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Environmental and
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Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-i


TABLE OF CONTENTS

3 METHODOLOGY.......................................................................................................................3-1
3.1 STUDY METHODOLOGY............................................................................................... 3-1
3.1.1 Introduction........................................................................................................3-1
3.1.2 Pre-feasibility and Screening..............................................................................3-3
3.1.3 Project Scoping..................................................................................................3-3
3.1.4 Consultation.......................................................................................................3-4
3.1.5 Legislative Review.............................................................................................3-4
3.1.6 Baseline Studies................................................................................................3-5
3.1.7 Analysis of Alternatives......................................................................................3-7
3.1.8 Impact Assessment............................................................................................3-7
3.1.9 Formulation of Mitigation and Management Strategies......................................3-9
3.1.10 Risk Analysis....................................................................................................3-10
3.1.11 Submission of IEE and EIA to GoB..................................................................3-10
3.2 STATUS OF PROJECT STUDIES................................................................................ 3-10
3.3 STUDY LIMITATIONS................................................................................................... 3-11

Appendix 3.1: The Study Team...................................................................................................1


LIST OF FIGURES

Figure 3.1: Project ESIA Evaluation Process.........................................................................................3-2


LIST OF TABLES

Table 3.1: Reference Studies................................................................................................................3-5
Table 3.2: Government and Multilateral Agency Sources......................................................................3-5
Table 3.3: ESIA Technical Studies........................................................................................................3-6
Table 3.4: Residual Impact Likelihood Ranking.....................................................................................3-8
Table 3.5: Significance Assessment Matrix...........................................................................................3-8


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Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-1

3 METHODOLOGY
3.1 STUDY METHODOLOGY
3.1.1 Introduction
This ESIA evaluates the interaction of the mine with the ecosystem and the community. The ESIA
Study Team has followed worlds best practice methodologies including the guidance provided by the
Equator Principles (2002), IFC Operational Policy 4.01 (Environmental Assessment) (1998i), and the
World Banks Environmental Assessment Sourcebook (1991a).

Asia Energy has committed to developing, operating, decommissioning and rehabilitating the Phulbari
Coal Mine in accordance with the Equator Principles and international mine best practice standards.
Accordingly, the ESIA has been undertaken over a 14 month period to enable environment field studies
and facilitation of community and stakeholder consultation activities. During this period, the ESIA study
team (the Study Team) has also contributed to mine planning and design by identifying and advising on
environmental and social constraints of the Project design and operational alternatives.

A key objective of the ESIA is to address recognised sustainability issues relating to natural resources
and protection of environmental qualities. Guiding principles are:

The Precautionary Principle. The precautionary principle states that if there are threats of
serious or irreversible environmental damage, lack of full scientific certainty should not be used
as a reason for postponing measures to prevent environmental degradation.
Inter-generational Equity: The principle of inter-generational equity is that the present
generation should ensure that the health, diversity and productivity of the environment is
maintained or enhanced for the benefit of future generations.
Conservation of Biological Diversity and Ecological Integrity: The premise of this principle is
that the natural environment provides the basic elements of all life on earth and thus,
maintaining biodiversity and ecological integrity is important for both anthropogenic and
anthropocentric reasons. The protection of biodiversity and maintenance of ecological
processes and systems are central goals of ecologically sustainable development.
Improved Valuation and Pricing of Environmental Resources: A central notion of sustainable
development is that the total stock of resources should be carefully managed to maximise the
welfare of society now and for all future generations, by addressing the inadequacies inherent
in market pricing mechanisms.

The Study Team was comprised of a number of local and international ESIA and technical disciplinary
specialists. Due to Bangladeshs limited experience in the mining industry, and open cut mining in
particular, international specialists with expertise in assessing open cut mine developments and related
environmental and socio-economic issues were engaged to guide the ESIA process. The Study Team
was also responsible for developing, organising and undertaking the necessary environmental and
social baseline studies. Recognised peer reviewers were engaged to test the robustness of
methodology and conclusions of key technical studies. The Project Study Team is given in Appendix
3.1.

Figure 3.1indicates the steps that have been undertaken during the ESIA evaluation process for the
Project.





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Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-2


ON GOING ACTIVITIES
- Community Consultation
- Analysis of Alternatives
- Identification of Environmental
& Social Constraints
- Peer Review
THE PROJ ECT
PROPOSAL
Pre-feasibility Studies
Screening
Scoping Consultation
& Legislation review
Impact Assessment
Baseline Studies
Formulation of Mitigation
& Management Strategies
Identification & Evaluation
of Residual Impacts
Submission of IEE & EIA
to Meet GoB
Requirements
Updated Mine Design &
Technical Reports
OUTCOMES
Project is Feasible
Category A (IFC)
Category Red (GoB)
Identification of Issues
Select Project Team
Set Terms of Reference
Evaluation of
Baseline Conditions
Environmental Management Plan
Resettlement Action Plan
Public Consultation & Disclosure Plan
Indigenous Peoples Development Plan
Risk Analysis
Granting of ESC
Granting of ECC
ESIA
Analysis of Alternatives



Figure 3.1: Project ESIA Evaluation Process



Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-3

3.1.2 Pre-feasibility and Screening
Pre-feasibility studies for the Phulbari Coal Project (the Project) were undertaken by Asia Energy
(GeoEng 1999). Following confirmation of Project feasibility, Project screening, involving consideration
of Government of Bangladesh (GoB) legislative requirements, and the policies of the major financial
lending institutions (contained within the Equator Principles (2002)), confirmed that an Environmental
and Social Impact Assessment (ESIA) must be undertaken. Further screening indicated that the Project
would be considered category Red
1
for the purposes of environmental assessment for the GoB and
Category A
2
according to the Equator Principles. For each category, the respective approving body has
issued specific guidelines that stipulate the required content of an ESIA. As indicated in Chapter 2, this
ESIA has been prepared in accordance with those guidelines.

3.1.3 Project Scoping
The aim of the scoping study was to gather information on the current status of Project planning and
design, make a preliminary assessment of the Projects area of influence, ascertain key environmental
and social aspects and receptors, and identify key potential impacts and gaps in knowledge.

As compliance with GoB legislation and policy is a requirement under the Equator Principles, the ESIA
process has been broken into three chronological phases:

preparation of an Initial Environmental Examination (IEE) as per GoB requirements;
preparation of an Environmental Impact Assessment (EIA) as per GoB requirements; and
preparation of an ESIA to Equator Principle standards.

The scope of the first two phases only considered the mine development and operation, including
infrastructure development, road and rail deviations, mine pit excavation, coal extraction and
processing, overburden dumping and rehabilitation.

Ancillary requirements to the mining operation (coal transport routes and infrastructure) require
significant GoB involvement and operational management, and are largely outside the direct control of
Asia Energy. As a result, it was decided that these aspects would not be included in the assessment
process until the first two phases were complete. Instead, options for coal transport routes and
infrastructure were identified in the EIA and preliminary environmental and social impact assessments
included in this ESIA (Chapter 11). An ESIA for coal transportation is being prepared separately.

The Terms of Reference of the ESIA included the following key components:

managing consultation with relevant government stakeholders, NGOs, and Project-affected
people;
identifying the Projects area of influence and relevant environmental and social aspects;
gathering and evaluating available baseline information;
designing, implementing and undertaking monitoring studies;
identifying environmental and social constraints to Project development;
identifying and assessing the likely environmental and social impacts of the Project.
Evaluation included direct, indirect and cumulative impacts;
designing mitigation and management measures to minimise potential impacts;

1
Projects identified as having potentially significant environmental issues. According to the Environment Conservation Rules
1997, all mining activities are classified as category Red.
2
Projects that are likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented.
Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-4

identifying opportunities to enhance beneficial impacts of Project development, and improve
social development opportunities; and
developing environmental and social monitoring programmes to evaluate the effectiveness of
mitigation measures.

3.1.4 Consultation
Consultation with government agencies and community representatives commenced in August 2004
and continued throughout compilation of the ESIA. The challenging task of stakeholder communication
was based on informed public participation and information dissemination, as outlined in the World Bank
Update No. 26, Environmental Assessment Handbook (1999). During preparation of the ESIA,
community consultation took the form of:

distribution of several community information sheets and a Project brochure in Bangla to
Upazila union officials and community members;
meetings with government and the eight Union Parishads located in Asia Energys licence
areas;
detailed discussion with NGOs;
opening of an Information Centre in the main street of Phulbari Township;
briefings with community groups by means of aggregated village workshops;
focus group discussions and individual case studies with particular categories of Project-
affected people; and
demographic; resettlement, town planning and health surveys.

Concerns and suggestions raised by stakeholders have been considered during the Project planning
and ESIA preparation process, and where possible tailored mitigation and management measures have
been developed.

A wide range of Upazila Government officials, departments and community representatives have been
consulted since August 2004. Consulted stakeholders and villages are identified in the Public
Consultation and Development Plan (PCDP), provided at Volume 4, Section 1 of this ESIA.

Consultation will continue as an ongoing process and will form a key part of design, development,
implementation and operation of the Project. The future strategy for consultation and information
disclosure is also identified in the PCDP.

3.1.5 Legislative Review
A review of GoB and international legislation, policies and guidelines was undertaken and included:

national legislation and policies;
international conventions to which Bangladesh is a signatory; and
Equator Principles policies and guidelines.

The review was conducted in two phases. The first phase identified the legislation, policies and
guidelines to which the Project must conform. This information was used during the alternatives
analysis process to ensure that Project design and planned operations fit within the GoB and
international legislative and policy framework. The second phase (detailed in Chapter 2) assessed the
preferred Project planning, design and operation options against national and international
requirements.
Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-5

3.1.6 Baseline Studies
Following a review of GoB EIA Guidelines (Department of Environment (DoE), 1997) and consultation
with the DoE, detailed baseline investigations were undertaken within an area incorporated by a 10
kilometre radius from the centre of the Deposit (as determined in August 2004). Groundwater, surface
water, biodiversity and social-economic studies occurred over a wider area to provide sufficiently
comprehensive baseline information and impact prediction

i. Reviewof Secondary Data
Available secondary information was sourced through consultation with government departments,
academic institutions, NGOs and other relevant stakeholders. Secondary data on geology, climate,
environment and water resources for the Phulbari area was mainly collected from private sector studies
(Table 3.1).

Table 3.1: Reference Studies
References
Ahmed (1994); Korea North-North Cooperation Corporation (2000);
BHP (1995a-b, 1998a-b); Mott Macdonald and Partners (1982);
British Geological Survey & Department of Public Health
Engineering (2001);
GeoEng International Pty Ltd (1999; 2000a-d; 2001a-b)
(site-specific studies commissioned by Asia Energy);
Mott Macdonald International et al (1993);
Sir M Macdonald & Partners & Hunting Technical
Services (1980); and
Wardell Armstrong (1991).

Regional secondary data was also collected from the following government and multilateral agency
sources (Table 3.2).

Table 3.2: Government and Multilateral Agency Sources
Agency
Department of Environment (DoE); Department of Education;
Department of Forestry; Rural Electrification Board (REB);
Department of Fisheries; Department of Agricultural Extension (DAE);
Water Resources Planning Organisation (WARPO); Bangladesh Bureau of Statistics (BBS);
Department of Public Health Engineering (DPHE); Local Government Engineering Department (LGED);
Public Works Department (PWD); Roads and Highways Department (RHD);
Bangladesh Water Development Board (BWDB); Bangladesh Power Development Board (BPDB);
Bangladesh Rural Development Board (BRDB); World Bank;
Bangladesh Meteorology Department (BMetD); Asian Development Bank (ADB);
Power Grid Company of Bangladesh (PGCB); International Finance Corporation (IFC); and
Gas Transmission Company Ltd (GTCL); Other financing, funding and research organisations such
as the Department of International Development (DFID),
the Bangladesh Institute of Development Studies (BIDS)
and CARE.









Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
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ii. Primary Data and Field Surveys
To comprehensively evaluate existing baseline conditions, a monitoring and data collection programme
incorporating a number of biophysical and social investigations was developed and implemented. The
methodology used to develop individual studies is contained within the various technical reports
appended in Volumes 2 to 4 of this report. Primary data studies given in Table 3.3have been
completed and results summarised in Chapters 7 and 8.

Table 3.3: ESIA Technical Studies
Study Comment
Coal resource evaluation Geophysical surveys and drilling assessed coal reserves and site-specific geological data.
Hydrogeological survey This survey provided an assessment of the hydrogeological regime and methods for groundwater
control. Water level data collection commenced in July 2004 and continues weekly. Groundwater
samples were collected every two months over a 12 month period at 14 sites for detailed water
chemistry analysis.
Arsenic in groundwater This study examined the occurrence of arsenic in groundwater from 64 locations within a 20 kilometre
radius of the Deposit.
Surface water survey Water levels have been measured at nine staff gauges on various watercourses and beels since August
2004. An additional nine gauges were installed in May 2005. Two automatic water level recorders have
also been installed. Water samples were collected monthly over a 12 month period from 14 locations
for chemical analysis. Flood modelling has also been carried out.
Climatological surveys A manually operated weather station has been operating in Phulbari since September 2001 measuring
daily temperature, humidity and rainfall. Two automatic weather stations were installed in November
2004 for measurement of temperature, wind speed and direction, barometric pressure, total and net
solar radiation, relative humidity and rainfall.
Air quality monitoring Air monitoring commenced in November 2004 and included analysing particulate matter (less than 10
microns (PM10) and less than 2.5 microns (PM2.5)) and total suspended particulates (TSP) using
portable air samplers and dust deposition gauges around the Mine Footprint. Sampling of ambient
sulphur dioxide (SO2) and nitrogen dioxide (NO2) concentrations was also undertaken.
Noise monitoring Noise loggers monitored ambient noise around the Mine Footprint. Noise descriptors including L10, L90,
Leq and a number of statistical parameters were also logged.
Biodiversity monitoring Wet (August to November 2004) and dry (December 2004 to March 2005) season fauna, flora and
aquatic field studies have been completed.
Survey of major institutional
features
Conducted in early 2004, this survey resulted in a database of education, religious and health
institutions, cultural sites, historical sites, and graveyards.
Demographic and socio-
economic information
A demographic and socio-economic survey was conducted of every household within the 5 Kilometre
Zone plus areas of the Mine Footprint outside this Zone.
Village checklist An inventory of all community infrastructure, services and facilities in villages located within the 5
Kilometre Zone.
Resettlement survey A survey of all households and business enterprises potentially affected by the proposed mine.
Host community survey A demographic and socio-economic survey conducted in the proposed host community sites.
Survey of government and
non-government institutions
The survey identified NGOs and government organisations in the Study Area.
Archaeology and heritage Archaeologically significant locations in and around the Study Area were assessed.
Population projections Projected population in the Study Area was assessed between 2004 and 2051 (in five-year intervals).
Anthropology and
indigenous groups
The traditions, cultural inheritance and impact of the Project on the indigenous groups were assessed.
Socio-economics The local and regional socio-economic impact of the mining operation on the community and the
environment has been assessed.
Health impact assessment A study of the local and regional impact of mining operations on community health and safety in the
Study Area and the collection of baseline health data.
Traffic survey Traffic counts were conducted in and around Phulbari to assess impacts on traffic flow and determine
new road cross-sectional requirements.
Town planning survey Ascertained land use characteristics within the existing Phulbari Township such as existing structure
types and conditions, zoning areas, transport routes, house types and plot sizes, public utilities and
access to facilities.
GIS land ownership survey This survey developed a GIS database of land ownership.


Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-7

3.1.7 Analysis of Alternatives
The Study Team investigated a range of options, which generally followed the guidance provided by
IFCs Operational Policy OP 4.01 (1998i) and the World Banks Environmental Assessment Sourcebook
Update: Analysis of Alternatives in Environmental Assessment (1996). The results of these
investigations are presented in Chapter 5. A preferred option was then adopted for detailed
assessment.

3.1.8 Impact Assessment
Impact assessment was a two part process, divided into assessment of impacts both before and after
the implementation of mitigation measures; the latter being referred to as residual impacts. A variety
of discipline-specific methods were used for impact prediction including modelling, experiences of
similar projects, experiences in similar biophysical and socio-economic environments, matrices and
checklists, and expert judgement. Discipline-specific methodologies are detailed in the respective
technical reports.

i. Assessment of Impacts before Mitigation
This assessment included consideration of:

direct/primary impacts;
indirect/secondary impacts;
cumulative impacts;
synergistic impacts;
the duration of impacts (short, medium, long term);
the areal extent of the impact (including any transboundary aspects);
whether impacts are temporary or permanent; and
legislative and policy implications.

Where mitigation measures were not expected to completely mitigate any adverse potential impacts, an
assessment of residual impacts was undertaken.

ii. Residual Impacts
Assessment of residual impacts followed a similar methodology to that described above but included an
assessment of the significance of the residual impact. Evaluation of the significance of a residual
impact followed standard risk assessment methodology, such as that described in Australian Standard
AS/NZS 4360: Risk Management (2004), and included consideration of:

the likelihood of impact occurrence; and
the severity or consequence of the impact in the biophysical and/or socio-economic context
(including whether impacts will breach GoB legislation or Project objectives).

Apart from where it is indicated by modelling, it is recognised that the evaluation of the likelihood of
impact occurrence is largely subjective and based upon the expert judgement of discipline specialists.





Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
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a) Likelihood
Following the guidance provided in Table 3.4, an assessment of the likelihood of residual impact
occurrence was made for each environmental and social aspect in Chapters 9 and 10.

Table 3.4: Residual Impact Likelihood Ranking
Rating Definition
Certain The impact is expected to occur under normal operating conditions
Likely The impact will probably occur under normal operating conditions
Possible The impact should occur at some time under normal operating conditions
Unlikely The impact could occur under normal operating conditions
Rare The impact may occur in exceptional circumstances

b) Severity/Consequence
As the severity or consequence of an impact will be different for each environmental discipline, severity /
consequence rankings have been developed by specialists from each discipline. For all disciplines, the
rankings were developed based on consideration of:

whether the impact will breach legislative or policy requirements;
the sensitivity of receptors;
duration of the impact, i.e. whether the impact is permanent or temporary; and
the areal extent/magnitude of the impact and/or how many people it will affect.

The rankings for socio-economic residual impacts were also determined on the basis of the above list,
along with consideration of the potential for unrealised expectations by Project-affected parties.

c) Significance
The overall significance of a residual impact is considered to be a product of the severity or
consequence of a potential impact and the likelihood that it will occur (Table 3.5). Ratings for both
severity/consequence and likelihood have been ranked, and based on the combination of these factors,
the significance of a residual impact has been assessed as low (L), medium (M), or high (H).

Table 3.5: Significance Assessment Matrix
Severity / Consequence Rating
Likelihood
Rating
Negligible Minor Moderate High Very High
Certain L-M M M-H H H
Likely L L-M M M-H H
Possible L L-M M M M-H
Unlikely L L L-M L-M M
Rare L L L L-M M





Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
Methodology Page - 3-9

Significance is defined as follows:

High residual risk: H: This level of risk indicates that significant resources and/or Project modification
would be required to manage potential environmental damage. These risks can be accommodated in a
project of this size, however comprehensive and effective monitoring measures would need to be
employed such that Project activities are halted and/or appropriately moderated. No environmental or
social issues have been identified as having a high residual risk.

Medium- High residual risk: M-H: This level of risk also requires that sufficient resources are
allocated to monitoring operations and that on occasion some Project activities may need to be
moderated. However, it is not expected that activities would need to be halted or suspended for
extended periods. Four issues are identified in this category; air, water management, land loss and
unmet unemployment expectations.

Mediumresidual risk: M: Less significant than above risk rankings, however management procedures
will need to ensure necessary actions are quickly taken in response to perceived or actual
environmental damage. Issues identified in this category are soils, land use, noise, surface water
quality, groundwater levels, subsidence, visual impact, waste management, compensation, injudicious
use of compensation, split communities, community tension and increase in disease

Low- Mediumresidual risk: L-M: This level of risk requires ongoing monitoring, however resources
allocation are less of a priority than higher risk rankings. It is unlikely that Project activities would be
significantly disrupted. Five issues identified in this category are groundwater quality, terrestrial
species, aquatic species, pressure / disruption to infrastructure and demands on local government.

Lowresidual risk: L: This level of risk indicates ongoing monitoring; however resources allocation and
responses would have low priority with regard to higher ranked risks. Issue identified in this category
are flooding, greenhouse gases and re-establishment of businesses.

Where significance was assessed to be medium or higher, mitigation options were reviewed to
ascertain whether any further mitigation measures could be employed to further reduce impacts.

3.1.9 Formulation of Mitigation and Management Strategies
Measures to mitigate potential adverse impacts have been integrated with mine planning and design
activities. Identifying and assessing the appropriateness of mitigation measures before the mine plan is
finalised maximises opportunities for minimising, or preferably avoiding, potential impacts. A range of
mitigation options were considered during the mine planning and design process. For example:

reducing resettlement numbers (eg. the mine path was altered to avoid most of the eastern
part of Phulbari Township, at a resource loss of 20 Mt);
avoidance (eg. the option of using a tailings pond was rejected on social and environmental
grounds);
environmental measures (eg. water treatment facilities);
compensatory measures (eg. for land acquisition);
design optimisation (eg. use of conveyors rather than roads for conveying coal);
procedural measures (eg. rehabilitation to be undertaken in a progressive manner to minimise
environmental impacts); and
timing measures (eg. no blasting at night).



Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

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April 2006
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Mitigation measures have been tailored to suit the locality, taking into consideration:

concerns and suggestions raised during the community consultation process;
baseline biophysical and socio-economic conditions;
identified environmental and social constraints;
any impacts associated with the implementation or operation of proposed mitigation measures;
and
the level of design information available at the time of preparation of the ESIA.

Opportunities for enhancement of beneficial impacts of Project development were also considered at
this stage.

3.1.10 Risk Analysis
The Project is one of the largest developments of its kind in Bangladesh and has the potential of
bringing significant benefits to the country. However, there are a number of risks and uncertainties
associated with such projects. These relate to political, institutional, market, technical, environmental
and social issues. These issues have been subjectively evaluated in Chapter 15, and where possible
mitigation actions recommended and opportunities for financial institutions highlighted.

3.1.11 Submission of IEE and EIA to GoB
As indicated in Chapter 1, both the IEE and EIA have been submitted to the GoB and conditional
environmental clearance issued in favour of Asia Energy for the Project to proceed.

3.2 STATUS OF PROJECT STUDIES
Resource assessment and feasibility level hydrogeological, environmental, social and geotechnical
testing are complete. A conceptual Mine Plan, including mine infrastructure requirements, was
completed in September 2005. The Project Scheme of Development was submitted to the GoB in
October 2005.

The environmental monitoring programme is ongoing and will continue in modified forms throughout the
Project life in accordance with the Project Environmental Social Action Plan (ESAP). An ongoing
monitoring programme will cover:

meteorology;
air quality;
noise;
biodiversity;
surface water quality, level, volume, and velocity; and
groundwater depth and quality.

With regards to socio-economic data collection activities, the demographic, resettlement and village
check list surveys, which commenced in 2004 to collect baseline data from those households both
within and on the fringes of 5 Kilometre Zone, are mostly complete.


Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

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April 2006
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Consultation with stakeholders and information dissemination is also an ongoing process and existing
consultation activities will be continued and expanded upon throughout the life of the Project.

3.3 STUDY LIMITATIONS
i. Study Integration and Ancillary Developments
IFC Operational Policy OP 4.01 stipulates that an ESIA should evaluate potential environmental risks
and impacts in its area of influence. The Policy further defines the area of influence as the area likely
to be affected by the project, including all its ancillary aspects. While the main aspect of this scheme
(the mining operation) has been subjected to detailed baseline studies and impact assessment, ancillary
developments have not been subjected to the same level of assessment. While mining / exploration
leases are held for some of the mining operation site, physical areas and operational details for ancillary
developments require intensive consultation and negotiation with the GoB before they can be
confirmed. These constraints had limited ancillary scheme development to preliminary studies, and
conceptual planning and design at the time of ESIA writing.

Approval for the preferred location for resettlement of part of eastern Phulbari Township residents has
yet to be obtained from the GoB. The preferred areas for relocation of villages have been finalised.
Environmental studies on resettlement areas have been limited to a qualitative study of impacts arising
from the proposed western extension to Phulbari Township.

Studies on coal transport infrastructure options commenced in June 2005 with a preliminary
environmental and social impact assessment completed in September 2005. Due to timing constraints
and differences in the level of assessment undertaken, this report has been summarised into Chapter
11 of this ESIA rather than integrated into the main assessment chapters of the ESIA. This study was
undertaken within a short timeframe that did not allow specific, detailed environmental investigations to
be undertaken. It therefore relied heavily on information from previous studies, site inspections and
limited field monitoring. There are obvious limitations to this approach, as previous studies provided
limited information of specific relevance to this Project. The accuracy and reliability of this data are
unknown. An ESIA for coal transport, based on more detailed environmental field monitoring and social
assessment is being prepared separately (SMEC 2006).

The Mine Footprint initially included the entire portion of Phulbari Township east of the Little Jamuna
River. The Footprint was modified in mid-September 2005 to exclude most of the Township, which
reduced the number of households facing displacement by just over 25 percent, but has also reduced
the buffer zone distance between mine operations and residential areas, and shortened the life of the
mine. Air and noise models have been re-run to reflect these changes and air quality and noise
impacts, and suggested mitigation measures have been incorporated into this ESIA. However, due to
time constraints, other earlier reports which these changes may impact upon, have not been updated.
Thus, small discrepancies in presented data and analysis may be evident.

ii. Baseline Studies
This ESIA includes secondary information from previous studies and ongoing monitoring from various
government agencies. The accuracy and reliability of this secondary data are unknown.

Site-specific primary data collection for various studies commenced between 2001 and late 2004.
Where temporal variation of a parameter would affect impact assessment or design of mitigation
measures, it is general practice to collect data over at least a 12 month period. Site-specific monitoring
of meteorology and ambient air quality, commenced in November 2004, thus less than 12 months of
primary data has been collected for these disciplines at the time of reporting. However, site-specific
meteorological monitoring has been supplemented by 56 years of regional meteorological data from the
Dinajpur Bureau of Meteorological and a prognostic meteorological model based on synoptic data, and
site-specific ambient air quality monitoring has captured the entire dry season, considered to be the
Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1

Final Report
April 2006
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worst-case scenario for ambient air quality conditions. Therefore, while collection of marginally less
than 12 months of site-specific data is not ideal, it is considered that temporal variation has been
adequately reflected in impact modelling and mitigation proposals. Asia Energy plans to continue
monitoring into the Project development, operation and decommissioning phases, and has committed to
amending management and mitigation measures to reflect any temporal variations if necessary.

iii. Mine Planning
The consultant reports are based on available data at the time of writing. During the detailed mine and
infrastructure planning phases, alterations to mine shape, depth and configuration may occur. This is
part of the normal mine planning optimisation routine, but means that the final mine shape configuration
and infrastructure may vary to that presented in consultant reports as well as the ESIA. Any alterations
to the mine pit configuration may necessitate adjustments to estimated land acquisition and population
displacement figures contained within this ESIA, such as occurred in September 2005. However any
further mine configuration alterations is not expected to substantially alter the environmental and socio-
economic assessments contained within this report.

iv. Compliance with the Equator Principles
At this stage of mine planning, constant refinements are being made, and mine infrastructure design is
largely at conceptual stage. Therefore, due to time constraints given for completion of ESIA studies,
there have been some areas of non-compliance with the Equator Principles. These areas of non-
compliance relate mainly to the level of design information available for mine infrastructure and
mitigation measures at the time of writing the ESIA.

As some mitigation measures were only at the conceptual design stage (for example, site drainage and
Project landfill) or were in the process of detailed design at time of writing (for example, irrigation
system), a detailed assessment of potential impacts of all mitigation measures has not been
undertaken. Where detailed assessment was not possible, this has been indicated and a qualitative
assessment conducted to the extent possible.




Environmental & Social Impact Assessment (ESIA) of Asia Energys Phulbari Coal Project Chapter 3 of Volume 1
APPENDIX

April, 2006
Methodology Page - 1

Appendix 3.1: The Study Team
TECHNICAL
SMEC International Pty Ltd, Australia

Project management, social impact assessment, resettlement planning,
environmental monitoring, water hydrology and modelling, GIS, air quality,
noise, water quality, rehabilitation, traffic, Environmental Management
Plan, town planning, IEE, EIA/SIA and ESIA reporting
GHD Pty Ltd, Australia Resource evaluation, geotechnics, hydrogeology, local and regional
infrastructure and transport, economics, data management, geophysics,
river diversion studies
MineConsult Pty Ltd, Australia Mine design, mine scheduling
QCC Ltd, Australia Coal quality, coal treatment plant
Coffey Geosciences Pty Ltd Water management, initial mine water balance
Molino Stewart Pty Ltd Review of ESIA
Centre for Environmental and Geographic Information
Services (CEGIS), Bangladesh
GIS database, surveying, field hydrology instrumentation, data collection
Nature Conservation Management (NACOM) Dry and wet season ecological database, biodiversity field survey
Bangladesh Atomic Energy Commission (BAEC) Airborne particulate matter sample analysis, quality assurance auditing,
geophysical borehole logging
Bangladesh Centre for Advanced Studies (BCAS) Resettlement surveys
Health Promotions Limited Health impact assessment
Institute of Water Modelling (IWM), Bangladesh Regional surface water modelling
The World Conservation Union (IUCN) Legislation, policy advice, peer review of biodiversity
Dr K.M. Ahmed, Dhaka University Arsenic in groundwater assessment
Dr N Kamal K.Z. Ashan, Independent University Demographics
Dr Chris J ohansen Agriculture, economics
Mr Mannan, Independent University Anthropology, ethnic minorities
Professor M Hoque, J ahangirnagar University Archaeology, historical sites
Dr Amin, Hazi Danesh Science &Technology University,
Dinajpur
Soil science, agriculture
Professor SMM Rahman, Dhaka University Socio-economics
SWV Consulting Mine water balance
Peer Review
SMEC International Pty Ltd, Australia Peer review of biodiversity, social surveys
Dr Zaman, Canada Peer review of resettlement, community consultation
Dr Chris J ohansen Peer review of mine rehabilitation, soils
Dr Ricky Kwan Peer review of surface water hydrology
Dr Peter Hawkins, Australia Peer review of water chemistry
FUGRO, Australia Peer review of surveying
Ron Connolly and Associates Peer review of soils and rehabilitation
Wilkinson Murray Peer review of air quality, noise and blasting reports
Laboratories
ALS Environmental Laboratories, Australia Water quality testing
Bangladesh University of Engineering and Technology
(BUET)
Water quality testing
International Centre for Diarrhoeal Disease Research,
Bangladesh (ICDDR,B)
Bacteriological and arsenic testing


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