Contents

Introduction:.........................................................................................................

Purpose of the report:..........................................................................................

Observation with probable suggestions on environmental point of view:............

Overall Comments on the Feasibility Study Report:.............................................

Conclusion:.........................................................................................................

Table 1: Environmental impact valuation of the Project (Power plant)........................

Table 2: Sub-project feasibility test through screening the checklist and its
analysis under the environmental point of view (Power plant)...................................

1 Introduction:
Bangladesh is regarded to have a huge potential of economic growth
being led by its domestic demand and promising export industries, but
current insufficient and unreliable electricity supply is considered as a
serious obstacle for private investment and hampering economic growth.
According to Power System Master Plan 2010 (PSMP 2010), peak power
demand in Bangladesh is estimated to be 8,349MW in 2013, but
maximum generation was 6,675MW (recorded on July 12th) in 2013, out of
8,525MW (Public:4,794MW, Private: 3,731MW) of the installed capacity as
of July 2013. There is at least 20% of supply-demand gap in Bangladesh.
In addition, PSMP 2010 states that domestic power demand is forecasted
to grow by 11% every year, and reach 21,993MW in 2023 (with demand
side management). Bangladesh should address to meet this issue as a
matter of high priority. Considering the aforementioned background, The
Government of Bangladesh (hereinafter referred to as "GOB") has applied
a loan from the Japan International Cooperation Agency (hereinafter
referred to as "JICA") to finance Matarbari Ultra Super Critical Coal-Fired
Power Project in Bangladesh (hereinafter referred to as the Project)
which is to secure the power supply and to realize the policy of power
source diversification in the country.
The feasibility study is an evaluation and analysis of the potential of a
proposed project. It is based on extensive investigation to support the
process of decision making. Feasibility studies aim to objectively and
rationally judge the strengths and weaknesses of an existing opportunities
and threats present in the environment and in the resources required to
carry through, and ultimately the prospects for the success.
Review of feasibility studies (f/s) is essential to developing more concise
guidance. It can help to use conditional approval decisions to the fullest
extent when deficiencies exist. If any subjects or relevant issues are seen
absent in the feasibility studies (F/S) report, necessary subject matters
and issues are recommended to affix in the report which have not been
included before. If it is seemed that some irrelevance information have
been included in F/S, the reviewers chalk out the issues and finally
recommend the solution as needed.

2 Purpose of the report:

Main purpose of the report is for the reviewing the F/S to check the
irrelevancies of data used, analysis methods, subjects studied including
existing environment and resources that might be susceptible to
contaminate the environment for establishing the project. As it is coal
based power project, special attention has to be given to review and verify
the aspects especially on ash handling, gas emission from power plant,
port harbor development and other relevant issues. To identify the
relevant issues which have not been included in the F/S is also another

objective of the report. So, observation reviewed and necessary

recommendation for the F/S that might help to do the report more
authentic and accuracy will be included in the report.

3 Observation with probable suggestions on

environmental point of view:
1. Population density of Dhalghata stated in Table 15-1-2 is 6441
person/km2. Actually it will be 694 person/km 2; so, population
density should be changed as 694 person/km2 instead of
6441person/km2 (Reference: Page 15-11, Line-9).
2. Page no. 15-55 in item as pollution control, no. 7 of table 15.4-3, it is
stated that no hazardous waste will pollute the sediments but during
dredging in construction period and in maintenance for navigation in
port channel the sediments might be up lifted with sand.
Consequently, organisms like phytoplankton, zoo plankton, benthos
etc. might be damaged due to turbidity, though it is temporary, and
damage of organisms habitat caused by up lifting the sediments.
So, there should be a scope to remain the sediments in a portion
besides the main navigation gate way (if it is technically approved).
However, the stated issue might be checked carefully because the
phytoplankton is the 1st unit of Food chain. So, sediments will be dug
only when it is unavoidable situation and of course it will be
minimum level with careful measures. In this case, the rating might
be changed as D to B-.
3. In water quality for pollution control of power plant of page no. 15116, there is no mention on the impact of pilling works (if needed),
even its countermeasures. Normally, pilling works might be needed
for power plant construction; in this context, there is possibility to
occur sound pollution and occur contamination of the ground water
if it is not done properly. So, this
issue should be added in the
section.
4. In page no. 15-127, Gender issue has been discussed but it seems
somewhat insufficient information. Some issue related to gender
policy of Bangladesh (2011) should be stated in that section like in
any construction and operation works of the project, minimum one
tenth of the total employees should be as female. Other rights for
the women followed by gender action plan should be included
shortly in the section. Here, it should be mentioned that Gender
Action Plan for the project should be made perfectly to meet up the
compliance of Gender main streaming.

5. In the section of Topography and Geology of page number 15-173, it

is stated that the environmental impact is serious but there is no
any indication on the specific impact that might be occurred in
future. So, specific impact and its countermeasures should be stated
shortly. For example, the changes of topography might inhibit the
natural water ways in the catchment area of the project. So, it
should be stated that the project has the opportunity to overcome
the terrible situation come from topographical obstruction if the
natural water ways could be impeded.
6. In the section of operation phase of page no. 15-198, it stated as
The EMU shall also function as a grievance organization..
Here, Grievance redress committee with their responsibility and
accountability, redress mechanism and Aps list are not mentioned
clearly. So, the information mentioned should be included in the
section shortly.
7. In no. 9, column name source of potential impact in Table of 15.71 in page no. 15-205, it is stated as increase in employment and
business opportunity. In lieu of this statement, it could be more
appropriate to state as new upcoming increased establishment of
the project might deteriorate the local economy and means of
livelihood.
8. In table-15.7-1, page-15-206, sl. No.-11, and column-3: Stated as
Adverse impact due to water pollution. Instead of this statement, it
could be more appropriate as follows-Usages of surface water
polluted by different pollutants.
9. In table-15.7-1, page-15-207, sl. No.-16 and column-3: Stated as
only labor accidents words have been used. Here, it could be fine
if the statement is as same as follows- Labor accidents might be
occurred caused by in-safety movement of workers.
10.
In table-15.7-2, page-15-224, sl. no.-2, and column-3: Spelling
should be corrected as MARPOLE 73/78 instead of MALPOL.
11.
In table-15.7-1, 1st raw, column-4, page-15-201: Stated as
misdistribution of benefit and compensation. Here the word
misdistribution should be changed into uneven distribution or
other appropriate word.
12.
In table-15.8-1, sl. no.2 and column-2, page-15-241: Stated
headline as Monitoring parameters; here, it will be more
appropriate if the words are written as Monitoring parameters/
related laws.
13.
In table-15.8-1, sl. no.15 and column-4, page-15-247:
Monitoring parameters are not mentioned here. So, it is needed to
measure the greenhouse gases like co2 to be produced.

4 Overall Comments on the Feasibility Study

Report:
After reviewing the Feasibility Study Report, it seems that the report has
been made satisfactorily and followed mostly all aspects in depth which is
required to make good study report. With a few exception, the report
discusses the environmental issues which are mostly related to
establishing the coal based power project. The evaluation of
environmental impact assessment for the implementation of the project
and necessary countermeasures was satisfactory to good. If the
suggestions that have been stated in the present report are included in
the F/S report, the feasibility study report might be in as good to excellent
rating.

Two tables could be included in page no. 15-189 of F/S which is indicated
Environmental impact valuation in numeric value. If you think, it should be added
in F/S, then we will work more on the table.
Table 1: Environmental impact valuation of the Project (Power plant)

Parameters

Relative
Importance
Value

Degree of
Impact

Relative Impact

Positive
1.
Regional hydrology and
flooding
Erosion
Water pollution
Air pollution
Noise pollution
Traffic accidents,
Land/water
Loss of lands
2. Ecological/Ecosystem
Fish/Marine biota
Trees and vegetation
3. Human Interest
Infrastructure
development
Industrial Activities
Employment opportunity
Transportation and
communication
4. Quality of Life
Increase electricity
usage
Travel safety
Health
Education and literacy
Cultural Heritage
Total EIV

EIV

Negative

Physical

-19

2
3
3
2
1

0
-2
-2
-1
-1

-6
-6
-2
-1

-1

-4
-5

5
2

-1
0

-5

+3

+9

3
6
6

+1
+2
+2

+3
+12
+12

+36

+32
4

+2

+8

3
3
3
3

+2
+2
+2
+2

+6
+6
+6
+6
+44

Here, the total Environmental Impact Value (EIV) of the project is +44 which will improve to +68
maximum with proper implementation of the recommended EMP including mitigation and enhancement
measures.

Table 2: Sub-project feasibility test through screening the checklist and its analysis under the environmental
point of view (Power plant)

Sl.
No
.

Indicator

Parameter

Score

Score
obtaine
d

Annual average
temperature (oC)

Temperature measurement, information from Key- informants or reference

data from secondary other sources

<15

1520

20-25

25-30

Annual rainfall (mm)

Annual measurement or reference data from secondary sources

<1500

1500
2000

2000-

25003000

2500

Tree cut or removal/

terrestrial biodiversity
loss

No. of trees that might be cut

<40

4080

80-120

>120

Water table depth(ft)

Direct measurement or reference data from secondary sources

<20

2070

70-

>120

120

Seismic co-efficient

Reference data from relevant sources

<0.04

0.040.06

0.060.08

>0.08

Endangered species
(Biotic)

No. of species that might be damaged

1-5

5-10

>10

Protected area

Direct observation Whether it is in the protected area or not. Reference

data from relevant sources (DOE & Forest Dept.)

1-2

2-3

>3

besides the subprojects within 1 km

radius

Frequency of flood on
either side of the
project & highest Flood
level?

Frequency of flood on either side of the road

Flood
free

2-5
year
s

Every
year

Standin
g water
3-6
months

Frequency of cyclone in
the project area &
highest surge height?

Frequency of cyclone in the project area

Cyclon
e free

2-5
year
s

Every
year

Standin
g water
3-6
months

10

Project area(ha)

Agricultural land loss, erosion and sedimentation , dust nuisance etc.

<5

<510

>10-

>15-20

15

11

Structures within
permanent wet land(m)

Erosion, drainage congestion, flooding

<100

100500

>5001000

>10005000

12

Type of soil

Type of soil

Silty
clay

Silty

Silty
sand

Sand

13

No. of cross-drainage
structures

No. of cross-drainage structures

<4

4-8

8-12

>12

14

Burden on utilities

Qualitative/quantitative measurement on water supply, energy, sewerage

and communication

Very
small

Smal
l

Mediu
m

High

15

No. of archeological /
educational /

No. of archeological / educational / religious structures adjacent of road

per km

<1

1-2

2-3

>3-4

religious structures/
grave- yards within the
sub-project
16

polluted or
contaminated area

Water polluted reservoir, no. of waste damp area etc.

1-5

5-10

>10

17

No. of Places where

susceptible to

No. of place in hilly area, high land without slope protection

1-5

5-10

>10

landslides (no.)
18

Problem to nearby
community or to their
properties

No. of houses that might be damaged

1-5

5-10

>10

Total Score

38

Average score obtained= Total

score/No. of parameters

2.1

Result/ Overall impact

Medium
impact

Feasibility

Feasibl
e

The overall impact = the average of scores obtained in all parameters = (Total Score obtained through parameters
to be affected by project intervention)/ Number of Parameters
OI= S/n.1
Where,
OI = Overall Impact, S = Scores obtained, n = Number of Parameters,
On the basis of overall Sub-project is categorized as per following model:
Sl. No.
1
2.
3

Score
<1to 2
>2 to 4
>4 to 5

Category
Low Impact Sub-Component
Medium Impact Sub-Component
High Impact Sub-Component

5 Conclusion:
The observation and findings in relevant with environmental aspects for the
project implementation reviewed from the feasibility study report have been
stated in the text of the report. Overall environmental study illustrated in
feasibility study report was done effectively but some information and issues
have to be included carefully so as to the report made earlier falls under
excellent category of rating. After reviewing the feasibility study report, it
seems that the project is feasible in the environmental point of view if the
necessary precaution and control measures are incorporated and also
implemented in construction and operational phases of the project.