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Document Review

Sl. No.	Name of the documents	Highlighted content of the document
1	FSM Assessment Report for CCC (2021)	Baseline sanitation/FSM situation of CCC areas
2	Chattogram Water Supply and Sewerage Authority Sanitation Master Plan, Volume 1: Main Report, June 2017	Target and technologies for different settings, including LICs/slums under the proposed sewerage catchment areas of Chattogram by CWASA.
3	Water Supply and Sewerage Authority (WASA) Act 1996	Legal provision of sewerage system by the authority
4	SRO No. 92-Act/2011	Defines responsibility for house connection for sewerage system
5	Institutional and Regulatory Framework for Fecal Sludge Management (IRF-FSM) for City Corporations 2017,	Defines role and responsibilities of actors for FSM with institutional capacity strengthening
6	National Action Plan (NAP) for Implementing IRF-FSM for City Corporations 2021	Recommended some specific actions to national and local stakeholders to implement FSM, including establishing FSM units and providing differential prices for LIC/slum users for FSM.
7	Pro-poor strategy for Water Supply and Sanitation (Revised 2020)	The mechanism for providing sanitation services to ultra-poor.
8	The Environment Conservation Rules, 1997	SCHEDULE-9: Standards for Sewage Discharge
9	Bangladesh National Building Code (BNBC) 2020	Setback for sanitation facilities in the building plot
10	Bangladesh Standards and Guidelines for Sludge Management 2015	Management options for municipal sludge. Sampling, sample preparation and analysis of sewage sludge and soil.
11	User Guide for City Service Delivery Assessment for Citywide Inclusive Sanitation 2020	Recommend methodological steps to develop CSDA.
12	Citywide Fecal Sludge Management (FSM) Action Plan for Chattogram City Corporation 2021	The FSM Action Plan for CCC gives “specific” and “time-bound” actions to be undertaken on all the different aspects of FSM by CCC in order to achieve “safely managed sanitation for all” by 2030.

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Identification of Key Stakeholders

Sl. No.	Name of the stakeholder	Justification of interview
1	Chattogram City Corporation Chief Executive Officer Superintending Engineer, FSM Focal	Primarily responsible for implementing Non-sewered sanitation. CCC has developed a FSM Action Plan. They are preparing a DPP for FSM project.
2	Chattogram Water Supply and Sewerage Authority (CWASA) Deputy Managing Director Project Director, Sewerage Project (Phase-I)	Primarily responsible for implementing Sewered sanitation. CWASA is implementing a sewerage project in Chattogram
3	Chattogram Development Authority Chief City Planner	Primarily responsible for approving building plan and developing the infrastructure plan for the whole City.
4	Department of Environment	Primarily responsible for compliance monitoring of the environmental issues.
5	WASH NGO Officials WSUP DSK	implement water, sanitation and hygiene interventions at CCC.
6	Community-Based Organization (CBO) President	Coordinate WASH interventions at the community level and the corresponding focal point of the community.
7	Private Slum Owner	Build houses in the slums and rent. Provide WASH facilities over there.
8	Manual emptier	Provide containment emptying systems
9	Chittagong University of Engineering and Technology Head, Department of Civil Engineering Head, Department of Urban and Regional Planning	Sector experts.
10	UNICEF Regional Office	Coordinate CWIS project at local level.

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Stakeholders Discussion and Consultation

A national consultation workshop on CSDA was organized at ITN-BUET during 23-25 October 2021 with support from UNICEF Bangladesh and PSB, LGD

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Stakeholders Discussion and Consultation

In the workshop, relevant officials from CCC, CWASA, CDA, CUET, DSK, WSUP, CWIS-FSM Support Cell, PSB (LGD) and UNICEF Chattogram Office participated.

Participants discussed the assigned scores against the questions, came to a consensus (if there is a disagreement) and updated the scores.

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CSDA Scoring Summary

Policies and legislation are appropriate, some legislation are not widely known among all stakeholders
Has an action plan, taking steps to prepare DPP
Collection and transportation leased out to private entities
CCC has taken charge of Arefinnagar FSTP from WSUP but the budgeting is not clear yet
Allocation for sanitation in the budget is not specified
Inclusion not mainstreamed in CCC, rather practiced by other parties (WSUP, DSK in LICs)

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CSDA Scoring Summary

Currently no investment plans
Service delivered through NGOs
Community capacity building programs through NGO support
No separate cell for FSM
Emptying service cannot reach LICs who live in hilly areas (they use manual services)
Public toilets and emptying service subsidized for the poor
Public toilet access is not suitable for disadvantaged people

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CSDA Scoring Summary

CDA does not monitor septic tanks during construction
Operating costs partially covered
Health safety of sanitation workers not monitored
Private sector engaged in emptying
FSTP not monitored
Public toilets are not gender-segregated

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CSDA Scoring Summary

New role of WASA as sewerage service provider not widely known by all stakeholders
Construction is going on as per master plan and budgets allocated from GoB
New organogram reflects the new role in sewerage services

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CSDA Scoring Summary

Current project taking care of house connections
Staff training and capacity building on-going, new organogram not approved yet
Willingness-to-pay studies carried out
Coordination exists between CWASA and CCC for cutting roads for sewers.
LICs remain unserved (hilly slope and uneven terrain) by sewerage, CWASA has plans for constructing toilets for CCC

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CSDA Scoring Summary

Cost recovery difficult with sewage service, O&M cost cannot be covered with tariffs, subsidy from water revenue required
Mostly not applicable since service has not been initiated

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Service Delivery Action Framework: Non-Sewered

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Policy, Legislation, Regulation

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
		Disseminate and sensitize the Institutional and Regulatory Framework for FSM and NAP to all relevant stakeholders, widely publicize BNBC provisions of onsite sanitation systems and relevant environmental regulations.	N, L	Disseminate and sensitize the Institutional and Regulatory Framework for FSM and NAP to all relevant stakeholders, widely publicize BNBC provisions of onsite sanitation systems and relevant environmental regulations.	N, L
Review regulatory framework for the protection of public health and environment, prepare a guideline for developing a sanitation safety plan	N, L	Develop a sanitation safety plan for the protection of public health and environment at CCC, Strengthen enforcement of environmental and public health regulations	L	Review and update the sanitation safety plan of CCC, as necessary	L
Review and establish by-laws addressing on-site systems and FSM services	N, L	Apply sanctions/penalty to regulate illegal connection to stormwater drains, non-compliance to CDA-approved plans on on-site sanitation systems, introduce regulation/standards for FSM service providers	L
Review existing standards for on-site sanitation systems and FSM services (e.g., ISO standards, BNBC)	N, L	Introduce a system of certification/license for private entities (mechanical emptiers, masons, treatment plant operators, end-product vendors)	N, L	Enforce regulation and standards for on-site sanitation systems and FSM service-providers (mechanical emptier)
Develop policy for public toilets in cities, including its operation and maintenance, access provision for disadvantaged and low-income groups	N	Disseminate and sensitize national public toilet policies for cities, introduce regulation or by-laws for operation and maintenance, access provision for disadvantaged and low-income groups	N, L

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Institutional arrangements

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Review the institutional arrangements for sanitation and update the organogram for CCC to include an FSM cell/unit according to the NAP for City Corporation.	N, L	Establish local institutional framework for services – with clearly defined roles and responsibilities for FS collection, treatment and re-use	L	Strengthen institutional roles for managing improved FS management, including treatment and re-use	N, L

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Planning

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
CCC should officially endorse the FSM Action Plan and take preparation for formulating the DPP accordingly.	N, L	Establish FSM services and systems to monitor and evaluate service quality, service level targets, equity and accountability of access to FSM services according to the FSM action plan. Also establish systems to monitor environmental performance of FSTPs.	N, L	Strengthen monitoring of all sanitation services, update plans for enhanced coordination among service-providers in future (e.g., when sewerage network of CWASA becomes operational)	N, L

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Financing

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Approve the financing requirements to implement the FSM action plan, which addresses the improvements to the poorest, women and vulnerable groups	N, L	Introduce specific pro-poor financial instruments (such as targeted subsidies)	N, L	Identify opportunities for financial flows generated from the sale of treatment end-products	L
Develop a business model for sanitation service delivery for CCC and encourage private entrepreneurs in sanitation service delivery by providing necessary incentives for inclusive service delivery (e.g., servicing the LICs)	N, L	Establish alternate revenue streams to finance sanitation services (e.g., sanitation tax)	L	Monitoring and tracking incentives, revenue streams associated with sanitation services	N, L
Introduce a separate budget head for sanitation service delivery in ADP	N	CCC allocates budget for sanitation service delivery in ADP	N, L	Explore alternate revenue streams to finance such activities (e.g., sanitation tax)	L
Build awareness and agreement around the budgetary requirements for inclusive sanitation services at the national level, and encourage the cities to develop proposals with inclusive sanitation services	N	Develop programs with inclusive FSM funding windows and incentives for cities, in coordination with the CWIS-FSM Support Cell	N, L	Monitoring and strengthening the FSM funding flows and incentives program	N, L

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Promotion, User engagement

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Consult users to identify sanitation needs and aspirations, taking account of constraints in LIC areas, ensuring women, youth, adolescent girls and vulnerable groups are heard	L	Improve technical options and services (e.g., FSM in hilly areas), in response to user feedback, strengthen the role of CDCs in sanitation option selection	L	Expand on the range and quality of technical options and services, in response to user feedback, expand the role of CDCs in FSM	L
Engage/ consult with landlords and other private entities (contractors, masons) on constraints to effective on-site containment systems	L	Develop assistance and enforcement packages for landlords and other private entities (contractors, masons)	L	Focus on enforcement of service quality for landlords and other private entities (contractors, masons)	L
Engage with manual emptier and their clients to develop a strategy for phasing out unhygienic manual emptying	L	Support transition from informal manual emptying to improved and regulated services (e.g., mechanical emptying)	L	The adoption of mechanical/safe emptying services	L
Stimulate customer demand/ willingness to pay for safe FSM	L	Stimulate customer demand/ willingness to pay for safe FSM	L	Stimulate market demand for re-use of faecal sludge	L
CCC allocates resources from existing/future projects for awareness raising activities at the local level regarding effective containment of FS at the household level, importance of desludging and adverse effects of illegal connection to drains, design appropriate IEC/BCC materials. The National Government (Ministry) to provide guidance on effectively designing awareness-raising activities suited to the context	N, L	Designing appropriate IEC/BCC materials and conducting awareness-raising activities at the local level	L	The city allocates resources from its regular budget for awareness-raising activities and popularize FSM	L

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Capacity, Technical assistance, Technology

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Develop an integrated city-level information system which will include adequate spatial information on tenure status, on-site containment systems, road and drainage networks. National Government (Ministry), through the CWIS-FSM support cell, will provide technical support to update this information system. The information system should contain adequate information for city-level sanitation planning and decision-making.	N, L	Deploy manpower at the city-level to update and manage information, training technical staff to operate and update the information system	L	Revise the CCC organogram to include necessary manpower to operate the system	L
Based on user feedback, identify a range of technological options for FSM in hard-to-reach hilly areas of CCC, pilot appropriate technological options	L	Use findings from the pilot studies to scale up these options over the entire LIC	L	Strengthen CCC capacity for delivering services, including treatment and re-use markets	L
Identify sanitation options appropriate to CCC’s future development scenario in consultation with CDA, identify needs for technological innovations, incorporate these aspects in the FSM Action plan	L	Develop context-specific sanitation solutions	L	Strengthening service delivery	L
Identify capacity gap required for CCC to address FSM service delivery	N, L	Undertake staff capacity building programs for CCC officials in delivering effective sanitation service	L	Refresher's capacity building program for trained staff and orientation program for new staff	L
Allocate resources ( for e.g., PPE, training materials) in ADP, in accordance with FSM action plan for health and safety training for sanitation and waste workers	L	Conduct capacity building training for health and safety training for sanitation and waste workers	L	Monitoring OHS practice of health sanitation workers as per SSP	L
Identify requirement of capacity building in the private sector (private masons, mechanical emptiers)	L	Conduct capacity building activities for the private sector	L
Based on user feedback, identify a range of technological options for decentralized wastewater treatment systems for newly developing apartment complex/residential areas	L	Use findings from the pilot studies to scale up these options	L	Strengthen CCC capacity for delivering services, including treatment and re-use markets	L

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Service Delivery Action Framework: Sewered

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Policy, Legislation, Regulation

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
		Disseminate and sensitize the Institutional and Regulatory Framework for FSM and NAP to WASA officials, especially the role of WASA in the IRF	N, L	Continued sensitization of Institutional and Regulatory Framework for FSM and NAP to future WASA officials	N, L
Review regulatory framework for the protection of public health and environment, prepare a guideline for developing a sanitation safety plan for the utility	N, L	Develop a sanitation safety plan for the protection of public health and environment for stakeholders associated with the sewerage network, Strengthen enforcement of environmental and public health regulations	L	Review and update the sanitation safety plan of sewerage network, as necessary	L
Publicize sewerage service-related regulations (WASA Rules, BNBC provisions for sewerage connections) to all stakeholders such as houseowners, private entities.	N, L	Develop a mechanism to apply sanctions/penalty to regulate unauthorized connection to sewerage lines, non-compliance to BNBC codes on sewerage connection systems.	L	Apply sanctions/ penalty to regulate unauthorized connection to sewerage lines, non-compliance to BNBC codes on sewerage connection systems.
Review existing standards for operation and maintenance of sewerage services and management of treatment plants (e.g., ISO standards, BNBC, ECR 1997)	N, L	Introduce a system of certification/license for private services for sewerage network (outsourced O&M, treatment plant operation). On-site sanitation service providers are to obtain license/certification from CCC.	L	Enforce regulation and standards for on-site sanitation systems (through CCC) and sewerage network.

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Institutional arrangements

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Endorse the proposed update of the CWASA organogram to include personnel to deliver services associated with sewerage network under construction	N	Establish institutional framework for services – with clearly defined roles and responsibilities for Sewerage network operation, treatment, and re-use	N, L	Strengthen institutional roles for managing improved sewerage management	N, L
Formulate of the CWASA organogram to include personnel to deliver sewerage services considering future network expansion	N, L	Revise and endorse the organogram to deliver sewerage services considering future network expansion	N, L	Strengthen institutional roles for managing improved sewerage management	N, L

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Planning

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
CWASA should review the CCC FSM Action Plan to define their service area for FSM services within the city corporation area (or revisit their role in providing FSM services)	N, L	CWASA to establish a system to monitor and evaluate service quality, service level targets, equity and accountability of access to FSM services. Also establish systems to monitor environmental performance of FSTPs operated by CWASA.	N, L	Strengthen monitoring of all sanitation services, planning for enhanced coordination with CCC	N, L

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Financing

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Searching funds for the expansion of sewerage network to all catchments as per the CWASA masterplan	N, L	Securing funds for the expansion of sewerage network to all catchments as per the CWASA masterplan	N, L
Developing a tariff structure for sewerage services considering maximizing cost recovery, economy of scale and willingness-to-pay of the households	N, L	Applying the tariff when sewerage service is initiated	L	Adjusting the tariff structure in future considering expansion of services	L
Estimating resources for O&M of sewerage network and STP in the annual budget	L	Allocating resources for O&M of sewerage network and STP in the annual budget	L	Adjusting the budget for O&M based on future expansion	L
Estimating resources for capacity building of CWASA staff for sewerage network service delivery	L	Allocating resources for capacity building in the annual budget	L	Adjusting the resources based on future need	L

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Promotion, User engagement

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Engage/ consult with landlords/users and other private entities (contractors, masons) on constraints to sewerage network connections in built-up areas	L	Develop assistance packages for landlords/users for sewerage network connections in built-up areas	L	Continue assistance packages for landlords/users for sewerage network connections in built-up areas	L
Engage with Low-income communities to explore the feasibility of connecting to CWASA sewerage network services, assess their willingness-to-pay for availing such services	L	Explore a range of technical solutions for sanitation service delivery, in coordination with CCC	L	Provide technical assistance to CCC, if necessary, in providing sanitation service to LICs	L
Stimulate customer demand/ willingness to pay for sewerage network services in areas serviced by CWASA	L	Develop a system for monitoring/tracking customer satisfaction for sewerage network services in areas serviced by CWASA	L	Using customer/user feedback to improve sewerage network services in areas serviced by CWASA	L
Engage with CDA for incorporating sewerage connection provisions by the landlords during building approval in areas serviced by CWASA	N, L	Engage with CDA for sharing approved building plans (with sewerage connection details) in areas serviced by CWASA	L	Monitoring and regulating sewerage connection details of landlords in areas serviced by CWASA	L

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Capacity, Technical assistance, Technology

Basic actions	Level	Intermediate actions	Level	Consolidating actions	Level
Review options for establishing a system of evidence-based decision-making in providing sewerage services and gathering customer feedback	N, L	Explore options for utilizing the CCC-developed integrated city-level MIS system or develop a separate MIS system for sewerage services, whichever feasible	L	Revise the CWASA organogram to include necessary manpower to operate the MIS	L
In coordination with CCC, identify a range of technological options for FSM in hard-to-reach LIC areas, provide technical assistance for adaptive technology	L	Use findings from the pilot studies to assist CCC in scale up these options	L	Provide technical assistance to strengthen sanitation delivery services of CCC, including treatment and re-use markets	L
Identify capacity gap required for CWASA to address sanitation service delivery	N, L	Undertake staff capacity building programs for CWASA officials in delivering effective sanitation service	L	Refresher’s capacity building program for trained staff and orientation program for new staff	L
Review requirements for occupational health and safety for sewerage network and treatment plant workers (e.g., PPE, training materials, standard operating procedures)	L	Conduct capacity building training for sewerage network and treatment plant workers	L	Monitoring OHS practice of sewerage network and treatment plant workers as per sanitation safety plan	L

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