Bhola-2 220MW Combined Cycle Power Plant

MIGA has been requested to provide guarantees covering equity and shareholder loan investments by Actis, and non-shareholder loans by yet to be confirmed lenders, into the operation of a 220 MW dual fuel combined-cycle gas turbine (CCGT) power plant located on Bhola island in Bangladesh (“the Project”). Further information on the  MIGA guarantees is available in the Project brief.

The Project is developed by Nutan Bidyut Bangladesh Limited (NBBL), an SPV of Shapoorji Pallonji Infrastructure Capital Company Private Limited of India. The Project is located on the right bank of the Dehular Khal canal and approximately 28 km south of the city of Bhola. The location is adjacent to the existing Bhola-1 power plant, a 225 MW CCGT owned by Bangladesh Power Development Board, which has been operational since 2015. The site is also adjacent to a temporary 95 MW natural gas power plant owned by Aggreko, operational since 2018. Construction commenced in 2018, and the Project has been operational since June 2021.

The Project includes operation of (i) 220 MW CCGT, utilizing 2 dual fuel turbines; 2 heat recovery steam generators; and 1 steam turbine; (ii) wet cooling tower system; (iii) 230 kilovolt (kV) gas insulated substation (which will be connected to an existing switchyard); (iv)  wastewater treatment plant; water intake and outfall; and (v) administrative buildings. Power is evacuated through existing 230 kV overhead transmission lines connected to the national grid.

The Project operates on natural gas as its primary fuel, and diesel will be used only in case of a failure in the gas network. Natural gas is supplied by the Sundarban Gas Company Limited (SGCL) and sourced from the Shabazpur gas field which is located approximately 6.7 km from the Project site. A pipeline, which is considered an Associated Facility to the Project (as defined by Performance Standard 1) is being constructed and commissioned by SGCL. For the period up until completion of the pipeline, gas is supplied by an existing pipeline also servicing the Bhola-1 power plant.

The Project was developed on a 30-acre site, part of which is leased from BPDB and previously formed part of the Bhola-1 site, and part of which has been acquired from local landowners. The land was previously used by local farmers, primarily for cultivation of paddy crops and beans.  The land around the site is also primarily farmland, though there are several villages within 3 km of the site boundary with the closest being farmer houses located approximately 200 meters from the boundary.

A consortium of SP Group, Global Infra, and Bisho Infra was engaged as the Engineering, Procurement and Construction (EPC) contractor and Operational Energy Group Bangladesh Private Limited Company (OEG) has been engaged as the Operations and Maintenance (O&M) Contractor. As of August 2021, operation of the plant is managed by the O&M Contractor with the EPC Contractor still remaining at the site involved in post-commissioning activities.

Existing Project lenders include Asian Infrastructure Investment Bank (AIIB), Islamic Development Bank and Infrastructure Development Company of Bangladesh (IDCOL). An Independent Environmental and Social Consultant (IESC) has undertaken construction monitoring on behalf of the lenders since the start of construction. A separate consultant was engaged by Actis and lenders in 2020 to conduct environmental and social due diligence and review of the Project against the requirements of the Performance Standards.

The Project is categorized as Category A according to MIGA’s Policy on Environmental and Social Sustainability (2013) because it includes activities with potentially significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented. Key risks and impacts include economic displacement, air emissions (including greenhouse gases); noise; water resource use and occupational and community health and safety. There are also potential cumulative impacts associated with the operation of the adjacent Bhola 1 power station, and potential continued operation of the temporary Aggreko power plant

While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention
• PS4:  Community Health, Safety and Security
• PS5:  Land Acquisition and Involuntary Resettlement
• PS6: Protection and Conservation of Biodiversity

The potential presence of Indigenous Peoples was assessed in the ESIA, which determined that there were no ethnic or cultural groups within the Project area that meet the PS7 definition of Indigenous Peoples. Therefore, PS7 Indigenous Peoples does not apply to the Project.

The risk of encountering cultural heritage was assessed in the ESIA, which determined that there are no known archeological or cultural sites or values in the Project vicinity and therefore, PS8 Cultural Heritage doesn’t apply. Nonetheless, a Chance Find Procedure was prepared and implemented during the construction phase.

In addition, the following World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines are applicable to the Project:

• General EHS Guidelines (2007)
• EHS Guidelines for Thermal Power Plants (2008)
• EHS Guidelines for Electric Power Transmission and Distribution (2007)

The following documents were reviewed by MIGA:

• Advisian. Lenders’ Environmental and Social Consultant Report. December 2020
• ERM. Environmental and Social Impact Assessment, Bhola-2 Power plant. January 2018.
• ERM. Environmental and Social Impact Assessment Addendum. January 2020.
• ERM. Climate Change Assessment for Flooding Risks at Bhola-2. May 2019.
• ERM. Climate Change and Flood Risk Assessment for Bhola, Bangladesh (DRAFT). August 2021.
• ERM. Cumulative Impact Assessment on Air Quality and Ambient Noise. September 2019.
• AECOM. Environmental, Health, Safety and Social Management System, NBBL. August 2017.
• AECOM. Involuntary Resettlement Audit for Bhola II Combined Cycle Power Plant. June 2019.
• AECOM. Livelihood Restoration and Development Plan. January 2020.
• AECOM. Environmental and Social Due Diligence Report for Bhola-2. March 2017.
• AECOM. Environmental and Social Quarterly Monitoring Audits, September 2018 – May 2021.
• Advocates Alliance Associates. Labor Compliance Audit, Bhola2. March 2020.

In addition to reviewing the above documents, MIGA carried out virtual (due to travel restriction related to the ongoing COVID-19 pandemic) environmental and social (E&S) due diligence in January and August 2021, which included meetings with key E&S staff and management. In addition, an IESC was engaged by the Project lenders to review the E&S aspects of the Project against the Performance Standards. As part of their due diligence, the IESC reviewed relevant E&S and technical documents and undertook a virtual visit to the Project site in December 2020. MIGA also liaised with AIIB, and took part in meetings to discuss the findings of a site visit conducted by AIIB in October 2020.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards.

Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:

An Environmental, Health, Safety and Social Management System (EHSSMS) has been established for the Project covering both construction and operations phases, which is in line with PS1. The EHSSMS was reviewed by the IESC, and deemed robust and to address relevant risks associated with the Project. Monitoring reports indicate that the EHSSMS has been adopted and is implemented by the O&M Contractor.

The O&M Contractor has a corporate wide E&S management system in place, certified to the ISO standards 14001 on environmental management, and 18001 on occupational health & safety. The O&M contractor will adopt and implement the Project’s EHSSMS for operations (ESAP item). 

 Policy:

NBBL has an Environmental, Health, Safety and Social policy which defines the environmental and social objectives and principles that guide the Project to achieve sound environmental and social performance for operation at a national and international level. The policy has been approved by the Project Director, and the policy along with a commitment statement is set out in the EHSSMS, which is published on the project company’s website.

Identification of Risks and Impacts:

Under the national Environmental Clearance process the Project was required to develop an environmental and social impact assessment (ESIA) for national permits and approvals. ERM, an international E&S consulting firm, was commissioned to develop an ESIA in line with national and international requirements, including the PS1. The ESIA was approved by the Department of Environment in 2016 for construction of the Project, and a subsequent operating permit was issued in June 2020.  

AECOM was contracted to conduct a gap analysis of the ESIA against the requirements of the PSs and AIIB’s in 2017, and identified a list of gaps, including assessment of cumulative impacts, stakeholder analysis, and livelihood impacts. A revised ESIA was developed addressing AECOM’s recommendations, which was completed in 2018.

Due to the establishment of the Aggreko plant in 2018, a separate Cumulative Impact Assessment (CIA) study was completed by ERM which included analysis of noise and air emissions with the three power plants in operation, as further discussed under PS3. A standalone Climate Change and Flood Risk Assessment was also carried out by ERM in 2019 and in 2021

Impacts related to the pipeline were assessed as part of the Project’s ESIA. This was supplemented by a biodiversity and migratory bird survey conducted by AECOM in 2019. The ESIA reports were reviewed by the IESC and considered to be adequate to the Project’s size and area of impact, and developed in line with good international practice and the requirements of PS1.

The Project is located on a low-lying island which is part of an active delta in the major Ganges–Brahmaputra–Meghna river basin. The Ganges and Brahmaputra rivers join the Meghna river north of Bhola Island and flows from the Meghna river shape the northern, eastern and western boundaries of the island on its course towards the Bay of Bengal. As the Meghna river passes the northern boundary of Bhola Island, a proportion of its flow (approximately 20%) diverges to form the Tentulia river. The Tentulia river flows along the western boundary of Bhola Island towards the Bay of Bengal and is connected to various rivers and canals, including the Dehular Khal which is immediately adjacent to the Project site. As a result of these hydrological characteristics, Bhola Island is categorized as an estuarine floodplain[1] as the water levels in the rivers and canals surrounding and traversing through the island are constantly fluctuating in response to river drainage from upstream watersheds and tidal effects from the Bay of Bengal. Furthermore, as the river and canal systems are well connected and highly transmissive, the water levels and river flows surrounding the Project site are also heavily influenced by the seasonal dynamics of rainfall occurring upstream of Bhola Island and extreme weather events originating downstream in the Bay of Bengal. Over 70% of the annual rainfall for the region is received over a 5-month period, resulting in peak-runoffs which historically have often led to significant flood impacts. Flooding is thus a common occurrence on Bhola Island and is a result of three possible flood event types: (1) overland flooding due to heavy rainfall occurring on the island; (2) riverine flooding due to heavy rainfall occurring near or upstream of the island which causes water levels and river flows to rise and accelerate, resulting in eventual overtopping of river banks; or (3) coastal flooding due to extreme weather events occurring in the Bay of Bengal which induce storm surge towards the island. Under extreme scenarios, all three flood events can occur in unison leading to potentially catastrophic economic, environmental, and social impacts. In response to these flood risks, the Government of Bangladesh is taking several measures to improve coastal resilience, including through the construction of dikes to reduce floods caused by storm surges. In particular, the eastern and western banks of Bhola Island are protected by earthen embankments, though there are several rivers and canals traversing Bhola Island which can propagate storm surge even under normal flood conditions.

A climate risk screening was performed for the Project using MIGA’s Climate Risk Screening Tool and supplementary World Bank climate datasets and tools. The Project was categorized with a high risk to potential climate change related impacts, and as such a localized climate risk and vulnerability modelling study was completed for the Project.  In 2021, ERM was commissioned to update the 2019 flood risk assessment they conducted to better evaluate how climate risks to the Project could evolve under various climate scenarios and across several time horizons. This analysis relied on localized climate change projections from an ensemble of climate models to study potential flood risks to the Project and to communities within a 1 km radius of the Project. The analysis relied on a 2-D flood routing model software (which has been  approved by U.S. Federal Emergency Management Agency for flood risk assessment) and employed field datasets as well as satellite imagery to assess overland, riverine and coastal flood risks due to changes in extreme rainfall and associated river flows, sea-level rise, and storm surge from tropical cyclones. The analysis of localized climate change projections highlighted with strong confidence that the intensity and frequency of extreme precipitation, high river flows, sea-level rise and storm surge from tropical cyclones will increase under all scenarios. As a result of this, flood risks to the Project and to the surrounding communities are expected to increase under all climate scenarios and across all future time horizons. A Project Flood Resilience Action Plan for the workers at the Project site will be implemented by the Project Enterprise (ESAP item). This plan will include near real-time flood monitoring, adequate back-up power, water and food supplies, emergency response facilities, evacuation plans and associated health and safety trainings.

As the Project currently sits on elevated land and has a raised embankment along its boundary with the Dehular Khal, the Project site is protected from median shifts in water levels but is not protected from the more extreme shifts which are likely under accelerated climate change events. Under these more extreme climate scenarios, water levels in the Dehular Khal could rise above the existing embankments along the Project boundary leading to flood impacts to the Project. The Project Enterprise will conduct an analysis of the embankments at the Project site along the Dehular Khal and the embankments will be raised and structurally strengthened to prevent the risk of riverine flooding and accelerated erosion under extreme flood scenarios (ESAP item).  In addition, there are several entrance gates and access points at the Project site which are likely to facilitate ingress of flood waters. These entrance gates and access points will be assessed by the Project Entity and corrective actions will be taken to demonstrate that there is no longer any risk of ingress to the Project site as result of open access points. (ESAP item).

The flood risk analysis of overland flooding resulting from rainfall occurring directly over the Project site highlighted that the existing stormwater drainage system at Project site is not adequate under both baseline and future climate scenarios. The existing system is designed to collect and convey rainfall with a return level of 6 to 8 years. The Project Enterprise will modify the stormwater drainage system to increase its capacity such that it can operate sufficiently for higher return levels of rainfall to ensure the system is climate resilient (ESAP item). This will include procuring emergency drainage pumps and similar machinery to evacuate on site flood waters, ensuring there are adequate maintenance plans to manage sediment discharge from the Project site, and regular de-silting of any channels to maintain carrying capacities.

As the Project site relies heavily on boat access, the Project Enterprise will develop plans for contingency docking options and implement resiliency measures for boat and port traffic areas to ensure safe access during extreme high-water events. (ESAP item).

The flood risk analysis conducted by ERM in 2021 also identified that there are 117 households within a 1 km radius of the Project. A 1 km radius was selected as ERM identified that this was the most appropriate area of flood influence due to the hydrological characteristics of the Project area. The analysis highlighted that all 117 households will experience increased flood risk under all future climate scenarios as they predominately sit in low-elevated areas with poor community drainage infrastructure. ERM also modelled how flood risks for these 117 households would change as a result of the Project. This was completed to evaluate if there is a risk of increased flooding to the households due to the construction and operation of the Project. ERM concluded that the Project will not exacerbate existing flood risks for the 117 households, as drainage outflows from the Project site will be directly discharged into the Dehular Khal, which has sufficient capacity to collect and convey this water. Nonetheless, as the 117 households are at risk to increased flooding due to climate change, the Project Enterprise will work alongside government partners to develop and implement a Community Flood Resilience Action Plan (ESAP item).  This plan will include flood and cyclone response training for nearby communities, potential investments to enhance the drainage of the main road leading to the Project site, dissemination of flood warnings to communities, and potential investments through a community investment plan to enhance community emergency response facilities and community drainage infrastructure.

Management Programs:

The EHSSMS was prepared based on the findings of the ESIA and the requirements of the PSs, and consists of a number of plans and programs to manage impacts and risks, including air emissions and water effluents, waste management, soil conservation, stakeholder engagement, health and safety plan, etc., as well as a monitoring program.

The plans and programs of the EHSSMS sets out requirements for NBBL as well as contractors, and the O&M Contractor will is contractually required to implement the relevant components during operations as described above.

The EHSSMS also defined key roles and responsibilities of NBBL and the contractors for implementation of environmental and social management programs. 

Organizational Capacity and Competency:

NBBL has an EHS team at the Project site, headed by a qualified EHS Manager and also including the Human Resources Manager and a Community Liaison Officer. For construction and commissioning, the EPC Contractor has an EHS Manager and a team of Site Supervisors with responsibility for the implementation of the EHSSMS. During operations, the O&M Contractor will maintain a similar organization with an EHS Manager which has already been appointed, and NBBLs EHS team will also be retained for operations.

Emergency Preparedness and Response:

NBBL’s EHSSMS includes emergency preparedness and response procedures which covers construction and operation. The procedures refer to relevant emergency scenarios, including spills, leaks, fire, vehicle accidents, natural hazards, etc., and include roles and responsibilities, training, and communication procedures. The procedures have been supplemented with relevant recommendations related to COVID-19 (see below). 

The O&M Contractor has developed a Contractor’s Emergency Response Plan, based on the EHSSMS.

Monitoring and Review:

NBBL, as well as EPC and O&M Contractors undertake regular E&S monitoring to demonstrate   compliance with national environmental standards and lender requirements. The NBBL EHSSMS includes a Monitoring Program, with parameters to be monitoring, monitoring locations, methods and frequency of monitoring; and criteria against which compliance and performance is assessed. The contractors implement the relevant parts of the monitoring program through the respective monitoring programs.

The EHSSMS also includes procedures for internal auditing and review of environment, health and safety, labor and social aspects of project activities. Internal audits have been carried out quarterly throughout construction phase, supplemented by quarterly external audits.  

During construction, independent monitoring was carried out by the IESC quarterly, including site visits and meetings with the communities. For the operations phase, the monitoring visits will be undertaken by the IESC on a semi-annual basis for the first two years of operations, then annually thereafter. The Project will also be required to submit annual E&S monitoring reports to MIGA.

Stakeholder Engagement:

Stakeholder consultations were originally conducted as part of the ESIA between 2016 and 2017 through bilateral meetings, letters, and public consultation meetings. NBBL implemented a Stakeholder Engagement Plan during construction, including stakeholder analysis, and various methods of communication for engagement depending on stakeholder’s interest and influence level. Methods include face-to-face meetings, site visits by authorities, door-to-door visits, community meetings, media information announcements, follow up response to complaints, and workshops. The Stakeholder Engagement Plan will be maintained for operation.

The key issues discussed during consultation meetings are summarized in the ESIA and included questions about compensation for affected land; employment opportunities and requests for community development projects, as well as concerns related to cumulative impacts, and air and noise pollution from the Aggreko plant. Following the COVID-19 outbreak, stakeholder engagement activities have been adopted in line with the Project’s COVID-19 Operating Procedure. 

The Project will result in the economic displacement of 130 farmers, and 38 sharecroppers from the area surrounding the Project, which has a population of over 22,000 people. This impact is mitigated through the implementation of a Livelihood Restoration and Development Plan (LRDP, refer to section on PS5). The results of stakeholder engagement undertaken to date (which have followed a process of informed consultation and participation) indicate that the community is supportive of the project.

External Communication, Grievance Mechanisms and Ongoing Reporting to Affected Communities

A Community Grievance Redressal Mechanism is implemented as part of the EHSSMS, and includes details of responsibilities, and various modes of filing a complaint. The grievance mechanism has been communicated to local communities and details are posted on notices and boards around the communities. Implementation and availability of the grievance mechanism has been confirmed as part of the IESCs quarterly monitoring.  

NBBL has publicly disclosed key E&S assessment and management programs on the Project website, including the monitoring program and grievance mechanism, in English and Bengali. A Community Liaison Officer is appointed as the primary contact for community members, and is in charge of ongoing reporting to affected communities as set out in the Stakeholder Engagement Plan.

PS2:  Labor and Working Conditions

The Project has been operational since June 2021, and the current headcount for operations is approximately 200 persons including the project company and contractors. As of August 2021, the EPC Contractor still had minimum staff remaining at the site, once post-commissioning activities have been completed the workforce is expected to be around 75. At peak construction, the workforce reached approximately 1,000 workers.

Working Conditions and Management of Worker Relationship:

NBBL has a Human Resources (HR) policies and procedures in place applicable to its staff, including a policy statement and provisions for freedom of association, equal renumeration, recruitment and training, working conditions and terms of employment, and security and safety policies for staff. In addition, policies are included against and prohibiting forced/child labor, discrimination and harassment, and including protection of rights for migrant workers. 

The EPC Contractor implemented separate HR procedures based on an in line with the NBBL policies for construction staff. For operations, the O&M Contractor has developed a draft HR policy which will be amended based on the requirements of PS2 and addressing gaps identified by the IESC, for example related to child/forced labor, retrenchment, collective bargaining, and grievance mechanism (ESAP item).

A labor compliance audit against regulatory requirements was undertaken for the Project in December 2019. The audit identified a number of non-compliances, primarily related to labor licensing and leave registers, which were subsequently addressed and closed out by NBBL and construction contractors.  

Temporary worker accommodation was provided to staff during the construction phase, located outside the Project site. Labor accommodation requirements in line with the IFC/EBRD Guidance Note on Worker’s Accommodation are included in the EHSSMS. O&M staff will be housed in onsite permanent buildings leased from BDBP.

A staff grievance mechanism is included in the HR procedures of the NBBL. As mentioned above, the O&M Contractor will revise its HR policies to include a grievance mechanism specific for workers in line with PS2. 

Protecting the Work Force:

According to the Bangladesh Labor Act (2006) there are different minimum working ages for children depending on the nature of the work. NBBL and EPC Contractor HR policies state that the minimum age of employment for the Project is 18 years of age, and prohibits the use of forced labor. The O&M Contractor will include the same requirements in its revised HR policies (ESAP item).

The HR policies also includes provisions against harassment and gender-based violence.

Occupational Health and Safety:

Consideration of Occupational Health and Safety (OHS) is incorporated into the EHSSMS, which includes an OHS Management Plan. The plan consists of description of roles and responsibilities, procedures for hazard identification, risk assessment and safety analysis, provision of appropriate equipment and training, and a system for near miss and incident reporting and investigation. A fully equipped ambulance with first-aid and life support systems is provided at the site for emergency purposes.

The EPC Contractor has implemented a stand-alone OHS Management Plan based on the provisions of the EHSSMS. The O&M Contractor has a corporate wide OHS Management System developed in line with the requirements of ISO 45001, and adheres to the OHS Management Plan incorporated into the project’s EHSSMS.

Occupational health and safety practices have been continuously monitored throughout construction by the IESC, and in cases where non-compliances have been identified, these have been addressed within an agreed timeframe.

Workers Engaged by Third Parties and Supply Chain:

The NBBL EHSSMS lays out obligations for contractors including EHS management and labor standards. The EPC and O&M contractors require sub-contractors to develop and implement workplace rules, processes, and procedures in line with the EHSSMS. A sub-contractor management procedure has also been established, including review of health, safety and labor practices and procedures of each contractor. The procedures include for health & safety and labor audits to be conducted every quarter during construction.

A procedure for identification of primary suppliers and ensuring that applicable labor requirements (i.e. minimum age of employment, no child/forced labor) are extended to the primary supply chain will also be incorporated into the EHSSMS (ESAP item).  

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency:

It is anticipated that the Project’s carbon intensity will be approximately 350-430 grams of carbon dioxide equivalent per kilowatt hour (gCO2eq/kWh).  This will result in greenhouse gas (GHG) emissions between 567,000 tons and 696,000 tons per year. Greenhouse gas emissions accounting will be undertaken on an annual basis and provided to MIGA as part of the Annual Monitoring Report.

Water will be supplied from the Dehular Khal which runs along the boundary of the Project site. A water supply assessment was undertaken as part of the ESIA to determine whether there are sufficient water resources to supply the Project without affecting other water resource users. It was determined that the expected water abstraction for the Project (384 m3/h) is estimated to be approximately 0.1% of the mean water flow of the Dehular Khal and impacts related to water availability are not expected. Approximately 75 m3/h of effluent will be discharged back to the Dehular Dhal following treatment in the Project’s wastewater treatment system.

Pollution Prevention:

During construction, the primary emissions were dust and particulate matter. These were addressed through mitigation measures (e.g. dust suppression; management of vehicle loads and speeds). The primary air emissions from operation of the Project comprise oxides of nitrogen (NOx) (i.e. nitric oxide (NO) and nitrogen dioxide (NO2)) and carbon monoxide (CO) emitted during the gas combustion process, and sulphur oxides in case the Project would operate on HSD.  

According to the ESIA, stack emissions are expected to be below national regulatory standards and those of the WBG EHS Guidelines (in line with EPC Performance Guarantees for the Project). Continuous Emissions Monitoring System (CEMS) analyzers have been installed in all stacks to ensure that emissions remain within the allowable limits.

The main existing point source emission points in the vicinity of the Project are the operational Bhola-1 and Aggreko gas fired power plants, which primarily emit a combination of NO2 and CO to the local airshed.

Air quality dispersion modelling was carried out as part of the ESIA studies for the Project, considering both the Project individually and cumulative impacts of the three plants on nearby sensitive receptors. Based on the modelling, ambient air quality parameters are not expected to exceed national standards but operation of the three plants simultaneously may result in minor exceedance of the WHO standard for NOx hourly average at two receptors. The Aggreko concession agreement expires in March 2022, and it is expected that the agreement will not be renewed and that the Aggreko plant will be decommissioned, which will significantly reduce the cumulative impact on the ambient air quality.

Ambient air quality monitoring with all power plants in the Bhola complex operational was conducted in June 2021, which indicated that parameters meet both national and WHO standards at all receptors for 24-hour averages Continuous air quality monitoring within the Project boundaries and routine ambient air quality monitoring at key surrounding receptors will be undertaken during operations as part of the EHSSMS. If at the end of two years of ambient air quality monitoring it is determined that the airshed has become degraded for NOx as measured by the hourly average parameter, NBBL will conduct a study of potential air quality mitigation and offset measures to improve the airshed (ESAP item).

Noise was generated from construction equipment during the construction phase and is generated from turbines and cooling towers during the commissioning and operations phases. Modelling of noise impacts undertaken as part of the ESIA concluded that the Project’s noise emissions are expected to be compliant with WBG EHS guidelines at all sensitive receptors during both the construction and operations phases, and will not result in an increase of more than 3 dB at the nearest receptor off-site. However, considering the cumulative impact from operation of the three plants as well as anthropogenic noise, exceedances of the applicable standards are expected at various receptors, for both day and night-time levels. The noise modelling demonstrates that the major contribution of noise emissions is from operation of the Aggreko plant. A noise impact analysis will be carried out during commissioning of the plant to ensure adherence with guaranteed performance levels and confirm the findings of the noise modelling, followed by implementation of mitigatory measures such as noise barriers if necessary (ESAP item) to ensure compliance with PS3 and the EHS Guidelines. Management of vibrations resulting from operation of the Project are managed as part of the EHSSMS, and related impacts on adjacent communities are not expected.

During operations, wastewater will be made up of process water that was not reused or recycled into the process. The Project includes a wastewater treatment plant with mechanical and biological treatment for its wastewater discharges, and it is expected that discharges will amount to approximately 75 m3/hour. Effluent will be treated to meet national and applicable standards of WBG EHS Guidelines prior to discharge to the Dehular Khal. Sanitary wastewater is collected and treated in the Project’s wastewater treatment plant. Rainwater from roofs and paved areas will is collected by a storm water drainage system and discharged to the Dehula Khal. Rainwater falling on potentially contaminated surfaces (such as oily drains, fuel gas area, car parking area) is directed to an oil & grease separator prior to discharge.

Hazardous materials, which primarily includes oil and fuel is stored in designated areas in accordance with the national requirements and standards, and WBG EHS Guidelines to prevent any spillage on the site. Spill kits are available in designated locations around the site, with related training provided to staff.    

The Project generates both non-hazardous wastes and hazardous wastes. Non-hazardous wastes include general solid waste, organic food waste and packaging waste, while hazardous waste includes used generator and turbine lube oil, contaminated rags/cloths and cleaning waste. Used oil and oily materials is collected on site and removed in drums for disposal. The EHSSMS includes a waste management plan appliable to construction and operation, implemented by both NBBL and contractors, including procedures for inventory, storage & handling, and disposal.

PS4:  Community Health, Safety and Security

Community Health and Safety  

The Project is located in a rural area around 2 km from the nearest community, though some individual farmhouses located closer to the site. The closest town, Borhanuddin, is approximately 3 km from the site.

Community health and safety issues associated with the construction and operation of the Project include unauthorized access to project sites, road safety, impacts associated with in-migration of the project workforce, impact on community water resource use and emergency situations. The site is fenced and boarded by a wall, and security posted to prevent community access to the site. The gas pipeline is below ground with minimal community health and safety risks following completion of construction.

Mitigation measures identified in the ESIA include that all high-risk areas including fuel storage areas will be secured with internal fencing and will be patrolled by security throughout the day. During both construction and operations, only authorized workers will be allowed to enter the site. Road traffic accidents will be minimized through driver training, enforcement of speed limits and regular maintenance of Project vehicles. There is an operational traffic management plan incorporated within the ESHHMS, applicable to both construction and operations phases. 

A Labour and Influx Management Plan (LIMP) has been established as part pf the EHSSMS in order to minimize Project-induced in-migration during construction, and implement mitigation measures to address adverse related impacts, including gender-based violence and transfer of communicable diseases. Worker camps are located outside of the site and were established in line with the IFC/EBRD Guidance Note on Worker’s Accommodation. As indicated in previous sections, human resource policies and procedures include a Code of Conduct for Project staff, including rules for interaction with local communities.

A procedure for managing and mitigating risks related to COVID-19 was established for the Project in June 2020, and includes transmission prevention measures, communication and responsibilities protocols, coordination with local health authorities, and home quarantining measures. The Project has also carried out COVID-19 information campaigns and face masks distribution programs in the local communities.

As discussed in the section above, water abstraction for the Project is not expected to affect community water resource use. The emergency response protocols implemented as part of the EHSSMS includes measures to prevent impact on community health and safety, and mechanisms to ensure communication with the adjacent power plants, local leaders and emergency services in case of an emergency.

Security Personnel:

A private security contractor is engaged by NBBL to provide unarmed security, and a Security Management Plan is implemented as part of the ESHSSMS, including provisions for recruitment and training, identification of security related risks, incident response and communication, and reporting. Other security measures include fencing of the site, use of Closed-Circuit TV, and restricted access to construction workers with valid ID cards. The Security Management Plan is aligned with IFC’s Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts.

PS5:  Land Acquisition and Involuntary Resettlement

General:

The Project has been constructed on 30 acres of land, out of which 17 acres has been purchased from local landowners, and 13 acres have been leased from BPDB. The area affected by the project was previously used for farming, primarily paddy crops and beans.

Displacement:

The portion of the Project footprint purchased by NBBL required economic displacement affecting 130 farmers with legal land titles for the plots. In addition to the land, one non-residential building, a tin structure used for keeping ducks and hens was affected.

A local consultancy was commissioned by NBBL to prepare a Livelihood Restoration Plan (LRP) and the land was acquired between 2016 and 2019 based on market rates for land and loss of crops.  A Resettlement Audit was commissioned by AIIB in 2019 which reviewed the LRP and land acquisition process against local regulatory requirements and the PS. The audit was carried out by AECOM and identified a list of issues and a corresponding action plan. AECOM was subsequently commissioned by NBBL to develop a Livelihood Restoration and Development Plan (LRDP) based on the findings of the audit and in line with PS5. As of August 2021, the LRDP is under implementation and includes additional compensation payments to landowners and sharecroppers, as well as identification of vulnerable households, and livelihood restoration programs.

Around 56% of the land acquired by NBBL was cultivated by the landowners, and the remaining areas by 38 sharecroppers (tenant farmers). The LRDP also includes supplementary payments for loss of crops, as well as livelihood support programs for the sharecroppers.

The portion of the land to be leased from BPDB was acquired by BPDB as part of the land acquisition for the Bhola1 power plant in 2007, and involved economic displacement affecting around 70 households. The land was purchased by BPDB in 2012-2013 and landowners were compensated based on local regulation.  Landowners affected by the original land acquisition that still reside in the adjacent communities are eligible for support through the livelihood restoration programs implemented under the LRDP described above.

With regards to associated facilities, approximately 650 landowners are affected by the land acquisition for the 5.5 km pipeline. The route is adjacent to an existing pipeline, and primarily affects paddy fields and betel nut plantations. The impact will be temporary, and once the construction is completed the land can be cultivated however with restrictions in terms of erecting buildings or planting trees. As of August 20201, the construction of the pipeline is approximately 60% completed, and SGCL has carried out land acquisition for the right-of-way is responsible for the land acquisition for the pipeline in line with local regulatory requirements. There is a memorandum of understanding between NBBL and SGCL which obligates SGCL to provide information and inventory related to land acquisition to allow NBBL to bridge the gaps between the national requirements and PS5. An LRDP for the pipeline is currently being developed by AECOM, commissioned by NBBL (ESAP item). The pipeline will be underground and once construction is finished affected farmers can grow crops over the pipeline, but will be restricted from planting trees, digging or erecting buildings in the right-of-way.

As discussed previously, a Project-level grievance mechanism has been established to allow affected people to submit grievances, including those arising from acquisition of land and disruption of livelihoods. Evidence to date indicates that the grievance mechanism is functioning as designed, as the Project has received and responded to a number of grievances related to land acquisition.

PS6:  Biodiversity Conservation and Sustainable Management of Living Natural Resources

The area on which the Project has been constructed previously consisted of modified habitat, used for crop farming. Biodiversity surveys and baseline information is included in the ESIA studies, and no protected areas, areas identified as critical habitats, or Endangered or Critically Endangered species (as per the IUCN Red List) were identified in the Project areas of impact. Significant biodiversity impacts are therefore not expected.

A Biodiversity Conservation and Management Plan is implemented as part of the EHSSMS, including description of roles and responsibilities, procedures for avoiding, minimizing and mitigating biodiversity impacts in construction and operations phases, and monitoring. The EHSSMS also includes procedures for management of invasive species in relation to barge and ship movements and transportation to and from the site.  

Supplementary biodiversity surveys of the pipeline route conducted by AECOM confirm no protected migratory bird species in the pipeline ROW or nesting in the ROW. Given there are ecological monitoring and management requirements are spread across different documents and survey reports, these will be consolidated into one updated Biodiversity Conservation and Management Plan, (which will lists ongoing ecological monitoring across the project site and pipeline right-of-way (ESAP item)). 

Broad Community Support is not applicable for this Project.

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org. 

• Environmental and social impact assessment report, January 2018
• ESIA Addendum, January 2020
• ESIA Annexes, January 2018

The above documentation and additional environmental and social information in Bangla is also available for viewing at the following location:

• NBBL Website: http://nutanbidyut.com/

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org