Government of the People’s Republic of Bangladesh Local Government COVID-19 Response & Recovery Project (LGCRRP) Local Government Division (LGD) Ministry of Local Government, Rural Development and Cooperatives (MLGRD&C) www.lgd.gov.bd Environmental and Social Management Framework (ESMF) March 2021 Environmental and Social Management Framework i Executive Summary Introduction. This Environmental and Social Management Framework (ESMF) has been prepared for the Local Government COVID-19 Response & Recovery Project (the Project) to identify, design and implement activities responding to the requirements of the national legal framework and the World Bank’s Environmental and Social Framework (ESF). The Government of Bangladesh (GoB) has prepared this project with financing from the International Development Association (IDA) of the World Bank Group (WBG). The project is expected to strengthen the response and recovery efforts of the urban local government institutions (ULGIs), Paurashavas (PSVs) and City Corporations (CCs), in response to the COVID-19 pandemic in Bangladesh. The Local Government Division (LGD) in the Ministry of Local Government, Rural Development and Cooperatives (MLGRD&C) will be implementing the project including management of relevant fiduciary and environment and social requirements for all the project components. The project will benefit 39.90 million residents of 329 PSVs and 12 CCs across the country. The project will support ULGIs to: (i) ensure continuity of basic urban services; (ii) ramp up local level COVID-19 responses in services, health, jobs and livelihoods, community outreach and awareness, and local economic development; (iii) mobilize and coordinate across various agencies operating at the local level; and (iv) strengthen their pandemic and disaster response systems. The project, under Component 1 will support the ULGIs with COVID-19 Response Grants (CRGs) for small – scale infrastructural activities responding to impacts of COVID-19 pandemic and under Component 2 for capacity building of ULGIs. A contingency emergency response component (CERC) is included as Component 3 for situations of urgent need of assistance. Purpose of the ESMF. World Bank Environmental and Social Framework (ESF) will apply to the Project in addition to national legislative requirements for environmental and social management. The ESMF will provide guidance on pre-investment works/studies (such as environmental and social screening, environmental and social assessment, environmental and social management plans, etc.), provide set of steps, procedures, and mechanisms for ensuring adequate level of environmental and social considerations, and integration in each investment in the project-cycle. Application of GoB Policies, Acts and Rules. The project activities will not have significant or irreversible impacts on the surrounding environments or communities, but likely to have localized minimal impacts. As per Environmental Conservation Rules (ECR)’97, most the activities associated with project components/sub-components are likely to fall under either Orange A or Orange B categories. The project will conduct environmental and social screening for all activities at the initial stage and based on screening results, and if recommended by the Department of Environment (DoE), further IEE or ESIA will be carried out for specified activities. DoE is the regulatory body and the enforcement agency of all environmental related activities in development projects. Relevancy of WB ESF. All Environmental and Social Standards (ESSs) of the World Bank ESF will be applicable to the project, except ESS5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement, ESS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, ESS 7: Indigenous Peoples, ESS 8: Cultural Heritage, and ESS 9: Financial Intermediaries and WB’s legal LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework ii operational policies related to projects on international waterways (OP 7.50) ,and Disputed Areas (OP 7.60) will not be relevant to the proposed project activities. Key Environmental and Social Risks. Considering the intensity of the associated environmental and social risk and impacts, the Project E&S risks have been rated as ‘Moderate’, as most of the impacts are localized and reversible in nature. Given the likely activities (rehabilitation and development of small-scale community infrastructure) to be financed, the project is not likely to lead to impacts that may pose substantial or high environmental and social risks to the project. Construction impacts will entail air and water pollution, noise emissions and waste generation. These adverse impacts are expected to be limited and site specific and will be minimized, avoided, or compensated with careful design and implementation of site specific ESMPs. The activities with substantial/significant environmental impacts including those generating hazardous waste are included in the negative list of activities the project will not finance. All activities will be designed and implemented using existing available land avoiding involuntary acquisition of land and displacement of people. Presence of small ethnic communities with indigenous status meeting the criteria of ESS7 is not likely in the urban areas. Implementation approach will be inclusive, transparent, and participatory. The environmental and social risks that require pre-mitigation include: (i) poor labor and working environment; (ii) occupational health and safety of project workers including induced risks regarding workplace and community health and safety; (iii) noise, vibration, and dust pollution including waste generation and management associated with civil works; (iv) induced risk of gender-based violence (GBV), sexual exploitation and abuse (SEA) and sexual harassment (SH); (v) potential for hiring child labor for civil works; and (vi) ensuring equitable project benefits to the indigenous and other disadvantaged and vulnerable communities. General Principle for E&S Management. The ESMF is prepared based on the following principles to lead the planning and implementation of the proposed project activities. • Site specific IEE, ESIA and ESMP will be prepared for activities as determined by DoE. In case, requirements of DoE’s ESIA guideline differs from those of WB ESF, the more stringent standards and requirements will apply. The subprojects will be handled with appropriate mitigation or compensation measures during implementation. • Planning and design of the any additional activities should ensure assessment of cumulative impacts. • Participation of stakeholders (especially local communities) will be ensured through continuous consultations and information disclosure, as well as providing differentiated scope for the disadvantaged and vulnerable people, by PIU/ULGIs in planning, implementation, and monitoring of sub-project activities. • PIU/ULGIs and PMU/LGD on the Project will ensure appropriate institutional set up with dedicated E&S staff for implementing environmental and social management plans and inter-agency coordination. • PIU/ULGIs will ensure that bidding documents for construction contractors have specific clauses related to implementation of ESMPs, as required. • Project workers engaged by contractors in project civil works should be provided with adequate health and safety facilities. Worker‘s/crew’s health and safety measures shall be ensured and use of personal protective equipment shall be required. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework iii • PIU/ULGIs at the local level and PMU/LGD at the national level will inform project stakeholders about project interventions and its potential impacts on the surrounding environmental and social elements. • Activities with the following attributes will be ineligible for financing under the project: - E&S Impacts identified in IEE/ESIA categorize the project as substantial or high risk (according to ESF). - Require land acquisition, or cause involuntary physical displacement, or result in loss of livelihoods of peoples. - Associate adverse impacts on the small ethnic communities with indigenous status as per the World Bank ESS7. - Associate significant environmental impacts, including those that significantly increase greenhouse gas emissions, hazardous waste and impact of natural habitats and biodiversity. • In case of triggering the CERC, the LGD will update the ESMF to cover the activities supported under the CERC. A list of Positive and Negative activities for CERC component is given in Annex 6. E&S Management and Implementation Arrangements. LGD will establish a Project Management Unit (PMU), headed by a National Project Director (NPD) and assisted by two or more Deputy Project Directors (DPDs) deputed by LGD. LGD will establish Regional Support Centers (RSCs) in each of the eight administrative Divisions for implementation of the project. Each RSC will be staffed by consultants, recruited by the PMU including for E&S and community development support. A high-level Project Steering Committee (PSC), chaired by the Secretary LGD will be set up at the ministry. Each participating ULGI will establish a small Project Implementation Unit (PIU) responsible for ensuring that planning, budgeting, implementation, and reporting are undertaken in accordance with project procedures. PIUs will consist of regular ULGIs staff, deputed on a part-time basis to coordinate project financed activities at the local level. The PMU in LGD will include a Senior Environmental Specialist, a Senior Social Development Specialist, and a Communications and Citizen Engagement Specialist. The RSCs will also have Environmental and Social Specialist and Community Development Specialist consultants. The PIUs in the ULGIs will be supported by LGD through RSCs for E&S management in subproject processes. Environmental and Social Assessment and Management Process. The PMU through RSCs will provide technical support to the PIUs in environmental and social screening, impact assessment and preparation of management plans. The RSCs will support the PMU in E&S appraisal of the CRG proposals from the PIUs. Following are the procedures for E&S management in subproject cycle. • If E&S screening identify any activities that requires further E&S assessment, respective PIUs will engage an independent E&S consultant to generate a detail environmental and social baseline of the subproject, conduct IEE and the ToR for ESIA (if recommended by DoE). The PIUs will share their IEE reports and the ESIA ToRs with DoE for Clearance. • The PMU will review and clear screening and environmental and social assessment reports of the PIUs before submitting for DoE clearance and provide necessary technical inputs. • PMU through RSCs will conduct verification of screening and assessment through field visits. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework iv • RSCs through relevant staff of PIUs will ensure that environmental and social considerations are given enough attention, weight, and influence over selection of construction sites and improvement of infrastructures. • Bid documents will be prepared by the PIUs. RSCs will make sure necessary environmental and social clauses are included in the bidding documents and ESMP implementation should be done by Contractors. RSCs and PIUs of the respective ULGI will supervise ESMP implementation and E&S compliance. • All the activities of the project will follow Environmental Code of Practices (ECoPs) prepared under the ESMF. • The project will ensure that ESIA addresses all potential environmental and social direct and indirect impacts of the project throughout its life cycle; and suggest appropriate mitigation measures. If any additional impacts are identified, IEE/ESIAs and ESMP should be reviewed and updated. Capacity Building Plan (CBP). Capacity building for environmental and social management will need to be carried out for all staff and consultants at the PMU and PIUs and those of the contractors. At the construction site, respective PIUs-will lead implementing the capacity building plan, though the contractors will also be responsible to conduct trainings for their workers. The various aspects that are covered under the capacity building will include general environmental and social awareness, key environmental and social sensitivities of the sites, key environmental and social impacts, ESMP requirements, OHS aspects, and waste disposal including e-wastes. Disclosure and Consultations. Considering the COVID-19 pandemic, basic information for preparing the ESMF was collected through sending checklist to select ULGIs and virtual consultations with different stakeholders at several ULGIs. The ESMF will be disclosed to the local and national level stakeholders through workshops, consultation meetings, and advertisement in print and electronic media. A national workshop will be held at Dhaka and stakeholders’ meetings will be held at some selected PSVs/CCs to disclose the ToRs and results of the IEE and ESIA. Workshops and stakeholders’ meetings will be organized following COVID-19 protocols. Summary of the ESMF and the subsequent E&S tools will be translated into Bengali language and disclosed locally. A separate Stakeholders Engagement Plan (SEP) has been prepared for the project, which will be the main guiding document for the PIUs and the PMU for information disclosure and stakeholders’ consultation. Grievance Redress Mechanism (GRM). Considering the overall need for the total project period, a central GRC will be established at the project PMU level to oversee the whole GRM operation, deal with strategic level grievances (Project planning and design issues, major social and environmental risks and impacts and issues that are beyond the scope and complexity to deal with other GRCs). The Division level RSCs will establish GRCs to administer grievances raising in their own areas of responsibilities, i.e in the ULGIs/PIUs of that Division. Uptake channels at various PIUs will be established where grievances will be received by dedicated desk, where complainants can go physically to register complaints. The GRCs will help to resolve issues/conflicts amicably and quickly, saving the targeted affected individuals and communities, vulnerable groups, project workers and other aggrieved persons resorting to expensive, time-consuming legal actions. The project will, however, not bar stakeholders from seeking resolution through courts of law on grievances that were not resolved through the project GRM. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework v List of Acronyms BDT Bangladeshi Taka LIPW Labor Intensive Public Works CC City Corporation LMP Labor Management Procedures CE Citizen Engagement M&E Monitoring and Evaluation CERC Contingency Emergency Response Component M&E Monitoring and Evaluation C-ESMP Contractor’s Environmental and Social MC Minimum Condition Management Plan MC Minimum Condition CHT Chittagong Hill Tract MGSP Municipal Governance Support Project CRG COVID-19 Response Grant MoHFW Ministry of Health and Family Welfare DoE Directorate of Employment MIS Management Information System DRM Disaster Risk Management MIS Management Information System E&S Environmental and Social MLGRD&C Ministry of Local Government, Rural Development EA Environmental Assessment and Co-operatives EAP Emergency Action Plan MoEFCC Ministry of Environment, Forest and Climate ECA Environmental Conservation Act Change ECC Environmental Clearance Certificate MoLGRD&C Ministry of Local Government, Rural ECoP Environmental Code of Practices Development and Co-operatives ECR Environment Conservation Rules MoU Memorandum of Understanding EHS Environmental, Health and Safety NGO Non-Government Organization EIA Environmental Impact Assessment NOC No Objection Certificate ENB Environment, Natural Resources and Bule NPD National Project Director Economy OHS Occupational Health and Safety ESA Environmental and Social Assessment OP Operational Policy ESCP Environmental and Social Commitment Plan PAD Project Appraisal Document ESF Environmental and Social Framework PAP Project Affected Persons ESIA Environmental and Social Impact Assessment PIU Project Implementation Unit ESMF Environmental and Social Management PM Practice Manager Framework PMU Project Management Unit ESMP Environmental and Social Management Plan POM Project Operations Manual ESS Environmental and Social Standards PPE Personnel Protective Equipment FGD Focus Group Discussion PRA Participatory Rural Appraisal FIDIC International Federation of Consulting Engineers PSC Project Steering Committee (Fédération Internationale Des Ingénieurs- PSV Pourashava (municipality) Conseils) RAP Resettlement Action Plan FM Financial Management RPF Resettlement Policy Framework FPIC Free, Prior and Informed Consent RSA Regional Standards/Safeguards Advisor GBV Gender-Based Violence RSC Regional Support Center GRM Grievance Mechanism SEA Sexual Exploitation and Abuse GoB Government of Bangladesh SEC Small Ethnic Community GRC Grievance Redress Committee SEVCP Small Ethnic and Vulnerable Community Plan GRM Grievance Response Mechanism SEP Stakeholders Engagement Plan IA Information Access SH Sexual Harassment IDA International Development Association SSI Social Sustainability and Inclusion IEE Initial Environmental Examination TLCC Town-level Coordination Committee IFC International Finance Corporation ToR Terms of Reference ILO International Labor Organization ULGI Urban Local Government Institution IPF Investment Project Financing UP Union Parishad LGCRRP Local Government COVID Response & Recovery WB World Bank Project WBG World Bank Group LGD Local Government Division WC Ward Committee LGSP Local Governance Support Project WHO World Health Organization LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework iii Table of Contents EXECUTIVE SUMMARY ............................................................................................................................................ I LIST OF ACRONYMS ............................................................................................................................................... V TABLE OF CONTENTS............................................................................................................................................. III LIST OF TABLES ...................................................................................................................................................... V LIST OF FIGURES..................................................................................................................................................... V CHAPTER 1: INTRODUCTION .................................................................................................................................. 1 1.1 BACKGROUND ..........................................................................................................................................................1 1.2 PURPOSE OF THE ESMF.............................................................................................................................................1 1.4 PROJECT DESCRIPTION ...............................................................................................................................................2 1.5.1 PROJECT COMPONENTS ..........................................................................................................................................3 1.5.2 PROJECT BENEFICIARIES ..........................................................................................................................................4 1.6 APPROACH AND METHODOLOGY OF THE ESMF .............................................................................................................4 CHAPTER 2: LEGAL, REGULATORY AND POLICY FRAMEWORK ................................................................................ 5 2.1 NATIONAL ENVIRONMENTAL AND SOCIAL POLICY, LEGAL AND REGULATORY FRAMEWORK ..............................................5 2.2 APPLICABLE INTERNATIONAL TREATIES SIGNED BY THE GOB ......................................................................................6 2.3 WORLD BANK’S ENVIRONMENTAL AND SOCIAL FRAMEWORK ....................................................................................7 2.4 GAP ANALYSIS OF WORLD BANK REQUIREMENTS AND NATIONAL LAWS ....................................................................12 2.5 APPLICATION OF GOB POLICIES, ACTS AND RULES ON LGCRRP COMPONENTS AND THEIR CLASSIFICATION .......................13 CHAPTER 3: POTENTIAL KEY ENVIRONMENTAL AND SOCIAL RISKS ...................................................................... 15 3.1 IMPACT ASSESSMENT AND PREDICTION ...............................................................................................................15 3.1.1 PROJECTED ENVIRONMENTAL AND SOCIAL IMPACTS RELATED TO PROJECT SITING ........................................................18 3.1.2 PROJECTED ENVIRONMENTAL AND SOCIAL IMPACTS DURING PROJECT IMPLEMENTATION ..............................................19 3.1.3 PROJECTED ENVIRONMENTAL AND SOCIAL IMPACTS DURING POST PROJECT OPERATIONAL PERIOD .................................21 CHAPTER 4: ENVIRONMENTAL AND SOCIAL MANAGEMENT PROCEDURES .......................................................... 24 4.1 GENERAL PRINCIPLE.........................................................................................................................................24 4.2 PROJECT IMPLEMENTATION ARRANGEMENT .........................................................................................................25 4.2.1 E&S INSTITUTIONAL AND IMPLEMENTATION ARRANGEMENTS .................................................................................26 4.2.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT AND MANAGEMENT PROCESS .................................................................26 4.3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT ..............................................................................................28 Environmental and Social Impact Assessment (ESIA) ...............................................................................................28 Contingency Plan for COVID-19................................................................................................................................29 4.4 ENVIRONMENT AND SOCIAL MANAGEMENT PLAN (ESMP) .....................................................................................29 4.4.1 SCOPE AND OBJECTIVES OF ESMP......................................................................................................................29 4.4.2 INCLUSION OF RELEVANT COMPONENTS OF ESMP IN CONTRACT DOCUMENTS ...........................................................30 4.4.3 PAYMENT MILESTONES ....................................................................................................................................30 4.4.4 GUIDELINE TO INCORPORATE ENVIRONMENTAL MANAGEMENT IN BID DOCUMENTS AND PROJECT’S OPERATIONAL MANUALS 30 4.4.5 ENVIRONMENTAL CODES OF PRACTICE (ECOPS) ....................................................................................................31 4.4.6 MANAGEMENT OF VULNERABLE AND DISADVANTAGED GROUPS, COMMUNITIES, AND INDIVIDUALS ...............................31 LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework iv 4.5 COVID-19 HEALTH AND SAFETY OF THE WORKFORCE ...........................................................................................31 4.6 LABOR MANAGEMENT PROCEDURES ...................................................................................................................32 4.7 COMMUNITY HEALTH AND SAFETY MEASURES ......................................................................................................32 4.8 REPOSSESSION OF LAND FROM ENCROACHERS FOR PROJECT WORKS .........................................................................32 4.9 CONSULTATION AND PARTICIPATION PLAN ...........................................................................................................33 4.10 GUIDELINE FOR PREPARATION OF ENVIRONMENTAL AND SOCIAL MONITORING PLAN ...................................................33 4.10.1 MONITORING PROGRAM ..................................................................................................................................33 4.11 ENVIRONMENTAL AND SOCIAL MANAGEMENT CAPACITY ........................................................................................34 4.12 CAPACITY BUILDING PLAN .................................................................................................................................35 4.12.1 TRAINING ON E&S MANAGEMENT .....................................................................................................................35 4.12.2 MONITORING AND EVALUATION ........................................................................................................................36 4.13 ESMF IMPLEMENTATION COST..........................................................................................................................37 CHAPTER 5: STAKEHOLDERS ENGAGEMENT, DISCLOSURE AND GRIEVANCE MANAGEMENT ............................... 39 5.1 STAKEHOLDER CONSULTATIONS AND INFORMATION DISCLOSURE..............................................................................39 5.1.1 METHODOLOGY AND TOOLS FOR THE CONSULTATION ............................................................................................39 5.1.2 OUTCOMES OF CONSULTATION MEETINGS AND REMOTE SURVEY .............................................................................40 5.2 CONSULTATIONS AND COMMUNICATION GUIDELINE ..............................................................................................41 5.2.1 TECHNICAL NOTE: PUBLIC CONSULTATIONS AND STAKEHOLDER ENGAGEMENT IN WB-SUPPORTED OPERATIONS UNDER THE OUTBREAK AND SPREAD OF COVID-19 ............................................................................................................................ 42 5.3 GRIEVANCE REDRESS MECHANISM .....................................................................................................................45 5.3.1 COMPOSITION OF LOCAL/SITE SPECIFIC GRC ........................................................................................................46 5.3.2 COMPOSITION OF PMU AND PSC LEVEL GRC ......................................................................................................46 5.4 INFORMATION DISCLOSURE ...............................................................................................................................48 ANNEXURE........................................................................................................................................................... 49 ANNEX 1: SAMPLE ENVIRONMENTAL AND SOCIAL SCREENING FORM ................................................................. 49 ANNEX 2: DETAILS OF THE ECOPS ........................................................................................................................ 54 ANNEX 3: WORKFORCE HEALTH AND SAFETY UNDER COVID-19 PANDEMIC IN BANGLADESH ............................. 62 ANNEX 4: QUARTERLY GRIEVANCE REPORT ......................................................................................................... 65 ANNEX 5: SUMMARY OF APPLICABLE ENVIRONMENTAL, SOCIAL AND SAFEGUARDS REGULATIONS OF GOB ...... 66 ANNEX 6: CERC POSITIVE AND NEGATIVE LIST ..................................................................................................... 70 Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework v List of Tables TABLE 2.1 WB ESS REQUIREMENTS AND RELEVANCE TO THE LGCRRP .........................................................................7 TABLE 2.2: GAPS BETWEEN GOB LAWS AND WORLD BANK ESSS THOSE APPLICABLE TO THE LGCRRP ....................12 TABLE 3.1: CATEGORIZATION OF LGCRRP ACTIVITIES BASED ON KEY PREDICTED IMPACTS AND THOSE ESS REQUIREMENTS ...........................................................................................................................................................15 TABLE 3.2: SUMMARY OF PROJECTED ENVIRONMENTAL AND SOCIAL IMPACTS AND THEIR SIGNIFICANCE (ESS RISK) .....................................................................................................................................................................................22 TABLE 4.1: TRAINING PLAN LGCRRP ............................................................................................................................35 TABLE 4.2: CAPACITY DEVELOPMENT INDICATORS .....................................................................................................36 TABLE 4.3: ESTIMATED COST FOR ESMF IMPLEMENTATION OF THE LGCRRP ............................................................37 TABLE 5.1: SUMMARY OF CONSULTATION MEETINGS ................................................................................................40 TABLE 5.2: FUTURE CONSULTATION GUIDELINE .........................................................................................................42 TABLE 5.3: GRC MEMBERSHIP AT LOCAL/SITE LEVEL ..................................................................................................46 List of Figures FIGURE 4.1: INSTITUTIONAL STRUCTURE FOR ESMF IMPLEMENTATION ....................................................................27 FIGURE 4.2: DIAGRAM: IMPACT ASSESSMENT PROCESS .............................................................................................29 LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Chapter 1: INTRODUCTION 1.1 Background The Government of Bangladesh (GoB) through the Ministry of Local Government, Rural Development and Cooperatives (MLGRD&C) has requested financing from the International Development Association (IDA) of the World Bank Group (WBG) to support the preparation and implementation of the Local Government COVID-19 Response & Recovery Project (LGCRRP, the Project) through the Local Government Division (LGD), to strengthen the response and recovery effort of urban local government institutions (ULGIs) to the COVID-19 pandemic in Bangladesh. The project finance from the World Bank is expected through Investment Project Financing (IPF) on IDA terms. The LGD will have overall responsibly for the implementation of project activities including fiduciary management and environmental and social (E&S) compliance for all the components and sub-components. The project will support all urban LGIs of Bangladesh including 329 Pourashavas (PSVs), with a total population of approximately 20.2 million, and 10 City Corporations (all except Dhaka North and Dhaka South), with a total population of another approximately 10.35 million. The LGCRRP will provide financial resources and capacity support to urban LGIs to: (i) ensure continuity of basic urban services; (ii) ramp up local level COVID-19 responses in services, health, jobs and livelihoods, community outreach and awareness, and local economic development; (iii) mobilize and coordinate across various agencies operating at the local level; (iv) strengthen pandemic and disaster response systems. It will strengthen the Government of Bangladesh’s pandemic response and recovery by: (i) directing scarce resources to critical COVID-19 hotspots, which are typically in dense urban settlements, especially targeting the urban poor, migrant workers, and vulnerable demographic groups; (ii) ensuring coordination and bringing synergies between national, sectoral, and local level initiatives; and (iii) providing a continuum between immediate emergency responses and short to medium term recovery. The World Bank Environmental and Social Framework (ESF) will apply to the LGCRRP in addition to national legislative requirements on environmental and social management. This Environmental and Social Management Framework (ESMF) has been prepared as per requirements of the applicable legal and policy framework of the Government of Bangladesh and the World Bank. 1.2 Purpose of the ESMF The ESMF is intended to be used as a practical tool during formulation, design, implementation, and monitoring of components and sub-components of this project. This document will be followed during project preparation and implementation for ensuring environmental and social integration in planning, implementation, and monitoring of project supported activities. For ensuring good environmental and social management in the proposed LGCRR project, the ESMF will provide guidance on pre-investment works/studies (such as environmental and social screening, environmental and social assessment, environmental and social management plans, etc.), provide set of steps, processes, procedures, and mechanisms for ensuring adequate level of environmental and social consideration and integration in each investment in the project-cycle. The document describes the principles, objectives, and approaches to be followed to avoid, minimize, or mitigate adverse impacts. The ESMF will facilitate compliance with the Government of Bangladesh’s policies, acts and rules as well as with the World Bank’s environmental Environmental and Social Management Framework 2 and social standards (ESSs) of the Environmental and Social Framework (ESF), and guide to prepare and conduct the detailed ESA/IEE/ESIAs/ESMPs of the later stages of the LGCRRP as appropriate to the project components/sub-components. 1.4 Project Description The objective of the project is to strengthen the capacity of the urban local governments’ response to the COVID-19 pandemic and preparedness for future shocks. The objective captures two important time dimensions: firstly, the immediate term, characterized by the need for ULGIs to better respond to and recover from the COVID-19 pandemic and its impact on urban populations; secondly, in the medium-to- long-term, when ULGI capabilities will need to be reinforced in order to more effectively prepare for future shocks similar to COVID-19 pandemic including disease outbreaks, disasters, and climate change impacts. Phasing and scope: The project will focus primarily on bridging the COVID-19 response gaps at the local level. In the short to medium term, it will support recovery and resilience by urgently addressing critical gaps in local health services, basic services delivery, especially those related to safety, health and wellbeing of affected communities and localities (e.g. water supply, wastewater, solid waste, rehabilitation of health and community facilities, ensuring COVID-19 safety in markets), with a strong emphasis on poorer neighborhoods (informal settlements, migrant worker housing, etc.) and disproportionately affected population groups (garment workers, women and children, differently-abled, etc.), as well as providing strong local level coordination and facilitation mechanisms for a broad range of institutional and community stakeholders working on COVID-19 response at the local level. Rehabilitation and development of essential services, as well as infrastructure and economic assets will be supported through labor intensive methods to support job creation and economic recovery. In the medium to long term, the Project will support pandemic and disaster preparedness, improving local resilience and capacity to manage crises. Provision of block grants: The project will address critical and evolving service delivery, livelihood and employment generation needs through the provision of COVID-19 Response Grants (CRGs) to local governments. Robust fiscal transfer and monitoring systems already exist (supported through the Local Governance Support Program 1 ) to efficiently channel resources to urban local governments and to monitor results on the ground rapidly. A first grant will be made available soon after project effectiveness to cover emergency needs and to plan for COVID-19 response and recovery actions. The grant will be supplemented with technical assistance. Multisectoral coordination and preparation of Local COVID Response and Recovery Plans: The proposed project will ensure complementarity with ongoing sectoral COVID-19 response interventions targeting individuals and households needs. ULGIs will establish local COVID Response Committees and prepare Local COVID Response and Recovery Plans, building on their role in providing critical physical, social and institutional infrastructure and services to meet communities’ health, food, and jobs needs, but also to effectively coordinate recovery and resilience efforts. Based on the Local COVID Response and Recovery 1Three consecutive phases of Local Government Support Program (LGSP) have successfully established formula-based block grants (BGs) to all Union Parishads (UPs) in Bangladesh. Currently LGSP 3 (P159683), a $300 million IPF, is ongoing supporting 4,543 Union Parishads (rural municipalities). Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 3 Plans, labor-intensive works will target low-income and most vulnerable urban households, ensuring COVID-sensitive implementation. Timeline and adaptive learning: The project is expected to be implemented over a period of four fiscal years, starting from FY 2021-22. It will consist of three components. Procedures for components 1 and 2 will be detailed in a Project Operations Manual (POM), which will be made available to all eligible ULGIs, as well as to other national and sub-national stakeholders. A separate POM will describe procedures for component 3 (CERC). A mid-year review is planned after three grant cycles based on the results from operational audit, progress status, COVID situation and performance of ULGIs in managing the grants to assess scope and geographical coverage of the remaining grants. Gender: The project will support women’s employment opportunities as well as enhancing their voice and agency. On the employment side, the project will ensure that livelihood and employment initiatives supported through the block grants target women workers and include training and skills development for women. With regards to voice and agency, the project will facilitate women’s participation in local COVID response plans and increase the availability and access to GBV service providers. 1.5.1 Project Components Component 1: Covid-19 Response Grants (US$275 million). Through Component 1, the Project will provide eligible and qualifying ULGIs with CRGs over a period of four fiscal years (FYs 21/22, 22/23, 23/24, and 24/25). Annual grant allocations will be disbursed on a six-monthly basis, with each eligible ULGI being potentially able to qualify for six 6-monthly grant disbursements over the project period. COVID-19 Response Grants (CRGs) will be used by qualifying ULGIs to finance activities that are intended to respond to the COVID-19 pandemic, for emergency response, relief, socioeconomic recovery, and preparedness to future disease outbreak, disasters, and climate change impacts. Qualifying ULGIs will be able to use their grants to fund a range of expenditures, grouped into four main pillars, consistent with the prioritization strategy outlined in the CRRPs: Health interventions aimed at saving lives (Pillar 1), Labor Intensive Public Works (Pillar 2), and Local economic development and preparedness to future shocks (Pillar 3 and 4). Expenditures with potential negative social or environmental impacts including with the Activities requiring land acquisition or resettlement and Activities with significant environmental impacts, including those that significantly increase greenhouse gas emissions are included in the negative list for funding. Component 2: Implementation and capacity building support, digital technology, and project management (US$25 million). Through Component 2, the Project will finance activities aimed at strengthening ULGIs’ medium-long term preparedness to shocks similar to COVID-19 and crisis-disaster response capacities. All ULGIs in the country will be covered by Component 2, including Dhaka North and Dhaka South City Corporations (which will receive support through this Component to strengthen their preparedness for future shocks). Support to ULGIs will also include basic capacity building inputs to ULGIs, aimed at ensuring that ULGIs are able to meet MC requirements. Support for the use and application of digital technology will cut across Component 2 activities, aimed at strengthening overall ULGI and Project performance in the immediate and medium to long terms. Sub-component 2.1: Implementation and capacity building support (US$ 17 million). Sub-component 2.1 will aim to assist ULGIs in: (a) implementing actions in response to the ongoing COVID-19 pandemic and its consequences; (b) strengthening their capacity to be prepared for future shocks including pandemics, disasters and climate change impacts; and (c) digital technology improvements. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 4 Sub-component 2.2: Project management and implementation support. Through Sub-component 2.2, LGCRRP will provide resources for project management and implementation support. At the national level, the PMU will ensure overall project management; at the sub-national level, Regional Support Centers (with guidance and support from the PMU) will coordinate project activities in their respective Divisions and provide ULGIs with technical backstopping and quality assurance. Component 3: Contingency Emergency Response Component (CERC). This CERC is included under the project in accordance with OP 10.00, paragraphs 12 and 13, for situations of urgent need of assistance. This will allow for rapid reallocation of Project proceeds in the event of a natural or man-made disaster or crisis that has caused or is likely to imminently cause a major adverse economic and/or social impact. To trigger this component, the Government needs to declare an emergency or provide a statement of fact justifying the request for the activation of the use of emergency funding. To allocate funds to this component, the Government may request the World Bank to reallocate project funds to support response and reconstruction. 1.5.2 Project Beneficiaries Project beneficiaries will include: (a) the residents of the eligible ULGIs, who will be expected to benefit directly from the various activities funded through CRGs. Component 1 will benefit 30.55 million residents of 329 Pourashavas and 10 City Corporations; and (b) Component 2 will benefit 329 Pourashavas and 12 City Corporations, which will be expected to become more capable of responding to health-related crises, disasters and climate shocks (benefiting 39.90 million urban residents).. 1.6 Approach and Methodology of the ESMF The ESMF has been prepared following the standard methodology consisting of the steps listed below. o Review of the program details and meeting/discussions with the IA and ULGIs. o Review of the policy and regulatory requirements. o Conduct reconnaissance field visit by groups of experts of WB and LGSP-3 team (responsible for preparing the project on behalf of LGD) and initial scoping and screening to determine the key environmental and social parameters and aspects that are likely to be impacted by the program activities. o Collect and analyze baseline environmental and social data with the help of secondary literature review and field data collection. o Consult with the stakeholders including beneficiary/affected communities and developing the consultation process. o Assess the potential and likely impacts of the project activities. o Prepare an outline of the environmental and social management issues according to the requirements of the 10 ESSs of the ESF. o Collecting E&S related basic information from selected Pourashavas through sending checklists electronically. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Chapter 2: LEGAL, REGULATORY AND POLICY FRAMEWORK 2.1 National Environmental and Social Policy, Legal and Regulatory Framework Key applicable national policies, strategies, plans, acts, rules and regulations laid out by the Government of Bangladesh in the following list. However, their key provisions, purpose, and relevance to the LGCRRP pertaining to the environment and social aspects are briefly discussed in Annex 5. • Bangladesh Environmental Conservation Act (ECA), 1995; Amendments in 2010 • Bangladesh Environmental Conservation Rules (ECR), 1997 • Bangladesh Environment Court Act, 2010 • National Environmental Management Action Plan (NEMAP), 1995 • National Environmental Policy, 1992 • The Noise Pollution Control Rules, 2006 • Bangladesh Biosafety Guideline 2007 • Bangladesh Climate Change Strategy and Action Plan (BCCSAP), 2009 • National Adaptation Program of Action (NAPA), 2005 • Bangladesh Medical Waste Management and Processing Rules 2008 • Bangladesh Labor Act, 2006, (as amended 2018) • Bangladesh Labor Rules, 2015 • Bangladesh Child Labor Mitigation Policy, 2010 • Bangladesh National Building Code, 2006 • Bangladesh Wildlife (Protection and Preservation) Act 2012 • The Communicable Diseases (Prevention, Control and Eradication) Act, 2018 • Acquisition and Requisition of Immovable Property Act, 2017 • CHT (Land Acquisition) Regulation, 1958 (as amended 2019) • The East Bengal State Acquisition and Tenancy Act 1950 (Act XV of 1951) • National Agriculture Policy, 1999 • The Water Supply and Sanitation Act (1996) • National Land Use Policy, 2001 • National Livestock Development Policy, 2007 • National Policy for Safe Water Supply and Sanitation, 1998 • Embankment and Drainage Act, 1952 • National Water Management Plan, 2001 (Approved in 2004) • Bangladesh Water Act, 2013 • National Water Policy, 1999 • The Ground Water Management Ordinance (1985) • Road Transport Act, 2018 • The Antiquities Act (1968) • National Fisheries Policy, 1998 • The Protection and Conservation of Fish Act (1950) • Protection and Conservation of Fish Rules (1985) Environmental and Social Management Framework 6 Other than the above, due to ongoing COVID-19 pandemic, World Health Organization (WHO) and Directorate General of Health Services (DGHS), under the Ministry of Health and Family Welfare, provided guidelines for infection prevention and control. The government has incorporated the life-threatening novel corona virus (COVID-19) in 'The Communicable Diseases (Prevention, Control and Eradication) Act, 2018’. With the notification of the gazette the government has a legal basis to take action against the people not following the government’s direction that relates to COVID 19. Health and safety issues relevant to COVID-19 should be addressed with reference to ILO Occupational Safety and Health Convention, 1981 (No. 155), ILO Occupational Health Services Convention, 1985 (No. 161), ILO Safety and Health in Construction Convention, 1988 (No. 167), WHO International Health Regulations, 2005, WHO Emergency Response Framework, 2017. Female labor, vulnerable groups’ labor (e.g. persons with disabilities) are covered under this domestic legislation. 2.2 Applicable International Treaties Signed by the GoB Bangladesh has signed most international treaties, conventions and protocols on environment, pollution control, bio-diversity conservation and climate change, including the Ramsar Convention, the Bonn Convention on Migratory Birds, the Rio de Janeiro Convention on Biodiversity Conservation, and the Kyoto Protocol on Climate Change. • Protection of birds (Paris) • Ramsar Convention • Protocol on Waterfowl Habitat • World Cultural and Natural Heritage (Paris) • Bonn Convention • Prevention and Control of Occupational hazards • Occupational hazards due to air pollution, noise & vibration (Geneva) • Occupational safety and health in working environment (Geneva) • Occupational Health services • Convention on oil pollution damage (Brussels) • Civil liability on transport of dangerous goods (Geneva) • Safety in use of chemicals during work • Convention on oil pollution • UN framework convention on climate change (Rio de Janeiro) • Convention on Biological Diversity (Rio de Janeiro) • International Convention on Climate Changes (Kyoto Protocol) • Indigenous and Tribal Populations Convention • ILO Convention No 29 on Forced Labor • ILO Convention no. 182 on Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 7 • Migrant Workers (Supplementary Provisions) Convention • Convention on the Elimination of All Forms of Discrimination Against Women 2.3 World Bank’s Environmental and Social Framework Since October 2018, all World Bank funded Investment Project Financing (IPF) are required to follow the Environmental and Social Framework (ESF) consisting of ten (10) Environment and Social Standards (ESSs). These ESSs set out their requirement for the LGCRRP implementing agencies relating to the identification and assessment of environmental and social risks and impacts associated with any project. The ESSs support the IAs in achieving good international practice relating to environmental and social sustainability, assist them in fulfilling their national and international environmental and social obligations, enhance transparency and accountability and ensure sustainable development outcome through ongoing stakeholder engagement. The ESF sets out its commitment to sustainable development, through Bank Policy and a set of Environmental and Social Standards that are designed to support LGCRRP, with the aim of ending extreme poverty and promoting shared prosperity. The part of Bank’s Environmental and Social Policy for investment project financing sets out the requirement that the World Bank must follow regarding projects it supports through Investment Project Financing. Table 2.1 summarizes the ESS requirements and their relevance to the LGCRRP components: Table 2.1 WB ESS requirements and relevance to the LGCRRP World Bank ESS Objectives Relevance & Extent of Relevance to Policy, Standards, the sub-project/project Directive World Bank It sets out the mandatory requirements of Applicable to the LGCRRP and it’s all Environment and the Bank in relation to the projects it activities Social Framework supports through Investment Project (ESF) for Financing. The types of E&S risk and Investment Project impacts that should be considered in the Financing environmental and social assessment. The required E&S management plan as well as the use and strengthening of the Borrower’s environmental and social framework for the assessment, development and implementation of World Bank financed projects where appropriate. ESS-1 Identify, assess, evaluate, and manage Relevant. ESMF has been prepared. Assessment and environment and social risks and impacts Detailed IEE/ESIA and ESMP will be Management of in a manner consistent with the ESF. Adopt prepared in addition to this ESMF, Environmental and differentiated measures so that adverse where required. Social Risks and impacts do not fall disproportionately on Impacts the disadvantaged or vulnerable, and they are not disadvantaged in sharing development benefits and opportunities LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 8 World Bank ESS Objectives Relevance & Extent of Relevance to Policy, Standards, the sub-project/project Directive ESS-2 Promote safety and health at work. Relevant. A separate LMP has been Labor-and- Promote the fair treatment, non- prepared, in addition to other site- Working- discrimination, and equal opportunity of specific management plans need to be Conditions project workers. Protect project workers, prepared during construction phase. with particular emphasis on vulnerable workers. Prevent the use of all forms of forced labor and child labor. Support the principles of freedom of association and collective bargaining of project workers in a manner consistent with national law. Provide project workers with accessible means to raise workplace concerns. ESS-3 Promote the sustainable use of resources, Relevant. With respect to Resource Resource- including energy, water, and raw materials. Efficiency, the site specific ESMP will Efficiency-and- Avoid or minimize adverse impacts on identify feasible measures for efficient Pollution- human health and the environment caused (a) energy use; (b) water usage and Prevention-and- by pollution from project activities. Avoid management to minimize water usage Management or minimize project-related emissions of during construction/ renovation, short and long-lived climate conservation pollutants/greenhouse gases. Avoid or minimize generation of hazardous and non-hazardous waste. Minimize and manage the risks and impacts associated with pesticide use. Requires technically and financially feasible measures to improve efficient consumption of energy, water, and raw materials, and introduces specific requirements for water efficiency where a project has high water demand. ESS-4 Anticipate or avoid adverse impacts on the Relevant. In the LGCRRP there is likely Community- health and safety of project-affected to be i) use of vibratory equipment, Health-and-Safety communities during project life cycle from construction debris handling and routine and non-routine circumstances. disposal etc. during construction; ii) Promote quality, safety, and climate high likelihood of direct exposure to change considerations in infrastructure increased construction related traffic design and construction, including dams. and equipment especially on campus Avoid or minimize community exposure to traversing settlement area with limited project-related traffic and road safety risks, carriageway/roadway width, and diseases and hazardous materials. Have in sensitive receptors such as schools, place effective measures to address religious place, health emergency events. Ensure that center/hospitals; iii) high dust levels, safeguarding of personnel and property is high noise and emission level in carried out in a manner that avoids or construction sites; iv) expansion of minimizes risks to the project-affected medical service and those operation communities. may cause potential waste generation; and v) influx of skilled migrant workers Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 9 World Bank ESS Objectives Relevance & Extent of Relevance to Policy, Standards, the sub-project/project Directive could potentially cause local discomfort or potential conflicts with local people and pose GBV/SEA/SH risk. Site specific management plans will be developed following the guideline of ESMF. ESS-5 Avoid or minimize involuntary Project will not involve in any kind of Land-Acquisition- resettlement by exploring project design land acquisition/requisition. So, no Restrictions-on- alternatives. Avoid forced eviction. separate RAP/RPF is required for Land-Use-and- Mitigate unavoidable adverse impacts LGCRRP. Involuntary- from land acquisition or restrictions on Resettlement land use by providing compensation at replacement cost and assisting displaced persons in their efforts to improve, or at least restore, livelihoods and living standards to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is higher. Improve living conditions of poor or vulnerable persons who are physically displaced, through provision of adequate housing, access to services and facilities, and security of tenure. Conceive and execute resettlement activities as sustainable development programs. ESS-6 Protect and conserve biodiversity and Not relevant since the project location Biodiversity- habitats. Apply the mitigation hierarchy is not expected to affect any Conservation and the precautionary approach in the biodiversity or habitat. design and implementation of projects that could have an impact on biodiversity. To promote the sustainable management of living natural resources. ESS-7 Ensure that the development process Not relevant to the LGCRRP, given that Indigenous- fosters full respect for affected parties’ the project will be implemented in Peoples human rights, dignity, aspirations, identity, urban (City Corporation and culture, and natural resource-based Pouroshovas) setting, it is unlikely that livelihoods. Promote sustainable small ethnic minorities present in the development benefits and opportunities in project areas meeting the criteria a manner that is accessible, culturally mentioned in ESS7 will be affected. appropriate and inclusive. Improve project design and promote local support by establishing and maintaining an ongoing relationship based on meaningful consultation with affected parties. Obtain LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 10 World Bank ESS Objectives Relevance & Extent of Relevance to Policy, Standards, the sub-project/project Directive the Free, Prior, and Informed Consent (FPIC) of affected parties in three circumstances. Recognize, respect and preserve the culture, knowledge, and practices of Indigenous Peoples, and to provide them with an opportunity to adapt to changing conditions in a manner and in a timeframe acceptable to them. ESS-8 Protect cultural heritage from the adverse This project is unlikely to adversely Cultural-Heritage impacts of project activities and support its affect any cultural heritage. However, preservation. Address cultural heritage as the ESMF includes a Chance Finds an integral aspect of sustainable Procedures to illustrate the course of development. Promote meaningful action to be taken in case any culturally consultation with stakeholders regarding significant objects/practices are cultural heritage. Promote the equitable discovered sharing of benefits from the use of cultural heritage. ESS-9 Sets out how Financial Intermediaries (FI) Not relevant as there is no financial Financial- will assess and manage environmental and intermediary involved. Intermediaries social risks and impacts associated with the subprojects it finances. Promote good environmental and social management practices in the subprojects the FI finance. Promote good environmental and sound human resources management within the FI. ESS-10 Establish a systematic approach to A separate SEP has been prepared to Stakeholder- stakeholder engagement that helps address ESS10. Engagement-and- Borrowers identify stakeholders and Information- maintain a constructive relationship with Disclosure them. Assess stakeholder interest and support for the project and enable stakeholders’ views to be taken into account in project design. Promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life-cycle. Ensure that appropriate project information is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner. Environmental and This Directive applies to the Bank and sets Applies to Bank in addressing E&S Social Directive for out the mandatory requirements for the aspects of this project Investment Project implementation of the Environmental and Financing Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 11 World Bank ESS Objectives Relevance & Extent of Relevance to Policy, Standards, the sub-project/project Directive Social Policy for Investment Project Financing (IPF). Bank Directive This Directive establishes directions for Applies to Bank in addressing E&S risks Addressing Risks Bank staff regarding due diligence and impacts on disadvantaged and and Impacts on obligations relating to the identification of, vulnerable persons or groups that are Disadvantaged or and mitigation of risks and impacts on, identified in this project area. Vulnerable individuals or groups who, because of their Individuals or particular circumstances, may be Groups disadvantaged or vulnerable World Bank’s The document provides guidelines to Applicable to all activities of project, as Guidance note on address issues and risks arising from influx civil works are envisaged in the sub- managing the risks of migrant labor leading to gender-based projects by ULGIs. However, risks of of adverse impacts violence, forced labor etc. especially GBV/SEA/SH will be low due to the use on communities focusing on Sexual Exploitation and Abuse of local workers. from temporary (SEA) and Sexual Harassment (SH) in civil project induced works sites. labor influx, 2016 ESF/Safeguards This note was issued on April 7, 2020 and Applicable to all activities of project Interim Note: includes links to the latest guidance as of during COVID-19 pandemic. Covid-19 this date (e.g. from WHO). Given the considerations in COVID-19 situation is rapidly evolving, construction/civil when using this note it is important to works projects check whether any updates to these external resources have been issued. This interim note is intended to provide guidance to teams on how to support Borrowers in addressing key issues associated with COVID-19 and consolidates the advice that has already been provided over the past month. As such, it should be used in place of other guidance that has been provided to date. General EHS The General EHS Guidelines contain Yes Guidelines, April information on cross-cutting 2007, IFC environmental, health, and safety issues potentially applicable to all industry sectors EHS Guidelines for The EHS Guidelines contain the Yes Construction performance levels and measures that are Materials considered to construction materials Extraction, April extraction activities such as aggregates, 2007, IFC limestone, slates, sand, gravel, clay, gypsum, feldspar, silica sands, and quartzite LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 12 2.4 Gap Analysis of World Bank Requirements and National Laws A gap analysis between WB’s ESSs and GoB Regulations was conducted as part of the E&S capacity assessment of the LGCRRP. The results of the gap analysis indicated that the E&S risk assessment and management system for development projects in Bangladesh is open-ended but just like other country's EIA systems, does not cover all the World Bank ESF's E&S Standards. The ECA/ECR does not even define the scope of the EIA study (or the IEE), leaving it to the EIA to determine the scope through initial assessment/screening. The coverage of the EIA study therefore would depend on the expertise of the EIA team or the DoE reviewers. There is no assurance that each E&S Standard (1-8 and 10) are considered in the EIA study and the formulation of the ESMP. Although the EIA is heavy towards the environmental aspects, more and more social issues are incorporated in the assessment. Moreover, the practice under normal circumstances does not include labor management issues. Another critical gap pertains to lack of provisions for requiring the preparation of project-specific E&S management plans. The eminent domain land acquisition system for example does not require the preparation of RAP. The projects are also not required to formulate their own Labor Management Procedures/Plans. Given the gaps, this ESMF will follow the most stringent standards and requirement. Table 2.2 below has given an overview of the gaps between GoB laws and WB’s ESSs and steps suggested to address those gaps. Table 2.2: Gaps between GoB laws and World Bank ESSs those applicable to the LGCRRP WB ESF Standard Gaps Gap Minimization ESS1: Assessment and (i) IEE/ESIA study screening and scoping do ESMF has suggested to follow the Management of not guarantee coverage of all ESS standards ESS1 requirements, given in the Environmental and in the assessment. relevant sections of Environmental Social Impacts and (ii) The stakeholder engagement during the Management Procedures. Risks conduct of the IEE/ESIA is limited and the In case, DoE rules/regulations do IEE/ESIA report is not disclosed. not cover the ESS requirements, (iii) The IEE/ESIA system in Bangladesh does relevant clauses should be added in not require analysis of alternatives. the Financial Agreements and Project Appraisal Document to follow the more stringent E&S requirements according to WB ESF. ESS2: Labor and (i) The Labor Act does not specifically A separate LMP has been prepared. Working Conditions require that development be assessed and Guideline for developing Site reviewed in terms of labor and working Specific Labor Management plans conditions including OHS requirements including OHS has been included in before approval. the LMP. (ii) The Labor Act does not require development projects to prepare Labor Management Plans/Procedure or OHS Plan. ESS3: Resource Existing energy and water conservation ESMP to be developed for LGCRRP Efficiency and Pollution policies, laws and regulations do not components will address this issue, Prevention and require development projects to assess and incorporate mitigation Management resource efficiency issues and incorporate measures for efficient use of water resources. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 13 WB ESF Standard Gaps Gap Minimization resource efficiency measures in their E&S risk management plans. ESS4: Community Covered under IEE/ESIA but the systems do Guideline for Community Health Health and Safety not provide clear requirements for the Safety has been addressed this development project and implementation. ESMF. Health issues are within the purview of MoHFW, which would be engaged in COVID-19 health management activities by the ULGIs under the LGCRRP. ESS10: Stakeholder The ECA/ECR does not specifically require A separate SEP has been prepared. Engagement and consultation but the IEE/ESIA guidelines In addition, guideline for Information Disclosure issued by DOE and other agencies stakeholder’s engagement recommends public consultations during provided in this ESMF will be scoping and the preparation of the followed. IEE/ESIA. There is also no provision for any stakeholder engagements during project implementation 2.5 Application of GoB Policies, Acts and Rules on LGCRRP components and their Classification The legislations relevant for environmental assessment for LGCRRP components are the Environmental Conservation Act 1995 (ECA'95) and the Environmental Conservation Rules 1997 (ECR'97). In order to set an illustrative directive for abiding by the act, Bangladesh Government through the Environmental Conservation Rules ’1997 and its subsequent amendments, as specified in rule 7(2), present a categorization of all the potential industrial interventions or projects into four distinct types- Green, Orange A, Orange B and Red, considering the site of the interventions and impact on the environment. The procedure and required documents for obtaining environmental clearance in favor of each category have also been presented by the DoE. As part of a government entity, LGD and PMU of the LGCRRP is obliged to abide by all these acts and rules, in addition of other GOB acts, rules or guidelines. As per ECR’97, most the components/sub-components and associated activities are likely to fall ranging under either Orange A or Orange B as has no such significant impact on the surrounding environmental and social components, likely to have localized and reversible environmental and social impacts demands IEE, and only a few demands advance level EA like ESIA. It is suggested that the project should conduct screening for all activities/schemes at the initial stage and based on screening result, and if recommended by DoE, further IEE or ESIA should be carried out for specified activities. It is the responsibility of the PMU/LGD at the national level and PIU/ULGIs (grantees) at the local level to conduct Screening, IEE and ESIA (if required) of the project activities, the responsibility to review IEE and ESIA for the purpose of issuing Environmental Clearance Certificate rests on DoE. The Department of Environment (DoE), the technical arm of the Ministry of Environment, Forests and Climate Change (MoEFCC) is the regulatory body and the enforcement agency of all environmental related activities. Like all other projects, this project also needs to meet the requirement of the DoE. The procedures for “Orange A and Orange B� Category include submission of: • An Initial Environmental Examination (IEE), and LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 14 • An Environmental and Social Impact Assessment (ESIA), if prescribed by DoE, and • An Environmental and Social Management Plan (ESMP) Environment clearance must be obtained by the respective implementing agency or project proponent (private sector) from Department of Environment (DoE). The environmental clearance procedure for Orange-A and Orange-B Category projects can be summarized as follows: Application to DoE→Obtaining Site Clearance→Applying for Environmental Clearance→Obtaining Environmental Clearance→Clearance Subject to Annual Renewal. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Chapter 3: POTENTIAL KEY ENVIRONMENTAL AND SOCIAL RISKS 3.1 Impact Assessment and Prediction A preliminary categorization of the project components/sub-components based on their environmental assessment requirement is given in Table 3.1 following the new WB ESF/10 ESSs. Table 3.1: Categorization of LGCRRP Activities Based on Key Predicted Impacts A. Component 1: Covid-19 Response Grants, Sub-components: N/A Pillar Purpose Indicative activities/investments Predicted Impacts Pillar 1: Saving (a) Stopping Provision of community hand - Impact on health and safety lives COVID washing stations, climate resilient of the workers and transmission; public toilets; sanitization, cleaning, communities To be coordinated and masks in municipality operated - Impact on, women and with other markets, burial grounds and disadvantaged groups stakeholders (e.g. crematoriums, schools, and public - Impact on waste generation, public health offices management and disposal departments) (b) ensuring Community awareness programs on - Impact on health and safety health service COVID protocols, vaccines, climate of the workers and delivery; change and health risks communities - Impact on women and disadvantaged groups - Impact on disposing accidental chemical and medical waste (c) protecting Improved access and provision of - Impact on health and safety vulnerable climate resilient municipality of the workers and households’ operated health clinics, support for communities access to vaccine distribution and community - Impact on women and preventive and counselling including GBV services disadvantaged groups essential health especially in low-income areas, - Impact on household waste services slums and high-risk areas exposed to generation and waste disease outbreak and climate change management impacts Environmental and Social Management Framework 16 Pillar Purpose Indicative activities/investments Predicted Impacts Pillar 2: Protecting Operations & maintenance schemes - Impact on land the poor and Provision of to ensure essential public service - Impact on air, water vulnerable essential services delivery/ infrastructure/-facilities - Impact on homestead/local & paid (e.g. water supply, sanitation, biodiversity employment for drainage, public parks, cleaning, and - Impact on livelihoods poor and streetlights), especially in low - Impact on health and safety vulnerable income, slums, and high-risk areas of the workers and exposed to disease outbreaks/ communities climate change impacts.2 - Impact on women and Labor-intensive public works (LIPWs) for repair and construction schemes disadvantaged groups ensuring that public works are pro- - Impacts on women mobility poor and inclusive of gender. The - Risk of GBV identification, registration and - Increase of vulnerability verification of beneficiaries for - Climate risk including LIPWs will be coordinated with flooding, and drainage relevant national departments. Daily congestion, green house wages will be based on national and gages emission, local rates. - Impact on waste generation, management and disposal. Pillar 3: Ensuring Local economic Upgrading/rehabilitating to climate/ - Impact on land sustainable development and health resilient standards - - Impact on air, water business growth & recovery from wet/informal food markets, local - Impact on livelihoods job creation COVID-19 industrial parks, special economic - Impact on health and safety impacts zones including access infrastructure of the workers and such as separate toilets for women, communities and child-care facilities3 - Impact on waste generation, Information Communication management, and disposal Technology (ICT) network and digital technology (for improving ULGI functioning, surveillance of climate/health risks) Pillar 4: Institutional, Municipal revenue generation and - Potential risks of Strengthening Disease outbreak, collection improvements. discrimination to policies, Disaster/Climate Measures to improve emergency disadvantaged and Preparedness institutions and response, including actions vulnerable communities, investments identified in local Preparedness groups and individuals Plans. including women Climate and flood proofing - Medical and e-waste municipality operated health clinics generation and schools, use of renewable energy (solar/ wind) to manage power disruptions. Investment and Use of Consultant services, incremental N/A activity servicing consultants and operating costs 2 New infrastructure and facilities or any upgrading and rehabilitation will consider: (i) disaster and climate risks to build resilience from disasters and climate impacts; and (ii) inclusive development targeting low-income areas and high risk communities to develop safe spaces and facilities for women, children and disable population. 3 Ibid. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 17 Pillar Purpose Indicative activities/investments Predicted Impacts costs (up to a other inputs for maximum of 5% planning, design, of CRG allocation) costing and supervision of interventions B. Component 2: Implementation and capacity building support, digital technology and project management, Sub-components: N/A Sub- Activities/Specific tasks Predicted Impacts components Sub-component COVID-19 response & recovery support to - Impact on land 2.1. ULGIs: - Impact on air, water Support for • Compliance with Minimum Conditions - Impact on homestead/local strengthening • COVID-19 response and recovery biodiversity ULGI COVID-19 planning - Impact on livelihoods response, • health interventions - Impact on health and safety of the recovery and • Labor Intensive Public Work planning, workers and communities resilience implementation and supervision - Impact on women and • Infrastructure & service delivery disadvantaged groups support (engineering) - Impacts on women mobility • project cycle and project management - Risk of GBV (project planning, budgeting, management, safeguards, - Increase of vulnerability procurement, M&E, coordination and - Climate risk including flooding, and reporting) drainage congestion Impact on • Digitalization of payments systems (for waste generation, management and public works) disposal • Health information technologies/web- - portal Medium to-long term support to N/A strengthen resilience: • own-source revenues • Pandemic and disaster preparedness (risk mapping, mitigation planning) • Emergency preparedness and response • Digitalization of property tax administration, own-source revenue management • Risk mapping, digitalization of contingency and DRM plans Sub-component National: N/A 2.2. • Coordination, oversight and supervision Project • ULGI compliance assessments and management and audits implementation • Monitoring & evaluation support • Financial & narrative reporting • Environmental & social management • Procurement LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 18 Sub- Activities/Specific tasks Predicted Impacts components • MIS for core management (FM, planning, etc.) Sub-national: N/A • Coordination and liaison • Backstopping and support in safeguard and fiduciary compliance, M&E, reporting, MIS Monitoring and Evaluation (M&E) N/A C. Component 3: Contingency Emergency Response Component (CERC), Sub-components: N/A Sub- Activities/Specific tasks Predicted Impacts components N/A Not defined, Zero allocation If CERC is triggered, this ESMF will be updated for management of potential impacts of CERC activities. 3.1.1 Projected Environmental and Social Impacts Related to Project Siting Site Specific Land Cover and Land Use Changes Expansion, construction, rehabilitation and refurbishment of facilities including civil works for renovation, rehabilitation, and refurbishment of existing facilities including markets, sanitation facilities, health centers, roads, drainage and waste management, etc. will be limited within existing available land at the local level, and therefore, potential E&S impacts will be only construction related. Loss of trees Siting of potential infrastructures by ULGIs may require cutting of trees and removal of natural/homestead/roadside vegetation. Drainage congestion and water logging Potential infrastructure construction activities can cause drainage congestion and water logging at the local area, if not properly considered the local drainage of runoff. Impacts on Vulnerable and disadvantage groups/communities/individuals The LGCRRP have been designed to provide a holistic support to improve skills and livelihoods of disadvantaged people, youth, women, tribal people, unskilled workers, vulnerable communities, etc. It aims to increase contribution to the economy, poverty reduction, and environmental sustainability through a set of targeted capacity building activities. Its activities targeting disadvantage groups, women etc will create employment through the engagement in labor intensive public works (LIPWs). However, these activities would also have risk of discrimination to the disadvantaged groups due to lack of social policies/standards that ensure equal representation. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 19 Given that the project will be implemented in urban (City Corporation and Paurashavas) setting, the small ethnic minority communities present in some of the project areas do not meet the criteria mentioned in ESS7. The tribal peoples present in some of the target ULGIs are mainstreamed with the urban population accessing all public services equally. 3.1.2 Projected Environmental and Social Impacts during Project Implementation Air Pollution. Civil works of new and existing facilities may generate emissions from excavation equipment, other machinery and construction traffic. The emissions may also include greenhouse gases (GHGs) from engine fuel combustion (exhaust emissions) and evaporation and leaks from vehicles (fugitive emissions) and emissions. The emissions from construction activities will deteriorate the ambient air quality and affect the public health. Noise Pollution. Noise will be produced by vehicular movement, excavation machinery, concrete mixing, and other construction activities. The schools, religious places and crowded market areas adjacent to the construction sites are particularly vulnerable to the increased noise levels. Water Pollution. During the construction/renovation activities ponds/canals/water streams-rivers can potentially cause some localized increase in water turbidity due to poor waste management. However, this increase in turbidity is not likely to have any significant impact on overall water quality and the aquatic fauna primarily because of its temporary and localized nature. The construction camps and other site facilities such as offices and warehouses will also generate considerable quantities of waste effluents. Other possible causes of land or water contamination include accidental leakage or spillage of fuels, oils, and other chemicals, and waste effluents released from construction sites. These effluents can potentially contaminate the drinking water sources of the area and can also be harmful for the natural vegetation, cultivation fields, water bodies, and aquatic flora and fauna. Impacts of Land Filling (at new construction site). Potential impacts that can arise from the proposed construction/ civil works at new sites may involve land filling querying earth from elsewhere. Land filling activity must avoid collection of topsoil from crop fields, hills cuttings and illegal sand mining from riverbeds. Soil Contamination. Much like water pollution discussed above, soils in the construction/ refurbish/ expansion area and nearby lands that are used for agriculture will be prone to pollution from the construction activities, construction yards, workers camps and other construction areas. Fuel and chemical material storage sites and their handling are also the potential sources for soil and water pollution. Improper siting, storage and handling of fuels, lubricants, chemicals materials, and potential spills from these will severely impact the soil and water quality and cause safety and health hazards. Generation of Solid Waste (Including Medical Wastes). Solid waste generated during the construction phase will include excess construction materials such as sand and soil, faulty/damaged parts, metal scraps, cardboard boxes and containers, and cotton swaths from workshops, and domestic solid waste from construction offices and camps. In addition to the above, small quantities of chemical waste will also be generated mainly from the vehicle maintenance activities (liquid fuels; lubricants, hydraulic oils; chemicals, such as anti-freeze; contaminated soil; spillage control materials used to absorb oil and chemical spillages; machine/engine filter cartridges; oily rags, spent filters, contaminated soil, and others). Besides, operation of medical camp, health centers and laboratories would also generate medical wastes. It is imperative LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 20 that such waste is responsibly disposed to avoid adverse environmental, human health and aesthetic impacts. Inappropriate disposal of these wastes can lead to soil and water contamination as well as health hazards for the local communities, livestock, and aquatic as well as terrestrial fauna. Site Clearance and Restoration. After the completion of the construction activities, the left-over construction material, debris, spoils, scraps and other wastes from workshops, and camp sites can potentially create hindrance and encumbrance for the local communities in addition to blocking natural drainage and or irrigation channels. Occupational Health and Safety. Generally, the construction/reconstruction activities may pose health hazards to the workers at site during use of chemicals and fumes, lifting and handling of heavy equipment, operating machinery, and electrical equipment, working near water or at height and more. The project will need fuels, oils, and asphalt during the construction in new campus for model diploma institutes. Inappropriate handling or accidental spillage/leakage of these substances can potentially lead to health hazards for the construction workers as well as the local community. Similar to the above, various construction/renovation/expansion of facilities may cause safety issues including physical injuries and accidental death. This may be increased in absence of proper training of unskilled workers to be engaged. Local community will also be vulnerable to accidental cases starting from minor injuries for careless disposal of chemical and gaseous materials to death for example movement of the heavy machineries and equipment. Similarly, Covid-19 contamination will be an important risk associated with the workers at the construction/renovation/expansion sites. Govt. imposed Covid-19 health safety protocol for workers and WHO’s Covid 19 safety guidelines should be followed to avoid any risk of spreading the virus among associated families/communities. Impacts on Livelihoods and Income. The LGCRRP will have positive impacts on enhancing technical skills and livelihoods of disadvantaged people, youth, women, labours and unskilled workers, vulnerable communities, etc. It will contribute to their income generation and poverty reduction. LGCRRP’s activities targeting disadvantage groups, women, and youth will create employment and enhance job opportunities. Impact on labor, working Conditions and labor risks, including risks of child labor and forced labor. The proposed activities will entail employment of a significant number of people especially during construction/reconstruction/expansion of facilities and labor intensive public works schemes. The majority of labor will be locally hired, with the exception of skilled workers who may not be found in the project areas. Potential risks for the hired skilled and non-skilled workers especially during construction period includes health hazards, poor living condition, accidental hazards risks, etc. Similarly, hiring labor from external area may cause social risk on the local communities includes gender-based violence, price hiking of daily used products/foods, etc. Risks are also associated in-terms of hiring child labors or forced labors, and due to presence of some proposed ULGIs in the border districts, considerable risk is associated to the labor trafficking. However, a separate LMP has been prepared to minimize the risk associated with labor influx. Impact on creating social discrimination for the most disadvantaged groups, vulnerable women/disabled persons. Project has included various activities targeted to uplift the capacity and skill of the disadvantaged groups of the society including vulnerable women, and disabled persons. Promotion of Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 21 entrepreneurs might have negative impact if not designed considering socially inclusive policies. As most of the activities will be decided during project implementation period, there is likelihood of such impacts on most disadvantaged and vulnerable groups, if not actively monitored. 3.1.3 Projected Environmental and Social Impacts during Post Project operational Period Loss of Local Vegetation. Construction of buildings and expansion/renovation of other infrastructures/facilities would increase human access in the existing facilities, which may lead to loss of more vegetation (herbs, shrubs and trees) at the surroundings due to human footprint and have potential impact on local wildlife biodiversity. In such cases of potential impact on plants and wildlife, demands detail baseline survey and implement appropriate natural habitat management activities by the authority. Generation of Medical Waste, Solid Waste and Chemical/Electronic Waste. Solid waste will be generated from during regular operation and maintenance activities of the constructed/renovated infrastructures. Chemical waste will also be generated from different activities, while e-waste may be generated under the digital management. Besides, medical waste would also be generated from the established medical camp and health centers. These wastes if not appropriately disposed of has a potential to contaminate soil and water resources, thus would affect community’s health as well as natural habitat. Standard lab and health safety protocol should be followed (e.g. WHO’s Laboratory and COVID-19 Safety Guidelines) during operation period. Noise Generation. During operation, noise levels along the proposed public works will be increased due to the higher traffic volume and mass people gathering. Traffic noise will be a significant nuisance to the sensitive receptors such as schools and religious places located vary close to the roads and also to the children and aged persons. Water Pollution and Drainage. Generally paved road increases the amount of impermeable surface area, which increases the rate of surface water runoff in the locality. During the operation phase, some localized increase in turbidity may take place during any maintenance works of the constructed/renovated sites. Similarly, the maintenance works can also generate a limited quantity of waste effluents. Impacts on Local Livelihoods. While effort will be exerted for livelihood improvement of the local targeted communities, yet some of the project activities may have reversible and mitigable impacts on them. The probable impacts on income and livelihoods are minor since project will have no involuntary displacement. However, there might be some informal settlers living in the govt. lands during expansion/rehabilitation works. In such cases, respective ULGI will compensate the informal settlers through their own arrangement. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Table 3.2: Summary of Projected Environmental and Social Impacts and their Significance (ESS Risk) Duration of Significance Prior Significance Potential Impacts Spatial Extent Reversible Likelihood Magnitude Sensitivity Impact to Mitigation after Mitigation Impacts related to project siting Land cover and land use Short term Moderate negative Local No Certain Moderate Moderate Low negative changes Loss of trees Short term Local Yes Certain Moderate Moderate Moderate negative None Short term Local but Drainage congestion and beyond Yes Likely Moderate Mild Moderate negative None water logging project footprint Impacts on Vulnerable Short term Local No Likely Moderate Moderate Moderate negative None and disadvantage Impacts during project implementation phase Air pollution Short term Local Yes Certain Moderate Moderate Moderate negative None Noise Short term Local Yes Likely Moderate Moderate Moderate negative None Local but beyond Water pollution Short term Yes Certain Moderate Moderate Moderate negative None project footprint Local but beyond Land Filling Short term No Certain Low Moderate Moderate negative None project footprint Soil contamination Short term Local Yes Certain Moderate Mild Moderate negative None Solid wastes and Short term Local Yes Certain Moderate Mild Moderate negative None hazardous wastes Site clearance and None Short term Local Yes Certain Moderate Mild Moderate negative restoration Occupational health and None Short term Local Yes Certain Moderate Moderate Moderate negative safety Local but beyond Substantial Livelihoods and Income Short term Yes Certain Moderate Moderate Moderate Positive project Positive footprint Environmental and Social Management Framework 23 Duration of Significance Prior Significance Potential Impacts Spatial Extent Reversible Likelihood Magnitude Sensitivity Impact to Mitigation after Mitigation Labor Impacts and risks of Short term Local Yes Certain Moderate Moderate Moderate negative None child labor, forced labor Social discrimination Short term Local Yes Certain Moderate Moderate Moderate negative None Impacts during post project operational period Loss of Vegetation Short term Local No Certain Moderate Moderate Moderate negative None Generation of Medical Waste, Solid Waste and Short term Local Yes Certain Moderate Moderate Moderate negative None Chemical Waste Noise generation Short term Local Yes Likely Low Mild Moderate negative None Water pollution and Short term Local Yes Certain Moderate Moderate Moderate negative None drainage Impacts on local Substantial Short term Local Yes Certain Moderate Moderate Moderate positive livelihoods positive LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 24 Chapter 4: ENVIRONMENTAL AND SOCIAL MANAGEMENT PROCEDURES 4.1 General Principle Due to the nature of some of the proposed project activities under LGCRRP and their potential environmental and social impacts, the project falls under ‘Orange A or Orange B’ category according to ECR, 1997 and also rated as ‘Moderate’ as per the World Bank E&S risk classification, which requires initial E&S screening, in some cases detail IEE, and/or ESIA and execution of environmental and social management plans. Therefore, the ESMF is prepared based on the following principles that can lead the planning and implementation of the project activities. • The PMU/LGD at the national level and PIU/ULGIs at the local level of LGCRRP is responsible for the compliance with national policies, regulations, and World Bank ESSs and Guidelines, as mentioned in this ESMF report. The ESMF will serve as the basis for ensuring E&S compliance. • PMU/LGCRRP is responsible for obtaining environmental clearance from DoE, local government agencies and World Bank as required, PMU will coordinate with the PIU/ULGIs in the process. • IEE, ESIA and ESMP need to be prepared for activities as determined by DoE. In case, requirements of DoE’s ESIA guideline differs from those of WB ESF, the more stringent standards and requirements will apply. • Planning and design of the any additional activities should ensure minimal assessment of cumulative impacts. • Environmentally sensitive areas, cultural heritage sites, restricted or disputed lands (if identified during project implementation) should be handled with appropriate mitigation hierarchy incljding compensation measures during implementation following standard procedures applicable for such sites. In case of cultural heritage sites identified during civil works, securing the area, informing IA, decide on preservation method as per expert opinion and keep the find secret if it is for the interest of the find. • Participation of stakeholders (especially local communities) should be ensured by PIU/ULGIs in planning, implementation, and monitoring of sub-project activities. • PIU/ULGIs and PMU/LGCRRP will ensure appropriate institutional set up for implementing environmental and social management plans and inter-agency coordination. PIU/ULGIs also ensure that bidding documents for construction contractors have specific clauses to ensure implementation of ESMPs, as required. • Contractors to be engaged in construction/renovation/expansion/repair and maintenance workers under the project should be provided with First Aid Kits at camp/work sites with adequate drinking water and sanitation facilities. Worker‘s/crew’s health and safety measures shall be ensured and use of personal protective equipment shall be required. • PIU/ULGIs at the local level and PMU/LGCRRP at the national level will inform project stakeholders about project interventions and its potential impacts on the surrounding environmental and social elements. • In case of triggering the contingent emergency support Component (CERC), PMU/LGCRRP-LGD will update the ESMF to cover the activities supported under the CERC. A list of Positive and Negative activities for CERC component is given in Annex 6. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 25 Subproject activities with the following environmental and social attributes will not be eligible for implementation under this project: o E&S impacts identified in IEE/ESIA categorize the project to substantial or high risk (according to ESF). o Requiring land acquisition, involuntary physical displacement, or result in loss of livelihoods of peoples. o Associate adverse impacts on the small ethnic communities with indigenous status as per the World Bank ESS7. o Associate significant environmental impacts, including those that significantly increase greenhouse gas emissions and impact of natural habitats and biodiversity. 4.2 Project Implementation Arrangement The Local Government Division (LGD) in the Ministry of Local Government, Rural Development and Cooperatives (MLGRD&C) will be responsible for project implementation. LGD will establish a Project Management Unit (PMU), headed by a National Project Director, a senior GoB official deputed by LGD; the NPD will be assisted by two or more Deputies, deputed by LGD. The PMU will have the responsibility for the following core functions: grant administration including disbursement, E&S management, compliance monitoring, monitoring and evaluation, financial and procurement management, and reporting. In addition, the PMU will ensure coordination of project implementation, including supervision of and support for the Regional Support Centers (RSCs). A high-level Project Steering Committee (PSC), chaired by the Secretary LGD, will include members from all relevant ministries and agencies (in sectors such as health, social protection, disaster management, and agriculture) will be set up at the ministry. The PSC will be responsible for strategic discussions and decisions, inter-agency coordination, and overall project monitoring and oversight. The PSC would be expected to meet on a six-monthly basis or on an as-needed basis. The PMU will consist of a team of consultants (reporting to the NPD and Deputy Project Directors). PMU consultants will include specialists to cover the following main areas: (a) ULGIs grants (including CRG allocations and management, ULGIs compliance assessments and audits); (b) ULGIs technical, institutional and capacity building support; (c) ULGIs disaster risk management and crisis response; (d) monitoring, evaluation and reporting (including MIS, ULGIs progress reports, LGCRRP narrative and progress reporting); (e) communications; (f) environmental and social management; (g) procurement; (h) financial management (including ULGIs and project financial reporting). For the implementation of key Component 2 activities, the project will establish Regional Support Centers (RSCs) in each of the eight administrative Divisions of Bangladesh. Each RSC will be staffed by consultants, recruited by the PMU; RSCs will be accountable to the PMU. The RSCs will ensure project coordination with administrative authorities and de-concentrated sector departments within their respective Divisions and backstop all ULGIs within each Division. Within each participating ULGIs, a small Project Implementation Unit (PIU) will be responsible for ensuring that planning, budgeting, implementation, and reporting are undertaken in accordance with LGCRRP procedures. PIUs will consist of regular ULGIs staff, deputed on a part-time basis to coordinate LGCRRP- financed activities at the local level. The PIUs in each ULGIs will ensure that TLCCs engage fully in project activities and play a key role in local-level coordination and in facilitating public engagement and consultations. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 26 4.2.1 E&S Institutional and Implementation Arrangements The PMU in LGD will include a Senior Environmental Specialist, a Senior Social Development Specialist, and a Communications and Citizen Engagement Specialist. The RSCs will also have Environmental and Social Specialist and Community Development Specialist consultants. The PIUs in the ULGIs will be supported for E&S management in subproject processes. Environmental and Social specialists will be full time PMU consultants to monitor ESMF, ESCP, SEP and LMP implementation and ensure compliance with both World Bank and Government E&S requirements. While, deputed staff of PIU will be responsible for E&S compliance and monitoring, ULGIs can spent a portion of the CRG for E&S expertise, if required. Institutional structure for ESMF Implementation has been furnished in Figure 4.1. 4.2.2 Environmental and Social Assessment and Management Process • The environmental and social experts of the PMU/LGCRRP through its regional units i.e. Regional Support Center (RSC) will provide technical backstopping and coordination support to the PIU/ULGIs to perform the environmental and social screening. The relevant experts of RSC and PIU will start the task during the preparatory stage of the project. • If E&S Screening would identify any activities that requires further E&S Assessment, respective PIU/ULGI will engage an independent IEE/ESIA consultant to generate a detail environmental and social baseline of the project, conduct IEE and the ToR for ESIA (if recommended by DoE). • PIU/ULGI will share the IEE report and the ESIA ToR with DoE for Clearance. • PMU/LGCRRP will review and clear screening and environmental assessment reports made by Environmental consultant before submitting for DoE clearance and provide necessary technical inputs. • PMU through RSC/LGCRRP will conduct verification of some screening and assessment through field visit. • RSC through relevant staff of PIU/ULGIs will ensure that environmental considerations are given enough attention, weight, and influence over selection of construction sites and improvement of infrastructures all over the country. • Bid documents will be prepared by the PIU/ULGIs. Environmental and social consultants of RSC will make sure necessary environmental and social clauses are included in the bidding documents and ESMP implementation should be done by Contractors. RSC consultants and PIUs Engineers of the respective ULGI will supervise ESMP implementation and E&S compliance. • All the activities of LGCRRP will follow existing Environmental Code of Practices (ECoPs) prepared under ESMF. • The project will ensure that environmental and social impact assessment addresses all potential environmental and social direct and indirect impacts of the project throughout its life: pre-project, during project and operation stages; and suggest appropriate mitigation measures. If any additional impacts are identified, IEE/ESIAs and ESMP should be reviewed and updated. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 27 Ministry of Local Government, Rural Development and Cooperatives (MoLGRD&C) Project Steering Committee Local Government Division (LGD) Project M&E Project Director Project Management Unit (PMU) Regional Support E&S Safegurds Centers (RSCs) Consultants Project Implementation Units (PIUs) E&S Other Assigned Consultants for Officials of PIU sub-projects ULGIs at District Level TLCCs/ Contractors ULGIs at Community Upazila Level Figure 4.1: Institutional Structure for ESMF Implementation Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 28 Screening. The screening matrix will help to decide the suitability of project activities in that particular site, and the level of Impact Assessment required. During screening, if it is found that the project may create major irreversible damage to the area or may violate an existing rules or regulations, including those generating hazardous waste will be included in the negative list of activities the project will not finance. For instance, any activities that may encroach into an ecologically critical area or a national/ global heritage site will be rejected by the PMU/LGCRRP. PMU/LGCRRP through its RSC experts must confirm that the findings of the screening carried out by the PIU/ULGIs. Moreover, alternative project activities/methods and/or operation will be considered, and the impacts will be assessed to make the project more environment friendly and socially acceptable. A sample screening form has been attached at Annex 1, which will be further developed during the implementation stage. The subproject will be Ineligible for proposed investment if E&S risks and impacts are identified in screening as substantial or high risk. 4.3 Environmental and Social Impact Assessment Initial Environmental Examination (IEE) If any E&S Screening exercise of a particular project activities recommend further E&S Assessment, then the IEE study will be conducted under PIU/ULGIs. However, according to the project planning, the activities those need IEE will be implemented at initial period and must be carried out prior to the actual interventions start. The purpose of the IEE is three folds: (i) to obtain Clearance from DoE and obtaining decision from DoE whether the particular project activities need further assessment such as detail ESIA or not; (ii) provide/finalize the ToR for the ESIA study, if required; and (iii) continue consultations with project stakeholders. Environmental and Social Impact Assessment (ESIA) The purpose of ESIA is to give the environment and people its due importance in the decision-making process by clearly evaluating the environmental and social consequences of the proposed study before action is taken. Early identification and characterization of critical environmental and social impacts allows the public and the government to form a view about the environmental viability and social acceptability of a proposed development project and what conditions should apply to mitigate or minimize those risks and impacts. In the preparation phase, the ESIA shall achieve the following objectives: • To establish the environmental and social baseline in the study area, and to identify any significant environmental issue; • To assess these impacts and provide for measures to address the adverse impacts by the provision of the requisite avoidance, mitigation and compensation measures; • To integrate the environmental issues in the project planning and design; • To develop appropriate management plans for implementing, monitoring and reporting of the environmental mitigation and enhancement measures suggested. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 29 The impact assessment will be conducted using major stages as shown in the following diagram Figure 4.2: Figure 4.2: Diagram: Impact Assessment Process Contingency Plan for COVID-19 LGCRRP will develop a contingency plan following the WHO guidelines and the World Bank requirements for each district to put in place procedures in the event of COVID-19 reaching the area or already there. The contingency plan will be developed in consultation with national and local healthcare facilities, to ensure that arrangements are in place for the effective containment, care and treatment of workers who have contracted COVID-19. The contingency plan will also consider the response at the events of infections among the workforce, community transmission is taking place and when it is likely that access to and from a target area will be restricted to avoid spread of COVID-19. The contingency plan will be lucid to GBV risks screening and putting in the corresponding measures to prevent and mitigate the SEA/SH risks. The contingent incidents will be duly registered with the GRM with observations of anonymity protocol. The Emergency Action Plan (EAP) will have contingency budget for any possible referral services available in the beneficiary areas. The Contingency Plan will be developed in consideration of the potential challenges with the project staff and workers in COVID-19 situations including health and safety of the workforce as well as the beneficiary communities. 4.4 Environment and Social Management Plan (ESMP) This section presents the outline environmental and social management plan (ESMP) of the LGCRRP. A more detailed version of ESMP must be included in the IEE and if required in ESIA of the respective PIU/ULGIs-LGCRRP. 4.4.1 Scope and Objectives of ESMP The basic objective of the ESMP is to manage risks and impacts of project interventions in a way that minimizes the possible adverse impact on the environment and people of the project influence area. The specific objectives of the ESMP are to: • Identify the mitigation measures during ESIA of CRG investments; and facilitate implementation of those during implementation by PIU/ULGIs-LGCRRP; • Maximize and sustain potential program benefits and control negative impacts; • Draw responsibilities for program proponent, contractors, consultants, and other members of the program team for the environmental and social management of the program; Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 30 • Define a monitoring mechanism and identify monitoring parameters in order to: o Ensure the complete implementation of all mitigation measures, o Ensure the effectiveness of the mitigation measures, o Maintain essential ecological process, preserving biodiversity and where possible restoring degraded natural resources and habitats; and o Assess environmental training requirements for different stakeholders at various levels. The ESMP will be managed through a number of tasks and activities and site-specific management plans. One purpose of the ESMP is to record the procedure and methodology for management of mitigation identified for each negative impacts of the project. The management will clearly delineate the responsibility of various participants and stakeholders involved in planning, implementation and operation of the project. 4.4.2 Inclusion of Relevant Components of ESMP in Contract Documents The specific IEE/ESIA should include a section on special environmental clauses to be incorporated in the Tender Document under General/Particular Specification. These clauses are aimed at ensuring that the Contractor carries out his responsibility of implementing the environmental and social management plan (ESMP), monitoring plan as well as other environmental and safety measures. Such clauses may specify, for example, penalties for non-compliance as well as incentives to promote strong compliance. The various contractors must be made accountable to implement the plans and mitigation measures which pertain to them through contract documents and/or other agreements of the obligations and importance of the environmental and social components of the program. In addition, the specific ESIA will ask to submit an ESMAP to encompass all of the detailed plans, measures and management systems they are required to develop and implement, to be based on the ESMF recommendation and ESIA findings, their work methodology, work force involvement, equipment’s standard, and work scheduling. 4.4.3 Payment Milestones Payments to contractors would be linked to environmental performance, measured by completion of the prescribed environmental and social mitigation measures. Contractors would be required to join forces with the executing agency, project management unit, supervising consultants and local population for the mitigation of adverse impacts of the program. For effective implementation of the proposed mitigation and monitoring measures they would attract trained and experienced environmental management staff. 4.4.4 Guideline to Incorporate Environmental Management in Bid Documents and Project’s Operational Manuals PIU/ULGIs-LGCRRP will be responsible to incorporate environmental management requirements in the bidding documents and the different operational manuals of the project activities, with the assistance of the environmental consultants or inhouse responsible staff. The generic guidelines to incorporate environmental and social aspects for this purpose are listed below. These are examples only and shall be further elaborated and expanded upon based on the findings and recommendations of the specific IEE/ESIAs. • Prepare cost estimates, to be incorporated in Bid Documents. • Contractor version of the Environmental Management Plan along with the ECoPs to be incorporated in the bid document‘s work requirements. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 31 • Penalty clauses for not complying with ESMP requirements to be incorporated (as oer addendum to Clause 17.2 Contractor‘s Care of the Works of FIDIC). 4.4.5 Environmental Codes of Practice (ECoPs) The environmental codes of practice (ECoPs) are generic, non-site-specific guidelines. The ECoPs consist of environmental management guidelines and practices to be followed by the contractors/ implementation organizations for sustainable management of all environmental issues. The contractor will be required to follow them and also use them to prepare site-specific management plans. Details of the relevant ECoPs listed below are in Annex 2. • ECoP 1: Waste Management • ECoP 2: Drainage Management • ECoP 3: Top Soil Management • ECoP 4: Topography and Landscaping • ECoP 5: Borrow Areas Management • ECoP 6: Air Quality Management • ECoP 7: Noise and Vibration Management • ECoP 8: Road Transport and Road Traffic Management • ECoP 9: Construction Camp Management • ECoP 10: Cultural and Religious Issues • ECoP 11: Workers Health and Safety. 4.4.6 Management of Vulnerable and Disadvantaged Groups, Communities, and Individuals The project will design and provide skills development training and livelihoods support to the vulnerable communities and establish mechanism at the ULGIs and project level to address risks of discrimination, sexual exploitation, and abuse (SEA) and sexual harassment (SH). Small Ethnic and Vulnerable Community Plan (SEVCP) will be included in the ESMP for works packages influencing vulnerable communities. The SEVCP will provide guidance in identification of vulnerable communities, engaging with them inclusively in development dialogue and developing measures to maximize subproject benefits to them. The project will identify these people with special needs for their age, gender, ethnicity, religion, physical, mental or other disability, sexual orientation, poverty and indigenous status including any challenges in their participation in subproject process and ensure non-discrimination to access project benefits. 4.5 COVID-19 Health and Safety of the Workforce The PIU/ULGIs should identify measures to address the COVID-19 situation. What will be possible will depend on the context of the project activities: the location, existing resources, availability of supplies, capacity of local emergency/health services, the extent to which the virus already exist in the area. A systematic approach to planning, recognizing the challenges associated with rapidly changing circumstances, will help the project put in place the best measures possible to address the situation. PIU should refer to guidance issued by relevant authorities, both national and international (e.g. WHO). Addressing COVID-19 at a project site goes beyond occupational health and safety and is a broader project issue which will require the involvement of different members of a project management team. The Labor Management Procedure (LMP), separate from this ESMF, details the requirements under the COVID-19 Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 32 pandemic for management of civil works. Health and safety measures for the workers have also been provided in Annex 3. 4.6 Labor Management Procedures A standalone Labor Management Procedure (LMP) has been prepared to fulfill the requirement of ESS2 and will be disclosed by PMU/LGCRRP prior to appraisal of the project by World Bank. Site specific LMPs will be prepared as part of the ESMPs/C-ESMPs as indicated in earlier sections of this ESMF. 4.7 Community Health and Safety Measures The Contractors shall follow the standards set by World Bank ESS4 in order to ensure the health and safety of the community. All schemes and sub-schemes including civil construction, renovation, repair roads and sanitation, installation of water supply & sanitation facilities, shall be inspected by LGCRRP and respective representatives of ULGIs/PIUs and to assess any risks or hazards associated. After inspection, the competent professionals from LGCRRP/ULGIs shall certify which shall reflect on the risk of adverse consequences posed by the nature and use of the structural elements and the natural conditions of the area. Since the locations of the project are in different zones of the country community people, beneficiaries and projected affected people are to be consulted for broader support in selection of location of the proposed schemes and sub-schemes activities. LGCRRP shall appoint quality management systems to anticipate and minimize any risks and impacts that may have on community health and safety. Traffic and road safety should be ensured, as the materials will be carried to the project sites by truck and local transport, therefore, reckless driving of the heavy vehicles are to be controlled to avoid accidents, noise and air pollutions. The proliferation of COVID-19 should be taken into cognizance while interacting with local community. Relations with the community should be carefully managed, with a focus on measures that are being implemented to safeguard both workers and the community. The community may be concerned about the presence of non-local workers, or the risks posed to the community by local workers presence on the project site. 4.8 Repossession of Land from Encroachers for Project Works Involuntary acquisition of land and displacement of people will be avoided for any investments under this project (negative list at Section Error! Reference source not found.). When a CRG investment proposed by ULGIs finds a small strip of existing land proposed for infrastructure development or rehabilitation is encroached in, the encroacher of public land, if persuaded, may elect to dispossess the land strip(s) voluntarily with or without compensation for the structures to be shifted to vacate the land. The ULGI will engage with the encroachers likely to be affected under any subproject to identify, discuss, and agree on mechanisms of dispossession and repossession of the strip of encroached land documented in site specific ESMPs. Only small strip(s) of encroached land (less than one decimal) will be acceptable that does not induce physical relocation or permanent economic displacement of people. The ULGIs will ensure that, • The dispossession is voluntary with or without compensation. • The remaining land is suitable to continue the current use. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 33 • The dispossession does not affect the livelihood of affected persons and, if it does, the ULGI devises and implements mitigation measures acceptable to the affected persons. • The affected persons/dispossessors are made aware of the grievance redress mechanism described at Section 5.3. • The act of voluntary dispossession with or without compensation of the affected structures will be documented through an MOU signed by the dispossessors with the ULGIs authorized representatives. • If compensation for affected structure is agreed in the MoU, the payment must be made before dispossession of the encroached land demarcated for the CRG subproject(s). 4.9 Consultation and Participation Plan A separate SEP has been prepared which discussed the ESS10 requirements elaborately. 4.10 Guideline for preparation of Environmental and Social Monitoring Plan The monitoring plan is the key element of ESMP to be prepared based on impact assessment described in earlier section. The Plan describe the potentially negative impacts of each program activity, lists mitigation and control measures to address the negative impacts, and assigns responsibilities for implementation and monitoring of these measures. The E&S Monitoring Plan for the each PIU/ULGI-LGCRRP will be prepared and included in the ESMPs. 4.10.1 Monitoring Program As one of the key elements of the ESMP, a two-tier monitoring program is proposed comprising compliance monitoring and effects monitoring. The main purpose of this monitoring program is to ensure that the various tasks detailed in the ESMP particularly the mitigation measures are implemented in an effective manner, and to evaluate program impacts on the key environment parameters. Various types of ESMP monitoring are discussed below. Compliance Monitoring. The purpose of the compliance monitoring is to ensure that the contractor implements the mitigation measures given in the ESMP are effectively and timely implemented. This monitoring will generally be carried out by the PIU/ULGIs-LGCRRP with the help of checklists to be prepared on the basis of the Mitigation Plan (to be prepared). Effects Monitoring During Project Implementation. Effects monitoring is a very important aspect of environmental management to safeguard the protection of environment. While the PIU/ULGIs are responsible for effect monitoring during the project implementation, a RSC headed by a Regional Coordinator under the Project Director/LGCRRP will be formed in each division consisting of other members like E&S Consultants, Stakeholders Engagement and Communication Consultant, and other nominated officials from PMU to assist the PIU/ULGIs in effects monitoring. The monitoring will comprise surveillance to check whether the contractor is meeting the provisions of the contract during construction and operation of the program including the responsible agencies for implementation and supervision. Performance Indicators. For evaluating the performance of the environmental management and monitoring plan, performance indicators are identified to for efficient and timely implementation of measures/actions proposed in ESMP. The indicators are defined both for implementation phase and for post project period. PIU/ULGIs will be responsible for compiling the information on these indicators and report to RSC-PMU/LGCRRP. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 34 Separate performance indicators for each environmental and social issue will be specified in the mitigation plans for the PIU/ULGIs and included in the associated IEE/ESIA. To measure the overall environmental and social performance of the project, an additional list of performance indicators is given below. • Number of inspections carried out by PIU/ULGIs or RSC-PMU per month. • Number of non-compliances observed by PIU/ULGIs or RSC-PMU. • Availability of environmental specialists in PIU/ULGIs or RSC-PMU. • Availability of social specialists in PIU/ULGIs or RSC-PMU. • Availability of environmental specialists with contractors. • Timely reporting of documents (as defined in ESMP and monitoring plan). • Number of trainings imparted to stakeholders/other capacity building initiatives. • Timely disbursement of compensation/ timely resettlement of program affectees (if any). • Timely implementation of activities schedule. • Number of grievances received. • Number of grievances resolved. • Number of constructions related accidents. 4.11 Environmental and Social Management Capacity The LGCRRP will be managed by LGD through a Project Management Unit (PMU). LGD has the capacity to manage environmental and social risks and impacts in a manner consistent with Bank requirements. LGD has long experience in managing environmental and social requirements under the safeguards OPs of the Bank as it has been implementing the Bank financed Local Governance Support Project (LGSP) since 2008.4 Some of the ULGIs have experience in managing social and environmental risks. LGD will be able to provide ULGIs with adequate support to mitigate the moderate environmental and social risks of the project. Internal E&S management System The PMU/LGSP in LGD at the central level usually screens projects for IEE or EIA as per ECR 1997 provisions, undertake the preparation of IEE/EIA and obtain ECC from the Department of Environment. The responsibility of E&S risk management lies on the PIU/PMU which includes conducting supervision and monitoring of project interventions as per recommendations of the ESMP. They usually hire consultants for ESA preparation (ESMF or EIA preparation). Supervision of E&S mitigation activities are also assisted by consultants, also hired by the PMU/PIU but typically not the same consultants who prepared the ESA. Project Director is responsible during the implementation stage of projects. He assisted by the E&S consultants has major role in engagement of contractors, construction supervision, environmental and social impact supervision and mitigation of the project. The responsibilities also include incorporation of the environmental codes of practices in the bid document of the contractors based on the approved IEE/EIA documents and hiring contractors is the responsibility of the PMU/PIU. There is no internal review or auditing systems for environmental and social management in LGD. There are some designated project level posts in the past to do the job to supervise the environmental and social impact issues, and for most of the cases they were trained to comply with the WB’s policies. It has inbuilt 4 LGSP 1 and LGSP 2 have been completed; LGSP 3 is ongoing. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 35 Grievance Redress Management (GRM) process guided by the GoB’s GRM Guideline 2015, but it is currently primarily managed on a reactive basis, coordinated through MLGRD&C. 4.12 Capacity Building Plan Capacity building for effective implementation of the ESSs requirements is a key element of the ESMP. Capacity building for environmental and social safeguard management will need to be carried out at all tiers of the LGCRRP, including LGD, ULGIs (329 Pourasavas and 10 CCs) and contractors. At the construction site, PIU/ULGIs-LGCRRP will take the lead in implementing the capacity building plan, though the contractors will also be responsible to conduct trainings for their own staff and workers. The various aspects that are covered under the capacity building will include general environmental and social awareness, key environmental and social sensitivities of the area, key environmental and social impacts of the project, ESMP requirements, OHS aspects, and waste disposal. Hence, a separate Capacity Building Plan (CBP) for the LGCRRP has been prepared which will be the main guiding document to build capacity of LGD and ULGIs for implementing this ESMF. Following paragraphs provides summary of the capacity building requirements as assessed in this report. 4.12.1 Training on E&S Management Advanced training on environmental and social management and monitoring will be useful for the officials of the LGD and ULGIs in successfully implementing environmental and social management. It is also necessary to provide basic training for key personnel on regulatory requirements, environmental impacts, and environmental assessment and management in home or abroad. They can participate in field-based training including the environmental and social impact assessment, screening, scoping, mitigation and monitoring of existing construction, rehabilitation and maintenance projects under the LGD. The training program for the proposed PMU and ULGIs Staff shall be based on their expanded functions and new and additional safeguards areas covered by the World Bank’s ESF. Hence, a general introduction to the new World Bank’s ESF should be priority, followed Labor and Working Conditions, Community Health and Safety and Stakeholder Engagement. In regard to IEE/ESIA, a training should also be schedule later in Year 1 of the project. The other areas which the units should immediately be trained on are field compliance monitoring and audits, particularly on C-ESMP Compliance and occupational and community health and safety audit, cultural heritage assessment and impacts management; and biodiversity and wildlife impact management for construction/renovation/expansion projects (Table 4.1). Finally, since in the long run it will be efficient for the staff of E&S units (central, regional and local levels) to contract out works to consultants, not only for preparation of IEE/ESIA, but also field monitoring and evaluation, it is imperative that the PMU, RSC and ULGIs staff shall be skilled in consulting contract management. Hence a training module on such topic is also proposed. Table 4.1: Training Plan and Budget under LGCRRP Seminar Prospective Time Duration Training No. of Responsibility Indicative Cost in Topic/Training Attendees Frame (Days) no. Participants million BDT Module 1. Introduction PMU and ULGIs Year 1, 3 12 350 PMU 1.20 to World Bank staff Year 3 Environmental ESF and Social Consultants Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 36 Seminar Prospective Time Duration Training No. of Responsibility Indicative Cost in Topic/Training Attendees Frame (Days) no. Participants million BDT Module 2. Labor and PMU and Year 1, 3 2 60 PMU 0.20 working contractors Year 2 Environmental conditions and Social Consultants 3. Community LGD, PMU and Year 2 3 1 30 PMU 0.10 health and contractors Environmental safety and Social Consultants 4.Stakeholder PMU and ULGIs Year 1 3 12 350 PMU 1.20 Engagement staff Environmental and Social Consultants 6. Preparation PMU and ULGIs Year 1 3 12 350 PMU 1.20 of IEE/ESIA staff, DOE by and Environmental under ESF invitation Year 2 and Social Consultants 7. ESMP PMU and ULGIs Year 1, 3 12 350 PMU 1.20 compliance staff and Field Year 2 Environmental monitoring Engineers and Social and audit Consultants 8. Cultural PMU and ULGIs Year 3 3 12 350 PMU 1.20 heritage and staff, Environmental religious Department of and Social institutions Archaeology Consultants impacts staff. management Total 6.30 4.12.2 Monitoring and Evaluation To keep track of the progress and outcomes of the implementation of the Capacity Building Plan, the management of the LGCRRP will periodically monitor and evaluate the sets of indicators in Table 4.2. The Capacity Building Plan Monitoring and Evaluation Reports should be provided to and discussed with the World Bank task team during each supervision mission. Table 4.2: Capacity Development Indicators Actions Indicator Method of Collection Inputs Staff Recruited at PMU and PIU No. of new staff hired Reports Number of consultants hired Trainings Conducted Number and types of trainings conducted Reports Coordination meetings Number of coordination meetings Office Records conducted conducted; invitation letters sent. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 37 Actions Indicator Method of Collection Outputs Expanded role of LGD, PMU and Memorandum Circular expanding roles and Copy of the MC PIU staff coverage Prepare new/update protocols Number and types of protocols developed Copies of the Protocols Prepare new/update guidelines Number and types of guidelines developed Copies of the Guidelines Outcomes Scope of activities Range of activities conducted Reports and Staff Interviews Skills of staff New tasks undertaken by staff Reports and Staff Interviews Resource endowments Annual budget, Office space, New Reports, Staff Interview equipment Coordination and involvement Number of agencies involved in E&S Reports and Staff Management of LGD and ULGIs Interview Results/Performance Preparation of subprojects/CRG No. of subprojects prepared adequately RSC-PMU and ULGIs proposals responding to the requirements of the new records ESF and relevant ESSs Review and approval of Number of site-specific E&S reports RSC-PMU and ULGIs subprojects/CRG proposals (screening, impact assessment and records management plans) reviewed and approved under the new ESF compliant system Environmental and Social Number of subprojects audited under new RSC-PMU and ULGIs Auditing ESF compliant system records Awareness of ESF Percentage of LGD and ULGIs staff that are Staff Interviews aware of the new ESF 4.13 ESMF Implementation Cost Estimated cost will be prepared for all the mitigation and monitoring measures to be proposed in the specific screening/IEE/ESIA and compliance required for the ESMF. The cost estimates for some of the mitigation measures to be identified in the ESMP will be part of civil works contract. Some of suggestive activities from screening/IEE/ESIA will be implemented by hiring experts (if required). The Development Project Proposal (DPP) of LGCRRP/LGD should reflect the ESMP activities with sufficient budget allocation for successful environmental and social management of the project. Total BDT 1083,00,000 is estimated for implementation of ESMF which should be embedded in the proposed total project budget from IDA. Table 4.3: Estimated cost for ESMF implementation of the LGCRRP Amount in SN Description million BDT Contractor’s Budget for development of management plans baseline study, development of safety operation plans and monitoring during construction 1 and operation, and monitoring of sites on COVID 19 health and occupation 2.00 safety Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 38 Amount in SN Description million BDT 2 Water, soil and air quality monitoring during construction (quarterly for 5 years) 5.00 3 Tree plantation development and maintenance 5.00 6 Independent Consultants to prepare IEE/ESIA and ESMP 30.00 7 PMU/ LGCRRP Environmental and Social staff 60.00 Capacity building, training plan implementation (sec 4.12) and institutional 8 6.30 strengthening TOTAL 108.3 LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 39 Chapter 5: STAKEHOLDERS ENGAGEMENT, DISCLOSURE AND GRIEVANCE MANAGEMENT A standalone Stakeholders Engagement Plan (SEP) has been prepared for LGCRRP which will be the main guiding document for the project in managing stakeholders’ engagement. The following sections are summarizing the ESS10 requirements for stakeholder’s consultations and information disclosures. 5.1 Stakeholder Consultations and Information Disclosure Considering the context of the COVID-19 pandemic, Field surveys through sending checklist of required information and virtual consultations with different stakeholders of existing ULGIs and CCs (covered under LGSP 3) that were carried out to develop this ESMF of LGCRRP, which were not enough considering the number of ULGIs (329 PSV, 10 CCs) to be involved and dimension of the stakeholders. Extensive field visits are required at the IEE/ESIA stage to overcome this shortcoming and conduct extensive discussions with the relevant stakeholders throughout the project sites to discuss components, sub-components, activities, potential positive and negative impacts, and measures taken to mitigate those impacts. It is also required to record the views of each of the respondents of the consultations, irrespective of gender, profession, religion, and age groups. The ToR of the IEE/ESIA should be described in the public meetings during the initial stage of the IEE/ESIA in all the sites of the proposed project. Findings of the IEE/ESIA will also be presented in local language going back to the same stakeholders while the draft is ready to submit for DoE clearance. Consultation meetings are necessary to identify issues and problems to enable LGCRRP to include corrective measures and to identify lessons and opportunities to enhance project implementation mechanism. 5.1.1 Methodology and Tools for the Consultation The consultation and participation process in preparing the ESMF was limited to selected stakeholders both at the ULGIs and at the regional and national level, since specific sites have not been identified yet. Stakeholders’ consultation and engagement at the individual household level was not carried out during the preparation of the ESMF. However, this will be done at the site level once they are identified. The consultation will be carried out in a culturally/socially appropriate manner so that specific requirement of various groups (separate venue and timing for women friendly consultation, access to venue for the persons with disability etc) are considered and consultations are planned accordingly Stakeholders are people, groups, or institutions, which are likely to be impacted (either negatively or positively) by the proposed project interventions or those who can influence the outcome of the project. A stakeholders mapping was conducted prior to conducting consultation meetings held virtually using web-based platform. The project affected parties include individuals, groups, local communities and other stakeholders that are directly or indirectly affected by the Project, with particular focus being accorded to those directly and/or adversely affected including those who are more susceptible to changes associated with project activities. The other interested parties are NGOs, community-based organizations, community development projects, governance agencies, development partners, media, community leaders, civil society, traders, construction laborers and consultants in the project area. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 40 The various tools identified in the SEP will be used for consultations including household level interviews, participatory rural appraisal, FGDs, stakeholder’s consultation meetings, issue specific consultation meetings, open meetings, and workshops at both local and national levels. During IEE/ESIA, consultation meetings and FGDs will be carried out in all sites/ULGIs and local level workshops will be organized at some selected wards (lowest administrative units of ULGIs) to ensure comprehensive coverage of the entire project area and provide specific list of interventions. During preparation of ESMF, LGCRRP has conducted 2 virtual consultations with different stakeholders during COVID-19 pandemic using virtual web-based platform. The discussion and the concerns and responses are extensively documented in the standalone SEP. A summary of consultation meetings is given below in Table 5.1. Table 5.1: Summary of Consultation Meetings No. Date Venue ULGI Type 1 February 02, 2021 Virtual Stakeholders Consultation 15 Pilot Pourasava covered under Workshop using Zoom the LGSP 3 2 February 09, 2021 Virtual Stakeholders Consultation 10 City Corporation covered under Workshop using Zoom the LGSP 3 In addition to the two virtual consultations, the team has conducted remote survey through sending specific checklist developed for collecting required information from 15 Pourasavas of LGSP 3. 5.1.2 Outcomes of Consultation Meetings and Remote Survey A summary of consultation outcomes is given below in: Stakeholders’ Consultation – 1: Virtual Stakeholders Consultation Workshop using Zoom with 15 PSVs • Participating ULGIs have capacity to implement the project activities maintaining E&S compliance at the local level. • PSVs have ample demand of funding through CRG method to overcome the COVID-19 setback. • Project should have activities to provide technology-based training to ensure future skills of the COVID-19 affected people. • Most of the ULGIs have scarcity of modern solid waste management and sewerage systems. • Some ULGIs have urged for investment on environmental improvement and beautification of the existing natural areas to improve living conditions of the citizens. • Some ULGIs have demand to improve local health services provided including infrastructure and equipment. • Most of the PSVs have inbuild practice of involving local stakeholders and beneficiaries in scheme selection and monitoring. • PSV’s engineers are primarily responsible for project implementation and E&S supervision and monitoring. • Women participation are ensured at all stages of project cycle by the ULGI leaders mentioned by the participants. Stakeholders’ Consultation-2: Virtual Stakeholders Consultation Workshop using Zoom with 10 CCs • Schemes implemented by the CCs are in comparison larger than the PSVs, hence required increased funding to combat pandemic impacts. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 41 • Type of schemes required for funding through LGCRRP in CCs are mostly around waste management, sewerage treatment, communication development, health service improvement, water and sanitation, housing and generating employment opportunities for city dwellers, specially for the lower income groups. • Most of the CCs have inbuild practice of engaging local stakeholders’ in scheme selection, planning and implementation monitoring and well setup local GRM process exist. • CCs staff responsible for project planning and implementation are experienced in E&S compliance monitoring and safeguarding. • No such evidence of violating E&S compliance was reported by the participants, except mentioning some minor and localized pollution events. • Climate change and disaster (e.g. recurring flooding, water logging, etc.) are common in most of the CCs, need to address by the CRG. As this was the first efforts of organizing web-based stakeholders’ consultation, due to time limitation several of the above important E&S issues could not be discussed. So, it is suggested that PIU/ULGIs LGCRRP will organize multiple stakeholders’ consultation at each construction/renovation sites during IEE/ESIA preparation engaging different stakeholders. Remote Survey-1: Sending Checklist to 15 PSVs A remote survey was done by sending an E&S checklist in the 15 pilot PSVs to collect specific data and information required to prepare the ESMF. Summary of the environmental issues found in the remote survey is given below: • Most of the surveyed PSVs have either natural flowing rivers/water bodies or vegetation coverage, those need to take care of during project planning and implementation. • PSVs have no such sensitive ecological area or biodiversity which required special attention for conservation. • PSVs have demand for development works through LGCRRP mostly around waste management, sewerage treatment, communication development, health service improvement, water and sanitation, housing and generating employment opportunities for city dwellers, specially for the lower income groups. • Most of the PSVs have never conducted any kind of advance level E&S assessment i.e. IEE/ESIA given that the type of schemes had no such adverse environmental and social impacts. • Most of the PSVs have noninstitutional practice of GRM, which might need to be improved by establishing institutional GRM process under LGCRRP. Capacity development for implementation of ESMF is a must for the staff of the PSVs. 5.2 Consultations and Communication Guideline Consultations with the key stakeholders will need to be carried out throughout the project life. These will include consultations and liaison with communities and other stakeholders during the project implementation and also extensive consultations with the grass-root as well as institutional stakeholders during the IEE/ESIA study. The framework for the future consultations is presented in Table 5.2 below: Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 42 Table 5.2: Future Consultation Guideline Description Objective/Purpose Responsibility Timing Frequency Consultations Information PMU, LGCRRP; During Project Project Specific with dissemination; Contractors; Implementation Location of communities and public relation; PIU interventions and other confidence building; impacted area. stakeholders awareness about during project risks and impacts; implementation minimizing conflicts and frictions. Consultations Sharing IEE/ESIA ToR PMU, LGCRRP During scoping Consultation with and IEE/ESIA stage of IEE/ESIA meeting at all communities and team selected Sites; other FGD at all selected stakeholders Sites during IEE/ESIA study Dissemination of PMU, LGCRRP During IEE/ESIA Consultation information on and IEE/ESIA study (once draft meeting at all project and its key team analysis is selected ULGIs; impacts and available for FGD at All proposed mitigation discussion and selected Sites; measures; soliciting feedback) before National views, comments, submission to DoE Stakeholders’ concerns, and for clearance Consultation; recommendations of stakeholders Consultations Liaison with PMU, Post Project Period As and when with communities and LGCRRP/PIU necessary communities project beneficiaries 5.2.1 Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations under the outbreak and spread of COVID-19 These restrictions have implications for World Bank-supported operations. In particular, they will affect Bank requirements for public consultation and stakeholder engagement in projects, both under implementation and preparation. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 43 During Implementation With growing concern about the risk of virus spread, there is an urgent need to adjust the approach and methodology for continuing stakeholder consultation and engagement, the following are some considerations while selecting channels of communication, in light of the current COVID-19 situation under the LGCRRP: • Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings; • If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings If not permitted, make all reasonable efforts to conduct meetings through online channels, including webex, zoom and skype; • Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders; • Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, and mail) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions; • Where direct engagement with project affected people or beneficiaries is necessary, such as would be the case for Resettlement Action Plans or Indigenous Peoples Plans preparation and implementation, identify channels for direct communication with each affected household via a context specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators; • Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders; • An appropriate approach to conducting stakeholder engagement can be developed in most contexts and situations. However, in situations where none of the above means of communication are considered adequate for required consultations with stakeholders, the team should discuss with the PMU whether the project activity can be rescheduled to a later time, when meaningful stakeholder engagement is possible. Where it is not possible to postpone the activity (such as in the case of ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance. During Project Preparation: Where sub-projects are under preparation and stakeholder engagement is about to commence or is ongoing, such as in the project E&S planning process, stakeholder consultation and engagement activities should not be deferred, but rather designed to be fit for purpose to ensure effective and meaningful consultations to meet project and stakeholder needs. Some suggestions for advising clients on stakeholder engagement in such situations are given below. These suggestions are subject to the coronavirus situation in country, and restrictions put in place by governments. The task team and the LGD should: • Review the country COVID-19 spread situation in the project area, and the restrictions put in place by the government to contain virus spread; • Review the draft Stakeholder Engagement Plan (SEP, if it exists) or other agreed stakeholder engagement arrangements, particularly the approach, methods and forms of engagement Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 44 proposed, and assess the associated potential risks of virus transmission in conducting various engagement activities; • Be sure that all task team and PIU members articulate and express their understandings on social behavior and good hygiene practices, and that any stakeholder engagement events be preceded with the procedure of articulating such hygienic practices. • Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings, and minimize direct interaction between project agencies and beneficiaries / affected people; • If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings. If not permitted, make all reasonable efforts to conduct meetings through online channels, including webex, zoom and skype meetings; • Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders; • Employ traditional channels of communications (TV, newspaper, radio, dedicated phone-lines, public announcements and mail) when stakeholders do not have access to online channels or do not use them frequently. Such channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions; • Employ online communication tools to design virtual workshops in situations where large meetings and workshops are essential, given the preparatory stage of the project. Webex, Skype, and in low ICT capacity situations, audio meetings, can be effective tools to design virtual workshops. The format of such workshops could include the following steps: o Virtual registration of participants: Participants can register online through a dedicated platform. o Distribution of workshop materials to participants, including agenda, project documents, presentations, questionnaires and discussion topics: These can be distributed online to participants. o Review of distributed information materials: Participants are given a scheduled duration for this, prior to scheduling a discussion on the information provided. o Discussion, feedback collection and sharing: ✓ Participants can be organized and assigned to different topic groups, teams or virtual “tables� provided they agree to this. ✓ Group, team and table discussions can be organized through social media means, such as webex, skype or zoom, or through written feedback in the form of an electronic questionnaire or feedback forms that can be emailed back. o Conclusion and summary: The chair of the workshop will summarize the virtual workshop discussion, formulate conclusions and share electronically with all participants. • In situations where online interaction is challenging, information can be disseminated through digital platform (where available) like Facebook, Twitter, WhatsApp groups, Project weblinks/ websites, and traditional means of communications (TV, newspaper, radio, phone calls and mails with clear description of mechanisms for providing feedback via mail and / or dedicated telephone lines. All channels of communication need to clearly specify how stakeholders can provide their feedback and suggestions. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 45 • Engagement with direct stakeholders for household surveys: There may be planning activities that require direct stakeholder engagement, particularly in the field. One example is resettlement planning where surveys need to be conducted to ascertain socioeconomic status of affected people, take inventory of their affected LGCRRPs, and facilitate discussions related to relocation and livelihood planning. Such survey activities require active participation of local stakeholders, particularly the potentially adversely affected communities. However, there may be situations involving indigenous communities, or other communities that may not have access to the digital platforms or means of communication, teams should develop specially tailored stakeholder engagement approaches that will be appropriate in the specific setting. The teams should reach out to the regional PMs for ENB and SSI or to the RSA for the respective region, in case they need additional support to develop such tailored approaches. • In situations where it is determined that meaningful consultations that are critical to the conduct of a specific project activity cannot be conducted in spite of all reasonable efforts on the part of the client supported by the Bank, the task team should discuss with the client whether the proposed project activities can be postponed by a few weeks in view of the virus spread risks. This would depend on the COVID-19 situation in the country, and the government policy requirements to contain the virus spread. Where it is not possible to postpone the activity (such as in the case of ongoing resettlement) or where the postponement is likely to be for more than a few weeks, the task team should consult with the OESRC to obtain advice and guidance. 5.3 Grievance Redress Mechanism The LGCRRP program will establish a grievance mechanism (GRM) for addressing grievances and complaints received from the project affected persons due to environmental and social issues. Grievance Mechanism (GRM) is a valuable tool which will allows affected people to voice concerns regarding environmental and social impacts for LGCRRP’s activities. LGCRRP would ensure that grievance redress procedures are in place and would monitor those procedures to ensure that grievances are handled properly.. The LGCRRP office will establish a procedure to answer sub-component -related queries and address complaints, disputes, and grievances about any aspect of the sub- component, including disagreements regarding the assessment and mitigation of environmental and social impacts. Details of the institutional arrangements and procedures are discussed in following sections. Communication & Awareness raising on GRM. The final processes and procedures for the GRM will be translated into local language (i.e. Bangla) and disseminated at all project locations. These shall be made available (in both leaflet and poster format) to all project locations with the PMU, RSCs and PIUs officials on site and in the offices of each DC of the respective ULGIs. Proposed Institutional Mechanisms. There will be two-tier grievance mechanism; 1st at local level (PIU/ULGI), and at PMU level (NPD). All the local level complaints will be received at the Project Office at ULGIs. All cases at the local level will be heard within two weeks of their receipt. PIU with the support of RSCS/PMU will inform all affected stakeholders and interested group about the project GRM and different committees at local, project, ministry level. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 46 5.3.1 Composition of Local/Site Specific GRC First level GRC will be formed in the local level where community or local people will be able to raise their grievances directly to the field level project office i.e. PIU/ULGI. PMU/LGCRRP with support from the PIU and RSCSs consultants’ team will inform all affected people and local community about the project Grievance Mechanism in local language. This local GRC will ensure easy accessibility by the PAPs, local communities and interested stakeholders, so that any grievances can be solved directly or within a very short period of time. The members of the local GRC will be respective Mayor as convener; Engineer from the PIU or other senior officials from ULGI as members secretary, nominated by Mayor; members representative from local ward members, teacher from Local Educational Institution, representative from Local Women’s Group, and representative from the PAP Group. (Table 5.3) The membership of the GRCs will ensure proper presentation of complaints and grievances as well as impartial hearings and investigations, and transparent resolutions. Where grievances are among the affected persons, the membership composition of the GRCs will consider any traditional conflict resolution arrangements that communities may practice. If the aggrieved person is a female, PIU will ask the concerned female ULGI Member or Municipal Ward Councilor to participate in the hearings. Members of the GRCs will be nominated by the PIU/ULGIs-LGCRRP Table 5.3: GRC membership at local/site level Organization Member 1. Mayor (PSV/CC) Convener 2. Engineer from PIU or other ULGI official Member-Secretary 3. Representative of Local Ward Councilors Member 4. Representative Teacher from Local Educational Institution Member 5. Representative from Local Women’s Group Member 6. Representative from the PAP Group Member 7. Women Representative of ULGI/WC (in case PAP is Member female) All complaints will be received at the Site/Upazila Project Office. All cases at the local level will be heard within two weeks of their receipt. Grievances received through any channel will be registered and a notification of receipt with assurance of necessary review and resolution given in writing to the aggrieved persons. 5.3.2 Composition of PMU and PSC level GRC If a decision at PIU/ULGI level is again found unacceptable by the aggrieved person(s), the case will then refer to the PMU with the minutes of the hearings at local level. NPD will be the convener and Social Specialist/Environmental Specialist will be the member secretary at PMU level. All the unsolved cases at the PMU level, decisions on unresolved cases, if any, will be made in no more than four weeks by an official designated by the Secretary, MLGRD&C. A decision agreed with the aggrieved person(s) at any level of hearing will be binding upon PMU. There will be budgetary allocation for local GRM committee members for participating meetings and refreshments during meeting. Figure 5.1 is showing a hierarchy of GRM process: LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 47 Secretary MoLGRD&C PMU (NPD level) LGD GRC (Local) PIU Offices at PSVs and CCs Complaints & Suggestions on environmental, social and resettlement issues Complaints and Suggestions In writing by COMMUNITY/USERS/BENEFICIARIES & AFFECTED PERSONS Figure 5.1: GRM Process of the LGCRRP Project To ensure that grievance redress decisions are made in formal hearings and in a transparent manner, the convener will apply the following guidelines: • Reject a grievance redress application with any recommendations written on it by a GRC member or others such as politicians and other influential persons. Applications of this nature will be redirected to go through the standard transparent process. • • Disqualify a GRC member who has made a recommendation on the application or separately before the formal hearing: Where a GRC member is removed, appoint another person in consultation with the Project Director. • The Convener will also ensure strict adherence to the impact mitigation policies and guidelines adopted in this ESMF, other standalone documents e.g. SEP, LMP, and the mitigation standards, such as compensation rates established through market price surveys. To ensure impartiality and transparency, hearings on complaints will remain open to the public. The GRCs will record the details of the complaints and their resolution in a register, including intake details, resolution process and the closing procedures. PIU will maintain the following three Grievance Registers: Intake Register, Resolution Register, and Closing Register. The Convener will also ensure strict adherence to the impact mitigation policies and guidelines adopted in this ESMF, LMP, and SEP. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 48 5.4 Information Disclosure The draft ESMF of LGCRRP will be disclosed to the local and national level stakeholders through different methods as described below. Workshop. A national workshop will be held at Dhaka to present the detailed project information including E&S aspects of LGCRRP to the key stakeholders. In addition, stakeholders’ meetings will be held at some selected PSVs/CCs to disclose the ToR and results of the IEE and ESIA, following COVID-19 protocols mentioned earlier. The workshops will also help to resolve conflicting issues among stakeholders. Besides, FGDs and personal interviews will be carried out at the all selected sites of the LGCRRP project area to generate communities’ views and concerns. Availability of the Document: Summary of the IEE, ESIA and ESMF report along with ESMPs will be translated into Bengali language and disseminated locally. The full report (in English) and the summary (in Bengali) will also be uploaded in the website of LGCRRP and World Bank. Hard copy of the IEE, ESIA, ESMF, SEP and LMP will also be available at LGCRRP regional offices, PSVs and CCs of the project area. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 49 Annexure Annex 1: Sample Environmental and Social Screening Form A. ENVIRONMENTAL SCREENING FORM (Sample) [This form is applicable for Paurashava and to be filled in by WLCC and kept in the Paurashava Scheme file] Screening Date:………………………........... District:……………………..………….; Upazila: ……………………………………. ................................... Paurashava:………………………………..; Ward No………………………........ Name of Ward Committee Chair:……………………………………………………… Names of Name Mobile No. NID No. other Ward Committee members participated in screening process SL 1 2 3 4 5 6 Part A: General Information 1. Name of the Scheme: ......................................................................................................... 2. Use of the Scheme:..................................... ………………………………………….. 3. Location of the Scheme: ………………………………………………………….. 4. The Scheme is located in an area (ward or part of a ward) where residents are: Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 50 [ ] All mainstream or non-indigenous peoples [ ] All indigenous peoples [ ] Majority mainstream or non-indigenous peoples [ ] Majority indigenous peoples 5. Women were consulted separately: [ ] Yes; [ ] No 6. Scope of Scheme works: [ ] New construction, [ ] I improvements, [ ] Repair/Renovation 7. Brief description of physical features of the Scheme: ................................................................................................................................................... ................................................................................................................................................. Part B: Environmental Issue 1) Potential Environmental Impact during Construction Phase: (a) Ecological impacts: (important Schemes include storm drain, bridge, box culvert, and boat landing jetty) • Felling of trees Significant □ Moderate □ Minor □ Number of tress • Clearing of vegetation Significant □ Moderate □ Minor □ • Potential impact on Significant □ Moderate □ Minor □ species of aquatic (i.e., water) environment (b) Physicochemical impacts: (all Schemes) • Noise pollution Significant □ Moderate □ Insignificant □ • Air pollution Significant □ Moderate □ Insignificant □ • Drainage congestion Very likely □ Likely □ Unlikely □ • Water pollution Significant □ Moderate □ Insignificant □ • Pollution from solid/ Significant □ Moderate □ Insignificant □ construction waste • water logging Significant □ Moderate □ Insignificant □ (c) Socio-economic impacts: (all Schemes) • Traffic congestion Very likely □ Likely □ Unlikely □ LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 51 • Health and safety Significant □ Moderate □ Insignificant □ • Impact on archaeological and Significant □ Moderate □ Insignificant □ historical • Employment generation Significant □ Moderate □ Insignificant □ 2) Potential Environmental Impact during Operational Phase: (d) Ecological impacts: (important Schemes include storm drain and boat landing jetty) • Potential impact on species Significant □ Moderate □ Minor □ of aquatic (i.e., water) environment (e) Physicochemical impacts: (all Schemes) • Potential air quality and noise Improvement □ No-improvement □ Deterioration □ level (especially for road ) • Drainage congestion Improvement □ Minor Improve □ No Impact □ (especially for drain) • Risk of Water pollution Significant □ Moderate □ Minor □ (especially for storm drain and jetty) • Pollution from solid waste Improvement □ No-improvement □ Deterioration □ (especially for SWM, and market ) (f) Socio-economic impacts: (all Schemes) • Traffic (especially for road, Improvement □ No-improvement □ Adverse □ bridge, box culvert, bus/truck terminal) • Safety Improvement □ No-improvement □ Adverse □ • Employment generation Significant □ Moderate □ Minor □ 3) Summary of Possible environmental impacts of the Schemes : 4) Category of Scheme : (follow Figure 2) (a) According to ECR 1997 : Green / Orange A / Orange B / Red / Not Listed (b) According to WB classification : Category B / Category C 5) Proposed mitigation measure (follow Attachment 7 as appropriate) 6) Overall Comments …………………………………………………………………………………………….. …………………………………………………………………………………………….. Part C: Social Issues Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 52 1. Will there be a need for additional lands to carry out the indented works under this Scheme? [ ] Yes [ ] No 2. If yes, required lands presently belong to- [ ] Government (Khas, other GOB agencies, PS, Public lands); [ ] Private citizens 3. If the required lands are Public Lands, the lands are presently used for: [ ] Agriculture (No. of persons/households using the lands: ……………………..) [ ] Residential purposes (No. of households living on them: …………………….) [ ] Commercial purposes (No. of persons: ..... No. of shops: …….) 4. If the required lands belong to the private citizens, the lands arc presently being used for: [ ] Agriculture (No. of landowners/households: …………………..) [ ] Residential purposes (No. of households: ………………………) [ ] Commercial purposes (No. persons: ......... No. of shops: .... ............. ) Number of non-titled persons/households who would lose their livelihood because of eviction from public lands and/or from obtained on voluntary contribution, or other means: ……………………………………………………………………………………………… 5. Does this Scheme affect any community groups' access to any resources that they use for livelihood? [ ] Yes [ ] No 6. If the land belongs to Small Ethnic Group, is it [ ] Legal [] Customary 7. If additional lands are required, they will be obtained through: [ ] Voluntary contribution [ ] Other means (Specify): ......................................... 8. Negative effects on neighborhood or community characters/behavior/norms? [ ] Yes [ ] No Endorsed by: Signature and Date: Name: Designation Mobile: LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 53 B. SOCIAL SCREENING FORM (Sample) A. Identification 1. Name of ULGI: ……………………..………………… District: …..…………... Ward/Mahalla: ……………………………………………... Upazila: …………………………. 2. Subproject/spot screened: .………….………….………..………………………………..………… …………………………………………………………………………………………………………………… 3. Project component: ............................................................................... 4. Brief description of the physical works: …………………………..................................………..….. …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… …………………………………………………………………………………………………………………… 5. Screening Date(s): ……………………………………………………………………………………… B. Participation in Screening 6. Names of Consultants’ representatives who screened the subproject: …………………….…..… …………………………………..…………………………………………………………………………….... 7. Names of ULGI officials participated in screening: .…………………….…………………………….. ………………………………………………..………………………………………………………………….. ……………………………………………………………………………...……………………………….…... 8. WLCC members, NGOs, community groups/CBOs participated in screening: List them in separate pages with names and addresses, in terms of road sections/spots and any other information to identify them during preparation of impact mitigation plans. 9. Would-be affected persons participated in screening: List them in separate pages with names, addresses in terms of road sections/spots where they would be affected, and any other information to identify them during preparation of impact mitigation plans. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 54 Annex 2: Details of the ECoPs ECoP : Waste Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Waste Soil and water pollution The Contractor shall from the improper • Develop waste management plan for various specific waste management of wastes streams (e.g., reusable waste, flammable waste, construction and excess materials from debris, food waste etc.) prior to commencing of construction the construction sites. and submit to RSC for approval. • Organize disposal of all wastes generated during construction in an environmentally acceptable manner. This will include consideration of the nature and location of disposal site, so as to cause less environmental impact. • Minimize the production of waste materials by 3R (Reduce, Recycle and Reuse) approach. • Segregate and reuse or recycle all the wastes, wherever practical. • Maintain all construction sites in a cleaner, tidy and safe condition and provide and maintain appropriate facilities as temporary storage of all wastes before transportation and final disposal. ECoP : Drainage Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Excavation and Lack of proper drainage for The Contractor shall earth works, and rainwater/liquid waste or • Prepare a program for prevent/avoid standing waters, which construction wastewater owing to the RSC will verify in advance and confirm during implementation yards construction activities • Provide alternative drainage for rainwater if the construction harms environment in works/earth-fillings cut the established drainage line terms of water and soil • Establish local drainage line with appropriate silt collector and contamination, and silt screen for rainwater or wastewater connecting to the mosquito growth. existing established drainage lines already there • Rehabilitate road drainage structures immediately if damaged by contractors’ road transports. • Build new drainage lines as appropriate and required for wastewater from construction yards connecting to the available nearby recipient water bodies. Ensure wastewater quality conforms to the relevant standards provided by DoE, before it being discharged into the recipient water bodies. • Ensure the internal roads/hard surfaces in the construction yards/construction camps that generate has storm water drainage to accommodate high runoff during downpour and that there is no stagnant water in the area at the end of the downpour. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 55 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source • Construct wide drains instead of deep drains to avoid sand deposition in the drains that require frequent cleaning. Ponding of Health hazards due to The Contractor shall water mosquito breeding • Do not allow ponding/storage of water especially near the waste storage areas and construction camps • Discard all the storage containers that are capable of storing of water, after use or store them in inverted position. ECoP : Top Soil Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Land clearing Earthworks will impact the The Contractor shall and earth fertile top soils that are • Strip the top soil to a depth of 15 cm and store in stock piles works enriched with nutrients of height not exceeding 2m. required for plant growth • Remove unwanted materials from top soil like grass, roots of or agricultural trees and similar others. development • The stockpiles will be done in slopes of 2:1 to reduce surface runoff and enhance percolation through the mass of stored soil. • Locate topsoil stockpiles in areas outside drainage lines and protect from erosion. • Construct diversion channels and silt fences around the topsoil stockpiles to prevent erosion and loss of topsoil. • Spread the topsoil to maintain the physico-chemical and biological activity of the soil. The stored top soil will be utilized for covering all disturbed area and along the proposed plantation sites • Prior to the re-spreading of topsoil, the ground surface will be ripped to assist the bunding of the soil layers, water penetration and revegetation. Transport Vehicular movement The Contractor shall outside ROW or temporary • Limit equipment and vehicular movements to within the access roads will affect the approved construction zone soil fertility of the • Construct temporary access tracks to cross concentrated agricultural lands water flow lines at right angles • Plan construction access to make use, if possible, of the final road alignment • Use vehicle-cleaning devices, for example, ramps or wash down areas. ECoP : Topography and Landscaping Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Land clearing Flood plains of the existing The Contractor shall and earth Project area will be • Ensure the topography of the final surface of all raised lands works affected by the (construction yards, approach roads, access roads, bridge end construction of various Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 56 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source project activities. facilities, etc.) are conducive to enhance natural draining of Construction activities rainwater/flood water; especially earthworks will • Keep the final or finished surface of all the raised lands free change topography and from any kind of depression that insists water logging disturb the natural • Undertake mitigation measures for erosion control/prevention rainwater/flood water by grass-turfing and tree plantation, where there is a possibility drainage as well as will of rain-cut that will change the shape of topography. change the local • Cover immediately the uncovered open surface that has no use landscape. of construction activities with grass-cover and tree plantation to prevent soil erosion and bring improved landscaping. ECoP : Air Quality Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Construction Air quality can be The Contractor shall vehicular traffic adversely affected by • Fit vehicles with appropriate exhaust systems and emission vehicle exhaust emissions control devices. Maintain these devices in good working and combustion of fuels. condition. • Operate the vehicles in a fuel-efficient manner Construction Air quality can be The Contractor shall machinery adversely affected by • Fit machinery with appropriate exhaust systems and emissions from machinery emission control devices. Maintain these devices in good and combustion of fuels. working condition in accordance with the specifications defined by their manufacturers to maximize combustion efficiency and minimize the contaminant emissions. Proof or maintenance register shall be required by the equipment suppliers and contractors/subcontractors Construction Dust generation from The Contractor shall activities construction sites, material • Water the material stockpiles, access roads and bare soils on stockpiles and access an as required basis to minimize the potential for roads is a nuisance in the environmental nuisance due to dust. Increase the watering environment and can be a frequency during periods of high risk (e.g. high winds). health hazard. Stored materials such as gravel and sand shall be covered and confined to avoid their being wind-drifted • Minimize the extent and period of exposure of the bare surfaces • Reschedule earthwork activities or vegetation clearing activities, where practical, if necessary to avoid during periods of high wind and if visible dust is blowing off-site • Restore disturbed areas as soon as practicable by vegetation/grass-turfing • Store the cement in silos and minimize the emissions from silos by equipping them with filters. • Establish adequate locations for storage, mixing and loading of construction materials, in a way that dust dispersion is prevented because of such operations LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 57 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source • Crushing of rocky and aggregate materials shall be wet- crushed, or performed with particle emission control systems. ECoP : Noise and Vibration Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Construction Noise quality will be The Contractor shall vehicular traffic deteriorated due to • Maintain all vehicles in order to keep it in good working vehicular traffic order in accordance with manufactures maintenance procedures • Make sure all drivers will comply with the traffic codes concerning maximum speed limit, driving hours, etc. • Organize the loading and unloading of trucks, and handling operations for the purpose of minimizing construction noise on the work site Construction Noise and vibration may The Contractor shall activities have an impact on people, • Notify adjacent landholders prior any typical noise events property, fauna, livestock outside of daylight hours and the natural • Educate the operators of construction equipment on environment. potential noise problems and the techniques to minimize noise emissions • Employ best available work practices on-site to minimize occupational noise levels • Install temporary noise control barriers where appropriate • Notify affected people if major noisy activities will be undertaken, e.g. pile driving • Plan activities on site and deliveries to and from site to minimize impact • Monitor and analyze noise and vibration results and adjust construction practices as required. • Avoid undertaking the noisiest activities, where possible, when working at night near the residential areas. ECoP : Road Transport and Road Traffic Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Construction Increased traffic use of The Contractor shall vehicular traffic road by construction • Prepare and submit a traffic management plan to the RSC for vehicles will affect the his approval at least 30 days before commencing work on any movement of normal road project component involved in traffic diversion and traffics and the safety of management. the road-users. • Include in the traffic management plan to ensure uninterrupted traffic movement during construction: detailed drawings of traffic arrangements showing all detours, temporary road, temporary bridges temporary diversions, necessary barricades, warning signs / lights, and road signs. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 58 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source • Provide signs at strategic locations of the roads complying with the schedules of signs contained in the Bangladesh Traffic Regulations. • Install and maintain a display board at each important road intersection on the roads to be used during construction, which shall clearly show the following information in Bangla: o Location: Village name o Duration of construction period o Period of proposed detour / alternative route o Suggested detour route map o Name and contact address/telephone number of the concerned personnel o Name and contact address / telephone number of the Contractor o Inconvenience is sincerely regretted. Accidents and spillage of The Contractor shall fuels and chemicals • Restrict truck deliveries, where practicable, to day time working hours. • Restrict the transport of oversize loads. • Operate road traffics/transport vehicles, if possible, to nonpeak periods to minimize traffic disruptions. • Enforce on-site speed limit ECoP : Construction Camp Management Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Siting and Location Campsites for The Contractor shall of construction construction workers are • Locate the construction camps at areas which are acceptable camps the important locations from environmental, cultural or social point of view. that have significant • Consider the location of construction camps away from impacts such as health and communities in order to avoid social conflict in using the safety hazards on local natural resources such as water or to avoid the possible resources and adverse impacts of the construction camps on the infrastructure of nearby surrounding communities. communities. • Submit to the RSC for approval a detailed layout plan for the development of the construction camp showing the relative locations of all temporary buildings and facilities that are to be constructed together with the location of site roads, fuel storage areas (for use in power supply generators), solid waste management and dumping locations, and drainage facilities, prior to the development of the construction camps. • Local authorities responsible for health, religious and security shall be duly informed on the set up of camp facilities so as to maintain effective surveillance over public health, social and security matters Construction Lack of proper The Contractor shall provide the following facilities in the campsites: Camp Facilities infrastructure facilities, • Adequate housing for all workers such as housing, water LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 59 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source supply and sanitation • Safe and reliable water supply. facilities will increase • Hygienic sanitary facilities and sewerage system. The toilets pressure on the local and domestic waste water will be collected through a services and generate common sewerage. Provide separate latrines and bathing substandard living places for males and females with total isolation by wall or standards and health by location. The minimum number of toilet facilities required hazards. is one toilet for every ten persons. Disposal of Management of wastes The Contractor shall waste is crucial to minimize • Ensure proper collection and disposal of solid wastes within impacts on the the construction camps environment • Insist waste separation by source; organic wastes in one pot and inorganic wastes in another pot at household level. • Store inorganic wastes in a safe place within the household and clear organic wastes on daily basis to waste collector. Establish waste collection, transportation and disposal systems with the manpower and equipment/vehicles needed. • Dispose organic wastes in a designated safe place on daily basis. At the end of the day cover the organic wastes with a thin layer of sand so that flies, mosquitoes, dogs, cats, rats, are not attracted. One may dig a large hole to put organic wastes in it; take care to protect groundwater from contamination by leachate formed due to decomposition of wastes. Cover the bed of the pit with impervious layer of materials (clayey or thin concrete) to protect groundwater from contamination. • Locate the garbage pit/waste disposal site min 500 m away from the residence so that peoples are not disturbed with the odor likely to be produced from anaerobic decomposition of wastes at the waste dumping places. Encompass the waste dumping place by fencing and tree plantation to prevent children to enter and play with. • Do not establish site specific landfill sites. All solid waste will be collected and removed from the work camps and disposed in approval waste disposal sites. Fuel supplies for Illegal sourcing of fuel The Contractor shall cooking wood by construction • Provide fuel to the construction camps for their domestic purposes workers will impact the purpose, in order to discourage them to use fuel wood or natural flora and fauna other biomass. • Made available alternative fuels like natural gas or kerosene on ration to the workforce to prevent them using biomass for cooking. • Conduct awareness campaigns to educate workers on preserving the protecting the biodiversity and wildlife of the project area, and relevant government regulations and punishments on wildlife protection. Safety In adequate safety The Contractor shall facilities to the • Provide appropriate security personnel (police / home guard construction camps may or private security guards) and enclosures to prevent unauthorized entry in to the camp area. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 60 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source create security problems • Maintain register to keep a track on a head count of persons and fire hazards present in the camp at any given time. • Encourage use of flameproof material for the construction of labor housing / site office. Also, ensure that these houses/rooms are of sound construction and capable of withstanding wind storms/cyclones. • Provide appropriate type of firefighting equipment suitable for the construction camps • Display emergency contact numbers clearly and prominently at strategic places in camps. • Communicate the roles and responsibilities of laborers in case of emergency in the monthly meetings with contractors Site Restoration Restoration of the The Contractor shall construction camps to • Dismantle and remove from the site all facilities established original condition within the construction camp including the perimeter fence requires demolition of and lockable gates at the completion of the construction construction camps. work. ECoP : Worker Health and Safety Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source Best practices Construction works may The Contractor shall pose health and safety • Implement suitable safety standards for all workers and site risks to the construction visitors which shall not be less than those laid down on the workers and site visitors international standards (e.g. International Labor Office leading to severe injuries guideline on ‘Safety and Health in Construction; World Bank and deaths. The Group’s ‘Environmental Health and Safety Guidelines’) and population in the contractor’s own national standards or statutory proximity of the regulations, in addition to complying with the national construction site and the standards of the Government of Bangladesh (e.g. `The construction workers will Bangladesh Labor Code, 2006’) be exposed to a number • Provide the workers with a safe and healthy work of (i) biophysical health environment, taking into account inherent risks in its risk factors, (e.g. noise, particular construction activity and specific classes of dust, chemicals, hazards in the work areas, construction material, • Provide personal protection equipment (PPE) for workers, solid waste, waste water, such as safety boots, helmets, masks, gloves, protective vector transmitted clothing, goggles, full-face eye shields, and ear protection. diseases etc), (ii) risk Maintain the PPE properly by cleaning dirty ones and factors resulting from replacing them with the damaged ones. human behavior (e.g. • Safety procedures include provision of information, training STD, HIV etc) and (iii) and protective clothing to workers involved in hazardous road accidents from operations and proper performance of their job construction traffic. • Appoint an environment, health and safety manager to look after the health and safety of the workers • Inform the local authorities responsible for health, religious and security duly informed before commencement of civil LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 61 Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines Impact Source works and establishment of construction camps so as to maintain effective surveillance over public health, social and security matters. Child and pregnant labor The Contractor shall • not hire children of less than 14 years of age and pregnant women or women who delivered a child within 8 preceding weeks, in accordance with the Bangladesh Labor Code, 2006 Water and Lack of Water sanitation • The contractor shall provide portable toilets at the sanitation facilities at construction construction sites, if about 25 people are working the whole facilities at the sites cause day for a month. Location of portable facilities shall be at construction sites inconvenience to the least 6 m away from storm drain system and surface waters. construction workers These portable toilets shall be cleaned once a day and all the and affect their personal sewerage shall be pumped from the collection tank once a hygiene. day and shall be brought to the common septic tank for further treatment. • Contractor shall provide bottled drinking water facilities to the construction workers at all the construction sites. Trainings Lack of awareness and The Contractor shall basic knowledge in • Train all construction workers in basic sanitation and health health care among the care issues (e.g., how to avoid malaria and transmission of construction workforce, sexually transmitted infections (STI) HIV/AIDS. make them susceptible • Train all construction workers in general health and safety to potential diseases. matters, and on the specific hazards of their work Training shall consist of basic hazard awareness, site specific hazards, safe work practices, and emergency procedures for fire, evacuation, and natural disaster, as appropriate. • Commence the malaria, HIV/AIDS and STI education campaign before the start of the construction phase and complement it with by a strong condom marketing, increased access to condoms in the area as well as to voluntary counseling and testing. • Implement malaria, HIV/AIDS and STI education campaign targeting all workers hired, international and national, female and male, skilled, semi- and unskilled occupations, at the time of recruitment and thereafter pursued throughout the construction phase on ongoing and regular basis. This shall be complemented by easy access to condoms at the workplace as well as to voluntary counseling and testing. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 62 Annex 3: Workforce Health and Safety Under COVID-19 Pandemic in Bangladesh (a) The PIU/ULGIs should identify measures to address the COVID-19 situation. What will be possible will depend on the context of the project activities: the location, existing resources, availability of supplies, capacity of local emergency/health services, the extent to which the virus already exist in the area. A systematic approach to planning, recognizing the challenges associated with rapidly changing circumstances, will help the project put in place the best measures possible to address the situation. PIU should refer to guidance issued by relevant authorities, both national and international (e.g. WHO). Addressing COVID-19 at a project site goes beyond occupational health and safety and is a broader project issue which will require the involvement of different members of a project management team. Assessing Workforce Characteristics • Breakdown of workers temporarily hired (i.e. workers from the community), and government officials. Where possible, there should be health check before employment, as workers that may be more at risk from COVID-19, those with underlying health issues or who may be otherwise at risk. • Consideration should be given to ways in which to minimize movement in and out of site to avoid workers returning home to affected areas. • Consideration should be given to requiring workers lodging in the local community to move to separate lodging facility (subject to availability) where they would be subject to the same restrictions. • Workers from local communities, who return home daily will be more difficult to manage. They should be subject to health checks regularly and at some point, circumstances may make it necessary to require them to either use accommodation on site or not to come to work. • Establishing a system for controlling entry/exit to the site, securing the boundaries of the site, and establishing designating entry/exit points (if they do not already exist). Entry/exit to the site should be documented. • Training security staff on the (enhanced) system that has been put in place for securing the site and controlling entry and exit, the behaviors required of them in enforcing such system and any COVID - 19 specific considerations. • Confirming that workers are fit for work before they enter the site or start work. While procedures should already be in place for this, special attention should be paid to workers with underlying health issues or who may be otherwise at risk. Consideration should be given to demobilization of staff with underlying health issues. • Checking and recording temperatures of workers and other people entering the site or requiring self- reporting prior to or on entering the site. • Providing daily briefings to workers prior to commencing work, focusing on COVID-19 specific considerations including cough etiquette, hand hygiene and distancing measures, using demonstrations and participatory methods. • During the daily briefings, reminding workers to self-monitor for possible symptoms (fever, cough) and to report to their supervisor or the COVID-19 focal point if they have symptoms or are feeling unwell. • Preventing a worker from an affected area or who has been in contact with an infected person from returning to the site for 14 days or (if that is not possible) isolating such worker for 14 days. • Preventing a sick worker from entering the site, referring them to local health facilities if necessary or requiring them to isolate at home for 14 days. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 63 • All rental vehicles should be parked in a secured place and no unauthorized use should be stopped until the contract is over. • Placing posters and signs around the site, with images and text in local languages. • Ensuring handwashing facilities supplied with soap, disposable paper towels and closed waste bins exist at key places throughout site, including at entrances/exits to work areas; where there is a toilet, canteen or food distribution, or provision of drinking water; in worker accommodation; at waste stations; at stores; and in common spaces. Where handwashing facilities do not exist or are not adequate, arrangements should be made to set them up. Alcohol based sanitizer (if available, 60-95% alcohol) can also be used. • Review worker accommodations, and assess them in light of the requirements set out in IFC/EBRD guidance on Workers’ Accommodation: processes and standards, which provides valuable guidance as to good practice for accommodation. • Setting aside part of worker accommodation for precautionary self-quarantine as well as more formal isolation of staff who may be infected. Persons with symptoms should: ▪ wear a medical mask, self-isolate, and seek medical advice as soon as they start to feel unwell. Symptoms can include fever, fatigue, cough, sore throat, and difficulty breathing. It is important to note that early symptoms for some people infected with COVID-19 may be very mild; ▪ follow instructions on how to put on, take off, and dispose of medical masks; ▪ follow all additional preventive measures, in particular, hand hygiene and maintaining physical distance from other persons. All persons should: ▪ avoid groups of people and enclosed, crowded spaces; ▪ maintain physical distance of at least 1 m from other persons, in particular from those with respiratory symptoms (e.g., coughing, sneezing); ▪ perform hand hygiene frequently, using an alcohol-based hand rub if hands are not visibly dirty or soap and water when hands are visibly dirty; ▪ cover their nose and mouth with a bent elbow or paper tissue when coughing or sneezing, dispose of the tissue immediately after use, and perform hand hygiene; ▪ refrain from touching their mouth, nose, and eyes. (b) Cleaning and Waste Disposal Conduct regular and thorough cleaning of all site facilities, including offices, accommodation, canteens, common spaces. Review cleaning protocols for key construction equipment (particularly if it is being operated by different workers). This should include: • Providing cleaning staff with adequate cleaning equipment, materials and disinfectant. • Review general cleaning systems, training cleaning staff on appropriate cleaning procedures and appropriate frequency in high use or high-risk areas. • Where it is anticipated that cleaners will be required to clean areas that have been or are suspected to have been contaminated with COVID-19, providing them with appropriate PPE: gowns or aprons, gloves, eye protection (masks, goggles or face screens) and boots or closed work shoes. If appropriate PPE is not available, cleaners should be provided with best available alternatives. • Training cleaners in proper hygiene (including handwashing) prior to, during and after conducting cleaning activities; how to safely use PPE (where required); in waste control (including for used PPE and cleaning materials). Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 64 • Any medical waste produced during the care of ill workers should be collected safely in designated containers or bags and treated and disposed of following relevant requirements (e.g., national, WHO). If open burning and incineration of medical wastes is necessary, this should be for as limited a duration as possible. Waste should be reduced and segregated, so that only the smallest amount of waste is incinerated (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19). • All vehicles should be cleaned thoroughly with disinfectants after returning to the parking facilities. Disposal of Personal Protective Equipment (PPE): The project intends to provide reusable (Cloth) masks since it can be washed and reused and waste at downstream will be less. The masks are washed daily if used for a significant period during the day. Washing can be by hand or machine wash (use warm or hot water) using normal household laundry detergent and/or color safe bleach. If PPE is exposed to infectious materials during use (e.g., body fluids from an infected person) the PPE is considered contaminated and the wearer should remove it promptly, using proper removal procedures. It is essential that used PPE is stored securely within disposable rubbish bags. Based on the PPEs quality, the PPEs need to be burnt or washed or buried. Otherwise, these bags should be placed into another bag, tied securely, marked (with date) and kept separate from other waste within the room. This should be put aside for at least 72 hours before being disposed of as normal. (c) Local Medical and Other Services • Given the limited scope of project medical services, the project may need to refer sick workers to local medical services. Liaise with the relevant local authorities and obtain information as to the resources and capacity of local medical services (e.g. number of beds, availability of trained staff and essential supplies). LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 65 Annex 4: Quarterly Grievance Report Period from………………….…………to……………………………………2021 Project Phase:…………………………………………. Case Complainant’s Nature of complaints and expectation Date of Method of Decisions and Agreement Progress Reason, if No. name, gender of complainant Petition resolution date of with and (solved/ pending and location submitted with dates communication commitment to pending) to the complainant complainant Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 66 Annex 5: Summary of Applicable Environmental, Social and Safeguards Regulations of GOB S.No. Policies/Act/Rules Key provisions and purpose Applicability to LGCRRP Project 1. Bangladesh Environmental This umbrella Act includes laws for conservation of the Yes, LGCRRP project needs NOC from the Conservation Act (ECA), 1995 environment, improvement of environmental standards, and local authority and ECC from the DoE. control and mitigation of environmental pollution. According to this act (Section 12), no industrial unit or project shall be established or undertaken without obtaining, in a manner prescribed by the accompanying Rules, an Environmental Clearance Certificate (ECC) from the Director General of DoE. 2. Bangladesh Environmental The Rule 7 classifies industrial units and projects into four Yes, some of the LGCRRP interventions may Conservation Rules (ECR), 1997 categories depending on environmental impact and location for be fallen under Orange B category, hence the purpose of issuance of ECC. These categories are: Green, would require both IEE, ESIA and ESMP Orange A, Orange B, and Red. The ECR'97 describes the approved by the DoE and have to deposit procedures for obtaining Environmental Clearance Certificates prescribe fees according to the schedule 13 (ECC) from the Department of Environment for different types of to obtain ECC. proposed units or projects. 3. Bangladesh Environment Court Bangladesh Environment Court Act, 2010 has been enacted to According to this act, government can take Act, 2010 resolve the disputes and establishing justice over environmental legal actions if any environmental problem and social damage raised due to any development activities. occurs due to LGCRRP interventions. 4. The Protection and Conservation This Act provides power to the government to: make and apply Yes, as the LGCRRP includes renovation of of Fish Act (1950) rules to protect fisheries; prohibit or regulate pollution to the existing buildings, operation of lab facilities, water bodies. installation of equipment’s, use of chemical substances, potential solid and liquid waste generation, etc. which has potential risk for water pollution and habitat alternation, if not properly managed. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 67 S.No. Policies/Act/Rules Key provisions and purpose Applicability to LGCRRP Project 5. Protection and Conservation of Section 6 states, “No person shall destroy or make any attempt to Yes, mostly during Fish Rules (1985) destroy any fish by poisoning of water or the depletion of fisheries construction/reconstruction/ refurbishment by pollution, by trade effluents or otherwise in inland waters. of the buildings, and waste management. 6. Bangladesh Wildlife (Protection The Act protects 1,307 species of plants and animals, including 32 Yes, project area might have presence of and Preservation) Act 2012 species of amphibian, 154 species of reptile, 113 species of these listed threatened animals in old mammal, 52 species of fish, 32 species of coral, 137 species of campuses. mollusk, 22 species of crustacean, 24 species of insect, six species of rodent, 41 species of plant and 13 species of orchid. Of these, eight amphibian, 58 reptile, 41 bird, and 40 mammal species are listed as endangered in the IUCN Red Data Book (2000, updated in 2015). 7. Bangladesh Labor Act, 2006, (as It provides the guidance of employer’s extent of responsibility and Yes, LGCRRP activities require labor from amended 2018); Bangladesh workmen’s extent of right to get compensation in case of injury by local and external areas. Labor Rules, 2015; and accident while working. Bangladesh Child Labor Mitigation Policy, 2010 8. Bangladesh National Building The BNBC clearly sets out the constructional responsibilities Yes, LGCRRP will include construction or Code, 2006 according to which the relevant authority of a particular renovation or expansion of existing buildings, construction site shall adopt some precautionary measures to etc. ensure the safety of the workmen. The Code also clarifies the issue of safety of workmen during construction. 9. The Noise Pollution Control Rules, The Noise Pollution Control Rules have been established in order Yes, many activities of the project will be 2006 to manage noise generating activities which have the potential to performed under the dense populated areas. impact the health and wellbeing of workers and the surrounding communities. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 68 S.No. Policies/Act/Rules Key provisions and purpose Applicability to LGCRRP Project 10. Road Transport Act, 2018 The new Road Transport Act 2018 has finally come into effect at Yes, LGCRRP project will use vehicles, deploy the start of November. After the long-standing Motor Vehicle drivers and operators of machineries in Ordinance of 1983, the new act introduces a myriad of updated construction sites of existing campuses. laws and adds new definitions for what constitutes an offence, with most of the fines and punishments receiving major bumps. 11. The Water Supply and Sanitation Regulates the management and control of water supply and Yes, LGCRRP will include construction of Act (1996) sanitation in urban areas. water supply and sanitation facilities. 12. The Ground Water Management Describes the management of ground water resources and Yes, construction sites may require deep Ordinance (1985) licensing of tube wells tube wells for meeting up water use. 13. The Antiquities Act (1968) Describes the preservation of cultural heritage, historic Yes, project locations may have elements of monuments and protected sites cultural, historic and protected value. 14. Acquisition and Requisition of The principal legal instrument governing land acquisition in No, project does not plan to acquisition or Immovable Property Act, 2017 Bangladesh is the Acquisition and Requisition of Immovable requisition of new land, but the potential Property. sites for construction are yet not identified. 15. Bangladesh Medical Waste The Government of Bangladesh promulgated the Medical Yes, project intervention of modernization Management and Processing waste (management and processing) Rule, 2008 for processing and operation of medical/health institutions Rules 2008 and management of MW in Bangladesh. The environmental may generate medical waste. assessment must show whether the wastes will be disposed of following the mechanism devised by rules. 16. Bangladesh Biosafety Guideline Biosafety guidelines are applicable to all research and Yes, project intervention of modernization 2007 development activities of modern biotechnology conducted in and operation of medical/health facilities laboratories of the government research institutes, state those may use hazardous enterprises, universities, international organizations located in chemicals/medicines. LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 69 S.No. Policies/Act/Rules Key provisions and purpose Applicability to LGCRRP Project Bangladesh, private companies or non-governmental organizations. It applies to laboratory and field trial, trans- boundary movement, transit, handling and use of all GMOs/LMOs that may have adverse effects on the conservation and sustainable use of biological diversity, taking also into account risks to human health. 17. The East Bengal State Acquisition The East Bengal State Acquisition and Tenancy Act 1950 (Act XV of No, project does not plan to acquisition or and Tenancy Act 1950 (Act XV of 1951) provides the ownership of diluvion land (eroded into river) requisition of new land, but the potential 1951) and alluvion land (accreted in situ). Land on the riverside of the sites for construction are yet not identified. AD line is public land and that on the countryside is governed by recorded ownership. 18. CHT (Land Acquisition) The Regulation replaces certain sections of the CHT 1900 Act, but Yes, as some to the project targeted Regulation, 1958 (as amended it was specifically adopted to clarify the government’s authority institutions are situated in the CHT area. 2019) for acquisition of land on the eve of the Kaptai dam construction. And, project has dedicated activities In the process, it remains as the most important legal instrument involving small ethnic communities (SEC). for the government with regard to land acquisition in the region. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 70 Annex 6: CERC Positive and Negative List A. CERC Positive List The positive list of works, services, non-consulting services and goods eligible for CERC component is shown in the list below. The works that will be financed under CERC will be those which do not trigger new ESS under the RISE program. Goods • Medical equipment and supplies • Non-perishable foods, bottled water and containers • Tents for advanced medical posts, temporary housing, and classroom/day-care substitution • Equipment and supplies for temporary housing/living (gas stoves, utensils, tents, beds, sleeping bags, mattresses, blankets, hammocks, mosquito nets, kit of personal and family hygiene, etc.) and school • Gasoline and diesel (for air, land and sea transport) and engine lubricants • Spare parts, equipment and supplies for engines, transport, construction vehicles • Lease of vehicles (Vans, trucks and SUVs) • Equipment, tools, materials and supplies for search and rescue (including light motor boats and engines for transport and rescue) • Tools and construction supplies (roofing, cement, iron, stone, blocks, etc.) • Equipment and supplies for communications and broadcasting (radios, antennas, batteries, and cell phones) • Water pumps and tanks for water storage • Equipment, materials and supplies for disinfection of drinking water and repair/rehabilitate of black water collection systems • Construction materials, equipment and industrial machinery • Water, air, and land transport equipment, including spare parts • Temporary toilets LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 71 • Groundwater boreholes, cargos, equipment to allow access to affected site, storage units • Any other item agreed on between the World Bank and the Burrowers (as documented in an Aide- Memoire or other appropriate formal Project document) Services and non-consulting services • Consulting services related to emergency response including, but not limited to urgent studies and surveys necessary to determine the impact of the disaster and to serve as a baseline for the recovery and reconstruction process, and support to the implementation of emergency response activities • Feasibility study and technical design • Works supervision • Technical Assistance in developing ToRs, preparing Technical Specifications and drafting tendering documents (Bidding Documents, ITQ, RFP) • Non-consultant services including, but not limited to: drilling, aerial photographs, satellite images, maps and other similar operations, information and awareness campaigns • Non-consultant services to deliver any of the activities described in the “Goods� section of this table (e.g., de bris removal, dump trucks, drones survey) Works • Repair of damaged infrastructure including, but not limited to: water supply and sanitation systems, reservoirs, canals, roads, bridges and transportation systems, energy and power supply, telecommunication, and other infrastructure damaged by the event • Re-establish of the urban and rural solid waste system, water supply and sanitation (including urban drainage) • Repair of damaged public buildings, including schools, hospitals and administrative buildings • Repair, restoration, rehabilitation of schools, clinics, hospitals • Removal and disposal of debris associated with any eligible activity Training • Conduct necessary training related to emergency response including, but not limited to the implementation of EAP Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD Environmental and Social Management Framework 72 • Training on rapid needs assessment and other related assessments Emergency Operating Costs • Incremental expenses should be borne by GoB source of funds for a defined period related to early recovery efforts arising as a result of the impact of an eligible emergency B. CERC Negative List In no case shall the activities for financing under the CERC exceed the environmental and social standards presented in the LGCRRP PAD, ESMF and RPF prepared prior to project approval. CERC activities will not trigger any new ESS. The following uses of LGCRRP resources by the CERC are prohibited: • Activities that would lead to conversion or degradation of critical forest areas, critical natural habitats, and clearing of forests or forest ecosystems • Activities affecting protected areas (or buffer zones thereof) • Land reclamation (i.e., drainage of wetlands or filling of water bodies to create land) • Land clearance and levelling in areas that are not affected by debris resulting from the eligible crisis or emergency • River training (i.e., realignment, contraction or deepening of an existing river channel, or excavation of a new river channel) • Activities that will result in the involuntary taking of land, relocation of households, loss of assets or access to assets that leads to loss of income sources or other means of livelihoods, and interference with households’ use of land and livelihoods • Construction of new roads, realignment of roads, or expansion of roads, or rehabilitation of roads that are currently located on communal lands but will be registered as government assets after rehabilitation • Use of goods and equipment on lands abandoned due to social tension / conflict, or the ownership of the land is disputed or cannot be ascertained • Use of goods and equipment to demolish or remove assets, Unless the ownership of the assets can be ascertained, owners consulted, assets valued, and losses compensated for in line with the program’s RPF • Uses of goods and equipment involving forced labor, child labor, or other harmful or exploitative forms of labor • Uses of goods and equipment for activities that would affect indigenous peoples, unless due consultation and broad support has been documented and confirmed prior to the commencement of the activities as well as preparation of necessary mitigation and plans compliant with ESS7 • Uses of goods and equipment for military or paramilitary purposes • Uses of goods and equipment in response to conflict, in any area with active military or armed group operations • Activities related to returning refugees and internally displaced populations LGD Local Government COVID-19 Response and Recovery Project (LGCRRP) Environmental and Social Management Framework 73 Activities which, when being carried out, would affect, or involve the use of, water of rivers or of other bodies of water (or their tributaries) which flow through or are bordered by countries other than the Borrower/Recipient, in such a manner as to in any way adversely change the quality or quantity of water flowing to or bordering said countries. Local Government COVID-19 Response and Recovery Project (LGCRRP) LGD