Chittagong Water Supply Improvement and Sanitation Project

PROPOSED

CHITTAGONG WATER SUPPLY IMPROVEMENT AND SANITATION PROJECT

ENVIRONMENTAL

MANAGEMENT FRAMEWORK

December,2009

Chittagong Water Supply and Sewerage Authority

GOVERNMENT OF THE PEOPLE’S REPUBLIC OF BANGLADESH

MINISTRY OF LGRD AND COOPERATIVES

(LOCAL GOVT. DIVISION)

Table of Contents

Acronyms

Executive Summary

Part- A: The project and the EMF

Project Background
Project objectives
Project description
Purpose of EMF
Structure of EMF

PART B: Environmental Policies, Laws and Rules

Relevant Environmental laws and requirements
Specific Applicability to CWSISP Activities
Bangladesh ECA95
Bangladesh ECR97

8. Bank's environmental safeguards

8.1 OP 4.01 Environmental assessment

8.2 Environmental Management in Sub-projects

8.2.1 Screening

8.2.2 EA requirements

9. Requirements on Environmental Clearance in Bangladesh

PART C: CONSULTATION,GRIEVANCE REDRESS& DISCLOSURE

10. Community / Stakeholder Consultations

11. Grievance Redress

12. Disclosure

PART D: GAP ANALYSIS AND CAPACITY BUILDING

13.Gap Analysis

13.1 Awareness of Environmental Issues

13.2 Institutional Capacity

13.3 Resources for Capacity Building

PART E: MONITORING, REPORTING AND AUDITING

14. Monitoring

15. Reporting and Auditing

PART F: ENVIRONMENTAL MANAGEMENT PLAN

16. General Considerations

17. Organizational Aspects

17.1 Pre-construction Phase

17.2 Construction Phase

17.3 Operation and Maintenance Phase

18. Responsibilities During Implementation

18.1 Responsibility of Working Contractor

18.2 Responsibility of Supervision Personnel

18.3 Responsibility of Executing Agency

18.4 Responsibility of Consultants

18.5 Responsibility of NGOs

18.6 Responsibility of Ministry

PART G: CONCLUSION AND RECOMMENDATIONS

19. Conclusion and Recommendations

References

Annexes

Annex I:Standards Related to Water Utilities in ECR 97.

Annex II: Participants in the workshop on CWSISP EMF/SMF December 14, 2009.

Annex III: Press reports on the workshop.

Annex IV: List of possible types of environmental impacts to be expected

List of Acronyms and Abbreviations
BUET / BangladeshUniversity of Engineering & Technology
BOD / Bio-Chemical Oxygen Demand
BWDB / Bangladesh Water Development Board
CCC / Chittagong City Corporation
COD / Chemical Oxygen Demand
CWASA / Chittagong Water Supply and Sewerage Authority
DPP / Development Project Proforma
DOE / Department of Environment
DPHE / Department of Public Health Engineering
EA / Environmental Assessment/ Appraisal
ECA / Environmental Conservation Act of 1995
ECC / Environmental Clearance Certificate
ECR / Environmental Conservation Rules of 1997
EIA / Environmental Impact Assessment
EMS / Environmental Management System
EMF / Environmental Management Framework
EMP / Environmental Management Plan
ES / Environmental Screening
GOB / Government of the People’s Republic of Bangladesh
GRC / Grievance Redress Committee
IDA / International Development Association
ISO / International Organization of Standardization
ISC / Inter Ministerial Steering Committee
IEE / Initial Environmental Examination
JIBIC / Japan Bank for International Co-operation
KWASA / Khulna Water and Sewerage Authority
LGED / Local Government Engineering Department
MDG / Millennium Development Goal
MLD / Million Litres Per Day
MOEF / Ministry of Environment and Forestry
NOC / No objection Certificate
NGO / Non Government Organization
NTU / Nephelometric Turbidity Unit
NWP / National Water Policy
NWMP / National Water Management Plan
OP / Operational Policy
O&M / Operation and Maintenance
PD / Project Director
PIA / Project Implementation Agency
PMU / Project Management Unit
PPMS / Project Performance Management System
PSC / Project Steering Committee
PVC / Poly Vinyl Chloride
RFP / Request for Proposal
SEA / Strategic Environmental Assessment
TOR / Terms of Reference
TDS / Total Dissolve Solid
UN / United Nations
USEPA / United State Environmental Protection Agency
WB / World Bank
WSS / Water Supply and Sanitation
WTP / Water Treatment Plant
WHO / World Health Organization

Executive Summary

Part- A: The project and the EMF

Project Background

Chittagong is the second largest city in Bangladesh and its foremost sea port and industrialized city with a present population of about 3.5 millionwithin the Chittagong City Corporation area. Currently, with a limited water production capacity and a dilapidated pipe network, the population is highly under served in respect of water supply. There are no water borne sewerage systems in Chittagong and stormwater drainage capacity is grossly inadequate. Chittagong Water Supply and Sewerage Authority (CWASA) intends to undertake a project named “CHITTAGONG WATER SUPPLY IMPROVEMENT AND SANITATION PROJECT (CWSISP)”to be financed by the World Bank to improve water supply and sanitation in the city.

Project objectives

The project objective is to increase the sustainable access to safe water and improved sanitation, as well as support the establishment of a longer term water supply, sanitation and drainage capital development and operational management program in Chittagong.

Project description

The Chittagong Water Supply Improvement and Sanitation Project (CWSISP) has three components. These components will support CWASA towards improving the service delivery of water supply to the population of Chittagong, improve the coordination between service delivery stakeholder agencies in Chittagong and prepare towards future investments in sewerage and drainage. Main project activities will include: (i) constructing selected water production, transmission, storage and distribution facilities, (ii) rehabilitating, replacing and extending the primary and secondary distribution pipes in selected areas, (iii) improving the management of existing on-site sanitation facilities, while simultaneously updating the sewerage and drainage master plans, and (iv) strengthening the operations and institutional structure of CWASA.

Purpose of EMF

The project components proposed may have environmental safeguard issues that are yet to be identified specifically. As per Bank guidelines, the sub-projects in components will be required to be designed and implemented by integrating the general policies, guidelines, codes of practice and procedures proposed in this EMF. The objectives are to ensure that the activities undertaken in the project:

Enhance positive environmental and social outcomes;
Prevent negative environmental impacts;
Identify and mitigate with appropriate measures the adverse impacts that might be caused to people; and
Ensure compliance with the World Bank’s environmental safeguards policies.

Structure of EMF

The EMF document is structured in a sequential manner to assist the reader to understand the background of the preparation of the document, purpose, objectives and its implementation during design, implementation and monitoring stages of any sub-project under the project. The chaptersare appropriately labeled so as to provide information on the coverage.

PART B: Environmental Policies, Laws and Rules

Relevant Environmental laws and requirements

The present Policies, Acts, Rules & Regulations with respect to the Environmental issues in the country are under the custodianship of the Ministry of Environment and Forest (MOEF)/Department of Environment (DoE). However, there are also sectoral laws dealing with different environmental issues in Bangladesh which were enacted at different periods. The activities under the CWSISP are likely to be covered by the Policies, Acts, Rules & Regulations under ECA 95 and ECR 97. However, it may be noted that provisions in these documents do not cover for all the planned activities especially in the case of waste water management.

Bank's environmental safeguards

The main purposes of the Bank’s safeguard policies are to (i) avoid harm to the environment and affected people and provide affected people an opportunity to participate in the development process; (ii) improve project design and performance; and (iii) protect the reputation of the Bank. The current set of safeguard policies cover a broad range of topics from environmental assessment to natural habitats, forests, resettlement, and Indigenous Peoples and others. The policies are the reflection of international conventions and internationally accepted principles of good practice in project preparation and implementation. Similar principles, supporting the aspirations for sustainable development, are generally reflected in policies in most client countries; however, implementation is often weak and variable. Out of Bank’s safeguards policies only OP 4.01 related to environment is triggered in the CWSISP.

Requirements on Environmental Clearance in Bangladesh

In Bangladesh the EA procedure has three tiers which are; (i) Screening; (ii) Initial Environmental Examination (lEE); and (iii) Detailed EIA.For the sub-projects (Orange-B and RED category) in the CWSISP, CWASA will need to obtain the clearance from the DOE in two stages i.e., (i) Initial Stage in which a Site Clearance Certificate (SCC) is obtained and (ii) an advanced Stagein which an Environmental Clearance Certificate (ECC) is obtained.

PART C: CONSULTATION, GRIEVANCE REDRESS & DISCLOSURE

Community / Stakeholder Consultations

Community/stakeholder discussions are basic requirements in the sub-project preparation and implementation. As the basic principles require, inputs and feedbacks received from stakeholder consultations are the major determinants in the selection, location and design of specific sub-projects and their implementation. It will be necessary to document the discussions in respect of participation, deliberations and the decisions reached.

Grievance Redress

The PIA will establish a procedure to answer to subproject-related queries and address complaints and grievances about any irregularities in application of the guidelines adopted for assessment and mitigation of environmental safeguards impacts. The complaints related to project activities that may create severe inconveniences during construction should be addressed based on consensus, the procedure will help to resolve issues/conflicts amicably and quickly without resorting to expensive, time-consuming legal actions. For the purpose, a Grievance Redress Committee (GRC) will be formed in the PIA.

Disclosure

The PIA will disclose this EMF in Bangla to the public in Bangladesh, and authorize the World Bank to disclose it at its Country Office Information Center and in its Infoshop. The PIA will ensure that copies of the document are available at the CWASAhead office and other offices, public libraries, and other places accessible to the general public. CWASA will also inform the public through notification in two newspapers (Bangla and English) about the ESMF and where it could be accessed for review. According to present schedule, the safeguards documents including EMF will be disclosed in Bank’s Infoshop before December 31, 2009. A public consultation workshop on EMF/SMF was held on December 14, 2009 which was widely covered in the local press the next day. The EMF is expected to be disclosed on the CWASA website soon.

PART D: GAP ANALYSIS AND CAPACITY BUILDING

Gap Analysis

The environmental management practices in CWASA are still adhoc and systematic organizational approach to the issue is yet to be developed. The factors which deserve attention can be broadly classified into three following categories i.e., (i) Low awareness on environmental issues; (ii) Inadequate institutional capacity; and (iii) Resource constraints.

Capacity Building

For establishing a sound Environmental Management System (EMS) in a Water/Wastewater utility, the management has to understand that an EMS is a valuable tool that provides a structure for strategic goal setting, improved decision making and efficient resource allocation across management priorities, balancing the management of operations throughout the value chain.The implementation of an EMSwhich minimizes negative and advance positive impacts on the environment is an achievable goal through implementation an environmental policy consisting of the components discussed in this section. The components of capacity building will consist of human resource development as well as investment in environment infrastructures including laboratories. CWSISP resources to the extent of about BDT 760 lacs have been earmarked for the purpose.

PART E: MONITORING, REPORTING & AUDIT

The purpose of monitoring measures that will be undertaken are to ensure that the environmental concerns are addressed, environmental assets are protected and quality is enhanced through mitigation measures and these are monitored and reported in an efficient and effective manner.Monthly report on the project performance management system (PPMS) should be submitted to the Project Implementation Agency (PIA) during implementation of project monitoring activities. The results will be used in a feedback loop to allow CWASA project steering committee (PSC), and contractor to modify project implementation activities as and when required. A quarterly report of PPMS on monitoring activities will be prepared, submitted by the PIA and made available for public viewing through the CWASA offices and through the CWASA website. Environmental audit should be conducted periodically (e.g., yearly) to review the effectiveness of environmental management.

PART F: ENVIRONMENTAL MANAGEMENT PLAN

In the context of a project, environmental management is concerned with the implementation of the measures necessary to minimize or offset adverse impacts and to enhance beneficial impacts. The EMP ensures that the mitigation and benefit enhancement measures identified in the IEE are fully implemented and clear line of responsibilities for the purpose are assigned in the subproject.

PART G: CONCLUSIONS AND RECOMMENDATIONS

The EMF as pointed out earlier is a document to provide guidelines as to how the environmental safeguard issues can be addressed for the project components that are yet to be identified specifically. In the process of development of this document, institutional capacity of CWASA has been reviewed and found inadequate for handling environmental safeguard issues. Thus, additional capacity will be made available through consultant services and project hired staff to overcome the deficit in capacity. The consultants and the project staff will be involved in design, pre-construction, construction and operational phases of the sub-projects during the project period and will be funded out of the project resources. However, it is essential that such capacities are internalized for sustainability.Best practice in environmental management must be inherent in project preparation and implementation.Strong public participation should be ensured at all stages of the project.

ENVIRONMENTAL MANAGEMENT FRAMEWORK

( CHITTAGONG WATER SUPPLY IMPROVEMENT AND SANITATION PROJECT )

Part- A: The project and the EMF

Project Background

Chittagong is the second largest city in Bangladesh and its foremost sea port and industrialized city. Eighty percent of Bangladesh's exports and imports are routed through the port of Chittagong. There are currently two export processing zones within the metropolitan area, while four more are planned. Thirty percent of manufacturing in Bangladesh takes place in Chittagong. Forty percent of the country's heavy industry is located here. Almost all of Bangladesh's industrial exports originate in Chittagong. This economic activity, amongst others, has prompted a large population influx. The present population within Chittagong City Corporation area is about 2.6 million (compared to about 600,000 in 1980 when the previous World Bank WSS project was conceived and under which the last major WSS infrastructure was completed). Chittagong metropolitan area is estimated to have about 3.8 million people, second only to Dhaka. The Government of Bangladesh has requested assistance from the World Bank to prepare the proposed project to improve water supply, sewerage disposal, sanitation and storm water drainage facilities in Chittagong. The project would be prepared and implemented by the Chittagong Water Supply and Sewerage Authority (CWASA).

The Chittagong Water and Sewerage Authority (CWASA) currently supplies water to about 40% (through various modes of supply) of the population of the Chittagong City Corporation (CCC) and its suburbs through a distribution network. People living in the Chittagong slums also rely on CWASA’s piped water, as there is no other reliable source of water available; but public standpipes are always remotely located. CWASA do not have any sewerage network. As a result waste water generated by the existing approximately 45,000 connections goes untreated to different water bodies like ponds, cannels & river and from there to the sea (Bay of Bengal). High standard buildings dispose of their black waters in septic tanks and their grey water directly into water drains. Lower income households rely on latrines. Large portions of the slum population have no access to adequate sanitation facilities. Industries are required to treat effluents before disposal into drains or water bodies, but this regulation is seldom enforced. CWASA is also legally responsible for developing and operating the storm water drainage in Chittagong. The Chittagong City Corporation (CCC) is in charge of smaller drains. Natural channels and wetlands that help Chittagong City to cope up with the drainage of storm water flows are rapidly being covered up with soil due to urban development. Public health is affected by the limited coverage of the water supply and absence of sewerage system and also due to recurrent flooding.

Chittagong WASA has recently completed a Master Plan for Water Supply & Waste Water Management for detailed planned area covering more than 550 square kilometers. In the Master Plans short term, medium term and long term plans for the year 2011, 2021 & 2031 respectively are considered. Feasibility studies on priority (short term) projects for 100 million liter per day (mld) capacity water treatment plant on the left bank of River Karnaphuli at Bhanderjuri and 220 mld capacity sewerage treatment plant on the left bank of River Karnaphuli at South Halishahar was conducted. Chittagong WASA needs to update The Storm Water Drainages Master Plan prepared by the Chittagong Development Authority (CDA) for implementation by Chittagong WASA.

Project objectives

a) Increasing the supply of safe potable water by constructing selected water production, transmission, storage and distribution facilities;

b) Increasing the delivery of safe potable water by expanding piped water supply services to under-served areas through the rehabilitation, replacement and extension of primary and secondary distribution pipes in selected areas (including water supply and sanitation service expansion into urban slums through a balanced program involving community participation);

c) Improving the management of existing on-site sanitation facilities, while simultaneously updating the sewerage and drainage master plans, identifying and designing priority investments for a longer term development program; and