421-i. Review of ESIA report on Water Management Infrastructure Project in Bhola District - Bangladesh

At the request of Facility for Infrastructure Development (ORIO), the Netherlands Commission for Environmental Assessment (NCEA) performed a quick scan of the Environmental and Social Impact Assessment (ESIA) report on the improvement of the Water Management Infrastructure on Bhola Island in Bangladesh. ORIO will use the quick scan as input in the appraisal of the project plan for the Implementation and Operation & Maintenance Phases, which is still ongoing at this moment. The specific recommendations in the quick scan will be further discussed during the appraisal process of the project plan with the Bangladesh Water Development Board (BWDB). Both BWDB and ESIA consultants have provided extensive responses and explanations to the NCEA recommendations. The NCEA quick scan is attached, as well as these reactions. (The comments of the ESIA consultants are only visible if downloaded.)

Advisory reports and other documents

Significant details

The NCEA observed that the ESIA report satisfactorily complies with the ToR and guidelines provided by the Bangladeshi Department of Environment.

Regarding the quality of the technical content of the ESIA, the NCEA concluded that overall, the ESIA report provides a comprehensive description of nearly all relevant information. However, an update of the ESIA will be required once the exact locations of the works are known, including the related footprint and affected population. The need for this update is acknowledged by the ESIA team. At the time of such an update, additional information can also be provided on a number of aspects, which the NCEA considered not yet sufficiently addressed in the current ESIA. The most important ones are:

• A better justification of the selected project components;
• The risk that rehabilitation of certain sections of the embankment may increase the risk of breaching of adjacent non-rehabilitated sections;
• The further detailing of the preliminary Environmental (and social) Management Plan before project approval or Environmental Clearance be given.

Meanwhile, ORIO has given a general response to the NCEA's main observations:

Justification project: It is said that an ESIA should be written as a standalone document, therefore ORIO only provided the ESIA to NCEA for their advice. Consequently, NCEA had not received the elaborate explanation/justification on the selection of the project components and project site, which was described in separate documents. These also provide an analysis of the risk of breaching of adjacent non-rehabilitated sections. This information may therefore fulfil recommendation one and two.

Updated ESIA: ORIO acknowledges the dynamic character of Bhola Island due to erosion, and therefore understands the need for an updated ESIA as soon as the exact project location has been determined. In case the project plan for the Implementation and O&M Phases are approved by ORIO, the updated ESIA would be necessary before the Implementation Phase starts. The social and environmental impact in the project area should be described and properly mitigated in case this effect is negative, in advance.

Parties involved

Members of the working group

Technical secretary: Ineke Steinhauer

Further details

Country: Bangladesh

Last modified: 05 Apr 2019