxides of Nitrogen, SO2 = Sulphur Dioxide, CO = Carbon Monoxide, O3= Ozone

4.2.3 Water Quality

17 This is at the corner of the current sub-station site immediately adjacent to the new project footprint. 18 WHO guideline for 24-hour period for all parameters; except NO2, which is one hour, and ozone which is 8-hour daily

maximum.

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151. Water quality is one of the important indicators of the environment. As such, water samples from the surface and groundwater sources were collected to understand the baseline condition of both of the sources. Some parameters of the surface water quality were measured in-situ during the field visit at Comilla. For groundwater, water samples were collected from tube-wells at different locations in the study area and tested in the Department of Public Health Engineering Central Laboratory. Water sample and quality assessment details are presented in Table 4.3.

Table 4.3: Water Quality Assessment Details

SL No

Water Source Type

Sample No

Location within100 m of the Project Site19

GPS Date & Time

Parameters

1 Surface Water

SW 1 Debpur N 23º 30’ 42.93” E 91º 06’ 1.78”

24/07/18 2:30 pm

Temperature, EC, TDS, Turbidity, Salinity, pH

2 Surface Water

SW 2 HarinDhara N 23º 30’ 45.76” E 91º 06’ 21.81”

24/07/18 3:30 pm

Temperature, EC,TDS, Turbidity, Salinity, pH

3 Ground Water

GW 1 Debpur N 23º 30’43.11” E 91º 06’ 2.45”

24/07/18 2:30 pm

Arsenic, Iron

4 Ground Water

GW 2 HarinDhara N 23º 30’ 45.42” E 91º 06’ 21.66”

24/07/18 3:30 pm

Arsenic, Iron

Source: CEGIS field Survey, 2018

Surface and Ground Water 152. A number of water quality parameters of surface and ground water around the study area during the field visit were tested; the values are presented in Tables 4.4 and 4.5. 153. It shows that the values of tested parameters are within or around the DoE standard. But some exceed the limits. Higher values of turbidity were likely caused by ongoing rain and runoff during sampling and the fact that water was seen being used for various purposes like cattle bathing and garden watering. It is possible that one groundwater sample was contaminated during collection (high turbidity value). Both surface and groundwater will be sampled and analyzed again before and during project construction, as part of the regular environmental monitoring program.

Table 4.4: Surface Water Quality of the Study Area Comilla

Location Sample No.

Water quality parameter

TDS (mg/L)

EC (μS/cm)

Turbidity (NTU)

Temperature (°C)

PH Salinity (ppm)

Debpur SW 1 107 211 14.9 26.5 7.82 160 ppm

Debpur SW 2 41.8 79.9 69.3 26.5 7.63 38.3 ppm

DoE Standard for Surface Water for Fisheries

500 80-1,000 - 25 6.5-8.5 -

Ground water

Table 4.5: Ground Water Quality

19 Note that tube wells are located in the villages, about 100-200 meters from the project footprint perimeter, and surface

water in the area is not used for drinking (given the availability of groundwater). 4 samples were used.

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Location Sample No.

Water quality parameter

Total Dissolved

Solid (TDS) (mg/L)

Electric Conductivity

(EC) (ms/cm)

Turbidity (NTU)

Arsenic (mg/L)

Iron (mg/L)

Temperature (°C)

PH

Salinity (ppm)

Harindhara GW 1 8.7 15.8 2.55 0.001 0.37 26.5 7.61 1.88

Harindhara GW 2 12.8 24.46 2120 0.003 1.0 26.5 7.6 1.89

DoE Standard Value for

Drinking Water 1,000 - 10 0.05 0.3-1 20-30 6.5-8.5 -

4.2.4 Noise Quality

154. For testing noise levels, various locations were selected including settlements, schools, bazaars etc. Two suitable sites were selected within the study area for recording noise level. DoE has defined standard noise levels during day time and night time, which is shown in Table 4.7. The study area has fallen under the category of Residential Zone and the values of noise levels were found slightly exceeding the residential daytime standard (probably due to the proximity of the Sylhet-Comilla highway, and also it was raining at the time of sampling, and rain on an umbrella may have also been a factor). The noise levels will be measured again before the start of the construction and then routinely during project construction, including night time readings. The noise values at present are shown in Table 4.8.

Table 4.7: Standards of Noise Levels for Different Zones of Bangladesh (latest WHO Europe guidelines for traffic areas noted in brackets)

Zone Class

Limits in dB21

Daytime Nighttime

(6 am – 9 pm) (9 pm – 6 am)

Silent zone 45 35

Residential zone 50 (53) 40 (45)

Mixed 60 50

Commercial zone 70 60

Industrial zone 75 70 Source: Bangladesh Gadget, 2006

Table 4.8: Daytime Noise Levels of the Study Area of Comilla

Sl. No. Place GPS Reading Values (dB)

Area Category by DoE Min Average Max

1 Debpur N 22º 19’ 40” E 91º 50’ 33” 40 56 74 Residential Zone

2 Harindhara N 22º 19’ 42” E 91º 50’ 40” 43 55 70 Residential Zone

Source: CEGIS field survey, July 2018 Note: Data Shown is 3 times average taken every 4 hours.

20 Turbidity results suggest that this sample may have been contaminated during collection. 21 There is no mentioning of any averaging time like that of WHO in the GOB Environmental Conservation Rules of

1997 and its amendment vide Bangladesh Gazette Additional September 7, 2006 under Schedule -4: Standards for Sound.

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4.3 Agriculture

4.3.1 Farming practices

155. The study area is mainly agriculture land. A rice-based cropping pattern is observed in the study area. A double cropping pattern is practiced by the farmers in the study area. The major cropping pattern within the study area is Fallow- High Yielding Variety (HYV) Aman-HYV & Boro which is about 61% of the NCA. During Kharif-II season, HYV Aman and Lt. Aman is grown under rain-fed conditions and HYV Boro is grown during the Rabi/dry season, under irrigated conditions. Local farmers stated that groundwater is the main source of irrigation during the Rabi/dry season. Groundwater is extracted with the help of Deep Tube Wells (DTWs) within and near the villages. Intercultural operations (weeding, thinning, etc.) are mainly done by traditional ways. The cropping intensity of the study area is about 200%. A detailed cropping pattern in the study area is shown in Table 4.10.

Figure 4.21:Seed bed of HYV Aman in the

study area Figure 4.22: Present condition under the

HVDC Station area

Table 4.10: Existing cropping pattern in the study area

Land type Kharif-I

(March- June) Kharif-II

(July-October) Rabi

(November-February) Area

(hectare) % of NCA

Medium high land (F1)

Fallow HYV Aman HYV Boro 31 61

Fallow Lt. Aman HYV Boro 20 39

Total 51 100

Cropping intensity (%) 200 Source: CEGIS estimation from field information; July 2018

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Table 4.11: Detailed information on the proposed HVDC Station area (agricultural production)22

SL No.

Name of HVDC Station

Area required

(ha)

Observations

HVDC Station

type

Energy efficiency

Cropping pattern Crop production

1 Harindhara,

Comilla 16.00

Back-to-Back

400kV

Double cropped area i) Fallow-HYV Aman-

HYV Boro(22%) ii) Fallow-Lt. Aman–

HYV Boro (78%)

i) HYV Aman: 25 tons , HYV Boro: 33

tons ii) Lt. Aman:27 tons, HYV Boro: 41tons

Total 16.00 Total rice crop production is 126 tons of which HYV Aman, Lt. Aman

and HYV Boro are about 25 tons, 27 tons and 74 tons Source: CEGIS estimation from field information; July 2018

Table 4.12: Area and location of Bio-ecological zones within the HVDC Station area

Bio-ecological zone Study Area (ha.) Project Area (ha.) Percentage (%)

Meghna Floodplain 79 16 100 Source: 1- NWRD 2012; 2-International Union for Conservation of Nature (IUCN), 2002 and CEGIS data base

22 If a drainage canal is constructed, it would have to cut across rice fields for a length of about 600 m, to the northwest.

This plan is not yet firm; prevailing drainage needs to be examined once the project site has been built up to the required height for setting the building plinths.

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4.3.2 Cropped area, yield and crop production

156. The crop yield rate haves been determined from the field level in consultation with farmers and local people. Therefore, crop production has been calculated on the basis of crop yield against crop area. In the study area, total cropped area (rice) is about 102 (51x2) hectare and total rice crop production is 359 tons. Among the rice crop production, the contributions of HYV Aman, Lt. Aman and HYV Boro are about 96 tons (27%), 54tons (15%) and 209 tons (58%), respectively. The detailed existing cropped area, yield and crop production of the study area are presented in Table 4.13.

Table 4.13: Crop area, yield and crop production in the study area

Crop name Crop Area (hectare)

Yield (ton/hectare)

Production (ton) % Contribution

HYV Aman 31 3.1 96 27

Lt. Aman 20 2.7 54 15

HYV Boro 51 4.1 209 58

Total 102 9.9 359 100

Source: CEGIS estimation from field information; July 2018

4.3.3 Seeds and labor

157. Seed, labour, fertilizer, pesticide 23 and irrigation are the major inputs used for crop production. Selection of seeds should be considered on the basis of more than 85% germination rate, free from disease infestation, good shape and size, and high yield potential. Agricultural labour is considered as one of the essential inputs for crop production. However, the labour requirement is not uniform throughout the year. Labour requirement varies from crop to crop. Seed/hectare and average number of labours used per hectare are presented in Table 4.14.

Table 4.14: Seed and Labor used in the study area Crop Name Seeds Used (Kg/ha) Labor Requirement (No/ha)

HYV Aman 40-45 160

Lt. Aman 35-40 125

HYV Boro 45-50 180

Source: CEGIS estimation from field information; July 2018

23 Soil within the project area can be tested for pesticides prior to construction. However, as the site has to be filled

and levelled, it is unlikely that any soil will be discarded, creating a hazard elsewhere. All soil will be needed to elevate the site to address the potential flooding risk, as discussed previously.

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4.3.4 Fertilizer and Pesticides

158. The rate of fertilizer used per hectare varies considerably from farmer to farmer depending on soil fertility, cropping pattern, and financial ability. The major fertilizers used in this area are Urea, Triple Superphosphate (TSP) and Murat of Potash (MP), in rice production. The use of pesticides depends on the degree of pest infestation. Application of pesticides has been noted at 1-2 times per year to control pests and diseases for the rice crops grown in the areas. The major insects, as reported by the farmers, are Stem borer, Green leaf hopper, Grass hopper, and Rice bug. Local farmer reported that they are using different types of pesticides such as Ostad, Score, Fighter, Hildon, Furadan 10G, Basudin 10G, Diazinon, Tilt, and Cumulus to prevent pest infestation in rice and vegetable cultivation. Liquid, granular and powder pesticides are being used for pest control. Farmers, in general, apply liquid pesticides with the help of a sprayer, but sometimes they mix granular/powder pesticides with the fertilizers and then apply this to the fields. Detailed information on fertilizer and pesticides application is presented in Table 4.15. Table 4.15: Detailed information on Fertilizer and Pesticides application in the study area

Crop Name Fertilizer (Kg/ha) Pesticides

Urea TSP MP Other (Gyp)

No of Application. Liq. (ml/ha) Gran. / Pow. (Kg/ha)

HYV Aman 110 80 50 0 1-2 700 5

Lt. Aman 80 60 30 0 2-3 400 0

HYV Boro 200 100 75 0 1-2 800 8 Source: CEGIS estimation from field information; July 2018

4.3.5 Information of Impacts on Crop from Transmission Line

159. Power will be transmitted through the existing 132 kV transmission line (see Annex 2, for the location of all towers for power transmission from India to the Comilla North sub-station) by converting this line into a 400kV transmission line (re-stringing, as needed). So, there is no possibility to impact on existing crop production (the only impact will come from land acquisition in the sub-station area).

4.3.6 Crop production at HVDC Station

160. A total of 16.0 ha of land is required for construction of the HVDC Station, which is agricultural land and also comprises pond and road. Total rice crop production is 126 tons in the HVDC Station area, of which HYV Aman, Lt. Aman and HYV Boro are about 25 tons, 27 tons, and 74 tons, respectively. Details are presented in Table 4.16.

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Table 4.16: Detailed information on the proposed HVDC Station area (agricultural production)

SL No.

Name of HVDC Station

Area required

(ha)

Observations

HVDC Station

type

Energy efficiency

Cropping pattern Crop production

1 Harindhara,

Comilla 16.00

Back-to-Back

400 kV

Double cropped area

i) Fallow-HYV Aman- HYV Boro

(22%) ii) Fallow-Lt. Aman–

HYV Boro (78%)

i) HYV Aman: 25 tons, HYV Boro: 33 tons

ii) Lt. Aman: 27 tons, HYV Boro: 41 tons

Total 16.00 Total rice crop production is 126 tons of which HYV Aman, Lt. Aman

and HYV Boro are about 25 tons, 27 tons and 74 tons Source: CEGIS estimation from field information; July 2018

4.3.7 Crop production at Tower Footings

161. About 0.365 hectares area is required at 2 tower footings for construction of towers (for transmission line access to the new sub-station components, coming from the existing transmission line) along the road from Harindhara to Debpur (immediately adjacent to the project footprint). This area is mainly used for agricultural (rice-based) crop production during the Kharif-II and Rabi/Boro seasons. A total of 1.20 tons of rice is produced, of which the contributions of HYV Aman, Lt. Aman and HYV Boro are 0.45 ton (37.5%), 0.30 ton (25%) and 0.45 ton (37.5%), respectively. 4.4 Biological/ Ecological Environment

162. No animals or plants in the project site are considered as endangered or endemic24. The site is also free of migrating birds. There has been no record of bird collision on existing TLs in this area in the past. The project area (16 ha) is an unexceptional, (usually) waterlogged rice-growing area, with just a few trees and one fish pond (see Annex 2). Within 5 km there is an abundance of similar habitat, as well as a few areas to the northwest which are more natural beel areas (marshes). The nearest IBA (according to Birdlife International) is 50 km to the south. Biological Environment 163. It is important to know details on the biological environment and its general components, including their functions and significance, to get a clear scenario about where the HVDC Station and transmission lines are going be set up. There is no important bird area (IBAs) or Key Biodiversity Area (KBAs) declared by the Birdlife International nor protected areas, including Ecologically Critical Areas (ECAs) within the study and project areas. Bio-ecological Zone: 164. The proposed HVDC Sub-station will be located in a waterlogged rice growing area, characterized by active rice fields, some abandoned plots, one dirt road, and a few trees, as well as a man-made fish pond.25 The project area occurs within the Bio-ecological zone Meghna

24 The Tire Track Eel, found in the project vicinity, is not endangered in the global IUCN Redbook listing, but is listed

as “endangered” by Bangladesh IUCN, although it is commonly found throughout all of Bangladesh (perceived to be under pressure of habitat loss). However, there is abundant aquatic habitat throughout all of this part of Bangladesh, so loss of 16 ha is considered inconsequential.

25 This pond will be retained within the project footprint.

70

Floodplain (Table 4.17). The IUCN Bangladesh has divided the whole country into 25 Bio-ecological Zones in the context of biological diversity, physiographic, and other parameters.

Table 4.17: Area and location of Bio-ecological zones within the HVDC Station area

Bio-ecological zone Zone Study Area

(ha.) Project Area (ha.) Percentage (%)

Meghna Floodplain 79 16 100

Source: 1- NWRD 2012; 2- IUCN, 2002. and CEGIS data base

Fisheries Resources: 165. The proposed new HVDC Station site belongs to a floodplain with a waterlogging problem and having a pond without dike (as noted above). These habitats have some contribution in the local fish production and local livelihoods as well. This baseline description focuses basically on the floodplain and pond fishery of the Project area. Fish Habitat 166. The habitats of the study area are identified as floodplain (water-logged area) and pond (see Annex 2), indicated in the land use data (Source: Land use Section), and the field investigation revealed the same. Parts of the floodplain are seasonally inundated up to 90 cm (Source: Land Type Section), including part of the project area, and thus supports only Small Indigenous Species of fish that are found throughout Bangladesh in this kind of habitat. 167. The pond, receiving water during the wet season, is the lone culture fish habitat (artificial), as it retains water year-round. Fish culture is done in the wet season by installing a net and following the semi-intensive26 fish culture technology. Fish Diversity 168. The floodplain (in this part of Bangladesh) is dominated by small indigenous species of fish, including Tengra (Mystus bleekeri), Golsa (Mystus cavasius), Chola Punti (Puntius chola), Shol (Channa striatas), Koi (Anabas testudineus), and Baim (Mastacembelus armatus). 169. The dominant fish species in the culture ponds in the area are expected to include Rui (Labeo rohita), Catla (Catla catla), Pangus (Pangasius pangasius), and Tilapia (Oreochromis mossambicus). The culture fish habitat in the project area is shown in Figure 4.23.

26 Semi-intensive fish culture: Semi-intensive fish culture depends largely on natural food which is increased over

baseline levels by fertilization and/ or use of supplementary feed to complement natural food.

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Figure 4.23: The culture pond in the project area27

170. A list of some common fish species in the study area and IUCN status is given in Table 4.18.

Table 4.18: IUCN status of fish species

Scientific Name English Name Local Name Habitats

IUCN Local

status, 2015

IUCN Global status, 2015

Capture fishery

Mystus bleekeri Bleeker’sMystus Tengra Floodplain LC LC

Mystus cavasius GangeticMystus Golsha Floodplain NT LC

Mastacembelus armatus Tire track eel Baim Floodplain EN28 NE

Puntius chola Chola Barb CholaPunti Floodplain LC LC

Pethia conchonius Red Barb KanchanPunti Floodplain LC LC

Channa striatas Snakehead Murrel

Shol Floodplain LC LC

Channapunctata Spotted Snakehead

Taki Floodplain LC LC

Anabas testudineus Climbing Perch Koi Floodplain LC DD

27 The four trees adjacent to the pond, along the dirt road, will be retained, if possible, or compensated through

replantation elsewhere. 28 See Footnote 23.

72

Scientific Name English Name Local Name Habitats

IUCN Local

status, 2015

IUCN Global status, 2015

Capture fishery

Culture fishery

Labeo rohita Rohu Rui Pond LC LC

Catla catla Catla Katol Pond LC NE

Cirrhinus cirrhosus Mrigal Carp Mrigel Pond NT VU

Oreochromis mossambicus Tilapia Tilapia Pond Exotic Fish

-

Pangasius hypophthalmus Sutchi Catfish Pangas Pond Exotic Fish

LC

Hypophthalmichthys molitrix Silver Carp Silver Carp Pond Exotic Fish

-

Semi-intensive fish culture: Semi-intensive fish culture depends largely on natural food which is increased over baseline levels by fertilization and/ or use of supplementary feed to complement natural food. Note: IUCN status (EN-Endangered, VU-Vulnerable, NT-Near threatened, LC-Least concern, DD-Data Deficient, NE-Not Evaluated)

Fish production 171. Field finding revealed the temporary small ditch in the project area. In 2015, the estimated annual total fish production in the project area is about 2.5 metric ton (MT). The fish production related to livelihood issue will be assessed and addressed separately.

73

Figure 4.24: Bio-ecological Zone of the Study Area

Existing fish pond

74

Ecosystem Diversity 172. The proposed HVDC Station area predominantly comprises agricultural land (no original, undisturbed habitat). The overall ecosystems in the study area can be classified in following categories: Terrestrial Ecosystem 173. Agricultural field (modified habitat): This land is usually used for paddy cultivation twice in a year and is inundated during the monsoon. The crop field ecosystem has the least diversity of floral communities but provides a wide area of grazing and feeding habitats for numerous indigenous fishes and birds. Aush Aman and Boro paddy is cultivated in the project area, as well as surrounding crop fields of the study area during the dry season (mid-November to the mid-June). These fields remain waterlogged throughout the monsoon period. 174. Species richness of terrestrial local fauna is mainly concentrated in settlements, and birds comprise a higher number of species than other classes. Common bird species (none are endangered) in the study area are Black Drongo (Dicrurus macrocercus), Common Myna (Acrido therestristis), House Crow (Corvus splendens), Bulbul (Pycnonotus flaviventris) and Eastern Spotted Dove (Spilopelia chinensis). These species use both the project area and study area for their feeding purposes, and all use the existing transmission towers and lines in the area for perching and roosting, as they do throughout all of Bangladesh.

Figure 4.25: Agricultural land of Project area Figure 4.26: Agricultural land of Study area

Figure 4.27: Avifauna of Project area (Drongo)

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175. Small terrestrial insects such as Grasshoppers (family Acrididae, Catantopidae), Dragonflies (FamilyLibelluloidea, Libellulidae) are also seen in the study area, as expected.

Figure 4.28: Insect at project area (Common Dragonfly)

176. Roadside: An Akancha road (elevated dirt road) connects Debpur and Harindhara village through the proposed project area. The roadside vegetation is very poor inside the project area, whereas the roadside vegetation in the study area is diverse in nature, in terms of biodiversity. The roadside vegetation of the project area contains poor floral diversity. Asian palmyra palm (Borassusflabellifer) is the only species among the trees (of which there are few, adjacent to the fish pond). Some other climbing herbs, such as Hear-leaf hemp vine (Mikania micrantha) and Spine Gourd (Momordica dioica), are seen along the roadside, including some short and tall grasses; all extremely common throughout Bangladesh, especially roadside habitat.

Figure 4.29: Roadside vegetation at Project area

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177. On the other hand, the overall study area is diversified in roadside vegetation. Asian palmyra palm (Borassus flabellifer), Mango (Mangifera indica), Jackfruit (Artocarpus heterophyllus), Banana (Musa acuminata), Shishu (Dalbergia sissoo), Garjan (Dipterocarpus turbinatus), Mahogany (Swietenia macrophylla), Neem (Azadirachtaindica) are seen as the main tree species (all are common in Bangladesh). Some vegetables, like Spine Gourd (Momordica dioica) and Bottle Gourd (Lagenariasiceraria), are also cultivated beside the road (as they are throughout Bangladesh). Apart from this, some bushy herbs and shrubs are found as roadside vegetation.

Figure 4.30: Roadside vegetation in the Study area

178. Some terrestrial reptile species are found in the study area (not the project area). A few Bengal Monitors (Varanus bengalensis) and Indian Cobras (Naja naja) are found in the bushy remains of the abandoned local crematorium (which is outside the project area). None of these are endangered. 179. Mammal species are fewer in number or have disappeared from the study area, with the disappearance of forest patches or a change in plant species composition. Bigger mammals are rare. Small mammals including Golden Jackal (Canis aureus), Small Indian Mongoose (Herpestes edwardsi) and Field rat (Rattus argentiventer) are the major species seen in the study area (they are not evident in the water-logged project area). 180. These mammals like golden jackal are natives to south-eastern and central Europe, Asia Minor, the Middle East and South Asia. Its range extends from northern India, Bhutan, Nepal and Bangladesh, through central, southern and eastern China and southward to Myanmar and beyond. Similarly, the field rats are native to south-eastern Asia. Its range extends from northern India, Bhutan, Nepal and Bangladesh, through central, southern and eastern China and southward to Myanmar, Thailand, Laos and Vietnam. All these animals are adaptable species and are also found in plantations, on agricultural land and around human dwellings. These are able to live in a number of different environments. No particular threats have been identified, and IUCN has assessed their conservation status as being of Least Concern.

https://en.wikipedia.org/wiki/Least-concern_species

77

181. Homestead vegetation (modified habitat): The proposed project area is an agricultural field. Therefore, no settlements are present there. However, the major homesteads exist on the east and west sides, approximately 65-150 m from the perimeter of the proposed site (see Annex 2 for locations of all homesteads and villages around the site perimeter); homesteads are comparatively higher in elevation than other landforms (as noted previously, about 13-14 meters asl). These homesteads possess mainly terrestrial tree species, i.e., Mango (Mangifera indica), Jackfruit (Artocarpus heterophyllus), Neem (Azadirachta indica), and Betel Nut (Areca catechu). None of these species are endangered; they are commonly found throughout South Asia as cultivated trees.

Figure 4.31: Homestead vegetation at Study area

Aquatic Ecosystem 182. The Gomti River, which flows 1.5 km to the north of the project area, is considered as the main source of water flow to all the local ecological components, both terrestrial and aquatic (in addition to annual monsoon rain, that is the main reason for waterlogging in the area). There is a partially encroached canal (Jaintar khal) present in the project’s surrounding area, which was the main drainage system for the crop field (this is at least 600 meters away from the project site perimeter, to the north).

Figure 4.32: Jaintar khal at Study area

78

183. The seasonal freshwater wetland possesses aquatic vegetation such as Water Lily (Nymphaea nouchali), Watercress (Enhydra fluctuans), Water Hyacinth (Eichhornia crassipes), Water Cabbage (Angiospermum obcordatum), and tall grasses. All these are commonly found throughout inundated areas of South Asia.

Figure 4.33: Aquatic flora at Project area

184. Common Amphibian and Reptile species also occur in this area, including Indian bull frog (Hoplobatrachus tigerinus) and Checkered Keelback snake (Xenochrophis piscator). Water-dependent birds are roaming in the floodplains, ditches and ponds and include Indian Pond Heron (Ardeola grayii), Cattle Egret (Bubulcus ibis), and Common Kingfisher (Alcedo atthis). These animals are all common to water-logged and wetland areas throughout Bangladesh and beyond (they are IUCN Least Concern animals). Further, the birds are co-existing with the existing sub-station infrastructure, adjacent transmission line towers, and the lines themselves, which radiate out from the current sub-station site (kingfishers, especially, use the transmission lines as predation perches).

Figure 4.34: Aquatic bird and amphibian in the Project area

79

Important Bird Area and Bird Migratory Route 185. Bangladesh falls within the East Asia/ Australasia and Central Asian fly zone (shown in Figure 4.35). Flyways are important for the strategic needs and movement of migratory birds. However, none of the threatened species is expected to be affected due to implementation of this project, as none of these migratory species has any core habitat within the project area (as noted previously, the nearest IBA is about 50 km to the south).

Figure 4.35: Birds flyways around the world

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186. There are no IBAs or Key Biodiversity Area (KBAs) declared by the Birdlife International nor protected areas, including Ecologically Critical Areas (ECAs) within the study and project areas. IUCN Status of all the species screening 187. The IUCN status of plants and animals that have been observed in the project and study areas has been noted above. To summarize, the IUCN Red List Status of observed avifauna (including aquatic birds), small mammals, reptiles and amphibians, fish, insects, and plants indicates no endangered or critically endangered species in this area. Only the tire-track eel has an endangered status in Bangladesh (IUCN Bangladesh), but it is very common throughout the country (as noted previously), and does not have IUCN global endangered status. An important point to make here regarding species and habitat protection is that only a small percentage of the water-logged and beel areas within 5-10 km of the project site will be forfeited. 4.5 Socio-Economic Environment

Socio-economic Conditions 188. The socio-economic conditions of people living in the study area are described in this section. The required data were collected from both primary and secondary sources. Methods for primary data collection included Key Informant Interviews, Informal Group Discussions, Field Observation, and Informal Consultations. On the other hand, relevant secondary data/information were collected from the Population and Housing Census, 2011 (BBS, 2012). Area and Location 189. A number of Mouzas are located on both sides of the proposed HVDC Station. These were considered for assessing the socioeconomic baseline conditions. Thus, the study area includes Maynamati Union under Burichang Upazila of Comilla District. The details of administrative locations are given bellow in Table 4.19. Table 4.19: Administrative location of the study area and area coverage (in %) by Mouza

District Thana/Upazila Union/Ward Mouza Total Study Area (Ha.)

Project Area (Ha.)

Mouza Area

Percentage

Comilla Burichang Moynamoti Debpur 14.59 2.22 59

Comilla Burichang Moynamoti Harindhara 44.81 12.35 28

Comilla Burichang Moynamoti PurbaSharippur 13.48 1.58 73

Comilla Burichang Moynamoti Mainpur 5.08 - 10

Source: Spatial Geographic Information System Analysis, CEGIS 2018

Demography 190. Demographic data have been collected from secondary sources. The following Table 4.21 illustrates that there are 283 households in the study area, where 1,404 people are currently living, including 726 males and 678 females. These estimated figures are the projected population for 2018, based on the growth rates (0.137%) of the BBS Census, 2011. The average male-female ratio is 107, where there are 107 males per 100 females; this is higher than the national figure of 100.3 (BBS 2012).

81

Table 4.20: Total Population, Sex Ratio and Household Size

Mouza Household Population Male Female Sex Ratio

Debpur 47 220 117 104 113

Harindhara 113 483 228 255 89

Purba Sharippur 89 532 297 235 127

Mainpur 12 58 27 31 89

Total/Average 261 1,294 669 625 107

Projected population 283 1,404 726 678 107

Source: Population and Housing Census 2011, BBS, 2012, *Estimated to 2018

Household size 191. The average household size in the study area is 4.8, which is higher than the national household size (4.46) of Bangladesh. The following figure (Figure 4.36) shows that most of the households (about 44.5%) in the study area comprise four to five members (BBS, 2012).

Source: Population and Housing Census 2011, BBS, 2012

Figure 4.36: Distribution of households by household members

0.0 5.0 10.0 15.0 20.0 25.0

0.8

8.3

18.1

23.7

20.8

11.7

5.7

10.9

4.8

H O U S E H O L D S C O M P R I S I N G ( % )

82

Age Structure 192. The highest number of the population (24.2%) in the study area belongs to the age category of 30 to 49 years old. Only 2.4% people are in 60 to 64 years category. The population data, when analysed to ascertain the size of the (potentially) active and working population indicates that 62.2% of the population are in the age bracket of 15-64 and can be classified under this category. A small percentage (4.3%) is 65 years or above. The categorization is made on the basis of the International Labour Organization reference for opting out of the potential labour force and the dependent population. The population in the 15 to 64 years category is considered as labour force whereas populations below 14 years and above 65 years are considered as dependents. So, the portion of the dependent and economically active population in the study area is found as 38:62, based on BBS, 2012. (Figure 4.37)


Figure 4.37: Age Structure of the study area

0.0 5.0 10.0 15.0 20.0 25.0

0-4

10-14

20-24

30-49

60-64

10.6

12.2

10.7

10.9

9.6

9.7

24.2

5.3

2.4

4.3

Age Structure (%)

83

Education 193. According to BBS 2012, the literacy rate (based on the definition of ability to write a letter in any language) in the study area is 57.2%, which is higher than the national literacy rate (51.8%). Data also show that the literacy rate of males is higher than that of females (Figure 4.38).


Figure 4.38: Literacy rate in the study area

52 53 54 55 56 57 58 59 60 61

Both

Male

Female

Lit

era

cy R

ate

(%

)

57.2

60.0

54.8

Literacy Rate (%)

84

Health care services and facilities 194. About 27% people in the study area usually take health care services from paramedics, and about 35% receive services from trained physicians. It is noteworthy that about 35% of the people have a tendency to go to the local healers29 and about 3% do not receive treatment due to their impoverishment. People reported that the tendency of receiving treatment from local healers for diseases has been changing, and at present people have started to go for treatments from the registered/trained physicians. It is assumed that economic wellbeing may drive them toward receiving treatment from trained physicians (Figure 4.39).

Source: CEGIS Field Survey, 2018

Figure 4.39: Treatment Facility of the study area

29 A person in a primitive society who uses long-established methods passed down from one healer to another to treat

a person suffering from various illnesses, many of which have psychological under pinning. Methods used by traditional healers include the use of roots, fetish dolls, voodoo dolls, and the smoking out of a possessing spirit or casting spells

35%

27%

35%

3%

Treatment Facility (%)

Trained Paramedic Quack No Treatment

85

Employment and Occupation 195. Employment status is shown in the following Figure 4.40. It is found in this Figure 4.40 that about 40.9% of the total population is employed in different sectors. Among them, 38.2% are male and a negligible portion (2.7%) is females. About 41.4% of people are engaged in household work, and 17.1% of the total population is not working. Only 0.5% people are looking for work.


Figure 4.40: Employment status by population

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

45.0

Male Female Male Female Male Female Male Female

Employed Looking for work Household work Do not work

38.2

2.70.2 0.4 0.4

41.1

9.1 8.0

Employment Status(%)

86

Main Occupation 196. In the study area, about 40.9% people are employed; of them, about 56% are engaged in the agricultural sector and 26% in the industrial sector. The remaining 18% of local people are engaged in the service sector. The agricultural sector includes crop-farming, fishery, livestock and poultry farming, broadly. The occupational profile is presented in the following graph (Figure 4.41).


Figure 4.41: Field of Activity in the study area

56%

26%

18%

Field of Activity (%)

Agriculture Industry Service

87

Availability of labor and wage rate 197. The availability of labor is high for non-farming activities, like brick field workers, earth workers, constructions workers, and cleaners, etc. In the study area, the maximum wage for male farming labor is BDT 500 (5.96 $ per day, 1 USD = 83.905 BDT,19 Aug 2018) and for female is BDT 250 (2.98 $ per day, 1 USD = 83.905 BDT, Aug 19 2018). On the other hand, the maximum wage for male non-farming labor is BDT 600. Female non-farming and farming laborers are negligible in the study area (Table 4.22). While Bangladesh has labor laws that are intended to prevent child labor (the minimum legal employment age is 14), enforcement, especially in the informal sectors in rural and peri-urban areas, continues to be difficult (the project can address this issue through clear project construction and employment contracts and associated monitoring).

Table 4.21: Labor availability and wage rate in the study area

Type of Activities Type of laborer Availability of laborer Wage (BDT)

Max. Mini.

Farming Male Medium 500 400

Female Very low 250 200

Non-farming Male High 600 500

Female Very low 250 200 Source: CEGIS Field Survey, 2018

Land Price 198. The prices of different types of land have been taken from the field survey. The knowledgeable people of study area, irrespective of occupations and ages, have given information about the land price. The land prices of Harindhara and Debpur Mouza have been outlined in Table 4.22, to get an overview on land price.

Table 4.22: Land price for a specific location District Upazila Location Types of Land Price per Ha. (BDT)

Comilla Burichang Harindhara, Debpur Homestead 44,460,000

Agricultural 74,100,000 Source: CEGIS Field Survey, 2018

Land Ownership 199. The land ownership pattern has been disaggregated according to the ownership categories defined by BBS in the following Table 4.23. About 30% of land owners are in small category and 25% are in the marginal category. The small owners comprise the largest portion of land holding category. On the other hand, 20% of households are medium and 10% households are large farmers.

Table 4.23: Land Ownership in the study area

Land Holdings Percentage

Land less (< 0 ha decimal) 15

Marginal (0.004 – 0.198 ha) 25

Small (0.202 - 1.008 ha) 30

Medium (1.012 – 3.032 ha) 20

Large (3.036 ha and above ha) 10

Total 100

88

Source: CEGIS Field Survey, 2018

Standard of living 200. Here, standard of living includes: housing condition, electricity coverage, sanitation facilities, and safe drinking water availability, which are discussed below. Housing condition 201. The housing condition in the study area shows that most of the houses are kutcha (57.6%). Only 7%of houses are pucka. The rest of the houses are semi-pucka and jhupri Housing condition30 is presented in Figure 4.42 below.


Figure 4.42: Distribution of houses by type of housing structure

Electricity 202. The electricity coverage across the study area is about 91.9%, whereas the national electricity31 coverage is almost 75% (both grid line and solar; the World Bank country review32 on access to electricity reports almost the same at 75.92%). It shows a very good situation of access to electrical power. Sanitation 203. Sanitation facilities in the study area show that about 38% of households have sanitary latrine facilities. 30% households are having non-water-sealed and 8% households are having water-sealed ones. However, there are no households without sanitation facilities in the study area (BBS, 2012). The findings of the field survey show that non-sanitary latrines are predominant in the kutcha houses, whereas water-sealed latrines are seen in puckka houses. The following Figure 4.43 shows the total sanitation facility situation in the study area.

30. BBS distinguishes housing structures into four classes such as- i) Jhupri: House which consist mud walls of 1.5 to

3.0 ft thickness, which carry the roof load. Earthen floor, thatch or CI sheets are used as roofing materials. There is no monolithic joint between the wall and the roof. ii) Kutcha: Walls: Organic materials like jute stick, catkin grass, straw, and bamboo mats. Split are bamboo framing. In some areas wall are made by earth. Foundation: Earthen plinth with bamboo or timber posts. Roof: Thatch-rice or wheat or maize straw, and catkin grass, with split bamboo framing; iii) Semi-puckka: Walls: Bamboo mats, CI sheet, Timber or bamboo framing. In some areas wall are made by earth, sometimes part or full brick. Foundation: Earthen plinth; Brick perimeter wall with earth infill; Brick and concrete also use. Roof: CI sheet with timber or bamboo framing; and iv) Puckka: House which is made by fully concrete, cement, and iron.

31. Bangladesh Economic Review2016, p-125, BBS, Dhaka 32. https://data.worldbank.org/indicator/EG.ELC.ACCS.ZS?locations=BD

0.0 10.0 20.0 30.0 40.0 50.0 60.0

Pucka

Semi-pucka

Kutcha

Jhupri

7.0

33.5

57.6

1.9

Housing Type(%)

89


Figure 4.43: Sanitation facilities by households Drinking water 204. About 96% of the people in the study area have access to a tube well for drinking water, and about 4% have tap water facility (BBS, 2012). The tube wells are located in the villages (where they are needed, and away from the existing farming areas, where fertilizers and pesticides are routinely applied); the villages themselves are scattered around the perimeter of the project site (nearest houses are 65 meters from the project perimeter on the west side; 190 meters away on the north side; 70-90 meters away on the east side; and about 110 meters away on the south side).


Figure 4.44: Source of Drinking Water

8%

30%

62%

0%

Toilet Facility (%)

Sanitary (water-sealed) Sanitary (non water-sealed) Non-sanitary None

4%

96%

0%

Source of Drinking Water (%)

Source of Drinking Water (%) Tap Source of Drinking Water (%) Tube-Well

Source of Drinking Water (%) Other

90

Self-assessed Poverty 205. Poverty in the study area was measured by food consumption. In this process, the respondents were asked to assess the overall food consumption situation of people living in the study area. Their responses were categorized into groups such as deficit, balance, or breakeven and surplus. According to the local people, most of the people are in balanced or breakeven category (55%); whereas only 35% of households are in surplus category. The remaining 10% of households are in deficit category. Indigenous People/Ethnic Community 206. The main ethnic communities of the Comilla district are Chakma, Tripura and Marma. According to the BBS 2012 data, 484 Chakma, 318 Tripura and 191 Marma communities are living in this region. However, there are no ethnic community / indigenous people found in the study area. Further, the project area itself is just farmland; there are no buildings, religious structures, or monuments of any kind within the project footprint (see Annex 2). Gender and Women 207. Field observations suggest that the whole study area is a highly male-dominated area. The roles of women in both decision-making at the household level and economic contribution to household income are deemed by the local communities (males) to be inconsequential. Traditional belief is very strong here that generally males make all major household decisions and at the same time they contribute to household income more than females. Very few women work as day laborers, but in that case, wage discrimination is very common. Women’s mobility in the area is mostly localized, except when they go for medical treatments, fetching water, farming activities, and visiting relatives. Road 208. The road connecting Harindhara and Debpur communities for many years runs through the middle of the acquired land (proposed project area). This road has been in use by local people, including school-going children of the communities for years as it is the only, and shortest, route from Harindhara to Debpur. 209. There is already an alternative soil-filled (kutcha) road connecting Debpur with Harindhara constructed by local authority (i.e., Union Parishad). Remaining 650 m section is able to be passed through though it is not yet paved. PGCB is coordinating closely with the chairman of Union Parishad to ensure the bypass road is completed before the start of land filling of the project area. The Union Parishad chairmen has also confirmed that the construction of the balance road would be completed soon.

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5 Anticipated Environmental Impacts and Mitigation Measures

5.1 Introduction

210. The project under consideration has several potential impacts associated with it. The risk assessment of such impacts for this project was done for not only the workers and the eventual employees but also for the local people and the surrounding environment as well. These impacts are identified from the nature of the fieldwork, the occupations and activities related to the project site, by consulting the experts, and through public consultations. 211. All environmental and social components are not equally impacted by expected project activities. Some components may be impacted while others are irrelevant. Environmental components which are likely to be impacted by project interventions are termed as Important Environmental Components (IEC). The IECs under physical and water resources likely to be impacted by the proposed HVDC BtB Station at Comilla and similar other ones along with the rationale for their selection are presented in successive tables in the respective sections below. Since the project will be quite confined to the project footprint and will use the existing road access and property of the current sub-station as a staging area, and there are already sub-station activities, transmission lines and towers in the area, this has helped to narrow down the environmental parameters most at risk (due to known sensitivities, documented resilience, and observed proximity to the project area). This process has made the scope of impact assessment relatively small and manageable, and has confirmed the Category B designation of the project (mostly due to ongoing activities at the site, very limited geographical scope of project construction, relatively benign project operations, and the common aspects of the altered habitat within the project footprint – evident throughout this part of Bangladesh). 5.2 Analysis of the impacts

5.2.1 Impact assessment methodology

212. Potential environmental and social impacts were identified based onsite visits, interviews with affected persons (APs), stakeholder engagement, environmental sampling, collection of relevant and available secondary data, review of relevant project documents such as the feasibility study, survey reports, etc. The significance of potential impacts was assessed using the criteria and methodology described below.

5.2.2 Impact Magnitude

213. The potential impacts have been categorized as major, moderate, minor or nominal, based on consideration of parameters such as: (i) duration of the impact; (ii) spatial extent of the impact; (iii) reversibility; (iv) likelihood; and (v) legal standards and established professional criteria. The magnitude of potential impacts has been identified according to the categories outlined below.

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Table 5.1: Parameters for Determining Magnitude

Parameter Major Moderate Minor Minimal

Duration Long-term (more than 15 years)

Medium-term Lifespan of the project (5 to 15 years)

Limited to construction period

Temporary with no detectable potential impact

Spatial extent Widespread far beyond project boundaries

Beyond immediate project components, site boundaries or local area

Within project boundary

Specific location within project component or site boundaries, with no detectable potential impact

Reversibility

Potential impact is effectively permanent, requiring considerable intervention to return to baseline

Potential impact requires a year or so for recovering with some interventions to return to baseline

Baseline returns naturally or with limited intervention within a few months

Baseline remains almost constant

Legal standards and established professional criteria

Breaches national standards and/or international guidelines/ obligations

Complies with limits given in national standards but breaches international lender guidelines in one or more parameters

Meets minimum national standard limits or international guidelines

Not applicable

Likelihood of occurrence

Occurs under typical operating or construction conditions (Certain)

Occurs under worst case (negative impact) or best case (positive impact) operating conditions (Likely)

Occurs under abnormal, exceptional or emergency conditions (Occasional)

Unlikely to occur

5.2.3 Sensitivity of Receptor

214. The sensitivity of an environmental receptor (a parameter that may be affected by the project) has been determined based on review of the local population (including proximity/numbers/vulnerability) and presence of features at the project sites or the surrounding area. Criteria for determining receptor sensitivity are given in Table 5.2.

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Table 5.2: Criteria for Determining Sensitivity

Sensitivity Determination Definition

Very High • Vulnerable receptor with no capacity to absorb proposed changes or

minimal opportunities for mitigation.

High • Vulnerable receptor with little or no capacity to absorb proposed

changes or limited opportunities for mitigation.

Medium • Vulnerable receptor with some capacity to absorb proposed changes

or moderate opportunities for mitigation

Low • Vulnerable receptor with good capacity to absorb proposed changes

and/or good opportunities for mitigation

5.2.4 Assigning Significance

215. Following the assessment of magnitude, and the quality and sensitivity of the receiving environment or potential receptor has been determined; the significance of each potential impact is established using the impact significance matrix shown in Table 5.3 (this is the official guidance provided by DoE to all projects which have to be assessed).

Table 5.3: Significance of Impact Criteria

Magnitude of Impact Sensitivity of Receptors

Very High High Medium Low

Major Critical Major Moderate Minimal

Moderate Major Major Moderate Minimal

Minor Moderate Moderate Minor Minimal

Minimal Minimal Minimal Minimal Minimal

5.2.5 Impact Matrix

216. Potential environmental impacts on the Important Environmental and Social Components (IESCs) during the pre-construction, construction, and operation phases of the project are presented in a matrix form in Tables 5.4-5.8 below. Important Environmental Components 217. Important Environmental Components (IECs) for the physical and water resources and their rationale are described in Table 5.4.

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Table 5.4: IECs: physical and water resources and their rationale.

IECs Rationale for selection

Ambient Air Quality • The construction of the HVDC BtB Station will generate a minor amount of air pollution from construction machineries and fuel combustion by vehicles used for supplying electrical components, equipment and construction materials. Dust on roadways may also be an issue (the Sylhet-Comilla highway, and the brick kiln and sand yard just across from the current sub-station). These may impact ambient air quality. Therefore, air quality has been considered as a temporary IEC.

Ambient Noise Quality • During each phase of construction of the HVDC BtB Station, noise will be generated by the construction equipment and related activities. Such noise may impact the local people and as such it has been considered as an IEC, although local communities are already subjected to constant noise from the Sylhet-Comilla highway.

Water Quality • During construction of the HVDC BtB Station site, the construction wastes may pollute the water in the adjacent waterlogged area. As a result, water quality (like pH, Temperature, Salinity, turbidity, etc.) may be changed. As such, it has been considered as an IEC. Drinking water (from tube wells) may also be at risk, during project construction and operation (in the event of accidents).

Project Site Aesthetics and Environmental Quality

• Construction wastes at the HVDC BtB Station at the project site may create hazards to the surroundings. Such activity may impact the environmental quality in and around the project area; as such, it has been considered as an IEC.

Land and agricultural Resources 218. IECs for land and agricultural resources and the rationale for selection of the IECs are described in Table 5.5.

Table 5.5: IECs: Land and Agricultural Resources and their Rationale IECs Rationale for selection

Land use change • The present land use practices (farming, and use of the dirt road for village access) will be changed in the HVDC station area due to the construction of the HVDC Station. The present agricultural land will be converted into non-agriculture land. Because of this reason, land use has been considered as one of the IECs.

Loss of crop production

• The crop production of the HVDC station area will be hampered during mobilization and construction work. Hence, crop production is taken as an IEC.

Soil quality deterioration

• The valuable topsoil and subsoil may be disturbed and likely to be displaced due to the construction of the HVDC Station. Because of this reason, soil quality has been considered as one of the IECs. However, to mitigate, it is likely that all soil within the project footprint will be required to elevate the site prior to construction of sub-station facilities (potential soil contamination – from pesticides – contained within the site.

Fisheries Resources 219. IECs for fisheries resources and the rationale of the IECs are described in the table below.

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Table 5.6: IECs on Fisheries Resources and their Rationale IECs Rationale for selection

Fish habitat area • The project site contains fish habitat (waterlogged rice field and abandoned plots). Raising the land for the HVDC station construction will alter this. Therefore, fish habitat area has been considered as an IEC.

Fish production • Alteration to land use will change the fish production potential. Therefore, fish production has been identified as an IEC.

Fish habitat condition

• Physical observation revealed that the habitat condition of the project site is good enough for fish habitation. Potential discharge of hazardous materials may contaminate water and change habitat conditions. Therefore, fish habitat condition has been considered as an IEC.

Biological Environment 220. IECs for the biological environment and their rationale are described in the table below.

Table 5.7: IECs on Biological environment and their Rationale IECs Rationale of selection

Vegetation • The proposed project site is mainly an agricultural field. In addition, this land acts as a seasonal wetland, to some extent. Main floras are herbs. Aquatic avifauna, insects, and water-dependent wildlife depend on it. Vegetation is also needed for covering, hunting, and for reproduction purposes. This IEC will reflect sensitivity to the changes and/or shifting of ecosystem types in that region.

Wildlife habitat • Wildlife need food, cover, water, space for better habitat, to keep their community intact and adaptation to the changing environments. When any of the four components becomes affected, the balance in ecosystem is also affected. In this changing environment, some species can benefit, and some may not. Therefore, the ecosystem will be constrained, and some species of wildlife will be stressed. Therefore, Wildlife Habitat has been considered as an IEC for this proposed project, although there are few wildlife in the area (since it is already a disturbed habitat).

Socio Economic Resources 221. Important Social Components (ISCs) for socio-economic conditions and their rationale are described in the table below.

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Table 5.8: ISCs on Socio-Economic Resources and their rationale ISCs Rationale for selection Land Acquisition • For the construction of the 400 kV BtB station, the project needs approximately

16 ha of private land. The proposed location is located in Harindhara, Debpur and Purba Sharippur village under Mainamati Union, which is close to the Mainamati Union parishad. The land acquisition procedure has already been completed by the District Commissioner office of Comilla. Most of the project affected people (PAPs) have received compensation (BDT 762,345,048) properly (some PAPs did not receive it yet). In this regard, proper compensation should be ensured to actual land owners for the land acquisition purpose. Therefore, land acquisition is selected as an ISC.

Employment Opportunities

• Construction of the grid line as well as the HVDC Station requires both skilled and non-skilled laborers and this will create employment opportunities for poor people in the vicinity of the proposed area and outside the proposed area. Furthermore, extension of industrialization will provide extra employment opportunities for the local people.

Health and Safety

• The safety and health of the public may be impacted due to the hazards created during the construction period. It is anticipated that the risk of accidents during the construction period is moderate due to the operation and movement of heavy equipment, vehicles and machineries. Besides, during construction work there is a probability of accidental risk for laborers. Additionally, an accident may happen during replacing the conductors. All these poses significant risk to the health of the working personnel and the people living in the neighboring areas.

Interference with Road Crossing

• There may be some interference with road crossings. During the construction phase, this will surely create some disturbance for traffic movement and create traffic congestion (on the Sylhet-Comilla highway). This will also deteriorate the volume and capacity of the existing road. After construction works, the road communication will remain normal. So, interference with road crossing is considered as an ISC. Note that the road joining Debpur and Harindhara, which crosses the site (mostly used for foot traffic), will be replaced by a better road that will run around the north perimeter of the site (already partially completed).

5.2.6 Assessment of Potential Impacts and Definition of Mitigation Measures

222. The potential impacts and responsive mitigation measures are listed in Table 5.9.

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Table 5.9: Impacts in different phases of Construction, and Mitigation A. Physical Environment and Water Resources

A.1 Impacts in Pre-Construction Phase are negligible There is little chance of impacts in this phase, as this phase primarily deals with documentation, planning, funding, tender process, contractor and manpower recruitment etc. A.2 Impacts in Construction Phase are temporary in nature, with good scope for recovery at a later stage Major activities during the construction phase, considered for assessing environmental and social impacts, include the following: • Transport of equipment and materials for construction works, via the current sub-station access and yard; • Establishment of construction camps for workers and temporary access tracks (on the edge of the current sub-station yard; southeast side); • Stringing of Lines from Towers to OHL Entry; • Civil construction works; and

• Electrical installations, communication setup and commissioning of the station. A.2.1 Air Quality

Impact Mitigation Residual Impacts

• During the construction phase, the activity would involve movement of vehicles carrying the construction materials via the Sylhet-Comilla highway through the sub-station yard. This would give rise to emission of dust particles (along the highway, at the current sub-station, and within the new project perimeter), thereby affecting air quality in the vicinity (especially during the dry season); the nearest houses are 65-190 meters away, depending on orientation. The significance of this potential unmitigated impact has been assessed as Moderate on the basis of impact magnitude and receptor sensitivity.

• Regular use of water spray systems will be introduced at the construction site to minimize dust.

• All sand piles will be covered at all times. All trucks carrying sediments will also be covered (additional sand will most certainly be required from the sand yard across the highway from the current sub-station).

• Exhaust emissions from vehicles, machinery equipment will comply with Bangladesh air quality emission standards.

• The impacts associated with deterioration of air quality are likely to be adequately addressed with the help of the above-mentioned mitigation measures. Hence, the significance of residual impacts will be Minor, and temporary; spatially limited and reversible.

A.2.2 Water Quality Impact Mitigation Residual Impacts

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• The surface water quality adjacent to the site (especially turbidity, etc.) may be affected in the construction phase. The construction of the labor shed, stock yard, building platforms, and the buildings and facilities themselves, as well as associated site preparation activities may generate sediment and solid waste dispersal into the adjacent water-logged area (but not likely the groundwater wells, which are in the villages (70-190 meters away, and at higher elevations, compared to the project site).

• The significance of this potential unmitigated impact has been assessed as Moderate on the basis of impact magnitude and receptor sensitivity.

• The laborer camp, stock yard, will all be located on the premises of the existing sub-station and southern edge of the new project footprint. Further, the whole new work site will be raised, leveled, and bounded by a construction-grade wall (normal practice in Bangladesh, in low-lying areas), to retain sediment within the footprint and maintain site stability (as it will be perched about the surrounding low-lying, waterlogged area). Nevertheless, the site will have surface drains to the surrounding area to avoid ponding on the work site.

• The small amounts of required concrete batching will be done on-site, to avoid the need for concrete trucking.

• The site will be organized for waste storage and eventual disposal (to the Comilla landfill).

• All sediment piles will be watered and covered.

• A worksite protocol will be established to avoid disposal of waste outside the project site.

• Fuel and other hazardous materials will be stored in a locked, bunded area that will securely contain the whole volume of material (plus 10%).

• Fuel transfers will be done on a concrete pad, with edge channels and walls.

• These mitigation measures will isolate all site activities and materials from the surrounding farmland and adjacent villages.

• The project will use the current sub-station toilet facilities, augmented as needed with a septic system that can be tied into for the permanent toilet facilities of the new sub-station.

• Work site conditions will be monitored and issues addressed on a daily basis.

• The impacts associated with the water quality deterioration are likely to be adequately addressed with the help of above mitigation and the significance of residual impact will be Minimal and temporary; spatially limited and reversible.

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• The World Bank/IFC EHS guidelines will be reviewed for other approaches that may be suitable for the construction phase of this project.

A.2.3 Noise Impact Mitigation Residual Impacts

• One major source of noise pollution will be movement of vehicles carrying sediments, construction material, and equipment at site. The traffic route will include the sand yard across the highway from the current sub-station, a small part of the highway, and the entry and yard at the current sub-station. Vehicles (number of daily transits need to be worked out, but are not expected to be high, given the small size of the work site, and the nature of components to be constructed) will be moving slowly, given the short distances. Impacts would be expected to be Minor. The construction of BtB Station will be restricted to day time hours. Note that the main source of noise in the area now is the traffic on the Sylhet-Comilla highway, which will continue to dominate.

• Vehicle traffic and construction activities will be contained within the work site and the current sub-station yard and a small stretch of the Sylhet-Comilla highway (the latter already has an over-riding noise signature, which the local communities live with).

• Noise levels will continue to be monitored in pre-construction and construction, and if there is exceedance at the village edges, noise baffles will be constructed.

• Finally, rotary drilling, for cast-in-situ bored piles, will be considered, to avoid the noise of pile driving (much quieter operation). For smaller facilities, floating cast concrete platforms on compacted soil can also be used.

• The impacts associated with the noise are likely to be adequately addressed with the help of the above-mentioned mitigation measures and hence the significance of residual impacts will be Minor and temporary; spatially limited and reversible.

A.2.4 Waste Impact Mitigation Residual Impacts

• Construction wastes like metal scraps and wooden packing material, and polythene may create a disturbance to the surrounding land, settlements, and the communities, if not properly managed.

• Domestic wastes from labor camp (food scraps and labor camp waste).

• These unmanaged impacts are deemed to be Moderate.

• All construction waste will be sorted and stored in a fenced area to the side of the work site, for later removal to the recycling agents and the most appropriate Comilla landfill (there are several in Comilla), as needed.

• Food waste from the labor camp can be composted on the edge of the existing sub-station. Other labor camp waste to be collected and sorted and handled like the construction waste.

• The impacts associated with the construction waste are likely to be adequately addressed with the help of these mitigation measures, and hence the significance of residual impacts will be Minor and temporary; spatially limited and reversible.

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A.3 Impact in Post-Construction Activities during the post-construction phase, considered for assessing environmental and social impacts have been found to be insignificant, however, fugitive emissions of SF6 should be monitored following the international guidelines. Annual inventory on the use of SF6 will be conducted to monitor usage and losses. A very high-grade sealing system and erection methodology will be followed to keep the loss of SF6 within 0.1% every year. SF6 gas handling system for evacuation and storage will always be used for the maintenance of the circuit breaker. SF6 emergency response plan should be prepared. Note that the current sub-station operational activities and noises are already evident in the area, and are managed and tolerated. However, the noise level will be continuously monitored.

B. Land and Agriculture Resources B.1 Pre-Construction Phase B.1.1Soil Quality


• During the pre-construction period, site clearance work will be done accordingly. So, site clearance will impact the fertile top soils that are enriched with nutrients.

• The significance of this potential impact before mitigation has been assessed as Minimal on the basis of impact magnitude and receptor sensitivity, as these fields will not be further farmed.

• The contractor will carefully clear the vegetation (rice field remnants) for site preparation and infilling, with sand, to allow construction of the HVDC Station.

• There are four trees along the road in the center of the site. These might be retained, if structure and facility arrangements within the site perimeter allow it. Otherwise, at least 8 trees will be planted around the perimeter of the site, as compensation.

• Soil quality will be of no consequence for the project or the local community, as there will be no further farming within the project footprint (therefore, impacts Minimal and permanent; limited to project area and irreversible).

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B.2 Construction Phase

B.2.1 Soil Quality


• Landforms at the HVDC Station site (rice fields) will be affected due to infilling of the whole site (above flood levels, using sand from the site perimeter and likely from the sand yard across the highway).

• The significance of this potential impact before mitigation has been assessed as Moderate on the basis of impact magnitude and receptor sensitivity. However, given that the land will not be further available to farming, soil quality has little concern, and there is no specific mitigation required.

• The existing sediments and sand from the nearby sand yard will be used to elevate the whole project site, for proper building construction and future flood protection. As such, sediments will be contained within a construction-grade retaining wall, to isolate the site from surrounding areas.

• It is likely that rotary drilling, for cast-in-situ bored piles, will be used. Sediments from this drilling process can be used for site infilling along the perimeter.

• Once construction is complete, open areas will be landscaped with grass.

•

• The impacts associated with changes of soil quality are of no consequence, since the area will no longer be farmed (appropriate land compensation will have been paid). Residual impacts will be Minimal and permanent; limited to project area and irreversible.

B.2.2 Land Use Impact Mitigation Residual Impacts

• Construction work will be done in Harindhara, Comilla for the HVDC Station under this project. A total of 16 ha of land will be required for construction of new HVDC Station of which 95% is agricultural land and remaining area are pond and road. After the completion of the HVDC Station, all of these lands will be changed into permanent structures and service area.

• The road crossing the site (from Debpur to Harindhara) will no longer be available.

• As such, the impact of this change is considered Moderate, since it is irreversible, but there is still an abundance of agricultural land in the immediate vicinity.

• • Landowners have been compensated, and

an alternative road around the northern perimeter of the site (almost completed) will be upgraded and completed before project civil work commenced.

• Compensation will have addressed the residual impact of taking over the farm land.

• Travel time along the new perimeter road to the north (from Debpur to Harindhara) will increase slightly (adding another 650 meters to the route. Residual impacts are therefore considered to be Moderate and permanent; limited to project area and irreversible.

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B.2.3 Crop Production Impact Mitigation Residual Impacts

• About 126 tons of annual rice crops produced in the HVDC Station area (of which HYV Aman, Lt. Aman and HYV Boro are about 25 tons, 27 tons and 74 tons) will be lost from production.

• The significance of this potential impact before mitigation has been assessed as Moderate on the basis of impact magnitude and receptor sensitivity. In any case, this crop production loss is accommodated in the compensation payments.

• Farmers will be allowed to undertake a final harvest prior to handing over land to the project.

• Compensation payments take into account the loss of land as well as its future production value.

• The residual impact is still considered to be Moderate and permanent; limited to project area and irreversible; paid compensation reflects this.

B.3 Impact in Post Construction i.e. Operation and Maintenance Phase

B.3.1 Soil Quality

• The soils of the surrounding HVDC Station area could be disturbed due to maintenance activities.

• The significance of this potential impact before mitigation has been assessed as Minimal on the basis of impact magnitude and receptor sensitivity.

• Maintenance work that requires excavation of soil is expected to be minimal; in any case, there will be a perimeter wall which will reduce loss of site soil to surrounding areas.

• The contractor should be careful during maintenance work (minimal soil disturbance).

• Residual impact on soil quality in the adjacent rice fields is expected to be Minimal and temporary (if it occurs); spatially limited and reversible.

C. Fisheries Resources

C.1 Pre-construction Phase- It is assumed that there would be no significant impact in this phase C.2 Construction Phase C.2.1 Fish habitat area


• Raising land for HVDC Station construction would cause the transformation of fish habitats into built-up area. This kind of loss can be termed as ‘irreversible losses with the likelihood of ‘certainty’. So, the impact magnitude is assessed as Moderate (given that the surrounding area will still support fish habitat and related production).

• The only suitable mitigation is to retain the existing fish pond. In any case, the pond owner will have been compensated for loss of the pond.

• Further, site activities will be contained within the perimeter wall, so that adjacent waterlogged areas will not be affected. There is still an abundance of aquatic habitat within 5 km of the project area (all the waterlogged areas between the villages near the Gomti River).

• The whole project site will be lost as fish habitat (with the exception of the fish pond). The residual impact is still considered to be Moderate and permanent; spatially limited and irreversible.

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C.2.2 Fish production


• Corresponding to habitat loss, the estimated loss of fish production would be about 3 metric tons annually (a Moderate impact).

• Since the fish pond will be retained, the impact can be fully mitigated (however, compensation for its loss is the other remedy and addressed separately).

• The residual impact is considered to be Moderate and permanent; spatially limited and irreversible (reflected in payment of compensation).

• With implementation of above mitigation measures, and payment of compensation, the residual impact would be Low.

C.3 Impact in Post Construction C.3.1 Fish habitat condition


• If the pond is retained, there is a small risk of site activities leading to contaminated runoff going into the pond (Minimal impact).

• The site will be walled off, so there is little chance of any runoff from routine (or accidental) site activities) going beyond the site perimeter (Minimal impact).

• Any liquids or service water used on site will be retained in a tank and trucked offsite, so there will be minimal risk of loss of liquids to the project site, or beyond.

• A septic system, requiring annual maintenance, will ensure that sewage does not enter adjacent areas.

• Proper site operation protocols should keep residual impacts on adjacent fish habitat Minimal and temporary; spatially limited and reversible.

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D. Biological Environment

D.1 Impact in Pre-Construction phase- No impact is assessed in this phase of the project.

D.2 Construction Phase

D.2.1 Vegetation


• The construction will permanently damage the existing seasonal wetland and crop field vegetation in the project site. Especially floating, submerged and attached floating macrophytes will be uprooted completely (and then covered over). In addition, some minor agricultural field vegetation of grasses, hear-leaf hemp vine and spine gourd will be destroyed as well. Furthermore, four Asian palm trees will also likely be cut down from the roadside vegetation in the middle of the site (although attempts will be made to retain them, depending on structure and facility configuration on the site). All of this kind of vegetation is very common in Bangladesh. Above all, the project site is very small in size (there is an abundance of such vegetation throughout the adjoining area) and also there is no chance of damaging vegetation outside the project area.

• The significance of this impact has been assessed as Minimal, based on the lack of sensitivity/importance of the existing vegetation.

• All project construction activities will be confined to the existing sub-station grounds and the new project footprint. Vegetation loss in this area will be unavoidable.

• Attempts will be made to retain the four palm trees. If they have to be cut down, at least eight similar types of trees will be planted around the project perimeter.

• Make laborers and local people aware of the benefit of native plant conservation.

• The loss of vegetation (mostly unavoidable) will still be a Minimal impact (permanent; spatially limited and irreversible).

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D.2.2 Wildlife habitat


• Three types of activities will have impacts on the existing wildlife. The first one is land development that will remove the feeding ground of wildlife (aquatic birds and other insects/animals). The second one is loss of shelter, due to loss of vegetation; wildlife will lose their sheltering places, which they need for protection. The last one is the loss of water bodies (within the project footprint). Wildlife is habitat specific; therefore, loss of water bodies might shift the ecosystem slightly. In addition, noise and lights at night from the labor sheds might disturb the wildlife in the area.

• However, there will still be availability of wetlands and waterlogged areas in adjacent areas. This will reduce the impacts to some extent. Note that about 90% of the wet areas in the study area are not actually wetlands – they are rice fields, some of which have been abandoned due to persistent water logging. The significance of this negative impact has been assessed as Moderate.

• Construction activities will be confined to the project footprint (which will become elevated above the surrounding rice fields and waterlogged areas) and the existing sub-station site and its access to the Sylhet-Comilla highway. All the adjacent wet areas to the east, west, and north (the majority of waterlogged areas in this vicinity) will be retained, although in the area to the northwest, if a drainage channel is constructed, these wet areas will be restricted to the channel and adjacent rice fields.

• • No working allowed during the night.

• With the confinement of construction activities to the elevated project footprint, and no disturbance to adjacent rice fields and waterlogged areas, the negative impact on wildlife remains Moderate and permanent, in a limited area (the project footprint) and irreversible.

D.3 Post Construction Phase

D.3.1 Wildlife habitat


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• After the construction of the HVDC station, operations will be started. During the operation period, some of the wildlife, such as some birds, might be disturbed during their course of daily life. The transmission line and other HVDC Station maintenance activities might cause this. However, this impact will be Minimal, since it is evident that wildlife, notably birds, already co-exist with the existing sub-station, towers, and transmission lines in the area (many birds use the lines as perches).

• Avoid excess lighting and use shaded lights during the operational phase.

• Towers and wires can be flagged for higher visibility for birds.

• Residual impacts are expected to be Minimal and occasional; spatially limited (in fact, towers and lines provide additional perching habitat for birds that are aquatic feeders).

E. Socio-Economic Conditions Social impacts may potentially be caused during various Project phases. The potential social impacts during the pre-construction, construction, and post-construction phases, along with the proposed mitigation measures to avoid, offset, reduce, or compensate these impacts, are pointed out in the following sections.

E.1 Pre-construction Phase E.1.1 Land Acquisition


• For the construction of the 400 kV BtB station, it needs approximately 16 ha land. The proposed location is located in Harindhara, Debpur and PurbaSharippur village under Mainamati Union, which is close to the Mainamati Union parishad. According to the local Chairman, the number of Project affected people (PAPs) is 160. The land acquisition procedure has already been completed by the District Commissioner office of Comilla. Most of the PAPs have received compensation (BDT 762,345,048) properly (some PAPs did not receive it yet). Note that only farmland has been acquired (no structures on that land – see Annex 2 - and no need for resettlement; impact is Moderate).

• Proper compensation will be ensured to the legal owner(s) according to the provisions of existing laws of Bangladesh (the final compensation being paid to those landowners who have not yet received it).

• Employment opportunities for the adversely affected people will be provided by the contractor, to the extent possible.

•

• With the help of these procedures and mitigation measures, the impacts associated with land acquisition will be adequately addressed (therefore, Minimal, but permanent and irreversible).

E.2 Construction Phase

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E.2.1 Health and Safety


• The safety and health of the public, and project workers, may be impacted due to the hazards created during the construction period. It is anticipated that the risk of accidents and possible negative impacts during the construction period is Moderate, due to the operation and movement of heavy equipment, vehicles, and machineries (however, these will be confined to the project site, the current sub-station access road, and a segment of the Sylhet-Comilla highway). Construction work will present a risk to workers (hazards and possible accidents, as well as noise and dust).

• The whole project work site will be fenced off and signs regarding potential hazards posted in conspicuous locations.

• Access from the highway to the current sub-station yard will be under traffic controls when trucks enter and exit (traffic managers with appropriate signs).

• Local communities will continue to be informed about project construction activities, schedules, and possible health and safety risks.

• The project will ensure that Bangladesh Labor Code regulations and the World Bank/IFC OHS standards are followed, including provision of safe working conditions and all appropriate personal protection equipment (PPEs).

• The Contractor will establish a mechanism for receiving and handling complaints about unfair treatment or unsafe living or working conditions (without reprisal).

• Health/accident insurance for employees/contractor staff will be provided for the duration of their contracts.

• A Health and Safety Officer (HSE tasks) will be designated and will provide regular briefing on worksite risks and the need to protect local communities. An accident reporting system will also be put in place, including notifications to ADB and Government of Bangladesh, and annotation of situation remedies. Special consideration will be given to risks associated with working at height and with electrical components (workers will be suitably trained for these tasks, and fitted with safety equipment).

• With the help of these mitigation measures, residual impacts will be Moderate to Minimal and temporary; spatially limited and reversible.

E.2.2 Interference with Road Crossing (Traffic Congestion)

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• With the establishment of an access track from the highway through the current sub-station yard to the project site, there may be some interference with highway traffic. After construction activities, the traffic patterns will revert to normal.

• The dirt road running across the project site from Debpur to Harindhara will be closed.

• These negative impacts are considered to be Moderate.

• Schedule deliveries of material/ equipment during off-peak hours.

• Deputize a flagman for traffic control at the highway-sub-station intersection.

• Regular notices (weekly) will be displayed on local community notice boards highlighting forthcoming traffic management information, including any unusual volume of truck traffic. Local village leaders will also be informed (via mobile phone), for verbal communication where needed.

• The cross-site road will be replaced with a better road around the northern perimeter of the project area.

• With the help of these mitigation measures, residual impacts will be Moderate and temporary; spatially limited and reversible.

E.3 Post Construction Phase: E.3.1 Health and Safety Impact Mitigation Residual Impacts

109

The safety and health of the public, and sub-station employees, may still be at risk during the operational phase, especially if the site is not fenced and secured, and if employees are not properly briefed and trained. However, it is anticipated that the risk of accidents and possible negative impacts during this phase is Minimal.

• The whole sub-station site will be fenced off and secured, and signs regarding potential hazards posted in conspicuous locations (no public access).



• Health/accident insurance for employees will be provided for the duration of their contracts.

• A Health and Safety Officer (HSE tasks) will be engaged to address workplace risks and conduct regular safety briefings, as well as maintaining an accident report system (as described previously).

With the help of these mitigation measures, residual impacts will be Minimal and occasional; spatially limited and reversible.

E.3.2 Positive Impact: Employment opportunity during construction phase.

Impact Implementation plan

• During the construction period, employment opportunities for both skilled and unskilled labor may occur (construction, carpentry, local trucking, provision of supplies, food, etc.). This is deemed a Moderate positive impact.

• The project will make a list of directly affected people (those who have lost their agricultural land), to see if they are interested in working in suitable positions during the construction phase.

• Local people’s (PAPs) engagement will be given priority.

• Appropriate technical and health/safety training and related equipment will be provided to these workers.

• Bangladesh labor code requirements will be applied, including provisions to prevent child labor.

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5.3 Possible Hazards

223. Table 5.11 below identifies the potential hazards from the pre-construction stage to the operation and maintenance activities stage, their root causes or sources, their consequences, possible occurrences and severities, along with the safety measures and post-safety measures occurrence and severity.

111

Table 5.11: Possible Hazards Associated with the Project

112

Hazard/ Incident Source/ Activity Consequences Required Safety Measures Occurrence/ Severity (with

safety measures)

Traffic or Heavy Vehicle Accident @Pre, During and Post Construction

During site visit for inspections, surveying, planning, equipment and components transportation, use of oversized vehicle, onsite and offsite activities including movement of construction trucks, etc.

Physical injury, loss of life, vehicle and/ or property damage, etc.

Drivers/ operators should strictly follow the rules and regulations; Drivers, operators, operator guides, site visitors should take care before coming out of or getting onboard any vehicle; Proper traffic marking on the road and effective signaling system should be implemented in and around the project site; Oversized vehicle permit from the authority should be taken before mobilizing such vehicles; Traffic safety should be ensured for oversized and slow moving vehicles; Provision and use of high visibility clothing for workers, operators, operator guides; Provision of safe walkways onsite etc.

Medium / High

Site Invading @ During Construction

Site invaded by local children during land filling and preliminary construction works (use filled land as playground).

Physical injury. Construction site should be kept under surveillance and made inaccessible to outsiders, particularly local children before starting any construction activity.

Low / Medium

Wall Scaling @ Post Construction

Scalable boundary walls. Physical injury, damage of property.

The facility should be under constant surveillance and personnel should be in place of active duty to look out for trespassers at all times; CCTV monitoring to be in place to assist catching trespassers or any suspicious activity in and around the vicinity of the facility; Barb-wires to be placed over the walls to discourage wall scaling; Danger label to be placed on the walls surrounding the facility.

Very Low / Low

Electrocution @ During and Post Construction

Cutting and welding activity, short circuit, faulty grounding in equipment; faulty wiring, loose connections, during repair and maintenance work of

Physical injury including burning and loss of life; May cause station shutdown due to an incident.

Use of Personal Protective Equipment (PPE), such as lineman’s gloves, safety goggles, safety shoes, or welding shield etc.; Proper training and awareness; Proper tools usage; Proper grounding of equipment, keeping safe distance from hazardous points; Prepare

Low / High

113

cable gallery, control panel, switchyard, instrumentation, etc.; power cable cut due to thunderstorm.

regular maintenance and inspection of station equipment, components etc. both indoor and outdoor ones; Maintain the inspection schedule properly and proper training for technicians and engineers; Proper warning signs and labels in place; Use of lock outs and tag outs and maintain hot work permit; Proper grounding of housing, casings etc.; Use buddy system (at least two personnel) during any electrical or welding work activity; Keep all the personnel present in the facility aware of any undergoing hot work at all times; Local people should be made aware of staying away from power lines particularly during storms and other adverse natural calamities.

Electromagnetic Field @ Post Construction

OHL lines coming to the HVDC station OHL entries with high voltage producing electric and magnetic field.

May exceed the recommended exposure level.

Electric and magnetic field strength measured at the Bheramara 500MW 400kV HVDC in Bheramara, Kustia) indicates low electromagnetic field levels.

Low / Low

Burning @During and Post Construction

Welding activity, electric works, come in contact with hot surface (ex. heat sink).

Physical injury Use of proper PPEs including safety goggles, appropriate gloves, appropriate tools, or welding shield, appropriate training, warning signs and labels identifying potential hazards.

Low / High

Blinding @ During and Post Construction

Cutting and welding, arc flashovers, sparks due to faulty or loose connections, component malfunction etc.

Eye injury, temporary blinding resulting in falling, tripping, electrocution.

Use of proper PPEs including safety goggles or welding shield; appropriate training, warning signs and labels identifying potential hazards.

Low / Medium

Hearing Impairment @During and Post Construction

Noise and vibration generated by heavy machineries, placing electrical heaving components such as power transformers and civil construction works such as drilling, piling, excavation works etc. Noise from corona effect during winter, transformer

Hearing complexity and cause of headaches for human beings resulting in loss of concentration resulting in the trigger of another potential hazard, scaring away the

Compliance with the National Noise Control Rules and Regulations and IFC occupational health and safety standards (requiring the use of ear protection at all noisy work sites); Equipment to be used by competent operators; Provision of equipment with low noise and vibration outputs i.e., equipment that come with dampers where possible or appropriate choice of modern equipment and machinery to reduce noise; Personal Protective Equipment (PPEs) provided and

Low / Medium

114

humming, loud tripping sound, etc.

wildlife and livestock, etc. Scare local people, health hazard for people with weak constitution or heart conditions amongst workers or employees as well as bystanders.

used where necessary; Consider suitable timing of construction work to reduce disturbance to the wildlife and the locality; Use components with lower noise level that falls in the same category or under the regular decibel level of the locality and silencer where possible.

Slipping @ During and Post Construction

Muddy plain during construction, moss grown on the pathways leading to slipping/ falling of engineers and technicians, water or any liquid spilled on facility floor and not wiped off.

May cause physical injury such as fracture, broken bones.

Proper path management, such as use of bamboo base for walking during construction; Regular scheduled maintenance and hire cleaners to remove moss from the path below the bus bars; Proper PPE shoes with slip grip will reduce chance of slipping significantly; use of sands and gravels in the pathway; Clean moss grown on the pathways; Wipe any water or liquid (proper procedure for wiping corrosive, flammable or toxic) off using appropriate cleaning materials/ tools.

Medium/ Medium

Tripping @ During and Post Construction

Tripped by stray pipe, rope, rods, unmanaged tools, cables, miscellaneous items, and equipment in the station, construction equipment and tools, weeds on the outdoor pathways etc.

Physical injury. Use of warning signs/ labels in places that may trigger a tripping incident and properly managed items and equipment; Use of PPEs; Manage items at all times to keep the site tripping free; Keep the outdoor pathways clear of weeds.

Medium / Medium

Falling Personnel @ During and Post Construction

Fall from elevated areas in the station such as steps, ladders, other high heights such as transformer top, towers, filters and reactors supporting structures, etc.

Physical injury and loss of life.

Fall protection such as use of nets or temporary boundary; creating awareness; use of PPEs such as hard hat, gloves, safety belts; Proper signs/warnings in locations where falling can result to an incident; Use proper climbing tools such as harnesses, lanyards, capstan hoists etc. to support activities that require hanging and working; Use buddy system to work on elevated areas

Medium/ High

115

such as supporting structures, towers, OHL entries etc. Only trained personnel to be used in high task situations.

Falling / Dropped Objects/ Struck by @ During and Post Construction

Objects such as tools, components dropped from elevated areas during repairs and maintenance works, Falling/ moving pipe, rods etc./ moving machines, tools/ debris dropped from elevated locations, vehicles, etc.

Physical injury, including head injury, leg injury and potential loss of life.

Proper use of PPEs such as hard hats, steel toe boots etc.; Proper training and awareness to not stand below working area; Proper hot work permit; Use of signs, yellow tapes and warning labels such as ‘Falling Object Hazard’ beneath the working area for maintenance or repair jobs etc.; Use buddy system.

Medium/ Medium

Cutting @ During and Post Construction

Unkempt site, lack of site management which could potentially have debris, including sharp objects lying on or partially buried in the construction activity, cut from working on maintenance such as cleaning, replacing etc.

Physical injury, and/ or vehicle damage etc.

Site visitors, planners should wear PPEs during site visits (safety induction training before all site walk-abouts; Vehicle should not enter the unmanaged site premises; Use proper PPEs such as gloves, and tools during maintenance and repair works.

Low / Medium

Pinching and/ or piercing @ During and Post Construction

Working with construction tools; Working (maintenance, replacing etc.) in cable connectors, insulators, housings, control panel, and other mechanical parts of electrical components etc.

May cause physical injury through pinching or piercing finger, scraping off skin etc.

Wearing proper PPEs such as hand gloves will reduce the impact of pinching or piercing of fingers and remove scraping altogether; Proper use of appropriate tools for any work; Avoid make-do work with improper tools; Scrap old or damaged tools with new and safer ones.

Low / Medium

Fire and/ or Explosion @ During and Post Construction

Short circuit, thunderstorm and lightning, presence of flammable substances such as lubricants, fire on transformer, control panel, and other electrical components, placing cable gallery, power transformer, switchyard, switchyard control, flammable chemical, etc.

May result in tripping, or temporary forced shutdown resulting in power outage, injury of personnel, loss of life, and damage to equipment, etc.

Provide proper fire-fighting equipment, such as fire extinguisher, water hose, installation of Active Fire Suppression system; proper grounding of equipment, installation of lightning arrester, surge protectors, fast-acting protective relays, etc.; Carry out preventive inspection and maintenance; The contractor should develop specific safety plan for ensuring safeguarding of site, equipment and personnel; The transmission lines and HVDC station should be properly designed ensuring

Medium / High

116

safeguarding of the entire system; Gravel around switchyard would provide separation distance from neighboring combustible material (dry grass, burnable bush, etc.); Ensure no oil spills/ oil seeps into the gravel and does not accumulate; Arrangement of fire-fighting equipment with training to the staff from workers to officers; The staff should be trained on emergency handling procedures; Fire and smoke evacuation drills; Control hot work via ‘Permit to Work’ from the responsible persons; Adoption of fire safety for each of the equipment and machinery subject to fire hazard; Safe handling and storage of flammable chemicals and fuels; Regular inspection and monitoring of pressurized parts and units; Consciousness during working period and general awareness; Entire facility to be pronounced non-smoking zone.

Earthquake @ Pre, During and Post Construction

A natural phenomenon. Potential damage to civil structure of the station, loss or interruption of power, loss of life, properties, process, triggering hazards such as fire/ explosion.

Comilla falls inside Zone II3: Moderate Risk Zone3. However, it is not a place that see many notable earthquakes, the most recent one of importance recorded in 7km from Barjala, Tripura, India (Aug 17, 2014, Mag 4.1, 38km Depth)4. Structures will be designed to withstand specified Richter scale earthquake effects using well-established procedures in accordance with relevant national and/ or international standards (with third-party review of sub-station specifications); fire extinguishing facilities to be provided; Evacuation drill and safety moves in a potential earthquake occurrence. 3Source: Al-Hussaini, T. M., Hossain, T. R., & Al-Noman, M. N. (2012). Proposed Changes to the Geotechnical Earthquake Engineering Provisions of the Bangladesh National Building Code. Geotechnical Engineering Journal of the SEAGS &AGSSEA, 43(2), 1-7. 4Source:https://www.earthquaketrack.com/bd

Low / High

https://www.earthquaketrack.com/in-26-barjala/recent

https://www.earthquaketrack.com/p/india/tripura/recent

https://www.earthquaketrack.com/p/india/recent

https://www.earthquaketrack.com/bd-84-comilla/recent

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-84-comilla/recent

Thunderstorm and Lightning @ Pre, During and Post Construction

A natural phenomenon. Potential damage to civil structures of the station, loss or interruption of power, loss of life, process, triggering hazards such as fire/ explosion.

Structures will be designed to withstand thunderstorms and lightning using well-established procedures in accordance with relevant national and/ or international standards; Fire extinguishing facilities to be provided; Lightning arresters will be checked for condition at regular intervals; Preparation should be in place during a moderate or severe weather alert.

High / Low

Flooding @ Pre, During and Post Construction

Heavy rainfall (natural phenomenon), insufficient or unkempt drainage system.

Potential damage to civil structures of the station, interruption or loss of power, injury, loss of life, process etc., triggering hazards such as fire/ explosion.

Despite being in a higher land filled area compared to the surroundings, proper and adequate drainage system based on historical precipitation record will be implemented inside the facility; Training should be provided to staff on an event of how to manage flooding; Drainage system should be kept active through cleaning and flushing under regular site maintenance and particularly ahead of the monsoon and rainy season.

Medium/ Low

Waste and Leakage @ During and Post Construction

Not handled properly, no adequate waste management/ disposal process in place during construction and during regular operations and maintenance; Leakage from components such as fluids, leakage from storage, leakage of insulation gas (sulfur hexafluoride SF6), etc.

Outbreak of diseases and other health related issues; loss of environmental quality due to air and water pollution.

Waste management of both human generated (by construction workers, staff, employees) and component generated (machines, utilities, equipment) should be handled accordingly; Component generated waste such as lubricants, coolants, etc. should be handled with proper storage and removal to avoid exposure to air and water; Switchyard insulation gas SF6 leakage should be monitored through pressure check.

Low / Medium

Water logging and Landscape Disruption @ During and Post Construction

Land filling with no drainage system in place around the project site.

Water logging of the surrounding area will be aggregated, instigate disruption of the overall landscape of the area leading to

Build a drainage system surrounding the land filled project area to remove water logging of the nearby fields and localities.

Medium / Low

https://www.earthquaketrack.com/bd-84-comilla/recent

118

hampering of irrigations of the paddy fields during dry season, and water removal during wet seasons.

Network Disruption @ Post Construction

Electromagnetic Interference (EMI).

Cellular network and internet of the locality being disrupted due to EMI around the station and a significant radius beneath the OHLs carrying high voltage.

Although there are no preventive measures for such, local people will need to be made aware of the disruption caused by EMI from the OHLs which may have some degree of impact on cellular network and internet services such as 3G, 4G, Wi-Fi etc. EMI shielding measures with OHL above roads, market places etc. will be used.

Very High / Low

Unsafe Working Place @ During and Post Construction

Lack of safe working condition.

Physical injury, electrocution, disease breakout, loss of health, loss of life.

Keeping all safety and precautionary measures in order (all workers and staff to have safety induction before working), providing awareness training, toolbox talk etc. maintaining first aid and well-equipped primary health center; Periodical health inspections, provision of medical leave for labors, awareness, etc. Access of emergency medical service such as medics and ambulance etc., health check-up of staff, discouraging staff to come to work place in case of contracting air or waterborne disease.

Low / Medium

Diseases Outbreak @ During and Post Construction

Construction workers, staff, employees having contagious diseases.

Health loss due to disease, loss of productivity.

Keeping all safety and precautionary measures in order, providing awareness training, toolbox talk etc. maintaining fully equipped first aid equipment in the construction facility; Access of emergency medical service such as medics and ambulance etc., random health check-up of workers in case of visual indications.

Medium / Medium

Sabotage @ Post Construction

Evil intention of damaging or disrupting national facility by planned

Injury or loss of life, loss of power, interruption of

Maintain connection with local police; Maintain vigilance of the surroundings for any suspicious activities around the station area;

Very Low / High

119

sabotage, intrusion, etc. power, loss of process, etc.

Station always trained security guards at the entrance and security round at intervals during night time; Active CCTV surveillance at all times; Provide adequate lighting inside the facility for high visibility during night time.

120

5.3.1 HVDC Electromagnetic Field (EMF)

224. Substations and OHL produce both electric and magnetic fields. Electric fields are created by differences in voltage. The strength of the electric field is measured in kilovolts per meter (kV/m). Any electrical wire that is charged will produce an associated electric field. This field exists even when there is no current flowing. The higher the voltage, the stronger the electric field at a given distance from the wire. Magnetic fields are created when electric current flows; the greater the current, the stronger the magnetic field. Electric fields are strongest close to a charge or charged conductor, and their strength rapidly diminishes with distance from it. Magnetic fields arise from the motion of electric charges. The strength of the magnetic field is measured in micro tesla, µT. 225. Health concerns over exposure to EMF are often raised when a new transmission line or substation is proposed. However, in spite of all the studies that have been carried out over the past 30 years, there is still no persuasive evidence that the fields pose any health risks. World Health Organization (June 2007) recommends using exposure guidelines published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). The ICNIRP (2010)33 has set the limits at 50 Hz for the public exposure as: (1) electric field strength (kV per meter) is 5 kV/m, and (2) magnetic field strength (micro tesla) is 200 µT (equivalent to 160 A/m); while for the occupational exposure as: (1) electric field strength is 10 kV/m and (2) magnetic field strength is 1000 µT. 226. A similar BtB station in the western district of Kushtia, Bangladesh–the Bheramara 2x500MW 400 kV HVDC BtB Station, is already operating. CEGIS measured the EMF of the existing Bheramara station, to investigate whether the exposure levels are below both public and occupational exposures as set by ICNIRP. The test was conducted in the second week of September 2018 and the maximum figures for both electric field and magnetic field are far below the limits set by ICNRIP. The detailed findings and comments are placed below. 227. Table 5.12 below lists the investigation location, date and time along with the specification of the device that has been used to capture the data for the investigation report. Table 5.13 lists the maximum value measured at Bheramara.

Table 5.12: Location, Date, Time and Device Specifications for the Investigation

Location: Bheramara 2x500MW BtB Station, Bheramara, Kushtia, Bangladesh

Date: Tuesday, September 11, 2018

Time: 12:00 - 1:00PM

Equipment: Electric and Magnetic Field Meter

Make: AlphaLabs Inc.

Meter Name: TriField Meter

Model: 100XE

Country of Origin: United States of America

Range: 0-100 milli Gauss for Magnetic Field, 0-1000 V/m for Electric Field

Resolution: 0.2 milli Gauss (0.02 µT) for Magnetic Field, 5 V/m for Electric Field

Frequency Range: 40Hz to 100kHz for both Magnetic and Electric Fields

Accuracy: ±20% for Magnetic Field, ±30% for Electric Field

Directions: 3-Axis for Magnetic Field, Single Axis for Electric Field

33 Source:https://www.icnirp.org/cms/upload/publications/ICNIRPLFgdl.pdf

121

228. The data required for this investigation has been captured from several locations in and around the station. The locations included the air insulated switchyard bays, the filter areas, the transformer areas, the control room, the panel rooms, etc. The data has been captured from the closest permitted and possible distance following appropriate procedures. The capture distance from the source has been recorded in Table 5.14. During the capture of the data for both Electric and Magnetic Fields, the meter needle showed small but consistent sways. These sways have been captured as Reading Minimum (min) and Reading Maximum (max) to cover the entire range of the needle sways; the two extremities subsequently have been used to calculate the average meter readings and recorded in Table 5.14.

Table 5.13: ICNRIP (2010) vs. Bheramara Measured (including meter accuracy) for Electric and Magnetic Field

Type of Measurement (Unit)

ICNRIP (2010) Occupational Exposure Limits (50Hz)

ICNRIP (2010) Public Exposure Limits (50Hz)

Maximum value Measured at Bheramara (50Hz)

Adjusted Bheramara Reading (50Hz) (Considering Meter Accuracy)

Electric Field (V/m)

10,000 5,000 560 730 (+30% for Electric Field)

Magnetic Field (µT)

1,000 (500 with IFC EHS guidelines)

200 (100 with IFC EHS guidelines)

0.5 0.6 (+20% for Magnetic Field)

229. The maximum Electric Field measured is 560 v/m at a distance of approximately 3.0 meters from the Reactor Connection Line in the 400kV side. Considering the meter accuracy, this value can be 730 V/m (+30%). The maximum Magnetic Field measured is 0.5 µT. Considering the meter accuracy, this value can be 0.6 µT (+20%). Both values are well below the public exposure level for 50Hz systems as set by ICNRIP. 230. It is to be clarified that the HVDC station only has High Voltage DC components inside the Valve Hall where the conversion from AC to DC and again from DC to AC take place. The entry to Valve Hall is prohibited during regular operations. The Valve Hall is usually de-energized before regular maintenance. It is not possible to experience personnel occupational exposure of electric and magnetic fields in the Valve Hall during regular operations and maintenance. Thus, this location is discarded. It is also noted that the Control Room, the panel locations, the switch/ pump house etc., where the personnel occupancy will be for the maximum duration of time, have relatively low magnetic field and non-existent electric field. Two readings have been collected from outside the boundary but very close to the station and the field strengths are found to be well under the public exposure level as set by ICNRIP as expected. 231. Based on the investigation, it is seen that the existing 2x500MW 400 kV HVDC BtB station in Bheramara does not pose any danger to public or occupational health as set by ICNRIP. The Comilla 500MW 400 kV HVDC BtB station has similar features of those in Bheramara. So, it can be confidently concluded that, the project will not have any adverse effect on public or occupational health during its regular operation and maintenance.

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Table 5.14: Data Captured for the Electric and Magnetic Field Investigations

Location of Capture Magnetic Field (milliGauss)

Magnetic Field in Micro Tesla (µT)

Electric Field (Volts/meter) Electric Field Approximate Distance from Source (meter)

Reading min

Reading max

Average Reading min

Reading max Average

230kV Line (Over Head Line) * 3.5 3.6 0.355 70.0 80.0 75.00 25.0

Tower 1 (230kV) * 3.0 3.5 0.325 450.0 460.0 455.00 30.0

400kV Conductor 2.0 2.1 0.205 470.0 510.0 490.00 8.0

Rector (400 kV) 3.4 3.5 0.345 290.0 310.0 300.00 3.0

Reactor Connection Line (400 kV) 2.5 2.7 0.26 550.0 560.0 555.00 3.0

Switch/ Pump House 3.0 3.2 0.31 0.0 0.0 0.00 0.5

AC Filter (230 kV) 4.0 4.1 0.405 40.0 50.0 45.00 2.5

AC Distribution Board (ACDB) Room Panel

3.5 3.7 0.36 0.0 0.0 0.00 0.2

Switchyard Panel Room (SPR) Panel 1.0 1.5 0.125 0.0 0.0 0.00 0.2

400kV Isolator 3.0 3.2 0.31 150.0 200.0 175.00 1.5

Filter Reactor (230 kV) 3.0 3.1 0.305 490.0 500.0 495.00 3.0

Filter Capacitor (230 kV) 4.9 5.1 0.5 480.0 510.0 495.00 2.5

Transformer (230 kV) Set A 4.2 4.7 0.445 65.0 70.0 67.50 2.0

Transformer (230 kV) Set B (New) 4.8 5.2 0.5 45.0 55.0 50.00 2.0

Smoothing Reactor (400 kV) 4.4 4.6 0.45 500.0 520.0 510.00 2.5

Transformer 400 kV 3.5 4.0 0.375 28.0 32.0 30.00 2.0

Control Room (Walkthrough)** 1.5 3.5 0.25 0.0 0.0 0.00 0.2

MAXIMUM 4.9 5.2 0.5 550.0 560.0 555.0

*Located outside the boundary of the station ** Data captured while walking inside the Control Room while pointing the device towards panels and equipment. The highest and the lowest readings are captured. Yellow boxes represent highest level of exposure captured. Blue boxes represent no electric field.

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6 Analysis of Alternatives

232. The project site has been finalized at a location which is adjacent to a 230/132kV in Burichang Upazila of Comilla. The 230/132 kV substation is built on a land area of approximately 6 ha and situated at 23°30'32.22''N and 91°06'06.66''E beside the Comilla-Sylhet Highway. 233. The acquired land falls partly in the Harindhara Mouza and partly in the Purba Sharippur Mouza of Burichang Upazila. The acquired land for 400 kV HVDC substation situated at 23°30'42.09''N and 91°06'13.14''E has a lot shape of a pentagon with a size of approximately 16 ha. 6.1 Constraints in Analysis of Alternatives 234. Of necessity, the new sub-station site has to be adjacent to the existing sub-station. There will be a transmission line connector of 0.2 km to link the HVDC BtB substation to the existing transmission line coming from India (and another similar connector at the Indian sub-station), which means the location of the transmission line will be determined by the substation and the last transmission tower in the system. 235. There is no scope for having the sub-station and final tower and connector in any other location. 6.2 Implications of Site selection for the Substation

236. The proposed site, adjacent to the existing sub-station, is the most innocuous of all available open sites in the Harindhara-Debpur area, since it falls within rice fields and abandoned plots that are waterlogged much of time, in any case. 237. There are no structures to be removed and no requirements for resettlement (although compensation has been paid for lost land and future agricultural production, and the cross-road will be replaced with a perimeter road to the north). 238. The proposed site also has access to the Sylhet-Comilla highway through the sub-station access, and also can take advantage of some open spaces within the existing sub-station perimeter. Further, the location of the substation does not affect any monument of cultural or historical importance. 239. The shape of the proposed site has been adjusted to maximize distances to nearest houses (190 meters on the north; 65 meters on the west; 70-90 meters on the east; and, 110 meters on the south).

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7 Information Disclosure, Consultation and Participation

240. Stakeholder consultation (a two-way flow of information and opinion exchange), or simply consultation, is a regulatory process of IEE by which the people's input on matters affecting them is sought. 241. Its main goals are in improving the efficiency, transparency and community involvement in policies, programs and projects. 242. It usually involves notification (to publicize the matter to be consulted on), consultation as well as participation (involving interested groups in the drafting of policy or designing programs). 243. Stakeholder Consultation is mandatory for any development project according to the guidelines of the DoE, which include approaching people to engage them in the project and noting their concerns about the impact and benefit of the project (from the local people’s point of view). 244. During the consultation process of the proposed HVDC BtB Station project interventions, as well as possible impacts. These were discussed with local people at length. 245. In the consultation process, the stakeholders got involved with the study consultants in reforming/developing the project interventions, considering the local needs and aspirations in line with the problems and solutions suggested by them. 246. The study team consulted with the stakeholders for obtaining their perceptions, views and feedbacks on the probable changes likely to happen within the project area. 7.1 Consultation with Stakeholder

247. Objectives and purpose of Stakeholder Consultation. 248. The main objectives of the stakeholder consultation/meetings were to:

• Inform local people about the goal and objective of the proposed project; • Make people knowledgeable about the components of the proposed project; • Make people aware about the problems that could be created by the proposed project; • Obtain suggestions (mitigation measures, enhancement measures, contingency

measures, compensation measures) to resolve those problems; and • Confirm that all the APs and stakeholders have been adequately consulted and have been

part of the various decision-making processes. 249. Location of Consultation and Discussion: The Process of Consultation and Discussion took place at times and places during the Field Visit. These are shown in the Table 7.1 below:

Table 7.1: Location of Consultation and Discussion

125

District Upazila Place Type of

consultation Date Time

Number of Participants

Comilla Burichang Debpur 230/132kB

Comilla SS Key Informant

Interview 24.07.2018 1.30 PM 3

Comilla Burichang Harindhara Mouza Informal

Discussion 24.07.2018 4:00 PM 8

Comilla Burichang Debpur Mouza Informal

Discussion 25.07.2018 10:00 AM 5

Comilla Burichang Chairman Office Consultation

meeting 25.07.2018 11:30 AM

23 (7 of whom were

female)

7.2 Project Stakeholders

250. Identification of Stakeholders: Stakeholders include all those who may affect or are being affected by policies, decisions or actions within a particular system (i.e., this project). Stakeholders can be groups of people, organizations, institutions and especially individuals. Stakeholders can be divided into primary and secondary categories. 251. Primary Stakeholders: Primary stakeholders are people who would directly benefit or be directly impacted by a certain project intervention. In the case of the proposed project, the primary stakeholders include the people living around the project area, or having crops or using the road that crosses the project site, particularly those who reside in the immediate vicinity of the project area. The primary stakeholders of the project include the farmers, local business community, students, and service professionals. Primary stakeholders were identified and consulted during the IEE field surveys. 252. Secondary Stakeholders: This category of stakeholders pertains to those who may not be directly affected but have interests that could contribute to the study, play a role in implementation at some stage, or affect decision making on project aspects. In this project, concerned departments under local government institutions and implementing agencies fall in this category. 7.3 Methodology

253. In this study, a participatory approach has been followed during the consultations with both primary and secondary stakeholders of the project. A checklist was prepared in relation to the project intervention and to explore stakeholders’ opinions on the project and its impact. The process of consultations with different stakeholders was of much help in exploring problems and possible suggested measures and to share information on the project activity and tentative impacts on environmental and social components. 7.4 Tools and Process Used

254. The basic tools, techniques and process used during consultations were: • Informal discussion; • Key informant interview; and • Consultation meetings.

Informal Discussion

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255. During the field visit, informal discussions were held in the presence of local people. The project intervention and activity of the proposed project were discussed during the informal discussions. Key Informant Interview 256. A Key Informant Interview was conducted with Sub-Divisional Engineer and two Sub-Assistant Engineers of PGCB of Comilla 230/132 kV Substation at their offices. With reference to project activities, several issues were discussed. Besides, project activities and relevant project tasks were shared, to get their consent. Stakeholder Consultation 257. A stakeholder consultation meeting was held with the Union Parishad Chairman, members and local people at Mainamati Union Parishad. The project intervention and activity of the proposed project were the main issues of discussion during this consultation. 7.5 Summary of Focus Group Discussion on Environment

Major Problems and Suggested Measures 258. The people of the area showed an overall positive attitude towards the proposed project; in general, as they feel that implementation of this project would play a great role for development of the region, as well as the country. The optimistic perception of the local people is (possibly) reflected by the higher percentage of education compared to the rest of the country. However, the participants expressed their concerns on several issues, which seemed reasonable. The livelihood related issues will be addressed separately by the social team. People’s suggestions about the site are presented below in brief. Water Logging 259. The first main concern the people of the locality want to be addressed is the potential aggregation of the water logging situation which has been hampering their livelihood for several years. The riverbank erosion and shifting of River Gomti further to the north of Debpur Mouza has already taken away cultivable areas from the flood plains. This is due to the Jaintar Canal losing its downstream connection to River Gomti and thus it cannot take the rainwater away as it used to. Cultivable lands that were producing three crops a year now only yield one or two crops at best. The concern is that the acquisition of land and subsequent land filling along with construction of the HVDC Station on 45 acres of land will add to the water logging situation further, in the Mouzas of Debpur, Purba Sharippur and Harindhara, where people have been experiencing drainage congestion in recent years. 260. The local community therefore made a request to the concerned authority to channel a canal or drainage system inside the boundary of the acquired land and route a drainage channel about 600 meters to the northwest, where it will link into the old canal system. This is intended to ease the water logging situation and help alleviate the suffering of the people (as a CSR-type activity supported by the project). Alternative Road 261. The second main concern of the people is the road that has connected Harindhara and Debpur communities for many years which now runs through the middle of the acquired land (proposed project area). This road has been in use by local people, including school-going children of the communities for years as it is the only, and shortest, route from Harindhara to Debpur.

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262. The local authority (i.e., Union Parishad) has already partially completed a soil-filled (kutcha) road which runs from Harindhara to the north-east side of the acquired land but is approximately 650 meters short of connecting to the other side; i.e., Debpur, as a bypass road. Remaining 650 meters section is able to be passed through though it is under construction by the chairmen of Harindhara Union Parishad. The local authority requests that the remainder of the road be funded and completed by the government so that the bypass road is completed before the start of land filling of the project area. Work on 650 meters road to provide alternate access has already been taken up by the Union Parishad chairmen, who has also confirmed that the construction of the balance road would be completed soon. 263. In consultations, local people identified that the proposed project may create some problems, but they are keen to proactively work to bring about solutions to the problems; an example would be the initiative to start working on the kutcha road connecting Debpur and Harindhara Mouzas. During consultation meetings, people shared their views and gave some important suggestions. They consider that implementation of the project will be in the best interest of the country. 264. A combined table on multidisciplinary problems/issues and solutions/measures is given below (Table 7.2).

Table 7.2: Major Problems and Suggested Solution by the Stakeholders

Issues Problems Solutions Water Resources Water logging problem is the main

issue for the study area. Adjacent canals have been filled up due to sedimentation. As a result, width of the canals has narrowed down with time. For this purpose, rain water cannot drain out properly from the study area and this creates water logging for the whole year around.

To drain out the logged water from the study area, a canal has been proposed and the detailed design will be updated when EPC contractor is on board.

Agriculture resources

Soil quality The topsoil and subsoil may be disturbed and likely to be displaced due to the construction of the HVDC Station.

Soil quality

• The contractor should be careful during site clearance activities.

• The contractor should carefully dig the hole for construction of the HVDC Station.

• The excavated soils materials should be properly stacked for refilling the digging area by maintaining the sequence of the soil profile (i.e. Topsoil –Subsoil –Substratum).

• The contractor should be careful during maintenance work.

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Fisheries Resources

• Fish habitat quality has degraded in the floodplain area due to the use of agricultural inputs like fertilizer, pesticides etc.

• Awareness campaign for the farmers to use agricultural inputs at a minimum (as possible).

Ecological Resources

• N/A • N/A

Health and Safety • Health and safety security of local community

• Health safety and security would be ensured during the construction and post construction phases.

• Avoiding accidents and unusual events during construction of the HVDC Station which may affect peoples’ health, especially for women and children; therefore, during construction work, a safety plan and its implementation would be ensured, and monitoring activities also would be enhanced.

265. Some photographs of the consultation meetings with different levels of stakeholders are given in Figure 7.1 below.

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Photo1: Discussion meeting with Engineers of Comilla Substation.

Photo2: Consultation meeting with Chairman and local people at Mainamati Union Parishad.

Photo3: Consultation meeting with Chairman and local

people at Mainamati Union Parishad (note: at least seven local women participated in this meeting,

facilitated by women in the project team).

Photo 4: Consultation meeting with Chairman and local people at Mainamati Union Parishad.

Photo 5: Discussion meeting with local people at

Harindhara village. Photo 6: Discussion meeting with local people at

Debpur village.

Figure 7.1: Some Photographs of Consultations

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8 Grievance Redress Mechanism

8.1 Objectives of Grievance Redress Mechanism

266. The Grievance Redress Mechanism (GRM) is intended to ensure any complaints are recorded properly and addressed smoothly. According to GRM, affected people and communities would place their claims/counterclaims to the Grievance Redress Committee (GRC) consistent with the grievance redress method. The affected people (AP) may appeal to the GRC against any disagreeable decision, practice or activity arising from construction-related activities and in compensating for land and assets. APs will be fully informed of their rights and of the procedures for addressing complaints, either verbally or in writing during consultation and at the time of compensation. 267. Many grievance redress mechanisms in Bangladesh have a number of similar features including:

• An assigned focal point or grievance redress officer who manages the grievance redresses mechanism. There are different focal points for different levels, to which people can appeal if they are unhappy with the decision made at their level;

• The provision and process of the grievance redress mechanism is well publicized; • A complaints form (with in-filling supported by a facilitator, for illiterate people) for which

a receipt is given; • Information about the complaint and its resolution is documented, often in a

management information system. This information is generally supposed to be available to all;

• A committee-based hearing process is used, which is often open. A resolution is generally sought using the applicable guidelines;

• If the aggrieved person is female, they will be assisted in hearings by a female Union Parishad Member, and if from a tribal community, by a tribal representative;

• Complaints should be dealt with within a specific timeframe, generally around two weeks; and

• The grievance redress mechanism does not pre-empt a person’s right to seek redress in the courts of law.

8.2 Guidelines to Redress Grievances

268. PGCB would establish a procedure to deal with and resolve any queries as well as address complaints and grievances about any irregularities. In this regard, a policy and/or guideline will be prepared and adopted for assessing and mitigating potential social and environmental impacts through a GRM. The GRM will deal with complaints and grievances related to both land compensation payments and environmental issues of the Project. GRC will be formed to receive and resolve complaints as well as grievances from aggrieved persons from the local stakeholders, including the APs.

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269. Based on consensus, the procedure will help in resolving issues/conflicts amicably and quickly, saving the aggrieved persons from having to resort to expensive, time-consuming legal actions. The procedure will, however, not prevent a person’s right to go to the courts of law. The Land Acquisition procedure has already been completed and land is in possession of the PGCB. During the field visit, it was found that most of the PAPs have got their compensation, except some of those lacking land documents. In this regard, a GRC is mandatory for solving any sort of problems that may arise during the construction period. 8.3 Complaints and Grievance Mechanism

270. Any complaints on ownership title or other suits falls under arbitration which is to be resolved by the judiciary system will not be within the purview of the GRCs. The APs will be informed about their right and entitlements in the focus group discussion facilitated by the project field level staff. People’s initial complaints/comments would be resolved in the focus group meetings. If the AP is not satisfied with the explanation, he/she may bring his/her complaints to GRC. In this regard, the local staff will assist the AP in lodging the complaints. 271. Other than disputes relating to ownership right under the court of law, GRC will review grievances involving all compensation payments or environmental disturbances. However, the major grievances that might require mitigations include:

• APs not enlisted; • Disturbance from the project • Losses not identified correctly; • Compensation/assistance not as per entitlement matrix; • Dispute about ownership; • Delay in disbursement of compensation/assistance; • Improper distribution of compensation/assistance in case of joint ownership; • Incorrect name in the award book of DC; and • Environmental Disturbances.

8.4 Grievances Redress Committees

272. Composition of Grievance Redress Mechanism: The GRC will be established locally at the Project site and centrally at the Project level to receive and settle grievances from APs and other local stakeholders. The two-tier GRM will be composed of Local GRCs (LGRC) at the union/municipal level, as the first tier, and Project GRC (PGRC) at the central level, as the second-tier. Most of the grievances will be resolved at the LGRC, but those cases that cannot be resolved will be forwarded to PGRC. The LGRC will be constituted with representation of the local Union Parishad (UP) Chairman and AP ensuring women’s representation. The PGRC will be constituted with representation from the Project Management Unit (PMU), Implementing Agency (IA) and one independent person from the civil society having knowledge about the relevant Bangladesh Legislation. 273. The following GRC composition is proposed for the LGRC with representations from the Project Proponent, IA, local elected officials and representatives of affected people, including women in the Project area, to ensure a participatory process and to allow voices of the affected communities in the grievance procedures.

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Executive Engineer, PGCB : Convener Representative of IA (Non-voting) : Member-Secretary Chairman of Union Parishad (UP) concerned : Member Female member of ward of the UP concerned : Member Retired teacher from the union concerned : Member Representative of PAPs : Member 274. One (1) representative of APs (based on the recommendation of the IA and approved by the Convener) will be a member of the LGRC. The Member-Secretary of the LGRC will be available and accessible to APs to address concerns and grievances. Post evaluation of some past projects indicates that GRCs have worked well and were successful in resolving disputes in a participatory manner, ensuring fairness in the decision-making process. Unresolved cases will be forwarded to PGRC. The LGRC is empowered to take a decision, which is bound upon the Project Proponent. But it requires the approval of the Project Director for implementation of the decisions. 8.5 Scope and Jurisdiction of GRC

275. Scope of Work of GRC: The GRCs will be activated with power to resolve issues not to be addressed under legal suit in the courts. The GRCs will receive grievance cases from the APs through the project IA. They will assist the APs in lodging their complaints in a proper format acceptable to the GRCs after they get ID cards from the PGCB or are informed about their entitlements and losses. GRCs will be activated to allow APs sufficient time to lodge complaints and safeguard their recognised interests. Where land acquisition will not be involved but relocation of structures or vacating land from cultivation will be required, the GRCs will facilitate resolution of the complaints. 8.6 Grievance Redress Process

276. The procedural steps of resolving grievances and the grievance redress processes are presented in Table 8.1 and Figure 8.1.

Table 8.1: Grievance Resolution Process (usual generic process for PGCB) Step 1 • Complaint relating to the environmental impacts will be entertained by the GRC

Step 2 • The contractor assists the aggrieved APs to produce a written complaint to the convener of GRC with stories and expectations. The contractor counsels the aggrieved persons on the mandate and procedure of grievance resolution.

• GRC scrutinize the case records and sort out cases to be referred to the Deputy Commissioner or the court of law and those to be resolved in GRC.

• Hearing is organized on cases with merit at the GRC secretariat or at Union Parishad/Municipality Offices at local level and resolution is given by the GRC in one month of receiving the complaints.

• Aggrieved APs satisfied with the resolution approach the executing agency for completion of process. The agreed resolution is forward to PGCB for approval by the Project Director before processing entitlements for the entitled person.

• In case the resolution is not acceptable to the APs, he/she approaches the Project Director through the GRC convener with assistance from the contractor for further review.

• Aggrieved APs may opt to approach to the Court of Law, if the resolution at PGCB is not acceptable to him/her.

Step 3 • The resolution accepted by the aggrieved APs at any level (local, PMU) is approved by the Project Director and forwarded back to the Conveners’ office keeping records at his/her office.

• Implementation of the approved grievance resolution.

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Figure 8.1: Grievance Redress Flow Chart (note that ongoing issues which pose a life-and-death scenario need to be resolved immediately)

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277. The PGRC at headquarters will keep records of complaints received for its use, as well as for use by ADB during regular supervisions. The GRM does not impede access to the legal system. Affected persons can resort to legal action through the country’s judiciary system at any time. They can also submit their grievances to ADB’s Accountability Mechanism. 8.7 Approval of GRCs and Entitlements of GRC Members

278. All the decisions and proceedings of GRC meetings at any level will be finally approved by the Project Director, contractor and PGCB. According to the agenda of the resettlement plan, the approved GRC decisions will be implemented in a location. 279. APs will be exempted from all administrative and legal fees. Complainants to the court will also have the right of free legal representation. The detailed procedures for redress of grievances and the appeals process will be widely publicized among the parties involved. 280. All GRC members will attend a training and orientation meeting earlier, before commencement of their work. Project staff and consultants/resettlement specialists will conduct the training. 281. Grievances will be heard once a month by GRC. Within two weeks of the hearing of the grievances the GRC will inform the concerned aggrieved persons and the PMU within a period of two weeks of their decision. 282. If necessary, PGRC will conclude its proceedings based on field inspection within a period of one month since the submission of the grievance. 8.8 Grievance Redress Monitoring

283. The Project Directors of PMU will keep records of all the grievances and their redress in monthly cumulative formats, which will be provided by the contractor and to be signed by the convener of the GRC. The format will contain information on the number of grievances received with nature, those resolved, and the number of unresolved grievances.

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9 Environmental Management Plan

9.1 Environmental Management Plan

284. The Environmental Management Plan (EMP) includes mitigation measures, enhancement (where possible), compensation, monitoring and contingency plans for managing the consequences of the Project interventions at the pre-, during, and post-construction phases of the project implementation.

285. Mitigation measures responding to all perceived impacts and a monitoring plan, with associated budgets, are included in the EMP, according to the following sensitive parameters:

• Physical Environment and Water Resources • Land and Agriculture resources • Fisheries Resources • Biological Environmental Resources • Socio-economic Resources

9.1.1 Physical Environment and Water Resources

286. The EMP for physical and water resources at the site of the HVDC 400 kV BtB Sub Station at Comilla is presented below in Table 9.1

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Table 9.1: EMP for Physical Environment and Water Resources

IESC Impact Mitigation/ Compensation/ Enhancement

EMP cost (lac BDT and

USD)

Responsibility

Pre-construction Phase No impact during Pre-construction phase. A full set of baseline data of air, water quality and noise background level will be collected prior to

construction. Construction Phase

Ambient Air Quality

Decline in air quality due to exhaust emissions, from vehicles, road dust, concrete mixture machine, dust emissions from the material stockyards and construction work at HVDC station sites.

• Regular use of water spray systems will be introduced at the construction site to minimize dust.

• All sand piles will be covered at all times. All trucks carrying sediments will also be covered (additional sand will most certainly be required from the sand yard across the highway from the current sub-station).

• Exhaust emissions from vehicles, machinery equipment will comply with Bangladesh air quality emission standards.

2 lac $2,383.65

PGCB and Contractor

Noise

Generation of noise due to transportation of materials, and unloading of materials, stringing of transmission line, construction work and installation of machines at HVDC station site

• Vehicle traffic and construction activities will be contained within the work site and the current sub-station yard and a small stretch of the Sylhet-Comilla highway (the latter already has an over-riding noise signature, which the local communities live with).

• Noise levels will continue to be monitored in pre-construction and construction, and if there is exceedance at the village edges, noise baffles will be constructed.

• Finally, rotary drilling, for cast-in-situ bored piles, will be considered, to avoid the noise of pile driving (much quieter operation). For smaller facilities, floating cast concrete platforms on compacted soil can also be used.

1 lac $1,191.83

PGCB and Contractor

137

Water Quality Disturbance to the surrounding water due to waste

• The laborer camp, stock yard, will all be located on the premises of the existing sub-station and southern edge of the new project footprint. Further, the whole new work site will be raised, leveled, and bounded by a construction-grade wall (normal practice in Bangladesh, in low-lying areas), to retain sediment within the footprint and maintain site stability (as it will be perched about the surrounding low-lying, waterlogged area). Nevertheless, the site will have surface drains to the surrounding area to avoid ponding on the work site.

• The small amounts of required concrete batching will be done on-site, to avoid the need for concrete trucking.

• The site will be organized for waste storage and eventual disposal (to the Comilla landfill).

• All sediment piles will be watered and covered.

• A worksite protocol will be established to avoid disposal of waste outside the project site.

• Fuel and other hazardous materials will be stored in a locked, bunded area that will securely contain the whole volume of material (plus 10%).

• Fuel transfers will be done on a concrete pad, with edge channels and walls.

• These mitigation measures will isolate all site activities and materials from the surrounding farmland and adjacent villages.

• The project will use the current sub-station toilet facilities, augmented as needed with a septic system that can be tied into for the permanent toilet facilities of the new sub-station.

• Work site conditions will be monitored and issues addressed on a daily basis.

• The World Bank/IFC EHS guidelines will be

1 lac $1,191.83

PGCB and Contractor

138


EMP cost (lac BDT and

USD)

Responsibility

reviewed for other approaches that may be suitable for the construction phase of this project.

Post Construction/ Operation Phase No impact during Operation Phase. Noise level and EHS status will be continuously monitored. Total 4 lac

$4,767.26

1 USD = 83.905 BDT, Aug 19 2018, *

9.1.2 Land and agriculture resources

287. The Environmental Management Plan for land and agriculture resources is presented below in Table 9.2.

Table 9.2: Environmental Management Plan for land and agriculture resources

IESC Impact Mitigation/ Compensation/ Enhancement Cost

(BDT Lac and USD $)

Responsible Agency

Pre- construction Stage

Soil quality

Soil quality might be deteriorated due to site clearance activities.

• The contractor will carefully clear the vegetation (rice field remnants) for site preparation and infilling, with sand, to allow construction of the HVDC Station.

• There are four trees along the road in the center of the site. These might be retained, if structure and facility arrangements within the site perimeter allow it. Otherwise, at least 8 trees will be planted around the perimeter of the site, as compensation.

N/A PGCB, Contractor.

Construction Stage

Land use

Agricultural land would be converted to non-agricultural land.

Landowners have been compensated, and an alternative road around the northern perimeter of the site (almost completed) will be upgraded and completed.

N/A PGCB, Contractor.

139

IESC Impact Mitigation/ Compensation/ Enhancement Cost

(BDT Lac and USD $)

Responsible Agency

Crop production

About 126 tons rice production would be permanently lost, due to the construction of HVDC Station.

• Farmers will be allowed to undertake a final harvest prior to handing over land to the project.

• Compensation payments take into account the loss of land as well as its future production value.

•

37.00 lac $44,097.49

DC Office, PGCB, Contractor.

Soil quality

The soils of the HVDC Station area will also be disturbed due to construction activities.

• The existing sediments and sand from the nearby sand yard will be used to elevate the whole project site, for proper building construction and future flood protection. As such, sediments will be contained within a construction-grade retaining wall, to isolate the site from surrounding areas.

• It is likely that rotary drilling, for cast-in-situ bored piles, will be used. Sediments from this drilling process can be used for site infilling along the perimeter.

• Once construction is complete, open areas will be landscaped with grass.

1.0 lac $1,191.83

PGCB, Contractor.

Post- construction Stage

Soil quality

• The soils of the surrounding of Harindhara, Comilla HVDC Station area will be disturbed due to maintenance activities.

• Maintenance work that requires excavation of soil is expected to be minimal; in any case, there will be a perimeter wall which will reduce loss of site soil to surrounding areas.

• The contractor should be careful during maintenance work (minimal soil disturbance).

1.0 lac $1,191.83

PGCB, Contractor.

Total 39.0 lac

$46,481.14

1 USD = 83.905 BDT, 19 Aug 2018 9.1.3 Fisheries resources

288. The Environmental Management Plan for fisheries resources is presented below in Table 9.3.

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Table 9.3: Environmental Management Plan for Fisheries Resources

IESC Impact Mitigation/ Compensation/ Enhancement Cost (lac BDT and

USD $) Responsible Agency

Pre-construction Phase No Impact during pre-construction Phase

Construction Phase Fish habitat area

• Net loss of fish habitat would be about 16 ha where floodplain contributes the most.

• The only suitable mitigation is to consider the possibility of retaining the existing fish pond. In any case, the pond owner will have been compensated for loss of the pond.

• Further, site activities will be contained within the perimeter wall, so that adjacent waterlogged areas will not be affected. There is still an abundance of aquatic habitat within 5 km of the project area (all the waterlogged areas between the villages near the Gomti River).

Compensation is considered in project cost.

PGCB and Contractor

Fish production • Estimated loss of fish production would be about 2.5 metric ton annually.

• Since the existing fish pond will be retained, the environmental impact can be fully mitigated (however, compensation for its loss is the other remedy and assessed separately).

Compensation is considered in project cost.

PGCB and Contractor

Post-construction Phase Fish habitat condition

• Fish habitat could be affected by the oil-mixed service water, which comes from the maintenance site

• Any liquids or service water used on site will be retained in a tank and trucked offsite, so there will be minimal risk of loss of liquids to the project site, or beyond.

• A septic system, requiring annual maintenance, will ensure that sewage does not enter adjacent areas.

N/A PGCB and Contractor

1 USD = 83.905 BDT, 19 Aug 2018

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9.1.4 Biological Environment

289. The Environmental Management Plan for Biological Environment is presented below in Table 9.4.

Table 9.4: Environmental Management Plan for Biological Environment


Cost (Lac BDT and USD $

Responsible Agency

Pre-construction Phase N/A Construction Phase Vegetation • Clearance of

vegetation for labor shed construction, site development and stocking materials

• All project construction activities will be confined to the existing sub-station grounds and the new project footprint. Vegetation loss in this area will be unavoidable.

• Attempts will be made to retain the four palm trees. If they have to be cut down, at least eight similar types of trees will be planted around the project perimeter.

• Make laborers and local people aware of the benefit of native plant conservation.

2.0 lac $2,383.65

PGCB and DoE, local government institutions (LGI), Contractor and/or third parties

Wildlife habitat • Changing of wildlife habitat quality

• Construction activities will be confined to the project footprint (which will become elevated above the surrounding rice fields and waterlogged areas) and the existing sub-station site and its access to the Sylhet-Comilla highway. All the adjacent wet areas to the east, west, and north (the majority of waterlogged areas in this vicinity) will be retained, although in the area to the northwest, if a drainage channel is constructed, these wet areas will be restricted to the channel and adjacent rice fields.

• No working allowed during the night.

2.0 lac $2,383.65

PGCB and LGI, Local stakeholders and/or third parties

Post-construction Phase Wildlife habitat • Wildlife

disturbance • Avoid excess lighting and use shaded lights during the

operational phase. • Towers and wires can be flagged for higher visibility for birds.

1.0 lac $1,191.83

Project director, PGCB and LGI, Local stakeholders and/or third parties

Sub-total 5.0 lac $5,959.12

1 USD = 83.905 BDT, 19 Aug 2018

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9.1.5 Socio-economic Resources

290. The Management Plan for Socio-economic Resources is presented below in Table 9.5.

Table 9.5: Management Plan for Socio-economic Resources

IESC Impact Mitigation/ Enhancement/ Compensation Cost (Lac BDT

and USD $) Responsible

Agency

Pre-construction Phase

Land Acquisition

• For the acquisition of land, affected people will lose their land permanently which will impact their livelihoods also.

• Proper compensation will be ensured to the legal owner(s) according to the provisions of existing laws of Bangladesh (the final compensation being paid to those landowners who have not yet received it).

• Employment opportunities for the adversely affected people will be provided by the contractor, to the extent possible.

RP cost* PGCB and DC office Comilla

Construction Phase

Employment Opportunity

• During the construction period, jobs will be created directly for both skilled and unskilled labor.

• The project will make a list of directly affected people (those who have lost their agricultural land), to see if they are interested in working in suitable positions during the construction phase.

• Local people’s (PAPs) engagement will be given priority. • Appropriate technical and health/safety training and related

equipment will be provided to these workers. • Bangladesh labor code requirements will be applied, including

provisions to prevent child labor.

Included into the project

cost

PGCB and contractor

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Agency

Health and Safety

• Workers may be exposed to occupational health risks and safety hazards.

• The whole project work site will be fenced off and signs regarding potential hazards posted in conspicuous locations.

• Access from the highway to the current sub-station yard will be under traffic controls when trucks enter and exit (traffic managers with appropriate signs).

• Local communities will continue to be informed about project construction activities, schedules, and possible health and safety risks.



• Health/accident insurance for employees/contractor staff will be provided for the duration of their contracts.

• A Health and Safety Officer (HSE tasks) will be designated and will provide regular briefing on worksite risks and the need to protect local communities. An accident reporting system will also be put in place, including notifications to ADB and Government of Bangladesh, and annotation of situation remedies. Special consideration will be given to risks associated with working at height and with electrical components (workers will be suitably trained for these tasks, and fitted with safety equipment).

Lump sum 10.00 lac

$11,918.2434

PGCB and contractor

34 The health and safety costs are embedded in the overall project cost, since these items are requisite for project construction throughout Bangladesh, and should be

considered required best practice. Nevertheless, a lumpsum is provided for additional items that may not be correctly anticipated at this point.

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Agency

Interference with Road Crossing

• The construction activities may create some interference with road crossing (temporarily) which will surely deteriorate the volume and capacity of the existing road.

• Schedule deliveries of material/ equipment during off-peak hours.

• Deputize a flagman for traffic control at the highway-sub-station intersection.

• Regular notices (weekly) will be displayed on local community notice boards highlighting forthcoming traffic management information, including any unusual volume of truck traffic. Local village leaders will also be informed (via mobile phone), for verbal communication where needed.

• The cross-site road will be replaced with a better road around the northern perimeter of the project area.

- PGCB and contractor

Post-construction Phase There is no impact in the post construction phase

Total 10.00 lac

$11,918.24

1 USD = 83.905 BDT, 19 Aug 2018 *Land acquisition cost 7,623.45 lacs BDT. Or 9.086 million USD

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291. In addition to the project-specific EMP, the pre-construction phase EMP activities will include a follow-up environmental audit of the existing sub-station, by an environmental officer from PGCB in Dhaka, to ensure that lapses and issues in current sub-station practices are properly addressed before project construction starts (see Annex 1). 9.2 Monitoring Tasks and Activities

292. Monitoring will be done internally, to provide feedback to the PGCB and to assess the effectiveness of the EMP and associated project implementation. Monitoring will be carried out by the PGCB PMU, through their field offices and prepare monthly reports on the progress of ESMP implementation. The Environmental monitoring report will be submitted to ADB semi-annually for review and disclosure.

9.2.1 Monitoring Plan

293. The environmental monitoring plan will help in detecting changes taking place during, as well as after, establishing the transmission connector line, tower, and sub-station, so that necessary steps can be taken to rectify defects or deficiencies, if any. The monitoring plan focuses on implementation of the mitigation/ enhancement measures during the pre-construction, construction and post-construction/operation stages35. The project implementation will be carried out under the overall supervision of the Project Director, and a designated project staff member will be responsible for the routine environmental monitoring (given the relatively limited nature of the monitoring program and the small study area). 294. The monitoring plan will focus on the implementation of the mitigation and compensation measures during the pre-construction, construction and post-construction/operation stages, as presented in Table 9.6

35 Monitoring, and submission of monitoring reports, will start from the date of loan effectiveness or start of works,

whichever is earlier.

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Table 9.6: Environmental Monitoring Plan for Physical and Water Resources

Measure/Indicator Method Locations Frequency Implementing

Agency Monitoring Agency

Cost (BDT Lac and USD $)

Pre-Construction Phase There is no impact expected in this phase, but a full set of baseline levels of air and water quality and background noise will be measured for

the following indicators. Construction Phase

ambient air quality (NOx, PM2.5, PM10)

In situ monitoring (sampling pump with NOx analyzer; same with sized filters, for 15-minute samples); calibrated to blanks. Corrective action required when NOx exceeds 200 µg/m3, PM2.5 exceeds 25 µg/m3, and PM10 exceeds 50 µg/m3, in two consecutive samples.

HVDC station site (center and perimeter)

Every couple of weeks

Project Director, PGCB, and Contractor

Environmental staff (PGCB)

1.0 lac $1,192

Noise (dB) In situ noise meter (LAeq1hr); calibrated to zero level.

HVDC - station site (center and perimeter)

Every couple of weeks (day and night)

Project Director, PGCB, and Contractor


0.5 lac or $596

Water Quality (drinking water in nearest well: oil, turbidity, coliform, arsenic, iron; nearest surface water (for fish): oil, turbidity, coliform, DO)

In situ analyzer for turbidity and DO; lab analysis for oil, coliform, iron, and arsenic in discrete samples (all calibrated to blanks and lab standards). Corrective action required when 10 NTU exceeded in at least two samples, DO is below 6 mg/l, iron greater than 1 mg/l, arsenic greater

HVDC station site (at perimeter) and nearest tube well

Monthly Project Director, PGCB and Contractor


0.5 lac or $596

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Table 9.7: Environmental Monitoring Plan for Land and Agricultural Resources

Measure/Indicator Method Locations Frequency Implementing Agency Monitoring Agency Cost (BDT

Lac and USD $)

Pre- construction Stage

Site clearance monitoring (to ensure collection and removal of vegetation).

Pre-Construction, Construction, Post-Construction Stages

Soil Quality (nature and texture)

Visual observations to determine the nature and texture of soil and how it is handled and stockpiled (all soil will be contained on site, to help infill). Corrective actions required if soil dumped outside site.

At HVDC station site (center and perimeter)

Once before construction, every few months during construction, and once after construction.

Project Director, PGCB, EPC Contractor (s)


2.0 lac $2,384

Table 9.8: Environmental Monitoring Plan for Fisheries Resources

Measure/ Indicator Method Locations Frequency Implementing

Agency Monitoring

Agency

Cost (BDT Lac and USD

$) Post- Construction

than 0.05 mg/l, oil greater than 0.01 mg/l, and coliform evident (for all these parameters, if they can be linked to project activities).

Operation Phase Noise monitoring is needed and the other routine monitoring of sub-station working conditions will continue.

Total 2.0 lac or $2,384

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Agency Monitoring

Agency


$) Fish habitat condition (type of vegetation and degree of waterlogging at site perimeter, as well as appearance of water)

Just visual to observe any significant changes around the project site perimeter. Any noticeable changes to be corroborated with the surface water quality results.

Project site perimeter

Once during dry season and during monsoon, each year, for two years.

PGCB and Contractor


3.0 lac or $ 3,575

Table 9.9: Environmental Monitoring Plan for Biological Environment

Measure/ Indicator Method Locations Frequency Implementing Agency Monitoring

Agency


$) Pre-Construction Phase

No significant impact will occur Construction Phase Vegetation clearance (all vegetation cleared from the site

Direct observation Whole of proposed HVDC station site

During site clearing and when completed.

PGCB and Contractor


1.0 lac or $1,192

Compensation against tree felling (at least 8 trees planted near site perimeter)

Direct observation HVDC station perimeter

Early in construction phase (and then in first year of operation).

PGCB and Contractor


1.0 lac or ** $1,192

Wildlife occurrence (observations of birds and small mammals in project vicinity)

Direct observation (informal, as noticed)

HVDC station site and immediate vicinity

Once before construction, as noted during construction, and as noted in first year of operation.

PGCB and Contractor


2.0 lac or $2,384

Post- Construction Phase (addressed above)

Total 4.0 lac or $ 4,767

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** The payment of compensation for felled trees required, if any, is handled by the project proponent (in this case PGCB) or their contractor through DC Office (usually) or any other government authority. Alternatively, at least 8 trees can be planted in a location that suits the owner (however, it is likely that there is no owner, as the trees are located on the edge of the cross-over road).

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Table 9.10: Monitoring Plan for Socio-economic Resources


Agency Monitoring

Agency Cost (BDT Lac

and USD $) Pre- construction Phase

No monitoring is required in this phase. Construction Phase

Employment Opportunity (number and type of jobs filled by local people)

• Direct observation • Consultation with

PGCB officials and contractor

• Consultation with local people

At the HVDC station site

Every quarter during construction

PGCB and Contractor


1.0 lac or $1,192

Health and Safety (on site)

• Direct observation (accident reporting protocol)

• Consultation with PGCB officials and contractor

• Consultation with laborers

At the HVDC station site, and adjacent tower location.

Daily, according to accident reporting protocol.

PGCB and Contractor


2.0 lac or $2,384

Post- construction Phase No monitoring is required in this phase.

Total 3.0 lac or $43,576

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9.3 Budget for the Environmental Management Plan (EMP)

295. For implementation of the Environmental Management Plan (EMP) and Environmental Monitoring Plan (EMoP), about BDT: 114.50 Lac would be required. The detailed probable cost of the EMP is presented in Table 9.11.

Table 9.11: Budget for EMP and EMoP

Segments EMP Cost (BDT

Lac) EMOP Cost (BDT

Lac) Total Cost (BDT

Lac) Total Cost USD

Physical Environment and Water Resources 4.0 2.0 6.0 7,151

Land and Agriculture Resources 39.0 2.0 41.0 48,865

Fisheries Resources 0.0 3.0 3.0 3,575

Biological Environment 5.0 4.0 9.00 10,726

Socioeconomic Features 10.0 3.0 13.0 15,494

Contingency Fund 38.82 13.18 52.0 59,591

Grand Total 96.82 27.18 111.0 145,402

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9.4 Environmental Management Responsibilities (PMU and Contractors) during Construction

296. PGCB will establish a Project Management Unit (PMU) that will oversee the construction and operation of the new sub-station. This PMU will be responsible for engaging and monitoring contractors who will be involved in different aspects of site preparation, construction of the sub-station components, and the single transmission tower near the sub-station site. The PMU will do its own monitoring (a trained Environmental Officer) who will be full-time at the site, and the contractor(s) will also have a person designated as their own HSE officer (handling all health, safety, and environmental safeguards matters). The Contractor’s HSE officer will communicate directly with the PMU Environmental Officer on a daily or weekly basis, as needed. The PMU Environmental Officer will report to PMU management, and will also be responsible for drafting the environmental monitoring reports that will go to the Government of Bangladesh and ADB. The PMU Environmental Officer will also manage the first entry point for complaints to go through the GRM, and will prepare various communications as needed to inform local communities about project construction activities that might impinge on them. The Contractor shall prepare an action plan (location, sequence, work site linkages as an Environmental Management System specific to the project) that addresses the site-specific elements in the project EMP, which will form part of the project construction contract. Environmental and social issues which become apparent to either the Contractor or the PMU Environmental Officer will be immediately reported (one to the other), and worked stopped, as needed, or an immediate remedy put in place, with all such actions documented by the PMU Environmental Officer, and relayed up to PMU management (and ultimately documented in the environmental monitoring report). 297. Remedial actions which cannot be effectively carried out during the construction stage should be carried out on completion of the works and before issuance of the acceptance of completion of works. 298. Related to this, project construction actions on the Indian side will be managed through an EMP there (which will be provided by PGCIL to PGCB), and environmental management will be monitored and relevant reports shared with PGCB. 9.5 Environmental Protection Plan (Contractors)

299. As noted above, the Contractor will be provided with a copy of the EMP, which will form part of the project construction contract (the EMP will also form part of tender documents, before contracting, with EMP items explicitly noted). As noted previously, the successful Contractor will then prepare an action plan or a site-specific EMP (location, sequence, work site linkages as an Environmental Management System specific to the project) that addresses the site-specific elements in the project EMP. In addition to site-specific requirements in the EMP, the Contractor will elaborate on the following items:

• A site plan showing work area, fuel containment area and refuelling location, lay down areas, parking area, equipment maintenance area, material storage area and the camp area (see Annex 2 for options for the worker camp within and near the existing sub-station yard; all within the project footprint). The exact number of workers required for project construction has not yet been confirmed, but may vary between 100 and 300 during different stages of construction. Projects like this may involve 50-60% local workers, based on past experience with similar projects handled by PGCB through contractors (so some workers may choose to not live in the camp).

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• A detailed drainage plan indicating location of all water exit points from the elevated platform that will characterize the sub-station site.

• Waste management plan. • Dust control plan. • Noise control plan covering the pre-construction, construction and operation stage to

ensure the noise level within the IFC or GoB standards whichever is more stringent. • Spill response plan (mostly to address fuel) including location and contents of spill

response materials storage and designated personnel to maintain spill response materials, as well as a specific plan in the event of a spill.

• Contractor’s response to the hazard risk assessment in this IEE. • A traffic management plan for the sub-station access area and adjacent part of the Sylhet-

Comilla highway. 9.6 Monitoring Plan

300. The environmental monitoring plan will help in detecting changes taking place during, as well as after, establishing the sub-station, so that necessary steps can be taken to rectify defects or deficiencies, if any. The monitoring plan focuses on implementation of the mitigation/ enhancement measures during the pre-construction, construction and post-construction/operation stages. 301. The project implementation will be carried out under the overall supervision of the Project Director. As noted previously, site monitoring will be the responsibility of both the Contractor’s designated HSE officer, and the PMU Environmental Officer, with the latter having seniority and authority regarding environmental management requirements.

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Table 9.12: A summary matrix table for monitoring the activity of contractors that is to be submitted to PGCB (Note that this is a generic example from other sub-station sites, and will be adjusted accordingly to the current sub-station project)

Indicators Issues Compliance Monitoring

Agency

Frequency of Compliance Checking

Complied Status Remarks

Complied Not

Complied

Site Establishment

• A layout plan for construction activities needs to be developed and approved by the Environmental and Social Compliance unit (through the PMU Environmental Officer)

PGCB & Contractor

Before commencement

of the site activities and first quarter or

commencement

Labor Employment

• The employment of laborers should give priority to local laborers.

• The contractors should publicize appropriate work positions to the villages and towns near the project area

• The workers and the staff members should have legal contracts for employment

• The contractors should provide the workers with the trainings of environmental protection and occupational health and safety.

PGCB & Contractor

Quarterly in a year

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Agency



Complied Not

Complied

Health and Safety

• The contractors should ensure the project is conforming to all the national and local safety regulations as well as the other measures about damage avoidance.

• Before the construction, the contractors should provide safety training for the workers.

• Sufficient daylight and night illumination (for the worker camp and security) should be provided;

• Adequate fencing needs to be provided around the site. This needs to be checked and maintained during the construction phase;

• No other people is allowed to enter camp site *** without approval by management staff of the contractor;

• The camping site should be provided and equipped with fire-protection equipment and fire extinguisher;

• Worker camp conditions (accommodation and food/personal hygiene facilities) to meet World Bank/IFC standards.

• The contractors should provide the workers with enough personal safety protecting devices, e.g. protective glasses, gloves, protective mask, dust cover, safety helmet, ear protectors, steel helmet and so on, and ensure them to be used on the construction site.

• The safety rules, the emergency pre-plan and the emergency contact information should be indicated on the bulletin board at the construction site.

PGCB & Contractor

Every Month

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Agency



Complied Not

Complied

Waste Management

• During the construction phase the Contractor must make provision for the appropriate removal of waste from the site to a permitted waste disposal facility. The accumulation of construction waste materials must be avoided as far as possible.

• All domestic waste generated by the contractor’s activities at the contractor’s camp must be stored in either refuse bins (i.e. steel or plastic 210L drums) or in a waste skip. The Contractor must ensure that these containers are emptied on a weekly basis, or as and when required.

• All litter shall immediately be deposited into refuse bins or the waste skip. No litter must be left in the work areas or contractor’s camp.

• Construction waste must be stockpiled in the contractor’s camp and the Contractor must dispose of this waste properly. Contaminated construction waste must be dealt with separately.

PGCB & Contractor

Every Month

Waste Water Management

• Domestic sewage must be properly treated through, e.g. septic tank, before discharge.

• The distribution of storm water runoff as evenly as possible from the site.

PGCB & Contractor

Every Month

Noise Control

• Limit construction times to the day time; • No noisy activities during weekend near local

communities; • Should any noisy activities be required during the

construction phase, which is beyond normal permissible limits, necessary permits must be obtained from the local authority and any other relevant authority

PGCB & Contractor

Every Month

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Agency



Complied Not

Complied

Community Engagement and Complain

Register

• During the construction period, the contractors should maintain open communication with the local governments and the people of the relevant community.

• Before the construction, the contractors should publicize the project information to the influenced party (e.g. local departments, enterprises and residents) in the form of community meeting.

• All the construction sites should have striking signs about the project information, including but not limited to:

• brief project description; • construction plan; • major construction activities; • principal environmental problems and mitigation

measures; • Names and telephones etc. of the project manager, the

supervision engineer and the environmental protection personnel.

PGCB & Contractor

Every Month

***This site refers to that of the EPC Contractor who will be working for the Project Proponent (i.e. PGCB) and reporting to the proponent or their hired consultancy agency. These are controlled by the Project Proponent through Terms and Conditions agreed by the EPC contractor before they are given the contract to provide

their services.

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10 Conclusion and Recommendation

10.1 Conclusion

302. The Power Grid Company of Bangladesh Limited (PGCB)’s project to construct a HVDC BtB Station at Comilla to import 500MW Power from Tripura (India) will have a significant positive impact on the development of the country. The power will be transported over a 400kV transmission line. The station will be converting this 400 kV AC to 400 kV DC and then to 230 kV AC so that it can be connected to the 230 kV National Grid of Bangladesh. The construction of this station will help cover the ever-growing electricity demand of the Eastern Region of Bangladesh. Additionally, the construction of the proposed new 400 kV HVDC BtB Station in Comilla will bolster the National Grid of Bangladesh by importing 500MW power. 303. Major Components of the Project involves construction of this 400 kV HVDC BtB Station are listed below:

• 400 kV GIS, 400 kV OHL Entry. 400 kV Shunt Reactor and Filters, 400 kV Valve Hall, 400 kV and 230 kV Control Rooms 230 kV Shunt Reactor and Filters, 230 kV OHL Entry, 230 kV GIS and Storage

• The main benefit of the HVDC BtB Station at Comilla will be manifold. Firstly, it will facilitate the import of 500MW power from Tripura (India) and, second, the HVDC system, which will allow inter-connection of two independent systems (by means of converter valves), will make the power supply a more reliable one. It may be noted here that quality-electricity is scarce, and the country’s business, manufacturing and trade has long been adversely affected by lack of superior electricity. The availability of quality electricity has also been a long-felt need of the household sector of the area. With the starting of the Economic Zones in the surrounding areas of Comilla, the commercial development of the area would be hastened, and the demand of electricity will be gradually increasing.

• This IEE report has been made compliant to all relevant legislation and policies pertaining to power sector activity in Bangladesh. Apart from national laws and policies, ADB’s Guidelines to ensure mitigation measures at international standards were reviewed and considered.

• The study, following a standard methodology, has collected all required qualitative and quantitative information on the physical environment, water resources, land resources, agriculture, fisheries, eco-systems and socio-economic conditions from both primary and secondary sources. Collected data have been used for conducting the initial environmental examination.

• The IECs (Physical environment) included air quality, noise level, water quality, construction waste; the IECs (biological environment) included: soil quality, land use change, loss of crop production, floodplain habitat, fish production, and terrestrial vegetation; the ISCs (socio-economic environment) included: land price, loss of land and livelihoods, employment opportunities, and health and safety. Gender concerns and economic development were also considered for examination of environmental impacts. Relevant mitigation measures and agency-wise responsibility fixing was also done.

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• The environmental assessment reveals that construction of the HVDC Station will lead to some generation of noise due to transportation, unloading of materials and construction activities; temporary disturbance to the surrounding water and settlements due to waste disposal, deterioration of soil quality during digging and earth-filling; interference with road transportation; and, reduction in crop and fish production in the area proposed for the station construction. Risks may arise also from traffic or heavy vehicle accidents during or in the post-construction period, electrification from falling materials and wires, etc., which may result in physical injury, loss of life, vehicle and/ or property damage. Appropriate mitigation measures have been suggested in the report, to address all types of hazards and risks identified in the report.

• The issues raised by the local stake holders with respect to impact assessment and mitigation measures required concerning movement of heavy equipment and construction vehicles, water logging in the area and an alternative road were noted by the project proponents for consideration in due course.

• The environmental monitoring plan will help the implementing agency in detecting changes taking place during, as well as after, establishing the station, so that necessary steps can be taken to rectify defects or deficiencies, if any. The monitoring plan focuses on implementation of the mitigation/ enhancement measures during the pre-construction, construction and post-construction/operation stages.

• The EMP will ensure that the project is implemented safely and in an environmentally friendly manner (environmental management requirements will be noted in the construction contract).

• A Joint Technical Team (JTT) has been formed by PGCB with PGCIL and the technical team expects the project to be delivered by 30 June 2021. JTT is jointly working towards successful delivery of the project for the mutual benefit of both Bangladesh and India.

10.2 Recommendations

304. Considering the emerging need of augmenting quality electricity by importation from the neighbouring country and ensuring an inclusive development in line with the vision of becoming a developed country by 2041, the 400 kV HVDC BtB Station in Comilla is considered very essential. 305. The proposed electricity station will contribute immensely to providing much needed quality-electricity for the development of the eastern part of the country. 306. The construction of the station will cause subsequent reverberations throughout the economy and ultimately cause a holistic development of the country. While the proposed HVDC station will have some minor environmental consequences (mostly temporary), these can be mitigated with the suggestions mentioned in this report. 307. It is recommended that the project may be duly supported by the financing from ADB and given site clearance as well as environmental clearance in the priority interest of national development.

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Annex 1

Environmental Audit for Comilla 230/132 kV Substation 1. INTRODUCTION

1.1 Background

1. The Government of Bangladesh (The Government) has made power sector development a priority for supporting the fast-economic growth. The Government has committed to a massive initiative to build a nationwide transmission and distribution network with the aim of providing electricity for all by 2021. As per the Power System Master Plan (PSMP) 2016, a transmission system capable of supplying 40,000 megawatts (MW) of electricity throughout the country is expected by 2030.36

2. Bangladesh’s power supply has not been able to keep pace with the rapid growth in demand,

and consumers have experienced frequent power outages. As of June 2017, the total nationwide dependable grid-connected peak demand was 9,479 MW, against an unconstrained demand of 12,644 MW, indicating that about 3,200 MW of the power demand was met by supply from captive generation and load shedding.37 On average, over 1,000 MW of load shedding occurs during summer. Electricity demand is projected to grow by more than 10 percent per year over the medium term. The PSMP 2016 has projected that demand will rise to more than 50,000 MW by 2041.

3. The shortage of electricity and poor quality of electricity supply from the aged and low capacity

grid network severely impact industry and service sectors, which account for a major share of growth in the economy. According to the latest 2013 World Bank Enterprise Survey, Bangladesh businesses on average suffered power outages for 840 hours per year, resulting in an output loss of approximately 3% of gross domestic product.38 The availability and reliability of power is hence a key constraint to job creation and poverty reduction.

4. The Government envisages to obtain financial support from the Asian Development Bank

(ADB) for the proposed HVDC Back to Back (BtB) Station at Comilla (Bangladesh) for 500 MW from Tripura (India) to ensure that the capacity of electricity supply. The proposed project is expected to provide support for the construction of a 16ha new HVDC BtB substation and 500 m long transmission lines (detailed project information can be found in the main IEE).

5. PGCB is the state-owned power transmission company in Bangladesh, and it is responsible

for operation, maintenance and development of the power transmission system (transmission lines and substations) at 132 kV and above.

1.2 Environmental Compliance Audit

6. The implementation of the Project could have both negative and positive impacts on the surrounding environment, depending on environmental sensitivities and the design of responsive mitigation measures. Environmental impacts include physical, ecological, and socio-economic impacts. This environmental assessment was carried out to prevent and

36 Power System Master Plan 2016, Power Division, Ministry of Power Energy and Mineral Resources, supported by

Japan International Cooperation Agency (JICA), September 2016. 37 The Bangladesh Power Development Board estimates that load shedding at peak time in 2017 was about 250 MW. 38 Enterprise Surveys data for Bangladesh 2013; http://www.enterprisesurveys.org/

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reduce adverse impacts to an acceptable level, and to enhance the positive impacts linked with the implementation of the Project. A rapid environmental assessment checklist for the Project was prepared to determine potential adverse environmental and social impacts during Project design and planning, construction, and the operation and maintenance phases of the substation and transmission line projects. This Project is categorized as an Environmental B project, based on the rapid environmental assessment and the ADB Safeguard Policy Statement (SPS) 2009. For Category B projects, the environmental impacts are expected to be less adverse than Category A projects. An Initial Environmental Examination (IEE) is required to address the anticipated impacts and to suggest appropriate mitigation measures. This IEE report was prepared based on the table of contents provided in Appendix 1 of the ADB SPS 2009.

7. As per ADB Operations Manual, Section F1/OP para 53, for projects involving facilities and/or business activities that already exist or are under construction before ADB's involvement, ADB requires the borrower/client to conduct an environment and/or social compliance audit to determine their safeguard compliance status. The audit by the borrower/client confirms that on-site environmental and social assessments carried out to identify past or present safeguards concerns related to the impacts on the environment, involuntary resettlement and Indigenous Peoples.

8. Where noncompliance is identified, ADB and the borrower/client agree on a CAP, implementation schedule, and sufficient funds to bring the project into compliance with the safeguard policy requirements. If an upgrade or expansion of a project is not foreseen, the audit report (including the CAP, if any) constitutes the EIA, IEE, resettlement plan, and/or IPP.

9. The audit report is disclosed on the ADB website following the disclosure requirements in this Operations Manual section (part C). For a project involving an upgrade or expansion of existing facilities that have potential impacts on the environment, involuntary resettlement, or Indigenous Peoples, the requirements for environmental and social assessments and planning specified in this Operations Manual section (part C) apply in addition to the audit.

10. The Project has to comply with the Safeguards Policy Statement (SPS), 2009 and Operational Manual F1 (2013). Also, the Project complies with the Bangladesh Environment Conservation Rules (ECR), 1997(amended in 2017). According to the categorization of ECR, 1997(amended in 2017), the Project has been categorized as ‘Red’ meaning that it has significant adverse environmental impacts, which are to be mitigated with proper mitigation measures.

11. The audit has been conducted with the aim to assess the Project’s compliance with:

• ADB Operations Manual, Section F1/OP (2013), para 53; • Environment Conservation Rules (ECR)1997 (amended in 2017) of GoB;

• Environmental and social safeguards according the Safeguards Policy Statement (SPS), 2009 and other relevant standards and guidelines of the ADB, including the World Bank/IFC EHS Guidelines; and,

• Proposed mitigation measures and monitoring procedures according to the environmental management plan (EMP), environmental monitoring plan as are applicable.

12. The purposes of the Environmental Audit Assessment are:

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• To identify present inadequacies in environmental management, and occupational health

and safety issues in the facilities to be augmented;

• To determine the need for remedial actions necessary to bring the subject facilities into

compliance with ADB safeguard policies; and • To recommend actions to be taken to improve and strengthen PGCB’s environmental,

health, and safety management.

1.3 Method and Approach

13. Reviewing all available relevant in-house documents and visit the 230/132 kV substations to conduct visual inspection and cross check the critical issues using the prepared checklist with following elements:

• General environmental management

• Waste management practices • Hazardous material management

• Ground water and soil contamination control

• Occupational health and safety management and • Noise management

2. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK

14. The Environment Conservation Act of 1995 establishes the requirement for an environmental assessment in Bangladesh. Any proposed "industrial unit or project" must obtain prior approval from the Department of Environment (DoE). The act has classified projects to be assessed by the DoE in four categories (Green, Amber A, Amber B, and Red). Power development projects are allocated to the Orange B category, which triggers an automatic requirement for an IEE. The DoE issues an authorization for the project to proceed subject to a satisfactory review of the environmental assessment. The authorization consists of two parts, one is a "site clearance", which gives approval to the site proposed for the project and the other is an "environmental clearance", which approves the content of the project.

15. The PGCB, as the project proponent, is responsible for carrying out the IEE and EIA studies of the proposed project. Therefore, it has the responsibility to administer the environment assessment process with the consultants, review the findings, and submit the documents to the DoE for review. A key requirement of the IEE/EIA for projects classified in the Amber and Red categories is an EMP. The function of the EMP is to enable PGCB to show the DoE how it will deliver the environmental performance assessed in the IEE/EIA (for which DoE approval is sought). The EMP should describe the management responsibilities, mitigation measures as well as the institutional arrangements, and explain how monitoring will be carried out.

16. Possession of a "clearance'' from the DoE does not relieve the developer of a project from the requirement to comply with other environmental regulations. The Bangladesh National Environment Quality Standards for industrial effluents have been set and compliance with them are mandatory. There are also statutory instruments that are applicable to power development projects, which are not primarily environmental but help to mitigate environmental impacts. Compliance with such statutory instruments is mandatory.

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17. Detailed assessment of policy, legal, and institutional framework has been described in Chapter 2 of the main IEE.

3. SITE BASELINE INFORMATION, AUDIT FINDINGS AND REMEDIAL ACTIONS

18. The 230/132kV substation in Burichang Upazila of Comilla, is approximately 6 ha and situated at 23°30'32.22''N and 91°06'06.66''E beside the Comilla-Sylhet Highway.

19. The Single Line Diagram of the current substation is as below.

Figure 1. Single Line Diagram of the 230/132kV Substation, Comilla Civil Structures for Equipment Housings, Control Room and Other Facilities

Table 1. Physical Features of Substation

Features Specification Land ownership PGCB

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Scheme 230kV-Double Busbar Scheme

132 kV-Main and Transfer Scheme

Substation type Outdoor

Voltage 230/132/33 kV

Insulation medium power circuit breaker SF6 Gas

Transformer Oil & Air cooled

Protection system description Auto fighting water spray system

20. The location of the 230/132kV Substation control room and the inside of the control panel are

shown as below.

Figure 2. Location of the 230/132kV

substation Control Room

Figure 3. Inside the 230/132kV substation

Control Room

21. The audit was based on criteria stipulated below:

• General environmental management

• Waste management practices

• Hazardous material management • Ground water and soil contamination control

• Occupational health and safety management and

• Noise management 22. These criteria were translated into a checklist (Table 2) which was used to identify issues of

strength to the subject or issues that need corrective actions so as to meet the minimum required standard.

23. Audit findings and the required remedial actions:

• The substation needs the yard cleanness and appropriate waste handling and disposal

practices; • Handling of hazardous and non-hazardous material needs to be improved especially in

storage arrangement and prevention of spillage; and

• Waste handling and disposal.

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24. There are no public concerns regarding the substation, as the substation is located a safe distance away from settlements.

4. CORRECTIVE ACTION PLAN (CAP)

25. Substation facilities should designate special areas/ points for solid waste collection and collect all unwanted scraps for a safe disposal. Wastes such as pieces of cables, switch gears and other waste could have special bins. Handling of hazardous and non-hazardous material needs to be improved especially in storage arrangement and prevention of spillage. A detailed and relevant Health and Safety Management Plan (including emergency procedures for high risk events) needs to be developed to supersede the existing accepted practices; this needs to include a protocol for logging and reporting accidents (this should then also apply to the new sub-station operations, as detailed previously). These details need to be addressed within the next year, with the advice of an environmental officer familiar with sub-station best practices (at which time specific tasks and associated budgets can be defined). This will be undertaken in the pre-construction phase as an EMP activity.

26. To ensure used and scrap equipment/material are properly disposed after removal/replacement, it is recommended for hand-over procedures of equipment/projects to include an environmental checklist which prompts the disposal method. This is required to avoid new debris and waste/scrap being accumulated at the substations in the future, leading up to project implementation.

27. Monitoring of air, noise, and drinking water quality needs to be undertaken on a quarterly

basis, to be consistent with the intended monitoring program for the new sub-station. Monitoring should also include visual inspections of the existing yard and perimeter.

5. CONCLUSION AND RECOMMENDATION

28. PGCB has been found to be adequately responsive on environmental safeguards during the operation of the current substation.

29. However, the substation needs the yard to be cleaned up, and appropriate waste handling and disposal practices established (see site aerial photograph in Annex 2). Handling of hazardous and non-hazardous material needs to be improved. especially in the storage arrangement and prevention of spillage. Corrective measures are recommended in the CAP for compliance with ADB’s SPS 2009 and IFC’s EHS guidelines.

30. Based on the findings of the environmental compliance audit, it can be concluded that PGCB is satisfactorily responsive in regard to complying with environmental safeguards during the operation and only the yard cleanness, collection and disposal of waste should be addressed before the commencement of activities planned under the HVDC BtB Station at Comilla (Bangladesh) for 500 MW from Tripura (India).

Environmental Audit Checklist for Comilla 230/132 kV Substation

Guidelines Considered Comilla 230/132 kV

Substation

• Storage facility

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• Drainage

• Oil leakage not evident

• Monitoring of workplace air quality not done routinely

• Good ventilation (ensure)

• Maintenance of air quality AC

• Enforcement of the application of personal protective equipment whenever exposure levels of fumes, solvents and other materials exceed threshold limit

• Noise control equipment not evident

IFC/ EHS Noise levels Ambient Noise (dB)

Day Night Level within 45 dB limit

Residential 55 45 Industrial 70 70

• Maintenance of equipment

• Use of protective gear when noise level exceeds 85 dB NA

• Safe working area (absence of radiation, magnetic fields)

• Monitor regularly for radiation and field levels and equipment integrity (earthing, protective shields, lockouts etc.

• Strict procedure for de-energizing before working on electrical equipment

• Training of personnel for safety procedures

• Physical factors in the workplace signage

• Lighting (including security lights)

• Fire detection mechanism/equipment

• Firefighting equipment

• Cleanness (inside and outside substation)

• First Aid Kit

• Features that pose safety risks (missing or broken slabs, dogged holes, etc.)

NI

• Fence or enclosure of the site (Restriction of unauthorized people)

• Safe and clean drinking water

• Toilets

• TV/Radio/internet

• Guard kiosk

• Noise

• Vibration

• Illumination

• Temperature

• Hazardous materials not properly stored

• Biological agents not evident

• Ionization radiation

• Training (Learning materials, equipment and tools)

• Training on operational hazardous and how to control the hazards NI

• Training on health risks, hygiene, and exposure prevention NI

• Training on accidents and accident prevention, protective equipment and clothing

NI

• OHSMS organization policy NI

• Emergency prevention, preparedness and response NI

• Investigation of work-related injuries, ill health, disease and accidents

• Safety inspection, testing and calibration

167

• Storage NI

• Labelling

• Handling

• Handling

• Disposal NI

• Availability of space for expansion

OHSMS- Occupational Health & Safety Management System

NA Not Applicable, Yes/OK t/f Yes, on transformers CB Yes, on oil Circuit Breakers AC Yes, with air conditioners NI It is there, but Need Improvements NI Need Improvements S/S Substation NT Need Training NR Need some Repair NM Need Maintenance Con Yes, it is contaminated

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Annex 2. Ancillary information on the site and existing transmission lines. Google Earth Image Analysis: Project Footprint and Associated Features (image from October 31, 2018):

Transmission Line Towers in the vicinity of the Comilla North sub-station and the origin of the existing India-Bangladesh Transmission Line. Each pin is a tower.

Access from highway to sub-station yard Possible camp and

storage locations

Alternative cross-road between villages (to be completed)

Transmission line tower (existing)

Proximity between project perimeter and villages

Proposed drainage canal route; about 600 meters long

India-Bangladesh border

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The Project Area on October 22, 2006 (the pins indicate the locations of transmission towers that were constructed later).

Close-up of the existing North Comilla sub-station (October 31, 2018)

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