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A Civil Society Study Report
Bhola IPP and its Impact on Local Communities
VOICES FROM THE GROUND
Hasan Mehedi
Sajjad Hossain Tuhin
Mahbub Alam Prince
Bhola IPP and its Impact on Local Communities
VOICES FROM THE GROUND
A Civil Society Study Report
Hasan Mehedi
Sajjad Hossain Tuhin
Mahbub Alam Prince
4 Mallick Bari Road, Boyra-Rayermahal
Khulna 9000, Bangladesh
Phone: +8801976702006; Email: clean.khulna@gmail.com
@CLEAN, 2018
Bhola IPP and its Impact on Local Communities
Voices from the Ground
A Civil Society Study Report
Publication
September 2018
Prepared by
Hasan Mehedi
Sajjad Hossain Tuhin
Mahbub Alam Prince
Cover Photo
Chimney of existing BPDB Power Plant (Bhola-I)
Supported by
NGO Forum on ADB
Expected Citation
Mehedi, H., Tuhin, S.H. and Prince, M.A. (2018). Bhola IPP and its
Impact on Local Communities: Voices from the Ground: A Civil Society
Study Report. CLEAN (Coastal Livelihood and Environmental Action
Network) and Bangladesh Working Group on External Debt
(BWGED), Khulna: September 2018
Published by
CLEAN (Coastal Livelihood and Environmental Action Network) and
Bangladesh Working Group on External Debt (BWGED)
CONTENTS
Acronyms 4
Glossary 6
Acknowledgement 7
Location: Bhola IPP 8
1. Background 09-12
2. Scope of the Study 13-14
3. Objectives 15-16
4. Process & Methodology 17-22
4.1 Literature Review 17
4.2 Secondary Data Collection 18
4.3 Field Observation 19
4.4 Key Informant Interview (KII) 20
4.5 Focus Group Discussion (FGD) 20
4.6 Study Team 21
4.7 Timeline of the Study 22
5. Challenges 23-24
6. The Area 25-30
6.1 Socioeconomic Conditions 27
6.2 Climatic Conditions 29
7. The Bhola IPP Project 31-32
8. Key Findings 33-62
8.1 Human Rights & Civic Space 33
8.2 Meaningful Consultation 35
8.3 Land Acquisition 37
8.4 Information Disclosure & Right to Know 41
8.5 Social and Environmental Impacts 44
8.6 Eligibility & Legitimacy 55
8.7 Emerging Concern 61
9. Recommendations 63-64
10. References 65-74
04 Voices from the Ground: A Civil Society Study Report
ACRONYMS
ADB Asian Development Bank
AIIB Asian Infrastructure Investment Bank
BBS Bangladesh Bureau of Statistics
Bhola IPP Bhola Integrated Power Plant (Bhola-II)
BPC Bangladesh Petroleum Corporation
BPDB Bangladesh Power Development Board
BOO Build, Operate and Own
BWGED Bangladesh Working Group on External Debt
CCPP Combined Cycle Power Plant
CLEAN
Coastal Livelihood and Environmental Action Network
DAE Department of Agricultural Extension
EIA Environmental Impact Assessment
ERM
Environmental Resources Management Private Limited
ESF Environmental and Social Framework
ESIA Environmental and Social Impact Assessment
ESS1 Energy Sector Strategy
ESS2 Environmental and Social Summary
FGD Focus Group Discussion
FPIC Free, Prior and Informed Consent
GAP Gender Action Plan
GOB Government of Bangladesh
GRM Grievance Redressal Mechanism
HH Household
HSD High Speed Diesel
IEE Initial Environmental Examination
IPP Independent Power Plant
05
Bhola IPP and its Impact on Local Communities
IsDB Islamic Development Bank
JICA Japan International Cooperation Agency
KII Key Informant Interview
LIMP Labour and Influx Management Plan
LGI Local Government Institute
MOEFC Ministry of Environment, Forest and Climate Change
MOLJPA Ministry of Law, Justice and Parliamentary Affairs
NBBL Nutan Bidyut Bangladesh Limited
NDC Nationally Determined Contributions
NEMAP National Environmental Management Action Plan
NEP National Environment Policy 1992
PCA Principal Component Analysis
PPA Power Purchase Agreement
PESMP Power & Energy Sector Master Plan
PGCB Power Grid Company of Bangladesh
PIIP Public Information Interim Policy
PPI Policy on Public Information (PIIP)
PPM Project-affected People's Mechanism
PSI Project Summary Information
RF Resettlement Framework
RPF Resettlement Planning Framework
SEP Stakeholder Engagement Plan
SGCL Sundarban Gas Company Limited
SP Group Shapoorji Pallonji Group
SP Infra Shapoorji Pallonji Infrastructure Company Limited
UNICEF United Nations Children's Fund
UP Union Parishad
USD United States Dollar
Upz Upazila
06 Voices from the Ground: A Civil Society Study Report
GLOSSARY
Paan Betel Leaf (Piper betle L.)
Bidyut Electricity/power
Char River strip or low land on river bank
Char land Grassland of Char
Ilish Hilsa Fish (Tenualosa ilisha Hamilton, 1822)
Khal Tidal Canal; natural water channel or creek which
works as a distributary of river or sea
Mound Around 37.5 kg
Parishad Council/Authority
Shakha Branch/distributary
Union Lowest administrative and local government
institute (LGI) of Bangladesh consisting of 13 - 20
villages (10,000 - 25,000 population) divided into 9
wards.
Upazila Sub-district; a local government institute (LGI)
under District and above Union. An Upazila consists
of 3 - 15 Unions
07
Bhola IPP and its Impact on Local Communities
ACKNOWLEDGEMENT
The study team would like to express sincere
gratitude to all of the villagers of Chhota
Manika, Dakshin Kutba, Gazipur Char,
Kutba and Shantipara villages for their
cordial participation, cooperation and
support even in a dreadful environment.
Hearty thanks go to Annabel Perreras, Azad
Abul Kalam, Biswajit Chandra Dey,
Mobashsher Hasan Shipon, Rayyan Hassan,
Reshma Begum, Sampad Chandra Dey,
Shafiqul Islam Sohag, Tapan Chandra Dey,
Vidya Dinker and M. Zakir Hossain Khan for
the continuous support, insightful
comments, stimulating discussions and
editing the report.
The team also grateful to NGO Forum on
ADB for its technical and financial support to
conduct the study.
08 Voices from the Ground: A Civil Society Study Report
LOCATION: BHOLA IPP
09
Bhola IPP and its Impact on Local Communities
BACKGROUND
01
After winning the general election in December 2008, the
present Grand Alliance government (led by the Bangladesh
Awami League) planned to boost electricity generation to
promote rapid economic development. To ensure
unquestioned construction of power plants the Government of
Bangladesh (GOB) endorsed the Quick Enhancement of
Electricity and Energy Supply (Special Provisions) Act, 2010
which has given immunity to all projects related with energy
and power. This denies citizens the right to approach the courts
for relief in case of injustice and destruction committed by
power plants1. The GOB also undertook a Policy guideline
called Policy Guidelines for Enhancement of Private
Participation in the Power Sector 20082. Under the policy,
administrative control has been deregulated to attract private
sector invest in the energy sector.
Later, the GOB also formulated a Power System Master Plan
(PSMP) in 20103 and Power & Energy Sector Master Plan
10 Voices from the Ground: A Civil Society Study Report
(PESMP) in 2016 under direct assistance from Japan
International Cooperation Agency (JICA) with a goal of
fulfilling 61% of total energy from fossil fuel including 35%
from coal by 20414. By endorsing this Master Plan, the GOB
violates its own pledge in the CVF Marrakech Communique
which is committed to shift to renewables as fast as possible5. It
is also contrary with the country's Nationally Determined
Contributions (NDC)6 which pledges to reduce 5% of estimated
emission voluntarily and additional 15% emission under
assistance from developed countries by 2030.
After policy reformation on energy sector, a number of new
bilateral investors like China, Germany, India, Japan, Korea,
Malaysia, Singapore and Spain started implementing a number
of energy projects besides the traditional and new multilateral
financial institutes including World Bank, Islamic
Development Bank (IsDB), Asian Development Bank (ADB)
and Asian Infrastructure Investment Bank (AIIB)7. Till
September 2018, AIIB has invested USD 285 million in three
projects in the energy sector including Bhola Integrated Power
Plant (Bhola IPP) Project8.
Bhola is the only island district of Bangladesh under the
administrative division of Barisal. Historically it has
experienced shortage of electricity due to grid connection
difficulties. After getting natural gas from Shahbazpur gas
field, the GOB permitted Venture Energy Resources Limited, a
local company to install 34.7 MW gas-based power plant. The
second power plant, 225 MW gas-based Bhola Gas-based
Power Plant (also called Bhola-I) in Kutba Union under
Burhanuddin Upazila, had been constructed in 2015 and
started generating power in the same year. Bangladesh Power
Development Board (BPDB) also planned to construct another
225 MW gas-based power plant along with 4 others, as per the
public declaration of the commerce minister9.
Simultaneously BPDB had signed another agreement in
September 2012 with Indian company Lanco Power
11
Bhola IPP and its Impact on Local Communities
International Private Limited to construct a gas-based power
plant beside Bhola-I on Build, Operate and Own (BOO) basis10.
Later, the agreement was cancelled and a new agreement was
signed in July 2015 with Shapoorji Pallonji Infrastructure Capital
Company Private Limited (SP Infra), a subsidiary of
Mumbai-based Shapoorji-Pallonji Group (SP Group) to construct
an Independent Power Plant (IPP) in the same area11&12. It was an
unsolicited agreement as it was signed without any open bidding
process13. Initially SP Group planned to transfer a half-done
power plant from Uttarakhand, India to Bhola, Bangladesh but
later it changed the decision as BPDB raised several questions on
the quality of existing power plant and process of transferring14.
According to the agreement, the power plant project will be fully
funded by SP Group15. After getting clearance from the GOB, the
Group registered a new company named Nutan Bidyut
Bangladesh Limited (NBBL) on 27 March 2016 to operate energy
business in Bangladesh16. Later it is revealed in January 2018 that
SP Group submitted a proposal to AIIB for private sector
financing in implementation of Bhola IPP17. AIIB approved the
project on 9 February 201818. Later, in June 2018, NBBL signed
separate agreement with IsDB to finance another USD 60 million
for the project19.
The power plant will use pipelined natural gas from Shahbazpur
Gas field owned by Sundarban Gas Company Ltd. (SGCL) as
primary fuel and High Speed Diesel (HSD) from Bangladesh
Petroleum Corporation (BPC) as a backup fuel to generate 225
MW power20. But according to different reports, NBBL will use
both of the fuels to generate 220 MW and 212 MW power
respectively21. The NBBL signed an agreement with BPDB to sell
generated electricity to Power Grid Company of Bangladesh
(PGCB) for next 22 years against a price higher than the state
owned companies22. The plant acquired 17.28 acres of land for
the project in which 11.5 acres leased from BPDB and 5.78 acres
has been purchased from local land owners. Other 5.5 acres of
land is required for gas pipeline and acquired by SGCL23.
12 Voices from the Ground: A Civil Society Study Report
The power plant will be likely to increase total power generation
of the country, but the question is who will sacrifice their lives
and livelihoods for electricity? The common people who depend
on the nature and natural resources to survive, or the big
companies who make profit from different investments? The
question takes us to the issues of climate change as Bhola is one
of the most vulnerable climate hotspots in the world which has
experienced several devastating cyclones and storm surges
including the commonly known ‘great Bhola cyclone’ which in
1970 took at least 500,0000 lives from this small island24.
13
Bhola IPP and its Impact on Local Communities
02
SCOPE OF THE STUDY
This study is solely inspired by the Constitution of the People's
Republic of Bangladesh which states in Article 18A. that "the
State shall endeavour to protect and improve the environment
and to preserve and safeguard the natural resources,
bio-diversity, wetlands, forests and wild life for the present and
future citizens25." Several policy instruments have been endorsed
by the GOB to comply with the constitution. Some of them are:
Bangladesh National Conservation Strategy (NCS) 1992
confirms that the state shall conserve the indigenous species
and natural elements of the country for next generation26.
Bangladesh Water Act (BWA) 2013 confirms justified use of
water and water licensing for the corporate and large scale
water use27.
Right to Information (RTI) Act 2009 which ensures
availability of information and accessibility of the citizens to
that information from public and private sector28.
The Easements Act 1882, which ensures the customary and
legal rights of common people to access their private and
common properties29.
National Environment Policy (NEP) 1992 pledges to
maintain ecological balance and ensure sustainable
development of the country through protection,
conservation and improvement of the environment30.
National Environment Management Action Plan (NEMAP)
1995 is committed to conserve habitats and biodiversity,
improve natural environment and promote sustainable
development for improvement of the quality of citizen's
life31.
National Water Policy (NWP) 1999 confirms availability of
water to all elements of the society including the poor
people, and natural fish and fisheries32.
14 Voices from the Ground: A Civil Society Study Report
National Fisheries Policy (NFP) 2006 covers preservation,
management and exploitation of fisheries resources in
inland open water33.
Noise Pollution (Control) Rules 2006 which defines
acceptable level of sound and noise pollution for the citizens
in residential and industrial areas34.
Wildlife (Conservation and Security) Act (WCSA) 2012
includes threatened flora and fauna as protected species in
its schedules35.
Besides, AIIB has come out with a number of policy directions of
a mandatory nature for its borrowing clients. Some of the notable
policy documents are Environmental and Social Framework
(ESF)36, Public Information Interim Policy (PIIP) 201637, Draft
Policy on Public Information (PPI) 201838, Energy Sector
Strategy: Sustainable Energy for Asia (subsequently amended in
2018)39 and Enhancing AIIB's Accountability: the Project-affected
People's Mechanism (draft for Phase II public consultation)40.
DOn principle these documents are, there to ensure that AIIB
address environmental and social safeguards, transparency and
due process in all there operations. Although there are evident
weaknesses in these policies yet there remains the commitment
to address these issues from the perspective of bank policy
compliance.
This study is highly inspired by national, regional and
international policy documents and intends to monitor Bhola IPP
as a response to the number of complaints received about the
project from affected communities of Burhanuddin Upazila,
Bhola. The study's scope is:
Assessment of public opinions on the Bhola IPP Project
Assessment of NBBLs project implementation process.
Screening of the project components in the light of national
social, environmental and human rights standards
Assessment of environmental and social impacts of the project
Assessment of the Environmental and Social Impact
Assessment (ESIA) report based on ground reality
Developing a set of community based and local civil society
recommendations according to people's opinions.
15
Bhola IPP and its Impact on Local Communities
03
OBJECTIVES
The broader objective of this investigative study is to assess
environmental and social impacts of the Bhola IPP project
implemented by NBBL and financed by AIIB and IsDB in
Burhanuddin Upazila, Bhola District, Bangladesh.
The specific objectives of the study are to assess:
1. To assess:
1.1. Engagement in Meaningful consultation with the local
communities as described in vision (paragraph 13) of
the ESF41; paragraph 4(a) under Environmental and
Social Assessment and Management standards
(ESS1)42 and paragraph-4 under Involuntary
Resettlement standards (ESS2)43 of Environmental and
Social Standards (ESS), which is one of the core
responsibilities of AIIB clients (ESF paragraph 67)44.
1.2. The willingness of local communities to establish the
power plant in Kutba Union, Burhanuddin in the light
of Free, Prior and Informed Consent (FPIC) principles;
1.3. The rights of self-determination of the land owners to
sell their lands to project executing agency (i.e., NBBL)
and adequate compensation and other requirements
according to paragraph 4 under ESS2 of ESF45;
1.4. Stand alone and cumulative impacts of the project on
local social and natural environment and
communities;
1.5. Authenticity of noise and other environmental pollution
mapping by the Environmental Resources Management
Private Limited (ERM) during ESIA preparation process
in the proximity area of the project;
16 Voices from the Ground: A Civil Society Study Report
1.6. Occurrence of flora and fauna enlisted in the Annexures
to the Final Report of Bhola ESIA
1.7. Veracity of the ESIA and violation of national and
international legal frameworks
2. To develop:
2.1. A set of recommendations based on the opinion of local
communities;
2.2. A set of recommendations according to the assessment
of the study team of Bangladesh Working Group on
External Debt (BWGED).
17
Bhola IPP and its Impact on Local Communities
PROCESS & METHODOLOGY
04
4.1 Literature Review
A systematic and structured review was conducted of all
available documents related to this project. To get detailed
information on the project, the study team reviewed published
documents of Bhola IPP Project such as Project Summary
Information (PSI)47, ESIA Report48, Annexures to the Final Report
of EISA, Environmental Monitoring Program (EMP)49, Grievance
Redressal Mechanism (GRM) in Bengali50 and Summary of the
ESIA Report (Bengali)51.
A comprehensive methodology has been followed to get both
qualitative and quantitative data. The process and methodology
of the study described bellow:
Figure 1: Process & Methodology of the Study
18 Voices from the Ground: A Civil Society Study Report
The study team also reviewed the relevant AIIB Policies and
Strategies including ESF, PIIP, Draft PPI, Draft PPM and ESS1 to
get a clear picture on gaps and barriers in the policies. The team
reviewed applicable national policies and acts e.g. BWA52, NCS53,
NEMAP54, NEP55, Environmental Conservation Act 1995
(subsequent amendments in 2000, 2002 and 2010)56, NWP57,
NFP58 and WCSA59 along with a number of research and study
reports on environment, biodiversity management, power
plants, fisheries and agriculture.
4.2 Secondary Data Collection
The demographic data has been culled from the Bangladesh
Population Census 2011 (published in 2013) by the Bangladesh
Bureau of Statistics (BBS)60, Banglapedia and the Local
Government Engineering Department (LGED). Data on
agricultural production and flora have been collected from
Burhanuddin Upazila office of Department of Agricultural
Extension (DAE). The team has also compared the ESIA of Bhola
Map 2: Map of the Study Site
19
Bhola IPP and its Impact on Local Communities
IPP with the draft Environmental Impact Assessment (EIA)
report on the 217.9 MW Gas-Fired Combined Cycle Power Plant
(CCPP) Project, Bhola, Bangladesh conducted by ERM in 2012 for
Lanco Power International Private Limited, which is
commissioned by the ADB61.
4.3 Field Observations
A two-member team visited Kutba and Sachra Union on 31
March 2018 and closely monitored the project sites, and the
villages in the vicinity of the proposed power plant as an initial
field observation exercise. The team also took interview of 5 key
informants including a small farmer, businessperson and
fisherfolk to understand the views of local residents. On the basis
of initial observation, the second team consisting 4 members
visited the project area including Burhanuddin Upazila, Kutba,
Dakshin Kutba, Gazipur Char and Chhota Manika Village from
13 - 16 August 2018 and observed environmental and social
impacts as well as conducted a biodiversity assessment of the
areas. The team visited the project area for the third time on 10-11
September 2018 and met villagers of Shantipara Village under
Kachia Union.
Table 1: Participants of the Study
Data Collection Tool Village
Key Informant Interview (KII) 6 3 9
Focus Group
Discussion (FGD)
Number of Participants
Total
Male Female
Total Participant: 5 Villages 36 21 57
Dakshin Kutba 6 2 8
Kutba 6 - 6
Gazipur Char 6 - 6
Chhota Manika - 13 13
Shantipara 12 3 15
20 Voices from the Ground: A Civil Society Study Report
22.2%
33.3%
11.1%
33.3% Businessperson
LGI Representative
NGO Activist
Schoolteacher
Figure 2: Participants of Key Informant Interviews
4.5 Focus Group Discussion (FGD)
The study team organized 5 FGDs in the villages of Dakshin
Kutba, Kutba, Gazipur Char, Chhota Manika and Shantipara in
Kutba, Sachra and Kachia Union under Burhanuddin Upazila. A
4.4 Key Informant Interview (KII)
A semi structured survey was conducted at the study site with
observation. The study team interviewed 9 persons as Key
Informants to receive insightful opinions and recommendations
based on their knowledge and experience. 6 persons were male
and 3 female among the participants. Among the participants
22.2% were businesspersons, 33.3% were schoolteachers, 11.1%
were NGO personnel and 33.3% were LGI representatives. The
team confirmed that 5 persons are listed as participants in the
consultation meetings organized by NBBL on 6 March 2017 in the
premises of Burhanuddin Upazila62 so that they would be able to
share their insights and opinions about the said consultation
meeting, especially from the perspective of effectiveness and
FPIC. The team also confirmed two participants who were the
land owners in the project site63.
21
Bhola IPP and its Impact on Local Communities
total of 48 persons participated in the FGDs organized by the
study team. Among the 48 FGD participants, 30 were male and
18 female. The FGDs covered participation from diversified
occupations and livelihoods including small farmers (18.8%),
Paan farmers (16.7%), small businesspersons (16.7%), livestock
rearers (10.4%), vegetable gardeners (12.5%), students (10.4%),
fisherfolk (6.3%), homemakers (4.2%), journalists (2.1%) and
teachers (2.1%) According to the ESIA report64 NBBL had
organized consultation meetings in the said villages. The study
team confirmed participation of 7 land owners whose names are
mentioned in the Annex of ESIA report65.
Figure 3: Participants of Focas Group Discussions
16.7%
6.3%
4.2%
2.1%
10.4%
16.7%
18.8%
10.4%
2.1%
12.5% Businessperson
Fisherfolk
Homemaker
Journalist
Livestock rearer
Paan farmer
Small farmer
Student
Teacher
Vegetable Gardener
4.6 Study Team
1. Azad Abul Kalam Member BWGED
2. Hasan Mehedi Focal Point BWGED
3. Mahbub Alam Prince Coordinator CLEAN
3. Sajjad Hossain Tuhin Research Coordinator CLEAN
22 Voices from the Ground: A Civil Society Study Report
4.7 Timeline of the Study
09 Feb - 15 Sep 2018 10 Feb 2018
31 Mar 2018 12 August 2018
13 August 2018 14 Aug 2018
15 Aug 2018 10 Sep 2018
Desk based study of different
literature, publications, policy and acts
Secondary data collection
Desktop study on the project
components
Sharing Meeting with Bangladesh
Working Group on External Debt
(BWGED) members on potential
impact of Bhola Integrated Power
Plant
Field observation in vicinity of the
project
Meeting with journalists and local
residents
Interview of 3 Key Informants
Visit to project area
Attempted entry to project site but
denied
Meeting with the affected community
Photo documentation of site
Interview of 3 Key Informants
FGD with Paan cultivators in Dakshin
Kutba Village
FGD with businesspersons,
journalists and others in Kutba
Village
FGD with women in Chhota Manika
Village
Interview of 3 Key Informants
FGD with farmers, fisherfolk and
others in Gazipur Char
Observation of villages adjacent to
the project on the other side of
Dehular Khal
Observing pollution in the
construction site
FGD with the affected community of
Shantipara Village
23
Bhola IPP and its Impact on Local Communities
CHALLENGES
05
5.1 Limited Resources
As a rather loose and voluntary network of organizations and
activists, Bangladesh Working Group (BWGED) had limited
resources to put forward towards the study. Only the travel cost
of the study team was met. The team members therefore could
not spend adequate time in the project area for more intensive
work.
5.2 Inadequate Human Resources
The study has been undertaken by small team of just four. The
study would have been better served by having a specialist on civil
engineering or power plants and a gender specialist on board.
Photo 2: A malnourished child in Kutba Village, Burhanuddin Upazila,
Bhola. Photo: Sajjad Hossain Tuhin
24 Voices from the Ground: A Civil Society Study Report
5.3 Lack of Equipment
The team had no means of access to monitoring equipment such
as a Sound Exposure Meter (SEM), Dissolved Oxygen (DO)
Meter, pH Meter, Soil Moisture Meter, Salinity Meter, Particle
Counter, Thermometer or Microscope to measure exact noise
levels, water temperature, dissolved oxygen (DO), acidity and
alkalinity of soil, moisture content, salinity, solid particles in the
air or microorganism in the soil and water. As a result, the team
had to rely on the values mentioned in the ESIA report or
secondary sources.
5.4 No Seasonal Data
Due to lack of resources and time, the team was unable to
measure pollution in the different seasons, i.e. summer, monsoon
and winter. Usually sound and air pollution seriously affect
communities in the vicinity of the plant. The study report fails to
capture all season pollution data, as also the impact of air, land
and water pollution on local communities. The team relies on
secondary sources to assess potential seasonal risks.
5.5 Environmental Constraint
The study was conducted mainly in August-September which is
the peak season for rain, storm, tidal surges and cyclones. The
team faced serious difficulties in survey work due to inclement
weather.
25
Bhola IPP and its Impact on Local Communities
06
THE AREA
Map 3. The project area in Burhanuddin Upazila, Bhola (Source: LGED)
Bhola is the only island district of Bangladesh under the
administrative division of Barisal. In total, it covers an area of
3,737.21 km2 which is divided into seven Upazilas, five
Municipalities, 62 Union and 461 villages66. Burhanuddin
situated at the middle part of the Bhola District in between
Shahbazpur channel and Tentulia River. Cumulatively, this
Upazila consist of 9 unions, 58 villages and a municipality. It lies
at 22.5000°N; 90.7217°E with 284.67 sq. km land area67.
The territory of two Unions, Kutba and Sachra, will be used for
Bhola IPP while areas in Deula, Kachia and Pakshia Unions will
be used for laying of a gas pipeline from the Shahbazpur Gas
field. Considering the influence of the project, demographic data
of Kachia, Kutba and Sachra is given below.
26 Voices from the Ground: A Civil Society Study Report
Figure 4: Livelihoods in the Project Area
Table 2: Demography of the Study Area (BBS 2014
68
)
Union Area
(km2)HH Population
Total
Male Female
Kachia Union 25.93 6,715 16,808 16,914 33,722
Kutba Union 23.08 4,752 10,868 11,378 22,246
Sachra Union 20.42 3,848 9,545 9,886 19,431
Total 69.43 15,315 37,221 38,178 75,399
The total population of the three unions is 75,399 of which 37,221
are male and 38,178 female. Rate of literacy is significantly low in
the project area, only 47.9%69 while the national average of
Bangladesh is 72.6%70. Most of the people in the area are
dependent on agriculture for their livelihood (52.6%) in which
43.1% are marginal farmers and other 9.5% are labourers. Fishing
is the second highest occupation (8.5%) followed by Paan
farming (6.2%).
9.5%
3.6% 2.7% 2.3%
6.2% 5.6% 6.3%
43.1%
12.2%
0.0%
5.0%
10.0%
15.0%
20.0%
25.0%
30.0%
35.0%
40.0%
45.0%
50.0%
27
Bhola IPP and its Impact on Local Communities
6.1 Socioeconomic Conditions
Bhola is ranked 27th in Principal Component Analysis (PCA) of
zonal disparity71 and the 8th most deprived district of
Bangladesh72. Burhanuddin is one of the most deprived Upazilas
and ranked 420 among 492 Upazilas of Bangladesh according to
composite deprivation index (CDI) of UNICEF73. 16.3% of its
population lives in extreme poverty and 28.3% of the population
is still facing poverty74. Low income and very limited per capita
land (with 40.11% landless population) indicated a poor
community and depressed social status of the local people.
In Kutba, most of the people are directly involved in farming
with livestock husbandry. Rice, wheat, Paan (betel-leaf), potato,
papaya, guava, lime, lemon, jackfruit, banana, mango, litchi,
blackberry, sugarcane, lentils, pulses, black gram, maize,
mustard, groundnut, sesame, pepper, chili, onion, garlic,
turmeric, ginger, tomato, radish, beans, pumpkin, pointed
gourd, cabbage, brinjal, okra, arum, cauliflower, cucumber,
melon and watermelon are the most prominent crops in the
Photo 3: Farmers are preparing seedlings in Dakshin Kutba Village,
Burhanuddin, Bhola. Photo: Sajjad Hossain Tuhin
28 Voices from the Ground: A Civil Society Study Report
project area75. 86.3% population lives in the rural environment of
the project area, and to many, nutrition (33.2%) and sanitation
(27.75%) is not readily available. However recently this area has
improved in open defecation (6.2%)76.
The study area is an active delta and all of the lands are
categorized as estuarine floodplains of the River Meghna. The
highest point of this area has recorded at 3m from mean sea level.
The Northern part is a bit higher in elevation than the southern
part because of the erosion and sedimentation of this active delta.
Loam soil with 56% silt, 23% sand and 21% clay makes this land
very fertile for cropping77. Major part of the project area is
medium height land (65.5%) which are less than 3 meter higher
than the mean sea level. 20.1% low land and a small portion of
high land (14.4%). The low lands are actually char land on the
river or canal (creeks) banks or river islets and usually treated as
wetlands. The villages of Dakshin Kutba and Chhota Manika are
situated in this low land coverage area.
Photo 4: Most of the lands in Bhola, especially Burhanuddin Upazila are
either medium high or low land which are at or just above the mean
sea level. Photo: Sajjad Hossain Tuhin
29
Bhola IPP and its Impact on Local Communities
6.2 Climatic Conditions
The climate of the study site is typically tropical with a mild
winter from October to March, hot and humid summer from
March to June and warm rainy monsoon from June to October.
Maximum and minimum temperature is variable all the year
round. In the month of January and December temperature falls
to the lowest around 12-15ºc and it reaches around 35-40ºc to the
maximum in the months of April, May and June. Monthly
average lowest temperature is 11.7 ºC in January and average
highest temperature is 35.4 ºc in May.
The average daily temperature is around 20-27ºC. Daily relative
humidity lies between 50-90%, which is lowest in the evening
and highest in morning. A humid, warm rainy monsoon occurs
here from June to October. The precipitation reaches its peak in
July and August. Maximum monthly precipitation occurs in July,
around 393mm. In the months of July and August this area
experience 20-25 days of rain. December and January are the
driest months in the project area78.
Figure 5: Climate Map of Bhola (Climate Data.org)
30 Voices from the Ground: A Civil Society Study Report
Bhola is one of the most
vulnerable areas of Bangladesh
which is regularly subject to
cyclones, tidal surges, floods and
river bank erosion79. Around 500
thousand people had died by the
well-known Bhola Cyclone 1970
which hit the area on 12
November 1970. Till date around
23 devastating cyclones have hit
the islands of Bhola including
Burhanuddin and the project
area. Some notable cyclones that
struck the area were in 1974, 1975,
1977, 1983, 1985, 1986, 1988, 1991,
1995, 1997, 1998, 2007, 2008, 2009,
2013, 2015, 2016 and 201780.
The project site is situated under the administrative unit of the
union Kutba. Kutba has a total land surface of 5,702 acres and
divided into 8 villages. Chhota Manika and Dakshin Kutba lies
along the Dehular Khal and the power plant site is under these
two villages. Gazipur Char is the village just opposite to the
construction site and Dehular Khal is the only natural setting
between them. Although, a very small creek named Mandartoli
Shakha Khal also flows just beside the project area. It emerges
from Mandartoli Khal, 1.8 km away from the project site, and
drops into the Dehular Khal.
Photo 5: More than 500,000 people
had died by the Bhola Cyclone in
1970. Source: Londoni.com
31
Bhola IPP and its Impact on Local Communities
07
BHOLA IPP PROJECT
Photo 6: The Government agreed to purchase electricity at a higher price than
state-owned power plants by signing a Purchasing Power Agreement
(PPA) on 27 August 2017. Photo: Energy & Power News
NBBL, a subsidiary of SP Infra, sought a loan of USD 60 million
from AIIB to construct a power plant in Bhola after getting a 22
year selling agreement from BPDB. Their proposal was approved
on 9 February 2018 by the Board of Directors of AIIB81. A
Summary of the Project Data is given below:
Name of the Project : Bhola Integrated Power Plant (Bhola IPP)
Project Location : Kutba Union, Burhanuddin Upazila,
Bhola District, Bangladesh
Capacity : 220/225 Megawatt
Type of Project : Combined Cycle Power Plant (CCPP)
Fuel : Natural Gas and High Speed Diesel
Land Acquisition : Total 28.28 Acres (17.00 acres from
Bhola I Project, 5.78 acres from Local
People and 5.5 acres for Gas pipeline)
32 Voices from the Ground: A Civil Society Study Report
ESF Risk Category : B (according to ESF of AIIB)
Industrial Risk Category
: Red (according to ECR of Bangladesh)
Project Period : Construction Period: 20 Months (April
2018 - December 2019)
Production Lifetime : 30 Years
Power Supply Period : 22 Years (as per agreement with BPDB)
Financier :
Asian Infrastructure Investment Bank (AIIB)
Islamic Development Bank (IsDB)
Borrower :
Nutan Bidyut Bangladesh Limited (NBBL)
Sponsor : SP Infra, a subsidiary company of SP
Group, Mumbai, India
Establishment of NBBL : 27 March 2016
Letter of Intent : 18 April 2016
IEE Report Submitted : 23 October 2016
ESIA Report Approved : 20 April 2017
ESIA Final (Released) : January 2018
Land Acquisition : January 2017
AIIB Approval : 9 February 2018
IsDB Loan Agreement : 25th June 2018
Total Budget : USD 271.9 million
AIIB Investment : USD 60.00 million
IsDB Investment : USD 60.00 million
NBBL Investment : USD 151.9 million
Category of AIIB Loan : Private Sector Loan
Sector of Investment : Energy/Power Generation
ESIA Prepared by : ERM India Private Limited
33
Bhola IPP and its Impact on Local Communities
KEY FINDINGS
08
8.1.1 Accessibility Denied
The representatives of project executing agencies did not allow
the study team in March, August and even in September 2018 to
enter in the project site. The security personnel even did not allow
the team to take photo of project site. So, all the observations were
seen from either just outside of the project site or from the other
bank of Dehular Khal which is in the territory of Sachra Union.
8.1.2 Pressure of Vested Interest Groups
The affected communities were so scared of talking to the study
team due to strong pressure from social and political powerful
groups. Every single respondents gave their contact information
Photo 7: Construction site of Bhola IPP which is full of dust. Photo taken
from other bank of Dehulia Khal. Photo: Hasan Mehedi
8.1 Accessibility & Civic Space
34 Voices from the Ground: A Civil Society Study Report
but none of them were willing to disclose their identity in the
monitoring report.
8.1.3 Uninformed People
Lack of Information about proposed Bhola IPP is very much
prominent in the locality which turned into a limitation. Most of
the people said that they heard the name of NBBL and Bhola IPP
for the first time from the study team. When the construction
started they had assumed it was the second phase of the existing
power plant (Bhola I). So, they were unable to express their
comments on different project documents such as ESIA,
Resettlement Framework (RF) or GRM.
8.1.4 Information Missing
There was a lack of critical information in the ESIA and other
documents provided by NBBL. The ESIA report stated that 15
different consultation meetings had been organized in the
communities, but there is no participant list of those consultations in
the ESIA. There was also no information regarding- date of land
acquisition, amount paid as compensation and resettlement,
starting date of construction works and budget for construction
works, available in any document in the public domain. It closed the
window of cross examination and obstructed the study severely.
8.1.5 Absence of the Community
According to the Annex of the ESIA report NBBL had conducted a
consultation meeting with the fishing community in Chhota
Manika village on 6 January 201782 and documented 12 fishing
households there. But the study team didn't find any fisherfolk in
Chhota Manika. The locals disclosed that those fisherfolk had
already changed their livelihood due to declined fish catch in
Dehular Khal. The NBBL also claimed that they had conducted a
discussion with BPDB's Chinese Village Labour Camp on 8th
January 201783. But the study team didn't find any such community.
According to the local people, there was a China Village where
labours and Chinese workers were living during the construction of
Bhola-I. But they left just after completion of that power plant.
35
Bhola IPP and its Impact on Local Communities
Photo 8: Momotaz Begum, a female smallholder in Sachra is saying about the
negative impacts of power plant on agriculture and health. Photo:
Hasan Mehedi
8.2 Meaningful Consultation
8.2.1 Public Consultation Denied
Meaningful consultation is obligatory for project executing
agencies according to the ESF of AIIB84. In the ESIA report NBBL
claims that it had conducted 15 consultation meetings with
different stakeholders including 7 meetings with the local
communities in Chhota Manika, Dakshin Kutba, Chinese Village
Labour Camp, Gazipur Char and Shantipara villages along with
8 meetings with the project-related GOB offices85. The ESIA
report also states that a Household (HH) survey had been
organized among 207 HHs from 5th to 12th January 201786.
NBBL also asserts that they have consulted respective
stakeholders at various points of time since January 2016 as a
part of the project development process, the land procurement
process or to undertake the ESIA87. The ESIA also mentions that
36 Voices from the Ground: A Civil Society Study Report
there were two rounds of formal stakeholder consultations of
which the first round was conducted in April-May 2016 and the
second round in January 201788.
However during the survey conducted by the study team of
BWGED, none of the 57 persons of those villages were able to
either recall any such consultations or identify any person who
had participated in those consultations.
8.2.2 Misrepresentation
According to the ESIA report, NBBL had organized a
consultation meeting in Burhanuddin Upazila Complex on 6
March 2017 with the participation of GOB officials, teachers, LGI
representatives and social elites89. The study team interviewed 5
from among the 37 persons who were said to have participated in
this consultation meeting. Three of the respondents told the team
that they participated in the meeting but their concerns were not
reflected in the report. Two participants who are also elected
female members of LGI denied
outright participating in any such
meeting in the Burhanuddin
Upazila office.
8.2.3 FPIC Violated Seriously
According to the ESIA report, the
Project received favourable support
from local inhabitants and other
stakeholders90. But members of the
affected communities who
participated in the survey
conducted by the study team
articulated that none of the
representatives from SP Infra or
NBBL took their consent about the
project or disclosed the positive and
negative impacts of the project.
Photo 9: Sajjad Hossain Tuhin is taking
photo of a herb in Chhota Manika village.
Photo: Mahbub Alam Prince
37
Bhola IPP and its Impact on Local Communities
8.3 Land Acquisition
8.3.1 Land Owners were pressurized to sell
NBBL claimed that they verified and consulted with land owners
regarding ownership, inheritance and mutation of records
between May 2016 and January 2017. The company also claimed
that 63 land owners had been identified who will
be impacted due to land procurement for
the power plant. 21 land sale
agreements have also been
executed with these land
owners in January 2017 based
on their signed consent to
the rates per decimal91. But
the land owners told the
study team that they
were paid around
Bangladesh Taka (BDT)
20,000.00 by the
middlemen of the
power plant while they
heard that the authority
paid around BDT
80,000-100,000 for every
decimal of land. In most of
the cases the local farmers
were pressurized by
middlemen to sell their lands
against the price fixed by them.
8.3.2 Communal Oppression
Most of the lands of the project site were historically
owned by Hindu communities of Dakshin Chhota Manika
village who are also the religious minority in the area. After 2
communal clashes in 1991 and 2001, they had to sell the land to
survive. A large number of the Hindu community also migrated
“In a
midnight of 2nd
week of December
2016, some of the
political leaders came to
my home and asked me
to hand over all documents
of my land. They threatened
me, 'otherwise, you will be
kicked out to India from the
village”.
- An Anonymous Hindu
farmer from Dakshin
Kutba Village
38 Voices from the Ground: A Civil Society Study Report
from the villages at that time. Among the land owners of the project
site, 8 pieces of land (59.17 Decimal) were owned by 19 from the
Hindu faith and 13 pieces of land (519.12 Decimal) were owned by
13 owners who were Muslim92. A Hindu land ownera told the
study team that one night several people led by a well-known
leader from the present ruling party came to their house past
midnight in second week of December 2016 and asked them to
handover all documents of their land. The leader threatened that it
would be good if they give the documents, otherwise the situation
will not favourable for them. The land owners followed the
instruction because they feared for their lives. Later they got BDT
20,000.00 from that leader against per decimal of land.
aAll names of local affected people are either changed or kept secret in this
report considering their personal security
142.18
3.44
4.50
8.00
28.00
9.00
1.75
5.00
3.00
12.00
20.00
11.50
98.22
73.53
23.00
3.73
35.00
46.00
22.00
28.44
20.00
40.00
60.00
80.00
100.00
120.00
140.00
160.00
Average Land Size
Asad & Others
Bilash Chandra
Suvash Chandra
Chunni Lal & Others
Noman Baklai & Others
Momtaj Begum & Others
Tofajjal’s Sister
Khokon
Joyar Master
Shampad
Krishna Babu
Lokman
Tofajjal
Shafijol Mridha & Others
Babul & Others
Suvash & Others
Mostofa & Others
Kibria & Others
Serajol Haque & Others
Amir Hossen
Figure 6: Land Owners of the Power Plant (Decimal)
8.3.3 Fake Land Owners
There is a list of 153 land owners in the Annexure of ESIA report.
But some of the land owners said that their names are not
available in the list when the study team disclosed the list before
39
Bhola IPP and its Impact on Local Communities
them. On the other hand, largest piece of land (142.18 Decimal)
owned by "Asad and others" according to the Annexure. The
study team couldn't find any such person in the area. The local
people also failed to identify any person and claimed that that
piece of land was not owned by any such person. It is clear that
the identified local influential political leader took that land from
local people and sold to NBBL at higher price.
8.3.4 Acquisition & Requisition Act Violated
The local communities claimed that they got only BDT 20,000.00
per decimal from middle men while others who gave land to
Sundarban Gas Company Limited (SGCL) for pipeline got
around BDT 100,000.00 for each decimal. People expressed that it
would be better if give land lands to SGCL rather than this power
project. The ESIA report also agreed that "land procurement
process was on the basis of voluntary land transactions and willing
buyer, willing seller negotiations"93. But according to the
Acquisition and Requisition of Immovable Property Ordinance
1982, the land owners are entitled to get twice of market price if
the land taken by any private company94. According the latest
law of 2017, they are to get thrice95. In this case the law is totally
bypassed and people were deprived from their rights.
Photo 10: Small piece of land is the lifeline of marginal farmers in Project area.
Photo: Sajjad Hossain Tuhin
40
I HAD TO CHANGE MY
LIVELIHOOD DUE TO THE
POWER PLANT
- A Villager of Dakshin Kutba
It is very difficult for me to walk along
the Dehular Khal watching the
current situation of my land. My
forefathers used to earn their
livelihoods by cultivating that land.
For me, I have spent my whole life at
working on those lands. I can
remember, our land gave us around
600-700 Mounds paddy every year.
But currently, several heavy
construction works are going on at
that place. Most of the lands are now
useless because of sand dumping.
Even about 5 years ago I used to go
fishing in the wetlands of that area.
But those practices diminished now.
One local shrimp species already
diminished. 40-50 share croppers
already migrated from our village to
Bhola town due to current projects.
Now I am managing a small tea stall
for my livelihood. But I was a
sharecropper and and a small farmer
earlier.
I know a very little but I am sure that
this power plant will create a vital
problem for my community.
41
Bhola IPP and its Impact on Local Communities
8.4 Information Disclosure & Right to Know
8.4.1 Information Disclosure Neglected
According to ESF of AIIB, all project executing agencies are
obliged to "...relevant information about environmental and social
risks and impacts of the Project is made available in the Project area in
a timely and accessible manner"96. But none of the 57 participants of
KII and FGDs agreed that the executing agency or any of its
representative disclosed even a brief on the project, let alone the
Environmental and Social Management Plan (ESMP),
Resettlement Plan, GRM or GAP. Both AIIB and NBBL website
contained only an undated PSI, Final Report of ESIA and
Annexures to the Final Report of ESIA when we last checked on
7 July 2018.
Given this situation and after analysing the ESIA Report,
BWGED sent a letter to the NBBL on 8 July 2018 and copied to
AIIB to disclose ESMP, Resettlement Framework (RF),
Stakeholder Engagement Plan (SEP), Gender Action Plan (GAP)
and Labour and Influx Management Plan (LIMP)97. In response
42 Voices from the Ground: A Civil Society Study Report
of the letter NBBL uploaded a translated Bengali version of PSIb,
Summery of Environmental and Social Impacts (E&S Summary)
and GRM on their website. Later it also uploaded Environmental
Monitoring Program (EMP) on their website98.
The local people, who have limited access to internet and the
techniques of using it, have no way to get these documents. So,
this disclosures are not in the project area and confirms neither in
a timely nor in an accessible manner.
8.4.2 Wrong and Complicated Translation
The translated versions of E&S Summery, EMP and GRM are full
of wrong translation and complicated sentences. The documents
seem copied from a bigger document and none of those consist
any issuing or responsible authority on the cover page. There are
enormous examples of wrong translation. The heading of E&S
Summery (dated 22 December 2017) is (in Bengali) mswÿßiæ‡c cÖK‡íi
cwi‡ekMZ I mvgvwRK mvims‡ÿc99. Spelling of the very first word is
wrong. Retranslated form of this headline will be "Summarized
Summery of Environmental and Social of the Project" which
doesn't mean anything.
The undated EMP (Bengali version)100 started from a number 7.3
means there is something before it which is hid by the executing
agency. It is named (in Bengali) Òcwi‡ekMZ ch©‡eÿbg~jK Kg©m~Px (wbg©vb I
cwiPvjb ¯Íi)Ó. There are at least three spelling mistake and one
misinterpretation in this headline. Similarly, the undated GRM
document started from a number 7.5 which means there is
something from number 1.0 which is hid101. The headline of this
document is (in Bengali) ÒAwf‡hvM Z`viK c×wZ - GbweweGjwc/GmGgwc/5Ó.
Retranslated form of this headline will be "Grievance Supervising
Process - NBBLP/SMP/5". If we ignore the wrong translation,
what is the meaning of NBBLP/SMP/5 in this document?
b Surprisingly, the Bengali version of PSI has been removed from NBBL
website on an uncertain day between 20th July and 12 August 2018
43
Bhola IPP and its Impact on Local Communities
These translated documents are unreadable for even the activists
who got higher education from academies let alone the affected
communities who are simply literate. It is observed that most of
the documents are either translated by using automated
translating software or translated by unskilled translators or
with bad intentions.
8.4.3 Communicative Options Denied
The ESIA agreed that literacy rate in project area is seriously low
(48.2%) than average of Bangladesh (72.6%)102. In this case, the
ESF of AIIB required proactive disclosure of the respective
documents "...in a form and language(s) understandable to the
Project-affected people..."103 from the client. The possible forms can
be radio and television advertisement, cartoons, graphic posters
and presentation, village level consultation with flip charts or
any other form understandable to the affected communities. But
none of the forms used to inform the community people about
potential negative impacts of the project and possible actions
supposed to be taken by NBBL to reduce negative impacts.
8.4.4 Translated ESMP Still Undisclosed
Voluntary disclosure of Environmental and Social Management
Plan (ESMP), Environmental and Social Management Planning
Framework (ESMPF), Resettlement Plan (RP), Resettlement
Planning Framework (RPF) are mandatory according to the ESF
of AIIB104. The ESIA report confirms that an ESMP along with
other management plans have been developed before January
2018 when the final report of ESIA was prepared105. An ESMP
document is also enclosed with the ESIA106. But even after 9
months, the translated ESMP is yet to be published and
disseminated to the affected communities.
44 Voices from the Ground: A Civil Society Study Report
Map 4: Map showing the place of Jetty, Betel Leaf Farms, Labour Camp and
Garbage Deposition by NBBL staffs
8.5 Social and Environmental Impacts
8.5.1 Noise Pollution
The project site situated in Dakshin Kutba village is a completely
rural residential area. According to the section 11 of Noise
Pollution (Control) Rules 2006 construction in the night is totally
prohibited107. In the residential area, noise pollution limit is 55
and 45 decibel [dB(A)] in the day and night respectively108. The
ESIA report reveals that there were objections from local
communities about noise pollution during operation of Bhola-I
power plant109. But the new project is only following the bad
practices of the previous project. However the ESIA report
agreed that the current noise level of the project is affecting
health and safety of local people110 and noise level during
construction period of Bhola IPP touched 85 decibel111 which is
30 decibel more than the permitted level. The local affected
communities complained to the study team that the NBBL
authority is running construction works even in the night which
is affecting their daily lives, especially homework of
school-going children.
45
Bhola IPP and its Impact on Local Communities
Photo 11: A woman from Dakshin Kutba village is collecting water from
Mandartoli Shakha Khal which has almost dried up with sand
deposits and sedimentation. Photo: Sajjad Hossain Tuhin
The noise pollution spread up to 3 km at the night time. As the
current power project already created health and safety
problems for the local people, the cumulative impact of noise
pollution will simply force them to leave the villages or to face
serious health problems. The affected communities said that they
have to move from the place if they want to live with a healthy
life because it hampers their psychological and physical
wellbeing.
8.5.2 Unplanned Construction Creates Flooding
Mandartoli Shakha Khal was one of the active water channels
(tidal canal) that emerged from Mandartoli Khal and flows by
the other side of the project site. The BPDB had closed southern
part of the Mandartoli Shakha Khal to construct homes for their
employees. Further, the NBBL embanked its northern part with
sand sacks and has taken over half of the canal. The sand from
the sacks has spilled out into the canal-bed causing siltation and
the canal to gradually dry up. Now the canal is only 1-2 feet deep
and has lost its water carrying capacity. As a result the water
overflows during high tide and floods the Dakshin Kutba
village. Around 100 HH premises and 400 betel leaf farms are
regularly submerged by river water twice a day. The situation is
quite tough for the local affected communities due to the
unplanned construction and lack of maintenance of the sand
bags of NBBL.
46 Voices from the Ground: A Civil Society Study Report
8.5.3 Destruction of Paan Farms
Since the past two years, a betel leaf top dying disease has been
seen which could possibly be a negative impact of excessive air
pollution created by Bhola-I power plant, as the affected betel
leaf cultivators charge. According to the affected communities,
Paan production has decreased at least by 30% in the last two and
half years when electricity generation started from Bhola-I power
plant. The current Bhola IPP has now created another problem
for them. The manmade disaster of water flooding the soil of
Paan farms causes rotting of Paan plant roots called die back
disease. The worrying factor is that these cultivators are
gradually losing mother plants and their livelihoods as well.
Future emission of toxic gases will totally destroy the Paan farms
and the farmers.
BETEL LEAF FARMERS IN PERIL
Betel leaf plants are very sensitive to moisture. Water
logging could destroy this vital crop. Most of the lands
surrounding the project site are under Betel leaf cultivation.
On an average almost 500 small farms were found within a
radius of 1 km. But, work carried out by the NBBL authority at
Mandartoli Shakha Khal has caused heavy deposits of sand
in the canal and water logging of these lands. Currently the
depth of the canal is less than one metre. During high tide it
overflows to the surrounding houses and Betel leaf farms.
Die back of Betel leaf and leaf damage has struck all these
farms. A farmer from Dakshin Kutba lamented that about
30% of the plants on his farm were already affected by die
back disease and it is the same scenario for all the other
farms of the area.
47
Bhola IPP and its Impact on Local Communities
Photo 12: Garbage left by the NBBL staffs in the Mandartoli Shakha Khal.
Photo: Sajjad Hossain Tuhin
8.5.4 Waste Pollution
Mismanagement of garbage and waste is very alarming at the
project site. No dustbin was seen at the project site which forces
the construction workers to put their dust anywhere. The study
team discovered a large amount of garbage at the Mandartoli
Shakha Khal and most of them were non-degradable such as
polythene, plastics, metal and so on. The Mandartoli Shakha
Khal is carrying these non-degradable and sometimes, toxic
wastes from the project site to other areas and thus pollution is
spreading out all-around the project site.
8.5.5 Declined Fish Varieties and Fishermen
The project site is an active floodplain, wetland and submerged
during monsoon. The local communities used to collect 15-20
species of indigenous fishes from the land. The BPDB's Bhola-I
power plant grabbed a major portion of land which reduced the
number of indigenous fish species. The affected communities
48 Voices from the Ground: A Civil Society Study Report
Photo 13: Fishing in the Dehular Khal. Photo: Sajjad Hossain Tuhin
reported that there were at least 15 species of fish in the project
site before 2017 when the construction of Bhola IPP started. After
filling the land by sands, all the species has been destroyed and
there are only 2-3 species can be found in rainy season in the
remaining wetland.
More than 70 species of fishes can be found in Dehular Khal112.
The ESIA report agreed that construction of jetty on Dehular Khal
and movement of vessels with oil and other materials will restrict
boat movement, use of nets and fishing in the canal113. It is also
agreed that there will be a potential reduction of fish resources in
Dehular Khal due to cumulative impact of BPDB's Bhola-I and
NBBL's Bhola IPP. Discharge of huge amount of hot water in
Dehular Khal will further destroy the habitat of indigenous fish
varieties. The Tentulia River and its nearby areas are the major
breeding area and habitat of Ilish fish (Tenualosa ilisha Hamilton)
which is the national fish of Bangladesh. It is mentioned in the
ESIA report that the dredging in Tentulia River during
construction period may temporarily drive away the fish114.
Specific compensations are proposed by NBBL for the aquacultures
whether it will be implemented or not. But compensations and
other deliverables for fishing communities are unspecific, vague
and thus depends on whims of executing agency115.
49
Bhola IPP and its Impact on Local Communities
8.5.6 Risk of Oil Spillage Ignored
According to the plan, BPC will deliver HSD by oil tankers from
Chittagong to the Jetty on the Dehular Khal crossing Bay of
Bengal, estuarine of Meghna River and Tentulia River. The
Dehular Khal is not much broad and doesn't have enough draft
for large oil tanker movement. So, there are two alternatives to
carry HSD from Chittagong: (1) Loading small tankers from
Chittagong, or (2) Unloading from big tankers to small tankers in
Tentulia River. In both of the cases there are huge risk of oil
spillage because on the one hand, the small tankers has serious
risk of sinking while crossing mouth of the Bay of Bengal, and on
the other hand, there are potential risk of leakage and sinking
during of small tankers during unloading process in Tentulia
River.
But the ESIA report only focuses on oil spillage during unloading
process at the jetty of Bhola IPP which is only small mouth of a
big loophole. The ESIA suggests, "A spill response plan and
Photo 14: Different places of the Dehular Khal and Mandartoli Shakha Khal
have been grabbed by the project executing agency. Photo:
Mahbub Alam Prince
50 Voices from the Ground: A Civil Society Study Report
emergency plan will be prepared to address accidental spillages or
release of hazardous wastes"116 which is for the project site and
Dehular Khal area only. This narrow view of a serious problem
left the Ilish sanctuary and all other aquatic resources by saying
the impacts will be "Negligible for habitats and Small for species"117.
8.5.7 Grazing Land Destroyed
The villagers of Chhota Manika, Dakshin Kutba and Gazipur
Char is highly dependent on livestock husbandry and all of the
families have a couple of either cattle, buffalo or goats. Earlier the
local inhabitants were using the project site as their grazing land
in dry season. The BPDB plant took almost half of the land. Then
the Bhola IPP have taken other half now. Now the affected
communities don't have any land for grazing. According their
opinion, either no assessment or enlisting work haven't taken
place to identify actual livestock rearers of the area or actual
rearers are left from the list. Most disappointing thing is the
NBBL has no plan to compensate the affected people who lost the
common grazing land due to the new power plant.
Photo 15: Death of an Irrawaddy Dolphin due to oil spillage in the
Sundarbans 2014. Photo: The Economic Times
51
Bhola IPP and its Impact on Local Communities
8.5.8 The Endangered Species are threatened Again
According to the ESIA report, only 139 species of plants, 12
species of amphibians, 23 species of reptiles, 53 species of birds,
21 species of mammals and 90 species of fishes found in the
area118. The actual number of species are much higher than
mentioned in the ESIA report. Among the enlisted fauna 48
species (5 mammals, 34 fishes, 1 birds, 1 amphibians and 7
reptiles) are either vulnerable or critically endangered or near
threatened in Bangladesh.
Most alarming thing is two species of fish (Pethia ticto Hamilton
and Monopterus cuchia Hamilton), one species of mammal
(Lutrogale perspicillata Hilaire) and two species of reptiles (Batagur
kachuga Gray and Gavialis gangeticus Gmelin) are not only
critically endangered or vulnerable in Bangladesh but also near
threatened or vulnerable in the world119.
Figure 7: Both nationally & globally vulnerable species
Gavialis gangeticus
Monopterus cuchia
Batagur kachuga
Pethia ticto
Source: Fishbase and Wikipedia
Lutrogale perspicillata
52 Voices from the Ground: A Civil Society Study Report
Among the enlisted fauna following species are protected under
WCSA 2012120:
3 species of Amphibians: Euphlyctis hexadactylus Lesson,
Hoplobatrachus tigerinus Daudin and Hylarana taipehensis
Denburgh
48 species of Birds out of 53 enlisted species in the ESIA
report
7 species of Fishes: Bagarius yarrellii Sykes, Labeo boga
Hamilton, Labeo nandina Hamilton, Labeo pangusia Hamilton,
Macrognathus aral Bloch & Schneider, Monopterus cuchia
Hamilton and Rasbora bola Hamilton;
18 species of Mammals: Bandicota indica Bechstein, Canis
aureus Linnaeus, Felis chaus Schreber, Herpestes auropunctatus
Hodgson, Herpestes edwardsi Saint-Hilaire, Lutrogale
perspicillata Saint-Hilaire, Megaderma lyra Geoffroy, Mus
booduga Gray, Mus musculus Linnaeus, Paradoxurus
hermaphroditus Pallas, Pipistrellus coromandra Gray,
Pipistrellus minus Wroughton, Prionailurus viverrinus
Bennetts, Rattus rattus Linnaeus, Scotophilus kuhlii Leach,
Scotozous dormeri Thomas, Suncus murinus Linnaeus,
Viverricula indica Saint-Hilaire and Vulpes bengalensis Shaw;
22 Species of Reptiles out of 23 enlisted species mentioned
in the ESIA report
According to the ESF of AIIB project activities in areas of critical
habitats are prohibited121. The project itself is not supposed to be
establish in the area because it is one of the important habitats of
nationally and globally critically endangered species. Besides,
killing or hurting or destroying habitat of any of the species is a
cognizable offence and subject to maximum one year jail or
penalty of BDT 50 thousand which can be double for second
time122. So the project disregarded the ESF of AIIB and existing
law on wildlife in Bangladesh as well.
53
Bhola IPP and its Impact on Local Communities
Photo 16: Unhygienic labour camp of Bhola IPP without any waste dumping
place. Photo: Mahbub Alam Prince
8.5.9 Local Labours Deprived
According to the affected communities, both of Bhola-I and Bhola
IPP project ignored the right of local people to be recruited as
labour of the project. The previous project appointed China
Chengda Engineering Company Ltd.123 for construction works and
subsequently they outsourced labour supply job to a third party
who appointed cheaper labour from different corners of the
country. The local people expected something different from this
project. The LIMP of Bhola IPP pledged that "the project proponent
will endeavour to maximise local employment..."124. But the local
affected communities told the study team that NBBL appointed a
third party, Sinam Group, to supply labour for construction work
and consequently the Group recruited more than 80% of labour
from Northern zone of Bangladesh. Only 5% of labour recruited
from the study area, according to the affected communities. As a
result around 50-60 families who were engaged with agricultural
labour has been migrated from the village, as the affected
communities said.
Photo 17: Barbed wire fence constructed by NBBL on the both side of access
road in the name of security which made obstructions for the local
people to access the road. Photo: Sajjad Hossain Tuhin
8.5.10 Right to Move Jeopardised
According to the Easements Act 1882125, no individual or
institution has rights to bar any citizen to access to private or
common property for their wellbeing. Accordingly the BPDB
didn't impose any bar on local people to access Char land,
Grazing land or the Dehular Khal126. But the NBBL barred the
local people from accessing to the bank of
Dehular Khal by hanging a cautionary board in
wrong language. Therefore, people don't have
access to the canal bank or Char land which is
only grazing land and a major location for
fishing. Besides, in the name of security, a one
km long iron fence were created on the both
side of road from main road to the project site.
This fence created obstacles for the local people
to access from their houses to the road which is
a clear violation of the law of Bangladesh.
54 Voices from the Ground: A Civil Society Study Report
55
Bhola IPP and its Impact on Local Communities
Photo 18: The Project Site and sorrounding area is completely a wetland.
Photo: Sajjad Hossain Tuhin
8.6 Eligibility & Legitimacy
8.6.1 Wrong Information on Land Category
In the ESIA report, The NBBL claimed that there is no wetland in
the project site or in the areas of proximity127. It is ridicules that
the same ESIA team found plants like False White Teak [Trewia
nudiflora L. (Mallotus nudiflorus (L.) Kulju & Welzenc)], Varuna
[Crataeva nurvala Buch.-Ham. (Crateva nurvala Buch.-Ham.)] and
Indian Oak (Barringtonia acutangula (L.) Gaertn.) near the
wetland128. The ESIA team also identified wetlands in the area as
a habitat of fish species129. The ESIA report again mentioned that
the level of land has to be raised at least 4.1 metre from present
level by filling 200,000 m3 sand by dredging Tentulia River130.
These evidences clearly show that the land is actually a wetland
whether it is mentioned in any national notification or not. The
c Corrected scientific names are given in the bracket as wrong scientific names
are written in the ESIA report
56 Voices from the Ground: A Civil Society Study Report
Map 5: Noise pollution experiment sites of ESIA Team which is more than
1.5 km far from the project site.
local inhabitants also mentioned that they used to catch
indigenous fish varieties from the project site before it started. So,
either the authority accepted the ESIA blindly without visiting
the project site or there were negotiations between NBBL and
authorities behind the curtain.
8.6.2 Fake Noise Pollution Test
According to the Annex of ESIA, two houses were selected by the
consultant to test existing noise pollution. The houses are Zakir
Hossain's house and Abdul Mazed's house in Gazipur Char
village131. Both of the houses are around 1.5 km far from the
project site and have a very few possibility of feeling extreme
noise pollution from there. The noise pollution is affecting the
community people of Dakshin Kutba village seriously which is
situated by the project site. But none of the places of this village
selected for testing noise pollution.
The BWGED study team visited both of the houses (i.e., Zakir
Hossain and Abdul Mazed) but the family members of both
families told that none of the representative from NBBL, ERM or
57
Bhola IPP and its Impact on Local Communities
EQMS Consulting Limited (the institution involved with noise
pollution testing) visited their house or test any noise pollution
in the premises of their houses.
Photo 19: NBBL says they tested noise pollution in premises of this house,
house owners says No. Photo: Sajjad Hossain Tuhin
8.6.3 Environmental Rules Violated
The final version of ESIA report was prepared on an unspecified
date of January 2018132 but surprisingly DOE approved the same
ESIA report on 20 April 2017133. So, it is assumed that the
authority had decided to build the power plant earlier and given
an approval when any ESIA was not prepared.
According to the Environmental Conservation Rules 1997
(subsequent amendments in 2002, 2003 and 2010), the power
plants come under Red Categoryd which requires an Initial
d Infrastructures are divided in three categories in the Environmental
Protection Act and Environmental Protection Rules of Bangladesh consider-
ing the level of social and environmental impact. The categories are Red,
Yellow and Green, where Red has severe impact and green has the least.
58 Voices from the Ground: A Civil Society Study Report
Figure 8: Covers of EIA Report 2012 and ESIA Report 2018 on Bhola
Combined Cycle Power Plant
Environmental Examination (IEE) report first and an EIA report
after approval of submitted IEE report134. But no IEE report is
disclosed till date by any respective agency i.e., NBBL, AIIB or
the GOB. It seems that there were no IEE report produced and
submitted to the DOE. So there are enough causes to believe that
the process of ESIA report directly violated the ECR 1997.
8.6.4 An Old Book with New Cover
ERM Singapore Private Limited which is also a subsidiary of
ERM Group like ERM India Private Limited conducted an EIA
for Indian company Lanco Power International Private Limited
to establish a power plant in the same area of Burhanuddin
Upazila, Bhola . It is clear that a good number of information and
data were simply copied and pasted from that EIA report to this
ESIA report for NBBL. Some examples are:
a) Page number 12 of EIA (2012) copied and pasted in page
number 2-1 of ESIA (2018) .
b) Total sections of EIA (2012) from page 12 to 28 (including
59
Bhola IPP and its Impact on Local Communities
paragraph 2.2, 2.2.1, 2.2.3, 2.2.4,, 2.3, 2.3.1, 2.3.2, 2.3.3, 2.3.4, 2.3.5,
2.3.6, 2.4, 2.4.1, 2.4.2, 2.4.3; table 2.1 and 2.2 and figure 2.1
and 2.2) was just copied and paste in ESIA (2018) from page
2-1 to 2-17.
c) Figure 9.1 from page number 369 of EIA (2012) copied and
pasted as figure 7.1 in page number 7-24 of ESIA (2018).
d) Almost 95% enlisted flora and fauna are same in both
documents.
8.6.5 Faulty List of Species
The ESIA report contains only 139 species of plants in the project
area . The consultant either surveyed the area very poorly or
intentionally ignored names of sensitive plant species which are
protected under WCSA 2012. The consultant ignored even the
Betel leaf or Paan (Piper betle L.) which is very commonly
cultivated in the project area.
The BWGED study team estimated the number of plant species is
not less than 450 in the area. Many of very common floral species
from Convolvulaceae (like Ipomoea spp.), Commelinaceae (like
Commelina spp.), Cyperaceae (like Cyperus spp.), Onagraceae (like
Ludwigia spp.), Linderniaceae (like Lindernia spp.) and so on are
absent at the ESIA report.
Some of the very common species of coastal zone like Green
Panicled Spot Flower (Acmella paniculata (Wall. ex DC.)
R.K.Jansen), Green Amaranth (Amaranthus viridis L.), Brahmi
(Bacopa monnieri (L.) Pennell), Fringed Spider Flower (Cleome
rutidosperma DC.), Variable flatsedge (Cyperus difformis L.), White
Water Sedge (Kyllinga nemoralis (J.R.Forst. & G.Forst.) Dandy ex
Hutch. & Dalziel), Diamond Flower (Oldenlandia corymbosa L.),
Sawtooth Fogfruit (Phyla nodiflora (L.) Greene), Black Catnip
(Phyllanthus niruri L.), Pepper-leaved Senna (Senna sophera (L.)
Roxb.), Coffee Senna (Cassia occidentalis Roxb.), Pink Morning
Glory (Ipomoea fistulosa (Mart. ex Choisy) D.F.Austin), Congo
Jute (Urena lobata L.), Elephant Grass (Typha domingensis Pers.
and Cuban Jute (Sida rhombifolia L.), are found in all of the nearby
villages and canal-banks.
60 Voices from the Ground: A Civil Society Study Report
The ESIA report says that "the core zone in the identified plot area of
11.5 acres land is highly disturbed and does not bear any natural
vegetation“139 but the study team found mangrove plants like
Milky Mangrove (Excoecaria agallocha L.) and Small Crab Apple
(Sonneratia apetala Buch.-Ham.) Along with a number of herbs and
grasses in the project site, especially on the bank of Dehular Khal.
Figure 9: Some of the plants missing in ESIA Report
Abutilon indicum (L.) Sweet Allamanda cathartica L.
Coccinia grandis (L.) Voigt
Senna tora (L.) Roxb.
Commelina benghalensis L.
Dentella serpyllifolia (Wall. ex Craib) Verdc.
Photo: Sajjad Hossain Tuhin
61
Bhola IPP and its Impact on Local Communities
8.6.6 ERM is not Even Independent
Independence and rigour is expected from a third party ESIA
consultant to conduct a just and fair Environmental and Social
Impact Assessment. ERM India Private Limited, a subsidiary of
Environmental Resources Management (ERM) Group of
companies which is closely related with SP Group and SP Group
and conducting ESF for it's different projects140. So there is a nexus
between this two companies which was a bar to ensure a sound
and fair ESIA.
8.7 Emerging Concern
Recently it is published in newspapers that NBBL's mother
company Shapoorji Pallonji Group signed an agreement with
IsDB to finance another USD 60.00 million for Bhola IPP. None of
NBBL, SP Group or IsDB disclosed details of neither agreement
nor the purpose of the money. The undisclosed mission can
create more problems for the affected communities of project
area.
62 Voices from the Ground: A Civil Society Study Report
63
Bhola IPP and its Impact on Local Communities
RECOMMENDATIONS
09
9.1 Recommendations of the Affected
Communities
9.1.1 A comprehensive and in-depth inquiry is required on
communal threats and price of lands considering security
and potential future threats to the affected communities.
9.1.2 Further assessment on livelihoods and needs of the affected
communities to design an adequate compensation plan.
9.1.3 Disclose the information in an understandable manner to
the communities and arrange meeting with the affected
people about compensations and safety measures to be
taken by the executing agency.
9.1.4 Formulation of a comprehensive plan with specific
compensations for indirectly affected farmers, Paan
cultivators, fishermen, agricultural and daily labours and
disseminate it among the communities in easy,
understandable and communicative way so that they can
claim adequate compensation from respective authority.
9.1.5 Remove the fences from entrance and exit points of the
residences of local affected communities.
9.1.6 Dredging of the Mandartoli Shakha Khal and maintenance
of the canal regularly so that water logging can be removed
and local people can use the water for irrigation and
household purposes.
9.1.7 Providing temporary and permanent job facilities to the
local people, especially to them who are directly affected by
the project.
9.1.8 Compensation for fragmented small lands which the people
cannot use now as the power plant took a part of it and small
parts are left which are not cultivable.
64 Voices from the Ground: A Civil Society Study Report
9.2 Recommendations of the Study Team
9.2.1 Correct and understandable translation of the documents in
easy Bengali language so that affected people can interact
and share their opinion on the project and its different
Redressal mechanism.
9.2.2 Undertaking programmes to provide health and education
support to the communities in addition to other
compensations.
9.2.3 Immediate formulation of a strict oil spillage response and
mitigation plan considering transportation and supply of
HSD from the oil refinery of Chittagong to the project site.
9.1.4 Reduce noise pollution by using modern silencing
technology and stopping operation of power plant after
permitted period (after 9:00 pm)
9.1.5 Prepare a comprehensive biodiversity management plan
focusing on endangered and vulnerable species.
9.1.6 Adequate and sound management of pollutants.
65
Bhola IPP and its Impact on Local Communities
REFERENCES
1 MOLJPA (2010). Quick Enhancement of Electricity and Energy Supply (Special
Provisions) Act 2010. Ministry of Law, Justice and Parliamentary Affairs
(MOLJPA), Dhaka: 12 October 2010. Retrieved from
http://bdlaws.minlaw.gov.bd/bangla_pdf_part.php?act_name=&vol=%
E0%A7%AA%E0%A7%A7&id=1059 accessed on 12 July 2018
2 BERC (2008). Policy Guidelines for Enhancement of Private Participation in the
Power Sector 2008. Bangladesh Energy Regulatory Commission (BERC),
Dhaka: 2008 (undated). Retrieved from
https://berc.portal.gov.bd/sites/default/files/files/berc.portal.gov.bd/
policies/d52d7b21_ceaf_4769_8396_da4c7b94c3ac/Policy%20Guidelines
%20for%20Commercial%20IPP,%202008%20(English).pdf accessed on 26
June 2018
3 MOPEMR (2010). Power System Master Plan 2010 (PSMP 2010). Ministry of
Power, Energy and Mineral Resources (MOPEMR), Dhaka: 2010
(undated). Retrieved from
https://powerdivision.portal.gov.bd/sites/default/files/files/powerdivi
sion.portal.gov.bd/page/7fd4a674_56a2_4726_ba2b_1cc0ad020813/SUM
MARYPSMP2010.pdf accessed on 9 June 2018
4
MOPEMR (2016). Power & Energy Sector Master Plan 2016 (PESMP 2016).
Ministry of Power, Energy and Mineral Resources (MOPEMR), with Japan
International Cooperation Agency (JICA), Tokyo Electric Power Services Co.,
Ltd. and Tokyo Electric Power. Company Holdings, Inc. Dhaka: September
2016. Retrieved from http://open_jicareport.jica.go.jp/pdf/12269742.pdf
accessed on 18 August 2018
5
CVF (2016). The Marrakesh Communique 2016. Climate Vulnerable Forum
(CVF), Marrakesh: 18 November 2016. Retrieved from
https://thecvf.org/marrakech-communique/ accessed on 13 August 2018
6 MOEFCC (2015). Intended Nationally Determined Contributions (INDC).
Ministry of Environment, Forest and Climate Change (MOEFCC), Dhaka:
September 2015. Retrieved from
http://www4.unfccc.int/ndcregistry/PublishedDocuments/Bangladesh
%20First/INDC_2015_of_Bangladesh.pdf accessed on 15 July 2018
7 Khatun, F. and Ahamad, M.G. (2013). FDI in the Energy and Power Sector
and Economic Growth in Bangladesh. Centre for Policy Dialogue (CPD),
Dhaka: November 2013. Retrieved from
https://cpd.org.bd/wp-content/uploads/2014/03/CPD-CMI-Working-
Paper-7.pdf accessed on 25 June 2018
66 Voices from the Ground: A Civil Society Study Report
8 AIIB (2018a). Approved Projects (Bangladesh). Asian Infrastructure
Investment Bank (AIIB), Beijing: Undated. Retrieved from
https://www.aiib.org/en/projects/approved/index.html accessed on 14
August 2018
9 Banglanews24 (2018). Five more gas-based power plant in Bhola soon (AwP‡iB
†fvjvq n‡e M¨vmwfwËK 5 we`y¨r‡K›`ª) in Bengali. Banglanews24.com, Dhaka: 14
March 2018. Retrieved from
http://www.banglanews24.com/economics-business/news/bd/642115.
details accessed on 1 August 2018
10 Asian Power (2012). India's Lanco to set up Bangladesh's Bhola Power Plant.
Asian Power: 16 September 2012. Retrieved from
https://asian-power.com/project/news/indias-lanco-set-bangladeshs-bh
ola-power-plant accessed on 18 July 2018
11 Coal Post (2015). Shapoorji Pallonji to set up a 225 MW dual-fuel power plant
in Bangladesh. The Coal Post: 24 August 2015. Retrieved from
http://www.coalpost.in/shapoorji-pallonji-to-set-up-a-225-mw-dual-fuel
-power-plant-in-bangladesh/ accessed on 13 May 2018
12 NewAge (2015). 225 MW Power Project in Bhola: Indian Shapoorji to relocate
its installed plant. The Daily NewAge: 3 July 2015. Retrieved from
https://bwged.blogspot.com/2018/09/225-mw-power-project-in-bhola-i
ndian.html accessed on 12 July 2018
13 Daily Star (2016a). New Power Plant in Bhola: Unsolicited deal for Indian
company?. The Daily Star: 7 March 2016. Retrieved from
https://www.thedailystar.net/frontpage/unsolicited-deal-indian-compa
ny-787495 accessed on 18 May 2018
14 Daily Star (2016b). Six power deals get go-ahead: Govt goes for wholesale
unsolicited power deals; special act being used for 'speedy deals' on 2-yr-old
proposals. The Daily Star: 17 March 2016. Retrieved from
https://www.thedailystar.net/frontpage/six-power-deals-get-go-ahead-
792436 accessed on 11 July 2018
15 Dhaka Tribune (2017). First power plant fully funded by India to be set up in
Bhola. The Dhaka Tribune: 29 August 2017. Retrieved from
https://www.dhakatribune.com/bangladesh/power-energy/2017/08/2
9/first-plant-india-bhola accessed on 12 April 2018
16 ERM (2018). Environmental and Social Impact Assessment of 225MW Dual
Fuel (Gas and HSD based) Combined Cycle Power Plant (Bhola - II):
Burhanuddin, Bhola District, Bangladesh: Updated Final Report.
Environmental Resources Management (ERM) India Private Limited,
Mumbai: January 2018. p. 1-3. Retrieved from
http://nutanbidyut.com/img/Updated-Final-ESIA-Report_NBBL.pdf
accessed on 5 July 2018
67
Bhola IPP and its Impact on Local Communities
17 Xinhuanet (2018). Spotlight: AIIB's power sector project hailed by millions in
rural Bangladesh. The Xinhuanet, Beijing: 18 January 2018. Retrieved from
http://www.xinhuanet.com/english/2018-01/18/c_136905267.htm
accessed on 19 January 2018
18 AIIB (2018b). Bangladesh Bhola IPP: Project Summary Information (PSI).
AIIB, Beijing: 9 February 2018. Retrieved from
https://www.aiib.org/en/projects/approved/2018/_download/Bangla
desh/PSI-Bangladesh-Bhola-IPP-120118.pdf accessed on 11 February 2018
19 IsDB (2018). The Islamic Development Bank co-finances 220MW Gas Fired IPP
in Bangladesh. Islamic Development Bank (IsDB), Delhi: 26 Jun 2018.
Retrieved from
https://www.isdb.org/announcement/the-islamic-development-bank-co
-finances-220mw-gas-fired-ipp-in-bangladesh accessed on 12 July 2018
20 ERM (2018). ibid. Executive Summary. p. IV
21 Energy & Power (2017). Shapoorji Pallonji Group Bags Power Supply Deal.
The Energy & Power: 28 August 2017. Retrieved from
http://ep-bd.com/view/details/news/NDQw accessed on 22 June 2018
22 Energy & Power (2017). ibid.
23 ERM (2018). ibid. p. 2-41
24 Wikipedia (2018). 1970 Bhola cyclone. Wikipedia: (undated). Retrieved
from https://en.wikipedia.org/wiki/1970_Bhola_cyclone accessed on 15
June 2018
25 MOLJPA (2017). The Constitution of the People's Republic of Bangladesh.
MOLJPA, Dhaka: November 2017. Retrieved from
http://bdlaws.minlaw.gov.bd/print_sections_all.php?id=367 accessed on
15 June 2018
26 MOEFCC (2016). Bangladesh National Conservation Strategy (NCS).
MOEFCC, Dhaka: September 2016. Retrieved from
http://bforest.portal.gov.bd/sites/default/files/files/bforest.portal.gov.
bd/notices/c3379d22_ee62_4dec_9e29_75171074d885/Executive%20Sum
mary(NCS).pdf accessed on 18 June 2018
27 MOLJPA (2013). Bangladesh Water Act (BWA) 2013. MOLJPA, Dhaka: 6
November 2013. Retrieved from
http://warpo.gov.bd/acts/WaterActEnglish.pdf accessed on 15 June 2018
28 MOLJPA (2009). Right to Information Act (RTI) 2009. MOLJPA, Dhaka: 6
April 2009. Retrieved from
http://bdlaws.minlaw.gov.bd/bangla_all_sections.php?id=1011 accessed
on 6 August 2018
29
MOLJPA (1882). The Easements Act 1882. MOLJPA, Dhaka: 17 February 1882.
Retrieved from http://bdlaws.minlaw.gov.bd/print_sections_all.php?id=49
accessed on 9 August 2018
68 Voices from the Ground: A Civil Society Study Report
30 MOEFCC (1992). National Environment Policy (NEP) 1992. MOEFCC,
Dhaka: 1992 (undated). Retrieved from
http://www.clcbd.org/document/download/36.html accessed on 18
June 2018
31 MOEFCC (1995). National Environment Management Action Plan (NEMAP)
1995. MOEFCC, Dhaka: 1995 (undated). Retrieved from
http://documents.worldbank.org/curated/en/329001468741610744/pdf
/multi-page.pdf accessed on 18 June 2018
32 MOWR (1999). National Water Policy (NWP) 1999. Ministry of Water
Resources (MOWR), Dhaka: 1999 (undated). Retrieved from
http://warpo.gov.bd/sliderdetails/c3674f62057bce14eb6a6a349000bba6.
pdf accessed on 12 April 2018
33 DOF (2006). National Fisheries Policy (NFP) 2006. Department of Fisheries
(DOF), Dhaka: January 2006. Retrieved from
http://extwprlegs1.fao.org/docs/pdf/bgd169565.pdf accessed on 13
April 2018
34 DOE (2006). Noise Pollution (Control) Rules 2006 (Bengali). Department of
Environment (DOE), MOEFCC, Dhaka: 7 September 2006. Retrieved from
http://doe.portal.gov.bd/sites/default/files/files/doe.portal.gov.bd/pag
e/e43886bc_0694_49f6_80f3_71d2a0edece1/Noise%20Control%20Rules.pdf
accessed on 29 July 2018
35 MOEFCC (2012). Wildlife (Conservation and Security) Act 2012. MOEFCC,
Dhaka: 10 July 2012. Retrieved from
http://extwprlegs1.fao.org/docs/pdf/bgd165019.pdf accessed on 16
June 2018
36 AIIB (2016a). Environmental and Social Framework (ESF). AIIB, Beijing:
February 2016. Retrieved from
https://www.aiib.org/en/policies-strategies/_download/environment-f
ramework/20160226043633542.pdf accessed on 11 February 2018
37 AIIB (2016b). Public Information Interim Policy (PIIP). AIIB, Beijing: January
2016. Retrieved from
https://www.aiib.org/en/about-aiib/.content/index/_pdf/20160226052
345422.pdf accessed on 11 February 2018
38 AIIB (2018c). Draft Policy on Public Information (PPI). AIIB, Beijing: January
2018. Retrieved from
https://www.aiib.org/en/policies-strategies/operational-policies/public
-consultation/.content/_download/draft_policy_on_public_information.
pdf accessed on 11 February 2018
39 AIIB (2018d). Energy Sector Strategy: Sustainable Energy for Asia (amended,
2018). AIIB, Beijing: 11 April 2018. Retrieved from
https://www.aiib.org/en/policies-strategies/strategies/sustainable-ener
gy-asia/.content/index/_download/energy-sector-strategy.pdf accessed
on 18 June 2018
69
Bhola IPP and its Impact on Local Communities
40 AIIB (2018e). Enhancing AIIB's Accountability: The Project affected People's
Mechanism (draft for Phase II public consultation). AIIB, Beijing: 2018
(undated). Retrieved from
https://www.aiib.org/en/policies-strategies/_download/consultation/
draft-AIIB-complaint-handling-mechanism.pdf accessed on 18 May 2018
41 AIIB (2016a). ibid. p 4
42 AIIB (2016a). ibid. p 30
43 AIIB (2016a). ibid. p 39
44 AIIB (2016a). ibid. p 24
45 AIIB (2016a). ibid. p 38
46 ERM (2017a). Environmental and Social Impact Assessment of 225 MW Dual
Fuel (Gas and HSD based) Combined Cycle Power Plant (Bhola -II):
Burhanuddin, Bhola District, Bangladesh: Annexures to the Final Report.
Environmental Resources Management (ERM) India Private Limited,
Mumbai: January 2018. Retrieved from
http://nutanbidyut.com/img/Final-Annexures-NBBL-ESIA-Report.pdf
accessed on 5 July 2018
47 AIIB (2018b). ibid.
48 ERM (2018). ibid.
49 NBBL (2018a). Environmental Monitoring Program (EMP). Nutan Bidyut
Bangladesh Limited (NBBL), Dhaka: Undated. Retrieved from
http://nutanbidyut.com/img/Environmental-Monitoring-Program.pdf
on 11 August 2018
50 NBBL (???b). Awf‡hvM Z`viK c×wZ - GbweweGjwc/GmGgwc/5. NBBL, Dhaka:
undated. Retrieved from
http://nutanbidyut.com/img/Grievance-Redressal-Mechanism-Bengali.pdf
accessed on 11 August 2018
51 NBBL (2017). Environmental and Social Summary (mswÿßiæ‡c cÖK‡íi cwi‡ekMZ I
mvgvwRK mvims‡ÿc) in Bengali. NBBL, Dhaka: 22 December 2017. Retrieved
from http://nutanbidyut.com/img/ES-Summary-BHOLA-II.pdf accessed
on 11 July 2018
52 MOLJPA (2013). ibid.
53 MOEFCC (2016). ibid.
54 MOEFCC (1995). ibid.
55 MOEFCC (1992). ibid.
56
MOLJPA (2010). The Bangladesh Environment Conservation Act 1995 (subsequent
amendments in 2000, 2002 and 2010). MOLJPA, Dhaka: 1995 (undated).
Retrieved from http://extwprlegs1.fao.org/docs/pdf/bgd42272.pdf
accessed on 6 June 2018
70 Voices from the Ground: A Civil Society Study Report
57 MOWR (1999). ibid.
58 DOF (2006). ibid.
59 MOEFCC (2012). ibid.
60 BBS (2013a). Population and Housing Census 2011 (Community Report:
Bhola). pp 41 - 222. Bangladesh Bureau of Statistics (BBS), Dhaka: July
2013 Retrieved from
http://203.112.218.65:8008/WebTestApplication/userfiles/Image/PopCe
n2011/COMMUNITY_Bhola.pdf accessed on 12 June 2018
61 ERM (2012). Environmental Impact Assessment (EIA) report on 217.9 MW
Gas-Fired Combined Cycle Power Plant Project, Bhola, Bangladesh.
Environmental Resources Management Private Limited (ERM),
Singapore: August 2012. Retrieved from
https://www.adb.org/sites/default/files/project-document/73497/4691
6-014-ban-esia-draft.pdf accessed on 25 July 2018
62 ERM (2017a). ibid. Annex W: Public Consultation Minutes (Appendix-4:
Participant List). pp. x-xiv
63 ERM (2017a). ibid. Annex T: List of Land Owners
64 ERM (2017a). ibid. Annex U: Stakeholder Consultation Records (Socio-
economic Baseline) (Table 1.1: Summary of Stakeholder Consultations). pp. U1
65 ERM (2017a). ibid. Annex T: List of Land Owners
66 Banglapedia (2015). Bhola District. Asiatic Society of Bangladesh. Dhaka:
2015 (undated). Retrieved from
http://en.banglapedia.org/index.php?title=Bhola_District accessed on 18
July 2018
67 Banglapedia (2015). Burhanuddin Upazila. Asiatic Society of Bangladesh.
Dhaka: 2015 (undated). Retrieved from
http://en.banglapedia.org/index.php?title=Burhanuddin_Upazila
accessed on 18 July 2018
68 BBS (2013b). District Statistics 2011: Bhola. p 14. BBS, Dhaka: December
2013. Retrieved from
http://203.112.218.65:8008/WebTestApplication/userfiles/Image/Distric
t%20Statistics/Bhola.pdf accessed on 25 July 2018
69 BBS (2013b). ibid. p 51
70
BBS (2017). Bangladesh Statistics 2017. BBS, Dhaka: 2017 (undated). Retrieved from
http://bbs.portal.gov.bd/sites/default/files/files/bbs.portal.gov.bd/page/a1d3
2f13_8553_44f1_92e6_8ff80a4ff82e/Bangladesh%20%20Statistics-2017.pdf
accessed on 25 June 2018
71
Khondker, B.H. and Mahzab, M.M. (undated). Lagging Districts Development:
Background Study Paper for Preparation of the Seventh Five-Year Plan.
Planning Commission, Ministry of Planning, Dhaka: Retrieved from
http://www.plancomm.gov.bd/wp-content/uploads/2015/02/15_Lagging-R
egions-Study.pdf accessed on 18 August 2018
71
Bhola IPP and its Impact on Local Communities
72 UNICEF (2010). A Case for Geographic Targeting of Basic Social Services to
Mitigate Inequalities in Bangladesh. United Nations International Children's
Emergency Fund (UNICEF), Dhaka: August 2010. Retrieved from
https://www.unicef.org/bangladesh/Geo_targeting_25dec_PDF.pdf
accessed on 10 June 2018
73 UNICEF (2010). ibid.
74 World Bank (2010). Bangladesh Interactive Poverty Map 2010. World Bank,
BBS and World Food Programme (WFP), Dhaka: 2010 (undated).
Retrieved from
https://files3.marcomcentral.app.pti.com/twb/storefront_assets/interac
tive_maps/bangladesh-v5/res/data/zila_and_upazila_data.zip accessed
on 22 August 2018
75 BBS (2013b). ibid. pp 30 - 39
76 World Bank (2010). ibid.
77 Krantz, M. (1999). Coastal Erosion on the Island of Bhola, Bangladesh. Earth
Sciences Centre, Department of Physical Geography, Göteborg
University: 1999 retrieved from
https://www.bioenv.gu.se/digitalAssets/1347/1347852_b178.pdf
accessed on 18 August 2018
78 BBS (2017). Bangladesh Statistical Year Book 2016. BBS, Dhaka: March 2017.
Retrieved from
http://bbs.portal.gov.bd/sites/default/files/files/bbs.portal.gov.bd/pa
ge/d6556cd1_dc6f_41f5_a766_042b69cb1687/PocketBook2016.pdf
accessed on 11 July 2018
79 BBS (2013b). ibid. p 21
80 Wikipedia (2018). List of Bangladesh tropical cyclones. Wikipedia (undated).
Retrieved from
https://en.wikipedia.org/wiki/List_of_Bangladesh_tropical_cyclones
accessed on 25 May 2018
81 AIIB (2018b). ibid.
82 ERM (2017a). ibid. Annex U: Stakeholder Consultation Records (Socio- economic
Baseline. Table 1.1: Summary of Stakeholder Consultations). p U4
83 ERM (2017a). ibid. Annex U: Stakeholder Consultation Records (Socio-economic
Baseline. Table 1.1: Summary of Stakeholder Consultations). p U5
84 AIIB (2016a). ibid. p 21
85 ERM (2017a). ibid. Annex W: Public Consultation Minutes (Appendix 4:
Participant List). pp. xi-xiv
86
ERM (2018). ibid. Chapter 5: Socio-Economic Baseline (5.1.2: Methodology). p 5-3
87 ERM (2018). ibid. Executive Summary (0.7 Stakeholder Engagement). pp XXIV
- XXV
72 Voices from the Ground: A Civil Society Study Report
88 ERM (2018). ibid. p XXV
89 ERM (2017a). ibid. Annex W: Public Consultation Minutes (Appendix-4:
Participant List). pp. x-xiv
90 ERM (2017a). ibid. Chapter 10: Conclusion. p 10-1
91 ERM (2017a). ibid. Chapter 8.4: Information Disclosure and Consultation
(8.4.1 Land Ownership Identification). p 8-12
92 ERM (2018). ibid. List of the Land Owners (between the page S11 and U1)
93 ERM (2018). ibid. Chapter 6.5.1: Loss of Land. p 6-83
94 MOLJPA (1982). The Acquisition and Requisition of Immovable Property
Ordinance 1982 (Ordinance No. II of 1982). Ministry of Law, Justice and
Parliamentary Affairs (MOLJPA), Dhaka: 13 April 1982. Retrieved from
http://bdlaws.minlaw.gov.bd/print_sections_all.php?id=619 accessed
on 11 August 2018
95 MOLJPA (2017). The Acquisition and Requisition of Immovable Property Act
2017 (Bengali). MOLJPA, Dhaka: 10 July 2017. Retrieved from
http://bdlaws.minlaw.gov.bd/bangla_all_sections.php?id=1220 accessed
on 11 August 2018
96 AIIB (2016a). ibid. Paragraph 57: Information Disclosure. p 20
97 https://www.scribd.com/document/389131746/Let-
ter-of-BWGED-to-NBBL-for-Disclosure-of-Respective-Documents-on-Bho
la-IPP-8-July-2018
98 http://nutanbidyut.com/about.html
99 NBBL (2017). ibid.
100 NBBL (???a).cwi‡ekMZ ch©‡eÿbg~jK Kg©m~Px (wbg©vb I cwiPvjb ¯Íi). NBBL, Dhaka:
Undated. Retrieved from
http://nutanbidyut.com/img/Environmental-Monitoring-Program.pdf
accessed on 15 August 2018
101 NBBL (???b). ibid.
102 ERM (2018). Ibid. Chapter 5.3: Social Capital (Table 5.7: Demographic Features
of Study Area). p 5-10
103 AIIB (2016a). ibid. Paragraph 57: Information Disclosure by the Client. p 20
104 AIIB (2016a). ibid. p 20
105 ERM (2018). ibid. Executive Summary. p XXIII
106 ERM (2018). ibid. Chapter 7: Environmental and Social Management Plan. pp
7-1 - 7-31
107 DOE (2006). ibid. Section 11. p 7886
73
Bhola IPP and its Impact on Local Communities
108 DOE (2006). ibid. Schedule-1. p 7888
109 ERM (2018). ibid. Executive Summary (0.7: Stakeholder Engagement). p XXV
110 ERM (2018). ibid. Chapter 8: Stakeholder Engagement and Public Disclosure
(8.5: Key Feedback). p 8-13
111
ERM (2018). ibid. Chapter 2: Policy, Legal and Administrative Framework. p 2-46
112 ERM (2018). ibid. Chapter 6: Impact assessment & Mitigation/ Enhancement
Measures (6.3.5: Ecological Impacts). p 6-47
113 ERM (2017a). ibid. Chapter 2: Resettlement Framework (2.1.1 Scope of
Land-based and Resettlement Impacts). p X21
114
ERM (2018). ibid. Executive Summary (0.4: Key Impacts for Decision Making). p XX
115 ERM (2017a). ibid. Chapter 2: Resettlement Framework (Table 1.3: Proposed
Entitlements). p X35
116 ERM (2018). ibid. Chapter 6: Impact assessment & Mitigation/Enhancement
Measures (6.3.5: Ecological Impacts). p 6-51
117 ERM (2018). ibid.
118 ERM (2017a). ibid. Annex M-R. pp M1 - R3
119 http://www.iucnredlist.org/
120 MOEFCC (2012). ibid. Schedule 1 & 2: Protected Animal.
121 AIIB (2016a). ibid. Paragraph 4B: Environmental Coverage. p 32
122 MOEFCC (2012). ibid. Section 39 and 45
123 The Daily Star (2013). Govt inks 225MW power deal with Chinese company.
The Daily Star, Dhaka: 10 April 2013. Retrieved from
https://www.thedailystar.net/news/govt-inks-225mw-power-deal-with-
chinese-company accessed on 25 July 2018
124
ERM (2017a). ibid. Chapter 4: Labour and Influx Management Plan (LIMP). p X52
125 MOLJPA (1882). ibid.
126 ERM (2018). ibid. Executive Summary (0.7: Stakeholder Engagement). p XXV
127 ERM (2018). ibid. Executive Summary (Box 0.2: Key Environmental and Social
Considerations). p VI
128 ERM (2018). ibid. Chapter 4: Baseline Environmental Condition (4.4.4
Terrestrial Environment). p 4-68
129 ERM (2018). ibid. 4.4.5 Aquatic Environment. p 4-74
130 ERM (2018). ibid. Chapter 3.6: Resources and Utilities required for the Project
(3.6.2: Earth Filling). p 3-19
131 ERM (2017a). ibid. Noise Level Monitoring Report (pages between Annex V and
Annex W)
74 Voices from the Ground: A Civil Society Study Report
132 ERM (2018). ibid. Cover Page
133 DOE (2017). Approval of Environmental Impact Assessment (EIA) Report for
the Proposed 225 MW Dual Fuel (Gas and HSD) Based Combined Cycle Power
Plant Project at Burhanuddin in Bhola District. Department of Environment
(DOE), Dhaka: 20 April 2017. Retrieved from
http://nutanbidyut.com/img/EIA-Approval.pdf accessed on 5 July 2018
134 MOEFCC (2010). Environmental Conservation Rules 1997 (subsequent
amendments in 2002, 2003 and 2010). MOEFCC, Dhaka: 27 August 1997.
Retrieved from
http://doe.portal.gov.bd/sites/default/files/files/doe.portal.gov.bd/po
licies/2d85eb8f_1790_44de_837a_83c59077b393/Environment%20Conser
vation%20Rule-1997.pdf accessed on 22 June 2018
135 ERM (2012). ibid.
136 ERM (2012). ibid. 2.2 Environment-Related Policies in Bangladesh. p 12
137 ERM (2018). ibid. 2.2 Environment-Related Policies in Bangladesh. p 2-1
138 ERM (2017a). ibid. Annex M: Plant Species within Area of Influence. p M1 - M6
139 ERM (2018). ibid. Chapter 4.4.4: Terrestrial Environment (Available Habitats
in Area of Influence Core Zone). p 4.65
140 ERM (2017b). Environmental and Social Impact Assessment (ESIA) of Proposed
100 MW Solar PV Power Project: Veltoor, Telangana, India: Draft Final Report.
Environmental Resources Management India Private Limited (ERM),
Mumbai: March 2017. Retrieved from
http://www.eib.org/attachments/registers/77758459.pdf accessed on 25
June 2018
CLEAN (Coastal Livelihood and
Environmental Action Network)
has been established in 2010 with
active participation of
like-minded persons and
environmental groups of the
coastal zone of Bangladesh.
CLEAN inherits its ancestral
organization Humanitywatch
which was established in 1998.
On the way of journey, CLEAN
plays the role of the secretariat of
Bangladesh Working Group on
External Debt (BWGED),
Sundarbans Watch Group and
SDG Watch Bangladesh.
Towards reaching desired
mission, CLEAN have been
working since 1998 in seven
thematic areas. The thematic
areas are inter-related and highly
related with the lives and
livelihoods of coastal people. The
thematic areas are: (i) Agriculture
& Livelihoods (ii) Climate
Catastrophe (iii) Environment
and Forest (iv) Health &
Population (v) Humanitarian
Response (vi) Socioeconomic
Justice and (vii) Water
Management.
https://bwged.blogspot.com
BWGED (Bangladesh Working Group on External
Debt) is a loose forum of progressive development
activists and organizations from allover Bangladesh.
The BWGED was primarily formed by NGO Forum on
ADB to ensure safeguard for affected communities
and human rights defenders from adverse impacts of
IFI funded projects, but it is not limited to the members
of the Forum. The principle of all actions taken by
BWGED is the Bangladesh Peoples Safeguard
Position Paper which has been endorsed by the
members in early 2016 through a workshop organized
jointly by the Forum and Working Group.
MEMBERS
Organizational Member: Actionaid Bangladesh, An
Association for Socio-Economic Development
(AOSED), Bangladesh Environmental Lawyers
Association (BELA), Bangladesh NGO Network for
Radio Communication (BNNRC), Bangladesh
Poribesh Andolan (BAPA), Campaign for Sustainable
Rural Livelihoods (CSRL), Centre for Bangladesh
Studies (CBS), Christian Aid in Bangladesh, CLEAN
(Coastal Livelihood and Environmental Action
Network), Development Synergy Institute (DSI),
DEVREMATE, Equity and Justice Working Group
Bangladesh (EquityBD), Initiative for Right View (IRV),
ISDE Bangladesh, Nagorik Sanghati, Nagorik
Uddyog, Paani Committee, Paribartan-Rajshahi,
Participatory Research and Action Network (PRAN),
Prantojon Trust, Safety and Rights Society (SRS),
Society for Environment and Human Development
(SEHD), Society for Participatory Empowerment for
Development (SPED), SPEED Trust, Uttaran, Voices
for Interactive Choice and Empowerment (VOICE).
Individual Member: Abu Siddique, Basanti Saha,
Jibanananda Jayanta, Jyotirmoy Barua, Maha Mirza,
Sheikh Rokon and Tapas Das
