Initial Environmental Examination Report (Draft) Project Number: 51152-001 December 2018 BAN: Second PRAN Agribusiness Project Part 4 Prepared by Sylvan Agriculture Limited The 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 of this 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.
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51152-001: Second PRAN Agribusiness Project · Boroi/ Indian Jujube Zizyphus mauritiana Rhamnaceae 1 T 4 Acacia Acacia auriculiformis Fabaceae 3 T 5 Mangium Acacia mangium Fabaceae
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Initial Environmental Examination Report (Draft) Project Number: 51152-001 December 2018
BAN: Second PRAN Agribusiness Project
Part 4
Prepared by Sylvan Agriculture Limited
The 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 of this 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.
Initial Environmental Examination (IEE) of PRAN potato chips, Pasta and Flakes project
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ANNEX-A: ATTENDANCE SHEET OF PUBLIC CONSULTATION MEETING
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Attendance sheet of the Public Consultation Meeting
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Public Consultation Meeting at Olipur City Park, Olipur
Public consultation Meeting Rashel Kabir
Senior Manager-QMS
HRM, PRAN
Md. Giash Uddind
Businessman, Suraboi
Md. Ishar Ali
Retired Police Officer
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ANNEX-B: FOCUS GROUP DISCUSSION MEETING ATTENDANCE SHEET
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Attendance sheet of FGD with the land seller group
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Attendance sheet of FGD with the Business community
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Attendance sheet of FGD with the Ethnic community
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Attendance sheet of FGD with the Local people
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Focus Group Discussion (FGD) at
Olipur and adjacent to Lalchand Tea Estate
Local Participants’ participation Ethnic Participants sharing their perceptions
Businessmen Participants’ Participation Land Seller Participants’ Participation
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ANNEX-C: LAYOUT PLAN OF THE POTATO CHIPS, Pasta and Flakes PROJECT
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ANNEX-D: FLORA AND FAUNA SPECIES IN THE STUDY AREA
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Table-1: Checklist of Flora (Block survey)
SL# Common
Name Scientific Name Family Use Types*
Local
Status**
IUCN
Status***
1 Eucalyptus Eucalyptus obliqua Myrtaceae Timber T C NA
2 Teak tectona grandis Lamiaceae Timber T R NA
3 Jackfruit Artocarpus
heterophyllus Moraceae Fruits T VC NA
4 Vat clerodendrum
infortunatum Lamiaceae
Fuel
wood S VC NA
5 Dumur Ficus carica Moraceae Fruit T C NA
6 Acacia Acacia
auriculiformis Fabaceae Timber T C NA
7 Sal Shorea robusta Dipterocarpaceae Timber T C NA
8 Areca
palm/Supari Areca catechu Arecaceae Fruits T VC NA
9 Kadam Neolamarckia
cadamba Rubiaceae Timber T C NA
10 Coconut Cocos nucifera Arecaceae Fruits T VC NA
11 Peyara /Guava Psidium guajava Myrtaceae Fruits T VC NA
12 Mango Mangifera indica Anacardiaceae Fruits T VC NA
13 Bamboo Bamboo spp. Poaceae Timber T VC NA
14 Banana Musa sapientum Musaceae Fruits H VC NA
15 Date palm Phoenix dactylifera Arecaceae Fruits T VC NA
16 Chapalish Artocarpus
chaplasha Magnoliopsida Fruits T R NA
17 Bokua Neem Melia spp Meliaceae Timber T C NA
18 Dumur Ficus carica Moraceae Fruits T C NA
19 Mahagoni Swietenia
mahagoni Meliaceae Timber T VC NA
20 Fern Adiantum obliquum Pteridaceae Weed H VC NA
21 Zambura/pomelo Citrus maxima Rutaceae Fruits T VC NA
22 Mango Mangifera indica Anacardiaceae Fruits T VC NA
23 Boroi/ Indian
Jujube
Zizyphus
mauritiana Rhamnaceae Fruits T VC NA
24 Mangium Acacia mangium Fabaceae Timber T C NA
25 Jam Syzygium cumini Myrtaceae Fruits T C NA
26 Tejpata Cinnamomum
tamala Lauraceae Medicinal T R NA
27 Sada koroi Albizia procera Fabaceae Timber T C NA
28 Macrophylla Swietenia
macrophylla Meliaceae Timber T C NA
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SL# Common
Name Scientific Name Family Use Types*
Local
Status**
IUCN
Status***
29 Patabahar/
garden croton
Codiaeum
variegatum Euphorbiaceae Aesthetic S C NA
30 Lemon Citrus spp. Rutaceae Fruit S VC NA
31 Rain tree Samanea saman Fabaceae Timber T C NA
*Types: S-Shrubs, T-Trees, H-Herbs
**Local Status: C-Common, R-Rare, VC- Very Common
***IUCN status: NA=Not Available
Table-2: Checklist of Vegetation according to the Block study
Plot#1 (15m*15m area of block study)
SL. Common
Name Scientific Name Family
Number of
Species
Types of
Species*
1 Eucalyptus Eucalyptus obliqua Myrtaceae 15 T
2 Teak Tectona grandis Lamiaceae 2 T
3 Jackfruit Artocarpus heterophyllus Moraceae 2 T
4 Vat clerodendrum infortunatum Lamiaceae 10 S
*Types of species: S-Shrubs, T-Trees
Plot#2
SL. Common
name Scientific name Family
Number of
species
Types of
species*
1 Eucalyptus Eucalyptus obliqua Myrtaceae 10 T
2 Teak tectona grandis Lamiaceae 3 T
3 Dumur Ficus carica Moraceae 2 S
4 Acacia Acacia auriculiformis Fabaceae 2 T
5 Vat clerodendrum infortunatum Lamiaceae 120 S
*Types of species: S-Shrubs, T-Trees
Plot#3
SL. Common
Name Scientific Name Family
Number of
species
Types of
species*
1 Eucalyptus Eucalyptus obliqua Myrtaceae 15 T
2 Teak tectona grandis Lamiaceae 2 T
3 Acacia Acacia auriculiformis Fabaceae 2 T
4 Vat clerodendrum infortunatum Lamiaceae 30 S
*Types of species: S-Shrubs, T-Trees
Plot#4
SL. Common
name Scientific name Family
Number of
species
Types of
species*
1 Sal Shorea robusta Dipterocarpaceae 30 T
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2 Accacia Acacia auriculiformis Fabaceae 2 T
*Types of species: S-Shrubs, T-Trees
Homestead Forest Block survey (10 blocks each size 15m*15m)
Plot#1
SL. Common name Scientific name Family Number of
species
Types of
species*
1 Areca palm/Supari Areca catechu Arecaceae 7 T
2 Jackfruit Artocarpus
heterophyllus Moraceae 4 T
3 Coconut Cocos nucifera Arecaceae 2 T
4 Peyara /Guava Psidium guajava Myrtaceae 2 T
5 Mango Mangifera indica Anacardiaceae 6 T
6 Bamboo Bamboo spp. Poaceae 110 (1 bush) T
7 Banana Musa sapientum Musaceae 2 T
*Types of species: T-Trees
Plot#2
SL. Common Name Scientific
Name Family
Number of
Species
Types of
Species*
1 Banana Musa sapientum Musaceae 20 T
2 Mango Mangifera indica Anacardiaceae 6 T
3 Kadam Neolamarckia cadamba Rubiaceae 5 T
4 Areca palm/Supari Areca catechu Arecaceae 5 T
5 Jackfruit Artocarpus
heterophyllus Moraceae 3 T
6 Date palm Phoenix dactylifera Arecaceae 2 T
7 Eucalyptus Eucalyptus obliqua Myrtaceae 1 T
8 Acacia Acacia auriculiformis Fabaceae 1 T
*Types of species: T-Trees
Plot#3
SL. Common
Name Scientific Name Family
Number of
species
Types of
species*
1 Teak tectona grandis Lamiaceae 3 T
2 Areca
palm/Supari Areca catechu Arecaceae 4 T
3 Bamboo Bamboo spp. Poaceae 325(5 bush) T
4 Chapalish Artocarpus chaplasha Magnoliopsida 1 T
5 Mango Mangifera indica Anacardiaceae 1 T
6 Bokua Neem Melia spp Meliaceae 1 T
Initial Environmental Examination (IEE) of PRAN potato chips, Pasta and Flakes project
* IUCN Red List Status Bangladesh 2015: LC- Least Concern, DD- data Deficient, VU-Vulnerable, CR-Critical, EN-
Endanger, NT-Near Threaten
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ANNEX-E: SCREENING AND SCOPING REPORT
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SCOPING REPORT FOR
INITIAL ENVIRONMENTAL EXAMINATION (IEE) OF
PRAN POTATO CHIPS PROJECT
Prepared for:
Sylvan Agriculture Limited (SAL)
Prepared by: EQMS Consulting Limited
January 2017
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Scoping Report
Initial Environmental Examination (IEE) of PRAN Potato Chips Project
January 2017
Reviewed & Approved by:
Kazi FarhedIqubal
Executive Director
This report has been prepared and reviewed by EQMS company, with all responsible skill, care
and diligence within the terms of the Contact with the client, incorporating our General Terms
and Conditions of Business and taking account of the resources devoted to it by agreement with
the client.
We disclaim any responsibility to the client and others in respect of any matters outside the
scope of the above.
This report is confidential to the client and we accept no responsibility of whatsoever nature to
third parties to whom this report, or any part thereof, is made known. Any such party relies on
the report at their own risk
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TABLE OF CONTENTS TABLE OF CONTENTS ...................................................................................................................... ii
LIST OF TABLES ................................................................................................................................ iii
LIST OF FIGURES .............................................................................................................................. iii
LIST OF ABBRVIATION .................................................................................................................... iv
3.3.1 Requirement of the DoE, Bangladesh ........................................................................... 11
3.3.2 Environmental and Social Requirements of the Asian Development Bank .................. 12
3.3.3 International Finance Corporation (IFC)’ World Bank Group; Environmental, Health, and Safety (EHS) Guidelines (Food and Beverage Processing) .................................................... 14
4. ENVIRONMENTAL SCREENING AND CATEGORIZATION ......................................... 16
4.1 Project classification as per DOE, MoEF, Bangladesh................................................... 16
4.2 Project classification as per ADB Safeguard Policy Statement .................................... 16
Table 7-1: Primary Baseline Data to be collected .......................................................................... 26
Table 8-1: Work plan for conducting the IEE study ...................................................................... 31
LIST OF FIGURES Figure 2-1: Location Map of Project Site ........................................................................................... 4
Figure 2-2: Process Flow Chart ........................................................................................................... 7
Figure 3-1: Process of getting ECC at DoE for different categorized project ............................. 12
Figure 7-1: Approach for the proposed project IEE Study ........................................................... 25
Figure 7-2: Impact Assessment Process .......................................................................................... 29
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LIST OF ABBRVIATION ADB Asian Development Bank
BBS Bangladesh Bureau of Statistics
BD Bangladesh
BDS Bangladesh Standard
BIWTA Bangladesh Inland Water Transport Authority
BMD Bangladesh Meteorological Department
BOD Biochemical Oxygen Demand
BSTI Bangladesh Standards and Testing Institution
BWDB Bangladesh Water Development Board
COD Chemical Oxygen Demand
CO2 Carbon Dioxide
CO Carbon Monoxide
DoE Department of Environment
DG Director General
ECC Environmental Clearance Certificate
ECR Environment Conservation Rules
EHS Environment, Health and Safety
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EQS Environmental Quality Standards
FGD Focus Group Discussion
GoB Government of Bangladesh
GHG Greenhouse Gas
HDPE High-density polyethylene
HIP Habiganj Industrial Park
IECs Important Environmental Components
IEE Initial Environmental Examination
IFC International Financial Corporation
IP Indigenous People
IR Involuntary Resettlement
KM Kilometer
LDPE Low-density polyethylene
LGED Local Government Engineering Department
MoEF Ministry of Environment and Forest
MPN Most Probable Number
NEMAP National Environment Management Action Plan
NOC No Objection Certificate
NOx Oxides of Nitrogen
pH Potential of Hydrogen
REA Rapid Environmental Assessment
RHD Roads and Highways Department
SAL Sylvan Agriculture Limited
SO2 Sulphur Dioxide
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SPS Safeguard Policy Statement
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1. INTRODUCTION
1.1 Introduction
The PRAN agribusiness project is going to establish a new PRAN Potato Chips Project in
Habiganj Industrial Park (HIP) under its company name Sylvan Agriculture Limited (SAL).
The proposed project will be established in the HIP of Olipur, Habiganj District. The Project
is interested in taking project finance from the Asian Development Bank (ADB), which
requires an environmental and social assessment in line with the environmental and social
requirements of these lenders as well as the national regulatory requirements in Bangladesh.
PRAN-RFL Group has therefore initiated the Initial Environmental Examination (IEE) study
to comply with the IEE guidelines of the GOB and the Safeguard Policy Statement (SPS) of
the ADB. PRAN-RFL group engaged EQMS Consulting Limited to conduct the IEE study of
the proposed project.
1.2 Background
“PRAN” is the largest business group in Bangladesh, established in 1981. Currently “PRAN” is one of the most admired foods and beverages brand among the millions of people of
Bangladesh and other countries of the world where PRAN Products are regularly being
exported to different countries of the world. PRAN is currently producing Juices, Drinks,
Mineral Water, Bakery, Carbonated beverages, Snacks, Culinary, Confectionery, Biscuits,
and Dairy. The proposed project will produce real potato chips. This project will be located
in the Olipur site of Shayastaganj, Habiganj Sadar, Habiganj.
1.3 EQMS Purpose and Objectives
The objectives of this Initial Environmental Examination (IEE) will be to ensure that the
project compiles with ADB Safeguard Policy Statement (2009) and other social dimension
requirements as well as with that of the GoB, which may serve as input in the design of the
Project being prepared for possible financing by the ADB.
The reference framework for IEE study willtherefore follow the following standards/
guidelines:
Applicable Bangladesh national, regional & local regulatory requirements;
ADB’s Safeguard Policy Statement (SPS);
ADB Social Protection Strategy;
ADB’s Public Communications Policy;
The IFC Performance Standards for Environmental & Social Sustainability; and
The IFC General EHS Guidelines.
The key tasks were undertaken for screening and scoping for IEE study of the project
include:
Site assessment (Based on site reconnaissance);
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Categorization of the project as per the GOB regulations and potential lenders'
guidelines/standards;
Review of administrative framework applicable for the Project;
Identification of primary stakeholders;
Identification of key environmental and social issues and risks pertaining to the
Project; and
The scope of the IEE study with proposed approach and methodology.
1.4 EQMS Approach and Methodology
The approach and methodology adopted for the screening and scoping of the Project
comprise of:
1.4.1 Screening
EQMS reviewed the existing available data of the project with the client and secondary
information available in public domain with regard to the project, project location, and its
surroundings. The screening process was undertaken to identify environmental, social and
other sensitivities associated with the project. A review of the applicability of the reference
framework with respect to the proposed project was also undertaken as part of this
screening phase.
The EQMS team had a brief introduction meeting with the PRAN-RFL officials on
07/01/2017 at Habiganj Industrial Park (HIP) prior to site reconnaissance visit. EQMS
undertook 3 days (07/01/2017 to 09/01/2017) site visit to understand the site setting,
environmental and social sensitivities and to identify the relevant local stakeholders.
The site visit included an inspection of all the individual factories in the HIP and associated
facilities with PRAN-RFL officials. A consultation with the local community and previous
land owners was also conducted to understand the local environmental and social issues in
the area and to receive feedback from stakeholder on these issues.
1.4.2 Categorization
EQMS has categorized the project by following the DOE and ADB categorization criteria
based on the screening assessment, site visit, environmental and social sensitivities and
limited consultation. The project categorization with respect to ADB classification criteria
will now become a basis for the impact assessment, planning and implementation of
mitigation, monitoring and reporting mechanisms for the project to meet the potential
lenders' requirement.
A preliminary stakeholder mapping exercise was also undertaken to identify the key
stakeholders from Government/Community/at the local/regional level, who would be
required to be consulted during different stages of the Project.
1.4.3 Scoping
As an outcome of the screening and categorization exercise, EQMS has defined scope for the
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IEE study, which includes a detailed approach and methodology including field plan for
Environmental and Social baseline data collection, impact identification, impact
assessment/cumulative impact assessment and management plan.
1.4.4 Reporting
The outcome of the screening and scoping exercise is this report, which includes:
Site profile;
Overview of local legal requirements;
Overview of potential lenders' requirements;
Categorization of the project;
Key environmental and social issues/risks;
Preliminary stakeholder mapping;
Approach and methodology for IEE study;
Field plan for environmental and socio-economic survey including stakeholder
consultation;
Schedule for IEE study; and
Way forward.
1.5 Limitation
The scope of this review was limited to the desk-based study of available information in the
public domain and rapid site reconnaissance survey.
Uses of this Report
The present IEE Report has been prepared based on the primary field
investigations/assessment and secondary data collected from BMD, DoE, and published
journals, and books, public consultation, and site observations. The environmental and
social assessment is based on the information collected from the various agencies,
community consultations and observations. Professional judgment and subjective
interpretation of facts and observations have been applied for the preparation of this report.
Additionally, assessment is made on the basis of preliminary information available from
PRAN-RFL authority.
1.6 Layout of this report
The layout of the report is as follows:
Section 1: Introduction
Section 2: Project Description
Section 3: Administrative Framework
Section 4: Environmental Screening and Categorization
Section 5: Preliminary Stakeholder Mapping
Section 6: Key Environmental and Social Risks
Section 7: Approach and Methodology for IEE study
Section 8: Deliverables, report format &work Plan
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2. PROJECT DESCRIPTION
2.1 Location of the Project
The proposed project will be located inside of the Habiganj Industrial Park (HIP). The HIP is
administratively situated in the Nurpur Union under Habiganj Sadar Upazila of Habiganj
District, Bangladesh. The absolute location of the proposed PRAN potato chips project is
24°16'28.60"N latitude and 91°23'3.94"E longitude. The northern site of HIP is covered by
Surabahi, Shailjura and Gayerpur village; industries of the Square group on the South;
Sachiura, Noagaon, Dushashan village on the West and Olipur village, Dhaka-Sylhet
Highway, Dhaka-Sylhet Railway and Hilly areas are located on the East side. A location
Map of the proposed project site is presented in Figure 2-1. This project is situated about 120
KM far from the Dhaka.
Source: EQMS
Figure 2-1: Location Map of Project Site
2.2 Key features of the project site and surroundings
The salient features of the projects are described in Table 2-1.
Table 2-1: Salient features of the site and surroundings
1. Geographical Details Latitude: 24°16 28.60 N; Longitude: 91°23 3.94 E 2. Land use of Plant site 100% area under Habiganj Industrial Park (HIP)
3. Minimum Distances From Project Site
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a) City:
b) Village:
c) Railway Station:
d) Railway Line:
e) Highway:
f) River:
g) Khal:
h) International Airport:
I) River Port:
J) Market/Bazar:
Dhaka @ 120 km, Habiganj @ 12 km; Sylhet @ 85 km
Surabahi, Shailjura, Gayerpur, Sachiura, Noagaon, Dushashan, Olipur village @ around 2 km
Sutang @ 2.22 km; Sylhet @ 83 km
Dhaka-Sylhet @ 400 m from the project location
Dhaka-Sylhet @ 60 m, from the HIP entrance
Sutang @ 3 km
Inside the HIP and connected with Sutang river
Osmani International Airport, Sylhet @ 91 km
Ashuganj @ 47 km
Olipur Bazar @ close with HIP entrance
4. Displacement of Population None (project will be established inside of the HIP)
5. Seismic/Earthquake Zone: As per the Bangladesh Earthquake Zone the project is situated in Zone-I (Basic seismic coefficient is 0.08 g)
2.3 Access Road
The project site is well connected by the Dhaka-Sylhet Highway. The Dhaka-Sylhet railway
line is very close to the proposed project site. It’s around 400 m far from the project location. The distance from the HIP to Dhaka is approximately 120 km and Sylhet is 91 km. The
access road is suitable for transportation of equipment and material for setting up the
industry. Inside of the HIP road network developed in a planned way and a wonderful
traffic system are exist. It is mandatory to collect NOC from Roads & Highway Department
(RHD) and Local Government Engineering Department (LGED) to access the government
road.
2.4 Description about the project
2.4.1 Product description
Detailed product description of the PRAN potato chips is given below:
Table 2-2: Product Description
1 Process Name Frying process
2 Product Name Real Potato Chips
3 Ingredients
Real Potato & Seasoning (Red Chilli, Turmeric, Blackpepper, Cinnamon, Cumin Seed, Citric Acid, common salt)
4 Important product
Characteristics
Crispy & spicy in nature
5 Labeling instruction
Name and address of manufacturer, Logo (BSTI, Keep Your
Country Clean & Non-Veg) Allergen Information, Nutrition
Facts, MFG & Expire Date, MRP (Including All Of Taxes).
Environment Court Act, 2000 and subsequent amendments in 2002
Ministry of Environment and
Forest
GOB has given highest priority to environment pollution and passed ‘Environment Court Act, 2000 for completing environment related legal proceedings effectively
The National Water Policy,
1999
Ministry of Water
Resources
Protection, restoration, and enhancement of water resources;
Protection of water quality, including strengthening regulations concerning agrochemicals and industrial effluent;
Sanitation and potable water;
Fish and fisheries; and
Participation of local communities in all water sector development.
The Brick Burning (Control) Act, 1989
The Brick Burning (Control) Amendment Act, 1992 and 2001
Ministry of Environment
and Forest
Control of brick burning;
Requires a license from the MoEF for operation;
Restricts brick burning with fuelwood;
Water Supply and Sanitation Act, 1996
Ministry of Local Government, Rural
Development and
Cooperatives
Management and Control of water supply and sanitation in urban areas.
The Ground Water
Management Ordinance 1985
Upazila Parishad Management of groundwater resources;
any place without the license granted by Upazila Parishad.
The Protection and
Conservation of Fish Act 1950subsequent amendments in1982
Ministry of Fisheries and Livestock
Protection and Conservation of fishes in Government owned water bodies
National Fisheries Policy,
1998
Ministry of Fisheries and Livestock
Preservation, management, and exploitation of fisheries resources in inland open water;
Fish cultivation and management in inland closed water;
Prawn and fish cultivation in coastal areas; and
Preservation, management, and exploitation of sea fishery resources.
The Acquisition and
Requisition of Immovable
Property Ordinance 1982 and subsequent amendments in
1994, 1995 and 2004
Ministry of Land
Current GoB Act and Guidelines, relating to acquisition and requisition of land.
The Factories Act, 1965
Bangladesh Labour Law, 2006
Ministry of Labor This Act pertains to the occupational rights and safety of factory workers and the provision of a comfortable work environment and reasonable working conditions.
National Agriculture Policy,1999
Ministry of Agriculture
The act deals with the programs related to make the nation self-sufficient in food through increasing production of all crops, including cereals, and ensure a dependable food security system for all
3.3 Environmental Clearance
3.3.1 Requirement of the DoE, Bangladesh
The Department of Environment (DoE), the technical arm of the Ministry of Environment
and Forest (MoEF) is the regulatory body and the enforcement agency of all environmental
related activities. As per ECR, 1997, for obtaining the environmental clearance from DoE for
different category projects required to follow some specified steps. The steps for obtaining
Environmental Clearance Certificate (ECC) are given in Figure 3-1.
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Figure 3-1: Process of getting ECC at DoE for different categorized project
3.3.2 Environmental and Social Requirements of the Asian Development Bank
The Asian Development Bank (ADB) Safeguard Policy Statement (‘the SPS’) 2009 sets out the requirements for ADB's operations to undertake an environmental assessment for projects
funded by the bank. The goal of the SPS is to promote the sustainability of project outcomes
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through protecting the environment and people from potential adverse impacts. The overall
objectives of the SPS are to:
i) Avoid adverse impacts of projects on the environment and affected people, where possible;
ii) Minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is impossible; and
iii) Help borrowers/clients strengthen their safeguard systems and develop the capacity to manage environmental and social risks.
The SPS sets out the ADB policy objectives, scope and triggers and principles for following
three key safeguard areas:
i) Environmental Safeguards; ii) Involuntary Resettlement Safeguards along with those vis-à-vis Land
Acquisition; and iii) Indigenous Peoples Safeguards.
ADB Safeguard Categories
1. Environment
Proposed projects will be screened according to type, location, scale, and sensitivity and the
magnitude of their potential environmental impacts, including direct, indirect, induced, and
cumulative impacts. Projects are classified into the following four categories:
Category A. A proposed project is likely to have significant adverse environmental impacts
that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than
the sites or facilities subject to physical works. An environmental impact assessment (EIA),
including an environmental management plan (EMP), is required.
Category B. The proposed project’s potential adverse environmental impacts are site-
specific, few if any of them are irreversible, and in most cases mitigation measures can be
designed more readily than for category A projects. An initial environmental examination
(IEE), including an EMP, is required.
Category C. A proposed project is likely to have minimal or no adverse environmental
impacts. An EIA or IEE is not required, although environmental implications need to be
reviewed.
Category FI. A proposed project involves the investment of ADB funds to or through a
financial intermediary. The financial intermediary must apply and maintain an
environmental and social management system, unless all of the financial intermediary's
business activities have minimal or no environmental impacts or risks.
2. Involuntary Resettlement
The involuntary resettlement impacts of an ADB-supported project are considered
significant if 200 or more persons will be physically displaced from home or lose 10% or
more of their productive or income-generating assets. Projects are classified into the
following four categories:
Category A. A proposed project is likely to have significant involuntary resettlement
impacts. A resettlement plan, which includes assessment of social impacts, is required.
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Category B. A proposed project includes involuntary resettlement impacts that are not
deemed significant. A resettlement plan, which includes assessment of social impacts, is
required.
Category C. A proposed project has no involuntary resettlement impacts. No further action
is required.
Category FI. A proposed project involves the investment of ADB funds to or through a
financial intermediary. The financial intermediary must apply and maintain an
environmental and social management system, unless all of the financial intermediary's
business activities are unlikely to generate involuntary impacts.
3. Indigenous Peoples
The impacts of an ADB-supported project on indigenous peoples is determined by assessing
the magnitude of impact in terms of
customary rights of use and access to land and natural resources;
socioeconomic status;
cultural and communal integrity;
health, education, livelihood, and social security status; and
the recognition of indigenous knowledge; and
the level of vulnerability of the affected Indigenous Peoples community.
Projects are classified into the following four categories:
Category A. A proposed project is likely to have significant impacts on indigenous peoples.
An indigenous peoples plan (IPP), including assessment of social impacts, is required.
Category B. A proposed project is likely to have limited impacts on indigenous peoples. An
IPP, including assessment of social impacts, is required.
Category C. A proposed project is not expected to have impacts on indigenous peoples. No
further action is required.
Category FI. A proposed project involves the investment of ADB funds to or through a
financial intermediary. The financial intermediary must apply and maintain an
environmental and social management system, unless all of the financial intermediary's
business activities unlikely to have impacts on indigenous peoples.
3.3.3 International Finance Corporation (IFC)’ World Bank Group; Environmental, Health, and Safety (EHS) Guidelines (Food and Beverage Processing)
This guideline covers the processing of meat, vegetable, and fruit raw materials into value-
added food and beverage products for human consumption. Environmental issues in food
and beverage processing facilities primarily include the following:
i) Solid waste ii) Wastewater iii) Energy consumption iv) Emissions to air
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Table 3-2: Effluent Standard level for food and beverage processing project
Pollutants Units Guideline Value
IFC Standard DoE standard for (Inland
Surface Water)
pH - 6 – 9 6 – 9
BOD5 mg/l 50 150
COD mg/l 250 200
Total nitrogen mg/l 10 50
Total phosphorus mg/l 2 8
Oil and grease mg/l 10 10
Total suspended solids mg/l 50 150
Temperature increase °C <3b -
Total coliform bacteria MPNa / 100 ml 400 -
Active Ingredients / Antibiotics
To be determined on a case-specific basis
-
Notes: (a) MPN = Most Probable Number; (b) At the edge of a scientifically established mixing zone which takes into account ambient water Inland Surface Water means drains/ponds/tanks/waterbodies/ditches, canals, rivers, springs and estuaries.
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4. ENVIRONMENTAL SCREENING AND CATEGORIZATION
4.1 Project classification as per DOE, MoEF, Bangladesh
Depending upon location, size, and severity of pollution loads, projects/activities have been
classified in ECR, 1997 into four categories: Green, Orange-A, Orange-B and Red
respectively, to nil, minor, medium and severe impacts on important environmental
components (IECs).
As per the Schedule-1 of ECR 1997, corresponding category related to PRAN Potato Chips
fall under ORANGE-B Category for the following components:
Item 21: Processing fish, meat, food An initial environmental examination (IEE), including an EMP, is required for the proposed
project.
4.2 Project classification as per ADB Safeguard Policy Statement
Categorization for the proposed project was undertaken by using ADB’S Rapid Environmental Assessment (REA), Involuntary Resettlement (IR) and Indigenous people
(IP) assessment checklist during the screening and scoping exercise. The REA checklists for
the potato chips are given in Annex-A. The Involuntary Resettlement (IR) assessment
checklist and Indigenous People (IP) assessment checklist are presented in Annex-B and
Annex-C, respectively. The findings of the assessment are presented in Table 4-1.
Table 4-1: Project Categorization as per ADB Safeguards
SL No.
Criteria Relevance Remarks Category
1. Environmental Categorization
A. Irreversible Environmental issues and impacts of the project are anticipated during the construction and operation of the PRAN potato chips project and development of associated infrastructures
Irreversible impacts due to the project include:
Increase noise and vibration during construction of potato chips plant and operation;
Changes in air quality due to existing, proposed and future projects;
Affected aquatic ecology and surface water quality water discharge from
Based on irreversible, diverse and cumulative impacts, it should be categorize as “B”
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SL No.
Criteria Relevance Remarks Category
the plant;
Occupational health and safety;
Community health and safety;
Associated development in the area
B. Cumulative The PRAN-RFL group has already established more than 15 different types of industries in the HIP area. This new project will be effect on the local environment along with other industries that’s why a cumulative impact assessment is required to assess the impacts on the environment of the new project.
Cumulative impacts on physical, biological and socioeconomic environmental conditions
C. Diverse Nature of activities The nature of activities is not diverse for the area, as there is already an operational of similar different industries of PRAN-RFL in the HIP. However, the new plant will be able to supply new type of product (Real potato chips). They have already a potato crackers plant in the HIP.
D. Unprecedented Changes in land use Previously the land was used for agricultural activities. However, HIP changes the land use. Current land use of the project site is industrial.
2. Involuntary Resettlement Categorization
A. Mode of Acquisition
Purchased land by PRAN –RFL Group
The land purchased from the local people
In case of no foreseen adverse impact, project shall be categorized as “C”
B. Precedence The land for the proposed project site was obtain to establish an industrial park in 2012
During the land purchase PRAN-RFL group paid actual amount of this land comparing the market price
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SL No.
Criteria Relevance Remarks Category
C. Irreversible Project affected households Previously the land area was under agricultural land (only Boro paddy cultivated). The industrialization of the area has helped in providing them non-agricultural livelihoods.
3. Indigenous People Categorization
A. Presence Existence of indigenous people The Population census (2011) has shown that only 7 households with 34 persons in Nurpur UP
In case of no foreseen adverse impact, project shall be categorized as “C”
B. Impact Impact on indigenous/ethnic/schedules tribes
No adverse impact on the Ethnic minority is unforeseen
According to ADB guidelines, the Sylvan Agricultural Project can be categorized as
environment “Category-B” that’s why an initial environmental examination (IEE), including an EMP, is required for the proposed project.
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5. PRELIMINARY STAKEHOLDERS MAPPING
A key component of the IEE process is project related information disclosure,
communication and stakeholder consultation. Legislation/ guidelines such as the ECR1997
of GOB; Safeguard Policy Statement of ADB and IFC Performance Standards prioritize this
even further. PRAN-RFL group recognizes the benefits of information disclosure and
stakeholder consultation to ensure that all relevant concerns and opinions regarding this
particular project are integrated into the project decision making process and are adequately
addressed in the IEE process. Taking this into consideration, the key stakeholders for the
proposed project have been identified during the scoping process and these include:
Government Agencies - Regulatory as well as local government (including District,
Upazila and Union Parishad level);
Community and Union Parishad level stakeholders;
Research Institutions - Government and Independent;
Sub-contractors; and
Internal stakeholders – PRAN-RFL Group, local partner, employees.
List of key identified stakeholders which emerged from the site visit and preliminary
discussions have been presented in Table 5-1.
Table 5-1: Stakeholder Mapping
SL Particular Institutions
Government Local Office Locals
1. Environmental Policy and Law
Director, Department of Environment, Sylhet Divisional Office
-
2. Air Quality Director, Department of Environment, Sylhet Divisional Office
Local community/residents
3. Water Quality Director, Department of Environment, Sylhet Divisional Office
District/Upazila Department of Public Health and Engineering Officer-Habiganj
6. Biota and ecosystem District/Upazila Forest Officer-Habiganj
District/Upazila Fisheries Officer-Habiganj
Local farmers
Local fishermen
Union Parishad-Nurpur
7. Road traffic and accident records
Roads and HighwayDepartment, Ministryof Communications – Habiganj
Upazila LGED officer-Habiganj
Local community those who are using
the local roads
8. Global warming Upazila Parishad - Habiganj Union Parishad-Nurpur
9. PRAN Potato chips project related decision
PRAN-RFL Group Villagers
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SL Particular Institutions
Government Local Office Locals
10. Socio-economic census data
Union Parishad-Nurpur Local people, women and vulnerable group
11. Natural hazards and disaster (Flood, Cyclone, Tornadoes, Earthquake)
Red crescent
Upazila Disaster Management Committee-Habiganj
Union Disaster Management Committee-Nurpur
villagers, women and vulnerable groups
12. River and waterway BWDB-Habiganj
BIWTA-Habiganj
Users, Fisherman
13. Agriculture and irrigation
Upazila Parishad-Habiganj
Union Parishad-Nurpur
Farmers, villagers
14. Meteorological data BMD-Sylhet Station -
15. Topographical information
LGED-Habiganj -
16. Community Union Parishad-Nurpur -
17. Labor related Inspector of Factory and Establishment office-Habiganj
Local people, villagers, labor (local
and migrant)
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6. KEY ENVIRONMENTAL AND SOCIAL RISK
Potential environmental and social impacts have been identified through a systematic
process whereby the activities (both planned and unplanned) associated with the
construction and operation of the project have been considered with respect to their
potential to interaction with sensitive environmental and social resources or receptors.
Scoping of potential impacts has been undertaken in two stages:
Stage 1: Identification of potential interactions between project activities and environmental
receptors; and
Stage 2: Prioritization of these interactions in terms of their potential to cause significant
impacts taking into consideration the current knowledge of project activities and the existing
condition/sensitivities of environmental and social baseline.
6.1 Key Environmental Risks
Cumulative Impacts
Different types of industries (more than 15) are operational close to the proposed project site
in the Habiganj Industrial Park (HIP). As a result, the project impacts cannot be assessed in
isolation and the cumulative impacts are anticipated and also need to be assessed.
Climate Change
Climate Change is now a global concern and considered Bangladesh as the most climate
vulnerable country in the world. But it argues that Bangladesh has play only a very small
role in contributing to climate change and has very small GHG emissions per person
compared to larger developing countries. Bangladesh is not highly industrialized or
urbanized, and these are two of the main sectors that emit greenhouse gases.
The proposed project will use different goods and raw materials for its every day
production. The project will emit greenhouse gasses in two ways, from direct emissions
(emissions that are produced at the facility itself) and indirect emissions (associated with the
facility's use of energy).Detailed study on GHG emission will be conducted during the
baseline survey and impact assessment.
Natural Hazards
Bangladesh is positioned at the juncture of several active tectonic plate boundaries. On the
basis of the distribution of earthquake epicenters and morphotectonic behavior of different
tectonic blocks Bangladesh has been divided into three generalized seismic zones. The
northeastern folded regions of Bangladesh (Sylhet region) are the most active zones and
belong to the zone-I. The Bask seismic coefficient of this zone is 0.08. The proposed PRAN
potato chips fall in the seismic zone-I.
Severe flood, tornado, lightning, earthquake etc. may occur at any time during the operation
and maintenance of the project. An Emergency Response Plan is required to be prepared
and actions to be taken by the implementing agency to cope with any emergency period.
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Construction Period
As Bangladesh has a long monsoon period from mid-May to early October months, the
scheduling of the construction period will be an important issue in terms of construction
management and safety of the workers from construction schedule as well as safety and
health related concerns.
Population Influx
The proposed project will result in an influx of workers to the area because of construction
activities, plant operation activities and hence potential employment and contract
opportunities. This may result in stress on the local resources in absence of proper planning
for the drinking water and sanitation facilities of the workers.
Emission to Air/Air Pollution
During construction and operations of the project, it will be required to movement of
vehicles and heavy equipment’s that may create a small amount of dust and SOx, NOx and
CO2. But this small amount of pollution will be no significant impact on the overall
pollution of the ambient air quality.
During Construction stage building construction, pumping station, transportation of the
pipeline, construction of earth road, welding, cleaning and coating/wrapping of the pipeline
etc. could cause low atmosphere pollution in the air, which may create less health problem
on workers and surroundings inhabitants. The emission of dust, gaseous pollutants (SOx,
NOx and CO2) and suspended particulates will be also low and also of short duration.
The primary fuel for the plant will be natural gas, which is considered as a cleaner fuel,
however, these plants can pollute the area during plant operation stage with NOx and CO
emissions and can impact air quality of the area in absence of proper pollution control
measures.
Noise and Vibration
During construction period producing so much noise and vibration cause of movement of
vehicles, heavy equipment’s and Lorries will impact on workers, health as well as surrounding people. For this reason, it will impact on bio-diversity of the project area.
Impact on Sutang River
The Sutang River is almost 3 km far from the project site and well connected with a khal that
flows inside the HIP. If any hazardous waste, solid waste or others harmful materials are
through to the khal it can contaminate the surface water of the khal as well as the Sutang
river. There will be a possibility to impact on the aquatic flora and fauna in the project area
and its surrounding area. Detailed study will be conducted during the baseline survey and
impact assessment.
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Waste Water
During the operation stage, fresh water will be required to cleaning the raw potato at the
primary stage. At this stage, waste water will be produced. It will be required to collect
waste water in a proper way and take them to the treatment plant for further use and reduce
the environmental effect. A detailed study on wastewater management will be conducted in
further.
Solid Waste
During the construction and operation stage of the project, a large number of
workers/employees will be engaged with the proposed PRAN potato chips plant. At the
same time, a significant amount of solid waste will be produced from the domestic waste,
garbage, sludge from a wastewater treatment plant, water supply treatment plant, food
waste, by-product material etc. Solid waste can effect on the local environment if it is not
treatment properly. A proper solid waste management system is essential for maintaining a
healthy and sustainable environment in the project site.
Health and safety issues
Probability of occurrence of worker accidents is anticipated to be high in all construction
works. Concentration of labor force in the work area is anticipated to create unhygienic
conditions. Storage of flammable materials at site in large quantities may pose risk of fire
and explosion.
Fire and Explosion
Fire is considered as one of the important hazards for any industry. It can happen due to any
natural and manmade causes. To prevent the occurrence of fire and explosion an emergency
response/management system and capacity building of the workers are essential.
6.2 Social Risks
The project will be setup in the HIP area so it does not involve with land acquisition
activities. Previously the area was a low agricultural land and only single crop (Boro rice)
was produced here. Hence, there is no risk of involuntary resettlement and rehabilitation
issue linked to this project. However, there is a range of other social risks which emerged
from the scoping exercise are listed as follows:
Impact on Livelihood/Employment Generation
The project is expected to provide an opportunity to unskilled wage labor in the locality. The
wage earning will supplement their earnings from agriculture, fishing and household
industries. The impact of the project activities on the livelihood of these people requires to
be studied in detail.
Population Influx
The project will facilitate the influx of labor, skilled workers and staff (national and
expatriates) who would live or stay in the locality for varied length of time. The impact of
the population influx thus needs to be studied further.
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Labor Issue
The project in construction and operation phase will employ labor that would give rise to a
range of labor issues including protecting their rights, providing them requisite facilities,
protecting their health and providing a safe working condition to them. Hence, a detailed
examination is required to assess the risks to the labor engaged during the project work.
Community Health and Safety
The population influx, transportation, and storage of construction related materials are
expected to expose the local population to an increase risk accident, communicable and
vector borne diseases in the locality. Hence, a close assessment of the health care facilities
available in the project area and community health and safety is necessary.
Occupational Health and Safety
In addition to the labor employed for the construction, there will be a sizable number of
skilled and supervisory staff engaged during the project construction and operation. The
assessment of risk to their health and safety of their workplace will also be undertaken
during impact assessment.
Impact of indigenous or ethnic communities/groups, if any
The preliminary social screening of the area based on census 2011 data of the project
influence area and its surroundings shows that there is no ethnic community in the project
area.
Impact of Cultural Resources
The project site does not have any structure with cultural and heritage significance.
However, there are mosques and other religious places inside and around the project site at
various distances. The likely impact on these cultural resources will be studied during
impact assessment.
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7. APPROACH AND METHODOLOGY
7.1 Introduction
Based on the site reconnaissance survey, understanding of the type of data/information
required, the time period required for the monitoring, focus areas during IEE study, etc.
EQMS proposes the following approach and methodology for the IEE study.
Source: EQMS, R&D
Figure 7-1: Approach for the proposed project IEE Study
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7.2 Establishment of Environmental and Social Baseline
As outcome of scoping and reconnaissance survey of the site, following data/documents
requires being collected during IEE study for the proposed project.
7.2.1 Study Area
The study area considered for IEE will include an area within 2 km radius from the center of
the project site. The area of 2 km has been selected based on the location of project site and
its footprint, nature and spatial distribution of potential social and environmental impacts
(based on the experience of the similar type of projects).
7.2.2 Environmental and Social Baseline Data Collection
Environmental and social baseline data will be collected through primary monitoring and
baseline surveys and also based on information available through secondary sources.
Literature surveys will be done and relevant information will be collected for environmental
baseline. The baseline study included the following:
Reconnaissance survey of the Project site and surrounding area within 2 km radius
from center of the proposed project site to establish dominant features of the
biophysical and social environments;
The primary environmental baseline data will be collected with respect to ambient
air quality, water (surface and groundwater) quality, soil characteristics, noise level
and ecology;
Information on geology, meteorological conditions, water and ecological resources,
socio-economic status etc. will be collected from secondary sources.
A. Primary Baseline Data Collection
With the assistance of Client, EQMS will identify an accredited environmental laboratory of
repute, which will be engaged for collection of baseline information on micrometeorology,
ambient air quality, water quality (surface and ground water), ambient noise quality as per
aspects detailed in the following Table 7-1:
Table 7-1: Primary Baseline Data to be collected
SL# Environmental Attribute No. of
Locations Frequency Remarks
1. Ambient Air Quality
SPM, PM10 and PM2.5
Oxides of Nitrogen (NOx)
Carbon Monoxide (CO)
Sulphur Dioxide (SO2)
4 24 hrs / 2 weeks, 2 times
in a week
AAQ monitoring covering upwind, downwind and Crosswind directions and at Project site. Existing and proposed new industries within the air shed shall be identified.
2. Surface and Groundwater Quality: Physical parameters: pH, Temp ., DO, conductivity, Total Dissolved Solids, BOD, COD, NO3, Cl, Na, K, total coliform and fecal coliform
2 Once during the Baseline
survey
Surface and ground water samples will be collected from the study area.
Identifying endangered or protected species or endemic floral species prevailing in the study area.
Identifying any endemic fauna in the study area.
Identifying vegetation cover and current status of natural habitats or species.
Identifying and assessing ecological resources within the study area.
Terrestrial ecology and fisheries
Study Area
Once during The baseline
survey period
Ecological survey will be undertaken to assess the biodiversity aspects.
5. Land use and GIS mapping of the study area
PIA and within 2
km radius
Representing the period of monitoring
Based on available satellite imageries of the recent past year
6. Socio-economics One time survey
Mostly assessed through FGD and available secondary information
For the socio-economic aspects typically required within the IEE, EQMS will undertake the
following activities:
Undertaking consultation, interviews and FGD’s in the surrounding villages; Discussions with Government Departments, local authorities etc, as required;
Discussions with marginal farmers, vulnerable groups, indigenous people etc.
B. Secondary Baseline Data Collection
Readily available secondary information would be collected for following aspects:
a) Physical Environment
Regional setting
o Geography and geomorphology
o Land use
o Geology and soil
Climate and meteorology
o Climatic pattern
o Ambient temperature
o Relative humidity
o Rainfall
o Regional wind patterns (wind speed & direction)
Hydrology and water use
o Natural Hazards
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o Seismic activities
o Seasonal storms & cyclones
b) Socio-economic Environment:
Demographic profile
Education & literacy
Economic activities & livelihood pattern
Socio-economic Infrastructure & Indicators
o Health care facilities
o Education facilities
o Drinking water & sanitation
o Agriculture
o Transportation facilities
o Sites of cultural/archaeological importance
Few of the identified sources for collecting secondary data include the following:
Bangladesh Meteorological Department (BMD) at Dhaka;
Department of Environment (DoE);
Bangladesh Bureau of Statistics (BBS); and
Published technical journals and books.
7.2.3 Stakeholder Engagement & Analysis
Stakeholder engagement is the fundamental element of the approach to an IEE process.
Certain stakeholders are likely to be consulted in the course of the engagement process for
the IEE and have been identified based on the reconnaissance visit and presented in section
5 of this report.
Stakeholder Consultation
Consultation will be conducted with key stakeholders including the local population,
government department/agencies, farmers and fishermen;
Stakeholder consultation will be conducted with the intent of collecting baseline
information on the environmental and social conditions and sensitivities, developing
a better understanding of the potential impacts, informing the public of the proposed
project and to gain an understanding of the concern of the stakeholders;
Collected information will be used for formulating mitigation measures and
environmental and social management plan.
7.2.4 Impact Assessment
Analysis of the baseline data and incremental impacts of the project will be assessed in
accordance with the national guidelines for air, water and noise emissions; standards are
mentioned in ECR 1997, ADB guidelines and IFC’s performance standard and EHS guidelines, including the general guidelines and those for Food and Beverage Processing.
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The impact assessment will involve the prediction, evaluation, and mitigation of impacts
and will report on impacts including residual impacts and cumulative impacts (Figure 7-2).
Impact prediction will take into account control measures that are part of the project design.
Additional mitigation measures aimed at further reducing predicted impacts will be
proposed where necessary or appropriate.
Figure 7-2: Impact Assessment Process
What could
happen as a
consequence of
doing what is
proposed
Is it Important?
(Significance)
What can be done
about it?
Is there still a
significant
impact?
Aspects which will be considered in the impact assessment for both the construction and
operation phase of the project including air quality, greenhouse gases, water quality, noise,
ecology, waste, landscape and visual, traffic, soil, and groundwater, socio-economic and
health.
The IEE study will evaluate the significance of all the environmental and social impacts
associated with the proposed project under impact categories including positive or negative,
short term or long term, direct or indirect. The effectiveness of mitigation measures shall also be
assessed through environmental impact predictions on the different sensitive receptors
within any environmental component.
7.2.5 Risk Assessment
Risk assessment study will cover the following:
Hazards identification to determine the incident scenarios, hazard and hazardous
events, their causes and mechanism;
Consequence analysis to determine extent of the consequence of identified
hazardous events;
Frequency estimation to determine the frequency of occurrence of identified
hazardous events and various consequences;
Risk summary to determine risk level and their significance, and recommendation
for risk mitigation.
7.2.6 Environmental Management Plan (EMP) An Environmental Management Plan (EMP) would be prepared covering mitigation
measures, environmental control technologies and best available practices with defined
Predict Evaluate Mitigation/
Enhance
Residual Impacts
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Environmental Management System. The mitigation measures would be targeted at
reducing impacts to as low as reasonably practical. The EMP will comprise of (and not
limited to):
Feasible control technologies and mitigation measures to minimize adverse impacts
of proposed activities such as:
Pollution control measures proposed to meet the emission, effluent and noise
standards etc.;
Effluent treatment;
Solid waste management;
Environmental monitoring programme;
Occupational health and safety related mitigation measures.
Management of social impacts through mitigation measures at community as well as
household levels;
Mitigation and management plans for implementation with definite timeline and
responsibilities;
Organization required for implementation of management program during different
phases of the project;
Training the EMP implementation team; and
Monitoring and reporting mechanism both for regulatory compliance.
7.2.7 IEE report Format
EQMS will prepare the IEE report as per the following structures but not limited:
Executive Summary
Introduction
Description of the project
Administrative and regulatory framework
Baseline data
Impact and mitigation measures
Environmental and social monitoring program
Information disclosure, consultation, and participation
Grievance redress mechanism
Environmental and Social Management Plan
Conclusion
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8. Work Plan The work schedule for conducting field survey, baseline data collection and preparation of
IEE report in line with the potential Lenders' requirement for the proposed project is as
A. Project Siting Is the Project area adjacent to or within any of the following environmentally sensitive areas?
Cultural heritage site √
Legally protected Area (core zone or buffer zone √
Wetland √
A Khal is situated inside of the Habiganj Industrial Park (HIP) and connected with Sutang River
Mangrove √
Estuarine √
Special area for protecting biodiversity √
B. Potential Environmental Impacts Will the Project cause…
Impairment of historical/cultural areas; disfiguration of landscape or potential loss/damage to physical cultural resources?
√
Disturbance to precious ecology (e.g. sensitive or protected areas)? √
Alteration of surface water hydrology of waterways resulting in increased sediment in streams affected by increased soil erosion at construction site?
√
Deterioration of surface water quality due to silt runoff and sanitary wastes from worker-based camps and chemicals used in construction?
√
Increased air pollution due to project construction and operation?
√
Dust will be generate during the construction and also during operation phase of the project
Noise and vibration due to project construction or operation?
√
Noise and vibration will be generate during the construction activities and also during operation of the potato chips plant
Involuntary resettlement of people? (physical displacement and/or economic displacement)
√
Proposed PRAN potato chips will be establish inside of HIP
Disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable groups?
√
According to the population census 2011 there are only 7 households (male 18, female 26, total 34) in Nurpur Union
Poor sanitation and solid waste disposal in construction camps and work sites, and possible transmission of communicable diseases (such as STI's and HIV/AIDS) from workers to local populations?
√
Impacts can occur during construction and operation phase of the proposed project
Creation of temporary breeding habitats for diseases such as those transmitted by mosquitoes and rodents?
√
If canals inside the HIP will not be properly maintained, it can be breeding habitats
Social conflicts if workers from other regions or countries are hired?
√ At present worker are working in HIP from different region and culture
Large population influx during project construction and operation that causes increased burden on social infrastructure and services (such as water supply and sanitation systems)?
√
Local available resources will be affected due to population influx for setup new industries in HIP
Risks and vulnerabilities related to occupational √ Accidents may occur during incautiousness
PRAN Potato Chips Project (Bangladesh)
Agribusiness/Food
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Screening Questions Yes No Remarks
health and safety due to physical, chemical, biological, and radiological hazards during project construction and operation?
Risks to community health and safety due to the transport, storage, and use and/or disposal of materials such as explosives, fuel and other chemicals during construction and operation?
√
If fuel and oil and grease are not properly stored, transported and disposed
Community safety risks due to both accidental and natural causes, especially where the structural elements or components of the project are accessible to members of the affected community or where their failure could result in injury to the community throughout project construction, operation and decommissioning?
√
Generation of solid waste and/or hazardous waste?
√
Solid waste will be generate from the workers during operation and washing of potato
Use of chemicals? √ Citric Acid will be use
Generation of wastewater during construction or operation?
√
Generally waste water will be generate during washing the washing of raw potato
Appendix I: Environments, Hazards and Climate Change
Environment Natural Hazards and Climate Change
Arid/Semi-arid and desert environments
Low erratic rainfall of up to 500 mm rainfall per annum with periodic droughts and high rainfall variability. Low vegetative cover. Resilient ecosystems & complex pastoral and systems, but medium certainty that 10–20% of drylands degraded; 10-30% projected decrease in water availability in next 40 years; projected increase in drought duration and severity under climate change. Increased mobilization of sand dunes and other soils as vegetation cover declines; likely overall decrease in agricultural productivity, with rain-fed agriculture yield reduced by 30% or more by 2020. Earthquakes and other geophysical hazards may also occur in these environments.
Humid and sub-humid plains, foothills
More than 500 mm precipitation/yr. Resilient ecosystems & complex human pastoral and cropping systems. 10-30% projected decrease in water availability in next 40 years; projected increase in droughts, heatwaves and floods; increased erosion of loess-mantled landscapes by
Climate Change and Disaster Risk Questions The following questions are not for environmental categorization. They are included in this checklist to help identify potential climate and disaster risks.
Yes No Remarks
Is the Project area subject to hazards such as earthquakes, floods, landslides, tropical cyclone winds, storm surges, tsunami or volcanic eruptions and climate changes (see Appendix I)?
√
Could changes in precipitation, temperature, salinity, or extreme events over the Project lifespan affect its sustainability or cost?
√
Are there any demographic or socio-economic aspects of the Project area that are already vulnerable (e.g. high incidence of marginalized populations, rural-urban migrants, illegal settlements, ethnic minorities, women or children)?
√
Could the Project potentially increase the climate or disaster vulnerability of the surrounding area (e.g., increasing traffic or housing in areas that will be more prone to flooding, by encouraging settlement in earthquake zones)?
√
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and hill country wind and water; increased gully erosion; landslides likely on steeper slopes. Likely overall decrease in agricultural productivity & compromised food production from variability, with rain-fed agriculture yield reduced by 30% or more by 2020. Increased incidence of forest and agriculture-based insect infestations. Earthquakes and other geophysical hazards may also occur in these environments.
River valleys/ deltas and estuaries and other low-lying coastal areas
River basins, deltas and estuaries in low-lying areas are vulnerable to riverine floods, storm surges associated with tropical cyclones/typhoons and sea level rise; natural (and human-induced) subsidence resulting from sediment compaction and ground water extraction; liquefaction of soft sediments as result of earthquake ground shaking. Tsunami possible/likely on some coasts. Lowland agri-business and subsistence farming in these regions at significant risk.
Small islands
Small islands generally have land areas of less than 10,000km2 in area, though Papua New Guinea and Timor with much larger land areas are commonly included in lists of small island developing states. Low-lying islands are especially vulnerable to storm surge, tsunami and sea-level rise and, frequently, coastal erosion, with coral reefs threatened by ocean warming in some areas. Sea level rise is likely to threaten the limited ground water resources. High islands often experience high rainfall intensities, frequent landslides and tectonic environments in which landslides and earthquakes are not uncommon with (occasional) volcanic eruptions. Small islands may have low adaptive capacity and high adaptation costs relative to GDP.
Mountain ecosystems
Accelerated glacial melting, rockfalls/landslides and glacial lake outburst floods, leading to increased debris flows, river bank erosion and floods and more extensive outwash plains and, possibly, more frequent wind erosion in intermontane valleys. Enhanced snow melt and fluctuating stream flows may produce seasonal floods and droughts. Melting of permafrost in some environments. Faunal and floral species migration. Earthquakes, landslides and other geophysical hazards may also occur in these environments.
Volcanic environments
Recently active volcanoes (erupted in last 10,000 years – see www.volcano.si.edu). Often fertile soils with intensive agriculture and landslides on steep slopes. Subject to earthquakes and volcanic eruptions including pyroclastic flows and mudflows/lahars and/or gas emissions and occasionally widespread ashfall.
Probable Involuntary Resettlement Effects Yes No Remarks
Involuntary Acquisition of Land
Will there be land acquisition? √
Is the site for land acquisition known? √ Project will be establish inside of Habiganj Industrial Park (HIP)
Is the ownership status and current usage of land to be acquired known?
√ Land inside of the Habiganj Industrial Park (HIP)
Will there be loss of shelter and residential land due to land acquisition?
√
Will there be loss of agricultural and other productive assets due to land acquisition?
√
Will there be losses of crops, trees, and fixed assets due to land acquisition?
√
Will there be loss of businesses or enterprises due to land acquisition?
√ Business opportunities will be increase
Will there be loss of income sources and means of livelihoods due to land acquisition?
√ Income and livelihoods opportunities will be generate
Involuntary restrictions on land use or on access to legally designated parks and protected areas
Will people lose access to natural resources, communal facilities and services?
√
If land use is changed, will it have an adverse impact on social and economic activities?
√
Will access to land and resources owned communally or by the state be restricted?
√
Information on Displaced Persons:
Any estimate of the likely number of persons that will be displaced by the Project? [√] No [ ] Yes
If Yes, approximately how many?....................................
Are any of them poor, female-heads of households, or vulnerable to poverty risks? [√] No [ ] Yes
Are any displaced persons from indigenous or ethnic minority groups? [√] No [ ] Yes
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Annex-C: Indigenous People (IP) Assessment Checklist
KEY CONCERNS (Please provide elaborations on the Remarks
column) Yes No Remarks
A. Indigenous Peoples Identification
Are there socio-cultural groups present in or use the project area who may be considered as "tribes" (hill tribes, schedules tribes, tribal peoples), "minorities"(ethnic or national minorities), or "indigenous communities" in the project area?
√
Project site falls in Nurpur Union of Habiganj Sadar Upazila in Habiganj District of Bangladesh. As per Population Census of Bangladesh 2011, there are only one 7 households (male 18, female 26, total 34) in Nurpur UP. Detailed study will be conducted during IEE
Are there national or local laws or policies as well as anthropological researches/studies that consider these groups present in or using the project area as belonging to "ethnic minorities", scheduled tribes, tribal peoples, national minorities, or cultural communities?
√
Not Applicable
Do such groups self-identify as being part of a distinct social and cultural group?
√ Not Applicable
Do such groups maintain collective attachments to distinct habitats or ancestral territories and/ or to the natural resources in these habitats and territories?
√
Not Applicable
Do such groups maintain cultural, economic, social, and political institutions distinct from the dominant society and culture?
√
Not Applicable
Do such groups speak a distinct language or dialect?
√ Not Applicable
Has such groups been historically, socially and economically marginalized, disempowered, excluded, and/ or discriminated against?
√
Not Applicable
Are such groups represented as "Indigenous Peoples" or as "ethnic minorities" or "scheduled tribes" or "tribal populations" in any formal decision making bodies at the national or local levels?
√
Not Applicable
B. Identification of Potential Impacts
Will the project directly or indirectly benefit or target Indigenous Peoples?
√ Not Applicable
Will the project directly or indirectly affect Indigenous Peoples' traditional socio-cultural and belief practices? (e.g. child-rearing, health, education, arts, and governance)
√
Not Applicable
Will the project affect the livelihood systems of Indigenous Peoples? (e.g., food production system, natural resource management, crafts and trade, employment status)
√
Not Applicable
Will the project be in an area (land or territory) occupied, owned, or used by Indigenous Peoples, and/ or claimed as ancestral domain?
√
Not Applicable
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KEY CONCERNS (Please provide elaborations on the Remarks
column) Yes No Remarks
C. Identification of Special Requirements Will the project activities include:
Commercial development of the cultural resources and knowledge of Indigenous Peoples?
√
Not Applicable
Physical displacement from traditional or customary lands?
√ Not Applicable
Commercial development of natural resources (such as minerals, hydrocarbons, forests, water, hunting or fishing grounds) within customary lands under use that would impact the livelihoods or the cultural, ceremonial, spiritual uses that define the identity and community of Indigenous Peoples?
√
Not Applicable
Establishing legal recognition of rights to lands and territories that are traditionally owned or customarily used, occupied or claimed by indigenous peoples?
√
Not Applicable
Acquisition of lands that are traditionally owned or customarily used, occupied or claimed by indigenous peoples?
√
Not Applicable
D. Anticipated project impacts on Indigenous Peoples - Not Applicable
The PRAN agribusiness project is going to establish a new PRAN Potato Chips, Pasta and Flakes Project
inside of the Habiganj Industrial Park (HIP) under Sylvan Agriculture Limited (SAL), a subsidiary of PRAN
Group. Recently Potato project construction has been completed and initial operation is carried out from
November 2017. Yet full swing operation hasn’t been started. On the other hand, Pasta and Flakes
project operation hasn’t started yet. Still machine installation procedure is going on. Therefore, this operational period audit was conducted on solely Pran Potato Chips project.
The site visit was undertaken from 17th to 18th December 2017 and was attended by two environmental
and social safeguard specialists from EQMS Consulting Limited. Desk based study along with
observational field visits and internal/external stakeholder interview were adopted in this study.
Audit study has found in four major areas those are non-compliance to ADB Safeguard Requirement 1.
Along with the overall findings, specific findings were also highlighted. Required corrective action plan,
timeline and budget have been suggested as well.
1. Introduction
1.1. Introduction
“PRAN” is the largest business group in Bangladesh, established in 1981. Currently “PRAN” is one of the most admired foods and beverages brand among the millions of people of Bangladesh and other
countries of the world where PRAN products are regularly being exported to different countries of the
world. PRAN is currently producing Juices, Drinks, Mineral Water, Bakery, Carbonated Beverage, Snacks,
Culinary, Confectionary, Biscuit, Dairy, Health Food Drink, Breakfast and Refreshment, Rehydration,
Frozen Food and Kernel Sunflower Oil. All the PRAN products are produced as per international standard
maintaining the highest level of quality during its production processes. PRAN started its successful
journey to export market since 1996 and currently exports to over 118 countries.
The PRAN agribusiness project is going to establish a new PRAN Potato Chips, Pasta and Flakes Project
inside of the Habiganj Industrial Park (HIP) under Sylvan Agriculture Limited (SAL), a subsidiary of PRAN
Group. The proposed project will be established inside of the HIP of Olipur, Habiganj District, Bangladesh.
The project is interested in taking project finance from the Asian Development Bank (ADB), which
requires an environmental and social assessment in line with the environmental and social requirements
of these lenders as well as the national regulatory requirements in Bangladesh. PRAN Group has
therefore initiated the Initial Environmental Examination (IEE) study to comply with the IEE guidelines of
the GOB and the Safeguard Policy Statement (SPS) of the ADB.
1.2. Project description
The proposed project is located inside of the Habiganj Industrial Park (HIP). The HIP is administratively
situated in the Nurpur Union under Habiganj Sadar Upazila of Habiganj District, Bangladesh. The northern
site of HIP is covered by Surabahi, Shailjura and Gayerpur village; industries of the Square group (Square
denim and Shahjibazar power station) on the South; Sachiura, Noagaon, Dushashan village on the West
and Olipur village, Dhaka-Sylhet Highway, Dhaka-Sylhet Railway and Hilly areas are located on the East
side.
Recently Potato project construction has been completed and initial operation is carried out from
November 2017. Yet full swing operation hasn’t been started. Lack of row materials is the main reason
behind this. Main row material is potato which will be available from February/March. Once potato supply
will be available and stored, full swing production will be continued.
Pasta and Flakes project operation hasn’t started yet. Its infrastructural construction has been completed but still machine installation procedure is not started. Therefore, this operational period audit was
conducted on solely Pran Potato Chips project.
1.3. Objective
The objectives of this audit are to:
Review environmental compliance of the existing assets against the requirements of ADB SR1:
Environment, with consideration of international best practice
Propose a corrective action plan (CAP) that sets out the actions that the Project needs to
implement to achieve compliance with ADB SR1
2. Summary of National, Local and any Other Applicable
Environmental Laws, Regulations, and Standards
2.1. Bangladesh Environmental Policy, Regulations and
Guidelines
2.1.1. Government Environmental Policy, Regulations and Guidelines
National Environmental Policy, 1992
National Environment Management Action Plan (NEMAP), 1995
Environment Conservation Act (ECA), 1995 and subsequent amendments
The audit approach has involved a desk based review and a site visit to obtain
information. This report has been informed by the review of Project documentation and
questions and answers with SAL. In addition, clarifications and additional information
have been sought through meetings with local community and corporate social
responsibility (CSR) beneficiaries. The information obtained has been compared against
the individual requirements of SR1 to make informed, evidence-based judgments as to
whether the Project is compliant or not. The findings of the compliance audit have been
used to identify recommendations that form the basis of the corrective action plan, which
is presented in Section 6.
3.1.1. Desk Based overview
The desk based review of project documentation included the following key documents:
Initial Environmental Examination (IEE), 2017;
Stakeholder Engagement Plan;
Emergency response plan;
Quality plan;
Others (policy and plan).
3.1.2. Site Visit
The site visit was undertaken from 17th to 18th December 2017 and was attended by two environmental
and social safeguards specialist from EQMS Consulting Limited.
Internal stakeholder consultation
The following SAL personnel with responsibilities relating to environmental and social safeguards
compliance matters facilitated the EQMS environmental and social safeguard specialist during the site
visit and provided responses to questions before, during and after the site visit:
Table 3-1: Internal Stakeholder Lists
Sl Name Designation
1. M. A Latif S.M
2. Md. Shahin Mahmud D&M
3. Md. Mohiuddin M
4. A.B.M Eqram Hossain M-Qc
5. Md. Abdullah Miah SAM
6. Mohammed Ali AM(HRM)
7. Hasan Ahmed AM
8. Md. Rasel Kabir SH
External stakeholder consultation
A number of external stakeholders were consulted during the site visit.
3.2. Compliance rating
The compliance audit findings are presented in Section 5 alongside an overall compliance
determination which has been assigned on the following basis:
Compliance: Taking account of ADB’s policies and requirements, the Project’s practices, documents reviewed and field observations, specialists consider the
Project, on the whole, to be compliant with SR1
Non-compliance: Taking account of ADB’s policies and requirements, the Project’s practices, documents reviewed and field observations, specialists consider the Project
has at least one area that is not being performed to the required standard of SR1
and that this is of sufficient importance as to prevent compliance with SR1
3.3. Information gaps and limitations
The limitations of the audit approach are that of the duration of the site visit and, based
on the timeframes inherent in the audit process, the audit only presents a snapshot of
the Project’s performance during the review period.