Environmental Assessment and Review Framework July 2012

Pakistan: Sindh Cities Improvement Investment

Program (SCIP)

Prepared by North Sindh Urban Services Corporation Limited for the Asian Development Bank.

ENVIRONMENTAL ASSESSMENT AND REVIEW

FRAMEWORK (EARF) –TRANCHE 2 PFR 2012

(NORTH SINDH URBAN SERVICES CORPORATION)

(REVISED DOCUMENT AS PER TRANCHE-2 PROJECTS REQUIREMENTS)

(JULY 2012)

[This documents is prepared/ updated to identify the environmental requirements for Tranche-2 , keeping in view the Asian Development Bank safeguards policy 2009 and ADB guidelines 2003]

Supplementary Appendix L

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LIST OF ABBREVIATIONS

ACRONYM COMPLETE FORM

ADB Asian Development Bank

AMF Asbestos Management Framework

BCOP Building Code of Pakistan

DNI Distribution Network Improvement

DOS Director Operations and Services, NSUSC

EARF Environment Assessment and Review Framework

EIA Environmental Impact Assessment

EA Executive Agency

EPA Environmental Protection Agency

EMP Environmental Management Plan

GoP Government of Pakistan

HSE Health, Safety and Environment

HFL Highest Flood Level

IA Implementation Agency

ICB International Competitive Bidding

IEE Initial Environmental Examination

LARF Land Acquisition and Resettlement Framework

LARP Land Acquisition and Resettlement Action Plan

MD Managing Director

MGD Million Gallons per Day

MFF Multi tranche Finance Facility

NOC No Objection Certificate

Supplementary Appendix L

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ACRONYM COMPLETE FORM

NGO Non Governmental Organization

NSUSC North Sinth Urban Services Corporation

NEQS National Environmental Quality Standards

N/S Not Scheduled

PSU Program Support Unit

PFR Periodic financing Request

P&DD Planning and Development Department

PC Public Consultation

RAP Resettlement Action Plan

REA Rapid Environmental Assessment

RoW Right of Way

SCIP Sindh Cities Improvement Program

SEPA Sindh Environmental Protection Agency

SWM Solid Waste Management

TOR Terms of Reference

TMDP Temporary Drainage Management Plan

TMA Taluka Municipal Administration

UNESCO United Nations Educational, Scientific, and Cultural

Organization

USC Urban Service Corporation

WB World Bank

Supplementary Appendix L

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ENVIRONMENTAL ASSESSMENT AND REVIEW FRAMEWORK

Contents

LIST OF ABBREVIATIONS ........................................................................... Error! Bookmark not defined.

A. Development Activities Requiring Environmental Assessment and Review .................................. 5

B. Environmental Criteria for Additional Subproject Selection............................................................ 11

C. Responsibilities and Authorities of Various Agencies ................................................................. 12

D. Environmental Assessment and Review Procedures of Additional Subprojects .................... 14

1. Application of Selection Criteria ..................................................................................................... 14

2. Environmental Classification .......................................................................................................... 14

3. Preparation of Detailed Design ...................................................................................................... 14

4. Preparation of Construction Contracts .......................................................................................... 15

5. Monitoring During the Construction Period .................................................................................. 15

6. Monitoring of Subproject Operations............................................................................................. 15

E. Public Disclosure .............................................................................................................................. 15

F. Institutional Arrangements .............................................................................................................. 16

G. Environmental Management and Monitoring ........................................................................... 20

Table 2: Key tasks for Environmental Monitoring Plan ................................................................... 21

Table 3: Summary of Estimated Costs for EMP Implementation as per Business/Operating

Plan ........................................................................................................................................................ 21

APPENDIX 1: Draft Terms of Reference for Environmental Safeguards Specialist/Manager .. 23

APPENDIX 2: Environmental Management Plan for Tranche-1 Subprojects .............................. 25

APPENDIX-3: Semi-annual Environmental Monitoring Report ..................................................... 56

Supplementary Appendix L

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ENVIRONMENTAL ASSESSMENT AND REVIEW FRAMEWORK

A. Development Activities Requiring Environmental Assessment and Review

1. The Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to

provide a Multitranche Financing Facility (MFF) Tranche -2 PFR 2012 to the Government of Sindh

(GoS) to facilitate investments in the proposed Sindh Cities Improvement Investment Program

(SCIP or the Investment Program). This u p d a t e d Environmental Assessment and Review

Framework (EARF) is prepared as a means to ensure that the potential environmental

impacts of the subprojects financed under the MFF Tranche 2 are appropriately assessed and

mitigated to acceptable levels.

2. The MFF funding from ADB is expected to be released in stages (tranches). The

Investment Program will provide a set of investments, institutional and policy reforms, and

capacity building measures to improve service provision and address infrastructure deficiencies

and institutional constraints to the development of secondary cities of Sindh.

3. The SCIP aims to improve the quality of urban service delivery in several of Sindh’s

secondary cities. This proposed long-term program of support will target select growth centers,

clustered together to benefit from economies of scale and their strategic location along the

National Trade Corridor. This $300 million MFF will support comprehensive urban planning,

institutional reforms, including introduction of professionally-managed urban services providers,

and complementary infrastructure investments in water supply, wastewater, and solid waste

management (SWM) beginning in 2008, with phased investment over ten years. The

Investment Program will adopt a carefully phased approach; financing priority investments

where they are more likely to succeed and support improved cost recovery, with learning and

further investment subsequently rolled-out to new town clusters when ready. This long-term

partnership with the GoS will provide an opportunity for more substantive engagement on policy,

regulatory, management and financial aspects of urban service delivery, a prerequisite for

sustainable infrastructure services.

4. Under the MFF loan procedures of ADB, implementation of safeguards is to be achieved

by environmental assessment of every subproject to be undertaken following ADB Safeguard

Policy (2009). The subprojects under the Investment Program generally concern the

development of facilities in and around the urban areas of medium-size towns and are not likely to

affect sensitive areas, forests or wetlands. The subprojects might typically be expected to be

classified as Category B & C under ADB Environmental Assessment Guidelines (2003) that will

be followed for all subprojects. One Sub Project in Tranche -2 is classified as Category A

5. The GoP regulations, the Pakistan Environmental Protection Agency Review of Initial

Environmental Examination (IEE) and Environmental Impact Assessment Regulations (2000)

categorize development projects into two schedules according to their potential environmental

Supplementary Appendix L

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impact. The proponents of projects that have reasonably foreseeable impacts are required to

submit an IEE for their respective projects (Schedule 1). Projects that can have significantly

adverse environmental impact (Schedule 2) are required to submit an environmental impact

assessment (EIA) to the respective provincial environmental protection agency. The

requirements for EIA and IEE for different projects under the Investment Program will vary

(Table 1).

6. The first batch of investments under Tranche-1 covers subprojects in water supply,

drainage, and secondary solid waste connection system Two Initial Environmental Evaluations

(IEEs) have been carried out for the Tranche-1 subprojects following ADB’s safeguard Policy

(2003 now revised as per 2009) and Environmental Assessment Guidelines (2003) and

GoP’s environmental assessment regulations and guidelines. One EIA and Three IEE for

SEPA were prepared and NOC provided for the Tranche –I Project. Two IEE of ADB covers the

scopes and magnitude of the sub projects for Tranche I &II, except the sub-projects of Ghotki and

Jacobabad.

7. The table hereunder presents all sub-projects identified for Tranche-2 with environmental

requirements as per ADB guidelines 2003, ADB safeguard policy 2009 and environmental

guidelines of Pakistan Environmental Protection Agency (Pak-EPA). The Tranche II is overall

categorized as Category B

Sector Subproject Tranche Proposed ADB Category

GoP EPA Rules

Part A: Urban Planning, Institutional Development and Program Implementation Support.

Consultancy Services for new

subproject identification, detail

engineering design and preparation of

bidding document, EIA and construction

supervision and implementation of

these projects.

2 C N/S

Consultancy Services for Technical,

Operational and Business Process &

Financial Management to NSUSC

2 C N/S

Part B: Urban Water Supply and Wastewater Management Improvement

Sukkur: Construction of an extension of

the water treatment plant at

NaimashGah (NWTP) of 12 MGD

together with force main to Adam Shah

service reservoir, including meters and

pressure measuring devices.

2 B IEE

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Sector Subproject Tranche Proposed ADB Category

GoP EPA Rules

Sukkur, New Sukkur, Rohri, and

Khairpur: Replacement of old water

mains and supply and laying of all new

mains/transmission lines including

district meters as part of Master Plan,

supply and install appropriate leakage

detection and NRW Equipment to

reduce physical leakage from water

supply networks. insRefer to Grg No.

MMP-977P01-P-DR-WS-S-002, MMP-

977P01-P- DR-WS-R-001 and MMP-

977P01-P-DR-WS-K-001

2 C N/S

Sukkur: Supplying and laying of new

ring/trunk mains, including bulk meters

and refurbishment of an elevated tank

(OHR), and additional HSR. Refer to

Drg No, MMP-977P01-P-DR-WS-S-

002, MMP-977P01-P-DR-WS-R-001

and MMP-977P01-P-DR-WS-K-001

2 B IEE

Construction of water treatment plant at

Airport Road of 6 MGD together with

desilting and capacity enhancement of

storage lagoons and alternative supply

of treated water from Numaish Gah via

Adam Shah service reservoir. Refer to

Drg No MMP-977P01-P-DR-WS-S-002

& Schematic layout Drg No MMP-

977P01-P-DR-WS-S-

2 B IEE/EIA

Sukkur, Khairpur, Rohri: 9 Additional

DNI Zones – replacement of distribution

network, household connections,

installation of domestic and commercial

meters and associated investment in

transmission lines. Designed to provide

3,000 customers with 24/7 potable

1 B EIA/IEE

Supplementary Appendix L

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Sector Subproject Tranche Proposed ADB Category

GoP EPA Rules

water supply.

Rohri: Construction of rapid gravity

sand filter (6MGD) and transmission

line and laboratory at Existing water

treatment plant and distribution

networks and transmission mains

improvement. Location shown on MMP-

977P01-P-DR-WS-R-001

2 B EIA/IEE

Sukkur: Construction of new raw water

intake on the River Indus

2 A EIA

Shikarpur: Rehabilitation of drainage

system, force mains, and 3 disposal

stations, 2x 100 Kva transformers and

construction/replacement of three

existing force main and Master Planning

investment for sewerage improvement

2

B

EIA/IEE

Larkana: Rehabilitation & Improvement

of Sewerage & Drainage System (

based on Detail Design of Sewerage

Project Consultancy of Federal Govt.)

including 13 Transformers for 13

Disposal stations where new

submersible pumps has been installed

2 B EIA/IEE

Rohri: Improvement of Sewerage

system and waste Water Treatment

system at in Karo Naro and

Improvement of Umar Kash Wah and

New Yard Loco Shed (area) Sewerage

Disposal Station.

2 B EIA / IEE

Khairpur: Rehabilitation and wastewater

treatment plant at existing Stabilization

Ponds at Jamali Goth.

2 B EIA / IEE

Khairpur: Diverting wastewater of all disposal stations from Mir wah canal to

2 B EIA/ IEE

Supplementary Appendix L

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Sector Subproject Tranche Proposed ADB Category

GoP EPA Rules

safe discharge point by providing additional force-main for disposal stations

All 8 Towns: Supply of sewer/drain

cleaning Equipments, 4 Jetting

machines, 4 sucking machines, 16

small skid steer loaders-excavators.

2 C N/S

Sukkur, New Sukkur, Rohri, Khairpur,

Shikarpur, Larkana, Ghotki, Jacobabad:

Small Capital Works/Projects for

operational improvement of water

supply and sewerage system.

2 B EIA/ IEE

Sukkur, Rohri, Khairpur: Establishment

of NRW reduction and pressure

management zones Teams with

required resources.

2 C N/S

NSUSC Organization Improvements

Project Equipment required to improve

operational performance including

Central and Regional Control Centers,

establishment of stores, workshops

standalone equipment; tools, office

equipment and software

2 C N/S

Sukkur, New Sukkur, Rohri, Khairpur,

Shikarpur, Larkana, Ghotki, Jacobabad:

Energy Audit Investments and energy

conservation measures in all town water

and waste water plants.

2 C N/S

Part C: Solid Waste

Management

Sukkur, Rohri,Khairpur, Shikarpur: Solid waste management improvements sanitary landfill disposal works, landfill equipment landfill

1 B EIA

Sukkur, New Sukkur, Rohri, Khairpur,

Shikarpur, Larkana, Ghotki: Additional 2 C N/S

Supplementary Appendix L

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Sector Subproject Tranche Proposed ADB Category

GoP EPA Rules

SWM Secondary collection equipment

and SKIPS, System and replacement of

old TMA system including New SMW

Secondary Collection Equipment

including road mechanical sweepers.

Ghotki.& larkana: Solid waste

management improvements sanitary

landfill disposal works, landfill

equipment including transfer station.

3 B EIA/IEE

Part D:

Transition and

Operational

Support

Funding

Operations shortfall for NSUSC Operations

2/3 C N/S

8. This EARF has been prepared/updated for subprojects that will arise in the Tranche-2 as

required by ADB. The EARF identifies the broad scope of the MFF and outlines the policy,

procedures and institutional requirements for preparing subsequent sub-projects under the MFF

loan.

9. Planning and Development Department (P&DD) of the GoS will be the Executing

Agency (EA) with overall responsibility of the Investment Program. Sindh Cities Improvement

Investment Program (SCIP) has a Program Support Unit (PSU), established within P&DD in

2008. An Urban Policy and Strategic Planning Directorate h a s b e e n e s t a b l i s h e d within

P&DD to provide advice on urban policy and regional planning in Sindh. The PSU and the

Urban D i r e c t o r a t e will be separate, but collaborative and complimentary.

10. The Investment Program is supporting the creation of regional utilities, Urban Services

Corporations (USCs) under the Companies Ordinance, 1984, beginning initially with the North

Sindh Urban Services Corporation Limited (NSUSC) under Tranche 1 of SCIP. As provided by

the Sindh Local Government Ordinance, the NSUSC was established and subsequent

USCs, 0F

1 in other geographical areas, will be established by the participating Taluka

1 As EARF applies to the MFF as a whole, the term “NSUSC” will be used

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Municipal Administrations (TMA) / Municipalities to aggregate their water, wastewater and solid

waste management operations in a single institution to leverage economies of scale, introduce

new skills and management, and increase focus on systems operations, asset maintenance,

and financial and human resources management. This EARF also covers two additional cities

i.e. Ghotki and Jacobabad in operational sense with no major investment or ADB Category B is

envisaged, which are planned to be entrusted till end of 2012. All the project identified for these

two cities are also made part of this framework. Jacobabad investment needs are catered by

USAID and NSUSC will be operating the system only.

11. The NSUSC is operating under Governance of Board of Directors, will be the

implementing agency (IA) for the water supply, wastewater and SWM subprojects. In that role,

the NSUSC is responsible for ensuring that environmental assessments are prepared and

EMPs are implemented for subprojects as outlined in this framework. These EMPs are to be

submitted to ADB for review and approval prior to finalization of contracts award or

commencement of work. The NSUSC Managing Director, through Safeguards Unit working

under D i r e c t o r Operations and Services, shall monitor the progress of the environmental

work stream to ensure that all environmental assessments and clearances are submitted to

ADB prior to the Project Financing Request (PFR) for all lending tranches.

12. Each subproject will undergo environmental assessment after categorization and focus

on the most significant issues. Where a subproject requires an IEE, at least one public

consultation will be conducted with local community and potentially affected people. IEE will

be approved before commencement of detailed design while IEE results will be communicated

to the local community before commencement of construction. Any subprojects that are

categorized "A" will require full environmental impact assessment (EIA) and will include two

rounds of public consultation. The second consultation will be conducted after the draft EIA is

prepared which include the EMP. An EIA will be made available to the general public at least 120

days before the subproject approval by ADB. Similar procedure will also apply to Category “B

Sensitive” subprojects, with an IEE (including an EMP) as required. The scope and contents of

the IEE and EIA will be in accordance with ADB’s Environmental Assessment Guidelines (2003)

and ADB safeguard policy 2009.

B. Environmental Criteria for Additional Subproject Selection

13. Potential adverse environmental impacts associated with the subprojects can be

avoided or minimized through careful location, design, and route selection. Specific

environmental criteria for subproject selection are:

(i) The subprojects shall not disturb any cultural heritage designated by the

Government or by international agencies such as United Nations Educational, Scientific,

and Cultural Organization (UNESCO), and shall avoid any monuments of cultural or

historical importance.

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(ii) The subprojects shall not be located within core zone of any protected

areas such as national parks, nature reserves, or wildlife sanctuaries as designated by

Environmental Protection Agency (EPA). In unavoidable case if the subproject component

is in or near the protected area, NSUSC shall ensure mitigation measures acceptable to

the ADB, Sindh Environmental Protection Agency SEPA and concerned

agency/department

(iii) The subprojects shall have a government and ADB approved EMP prior to letting of

any construction contract associated with the project. The subproject EMP must have an

implementation and monitoring budget.

(iv) The subprojects shall not clear any existing forest resources classified by

government as forest or watershed with any kind of protected status. Where

unavoidable tree cutting outside said forest resource areas will be minimized and

compensatory planting will be conducted in a least of 4:1 ratio (four saplings planted

and tended for 5 years for every one tree cut greater than 10cm in diameter). The

budget for compensatory planting shall be included in the EMP.

(v) The subprojects shall only involve activities that follow GoP laws and regulations,

ADB’s safeguard Policy (2009) and ADB Environmental Assessment Guidelines

(2003), and this EARF.

C. Responsibilities and Authorities of Various Agencies

14. The EA will have the overall responsibility of the Investment Program. The EA will (i)

facilitate inter-departmental and inter-district coordination where the environmental aspect and

management crosses the administrative boundaries; (ii) broadly monitor and evaluate the

environmental performance of the Investment Program; (iii) provide quality assurance for social

and environmental safeguards; and (v) contract independent compliance reviews and audits

environmental compliance.

15. The IA will be solely responsible for the implementation of the entire environmental

assessment and review procedures for selecting additional subprojects. This will include, but

not be limited to, ensuring that the subproject selection criteria are strictly adhered to, that

preparation of IEEs or EIA will be carried out in a timely and adequate manner, environmental

monitoring and institutional requirements will be fully met while meaningful public consultations

will be carried out satisfactorily. IA will submit the categorization checklist, IEE and EIA, and

monitoring reports to ADB for review. The NSUSC is implementing agency (IA) for this EARF.

16. Prior to the submission of the PFR for a tranche of subprojects, the IA (NSUSC) will:

(i) Prepare an environmental screening checklist to classify the subprojects in each

tranche.

Supplementary Appendix L

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(ii) Prepare the terms of reference for environmental consultants to conduct

environmental assessments, prepare environmental assessments, IEE/EIA reports

including an EMP, and IEE/EIA for public disclosure.

(iii) Ensure that information disclosure and public consultation in accordance with

ADB’s environmental assessment requirements have been undertaken with affected

groups and local NGOs, review the environmental assessments and submit the IEE,

EIA/EIA, EMP documents to ADB.

17. Prior to the commencement of civil works for subprojects in a tranche, the IA will:

(i) Submit the IEE/EIAs for regulatory approval of the relevant provincial

environmental protection agency and obtain approval, e.g., environmental clearance,

Non-Objection Certificate (NOC), forest clearance and any environmental-related

clearances as per the regulatory requirements of the federal, provincial, or local

government.

(ii) Ensure that all regulatory clearances for the subproject that are obtained from the

relevant Government authorities are submitted promptly to ADB.

(iii) Ensure that the required mitigation measures during construction or the EMP are

included in the bidding document of the subproject and that the all bidding

contractors have access to the EIA/IEE and EMP.

18. During the implementation of civil works for subprojects in a tranche, the IA will:

(i) Ensure that an environmental management plan, including all proposed

mitigation measures and monitoring programs, are properly implemented.

(ii) Monitor the implementation of EMP and post its monitoring report on the

NSUSC website Uwww.nsusc.org.pk U .

(iii) In case unpredicted environmental impacts occur during project implementation,

inform ADB, review the EMP with the contractor, and implement alternative

environmental mitigation program.

(iv) If a subproject changes in scope, inform ADB and reconfirm the environmental

classification, determine whether a supplementary IEE or EIA study is required with

ADB, and carry out the study.

(v) Submit the requisite reports on environmental compliance and implementing the

Environmental Management Plan (EMP) as required by the Pakistan EPA and ADB.

(vi) Ensure that ADB be given access to undertake environmental due diligence for all

subprojects. However, the IA shall have the main responsibility for undertaking

environmental due diligence and monitoring of all the subprojects. The due diligence

Supplementary Appendix L

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report as well as monitoring reports on EMP implementation will be systematically

prepared and be available to the public, if requested.

19. During the MFF, ADB will:

(i) Review and comment on all subproject checklists and proposed environment

category, IEEs and EIA.

(ii) Review all environmental assessment reports as a basis for subproject and

tranche approvals.

(iii) Review regular monitoring reports, posting said reports on the internet (if not

already done so by government) and officially disclosing the summary

environmental reports for Category A and B deemed sensitive on the ADB website in a

manner compliant with ADB’s Safeguard Policy (2009).

(iv) Monitor the EMP implementation and due diligence as part of MFF reviews.

(v) Provide technical guidance to NSUSC, if required, in carrying out its

responsibilities and for building capacity for safeguard compliance.

D. Environmental Assessment and Review Procedures of Additional Subprojects

1. Application of Selection Criteria

20. Any subproject not meeting the criteria listed above will not be put forward for

consideration or inclusion under the MFF tranches. The environmental assessment of the

subprojects will be conducted by IA prior to the submission of the PFR for subsequent tranches

and in line with the requirements of the FFA. A final check on conformity with the selection

criteria will be made at the submission of detailed IEEs of additional subprojects for ADB's

clearance.

2. Environmental Classification

21. Environmental categorization using the Rapid Environmental Assessment checklist

approach in compliance with the ADB Environmental Assessment Guidelines will be applied to all

subprojects. ADB Safeguard Policy 2009 requires Category A and B sensitive environmental

assessment reports to be posted on the ADB website 120 days prior to board approval.

3. Preparation of Detailed Design

22. Detailed design work for each subproject will include and follow the recommendations of

the environmental assessments. The IA will include the requirements of the EMP and IEE/EIAs in

the bid documents and ensure the detailed designs include such requirements before

contracts are finalized. The Engineering Design and Construction Supervision Consultant will

review bid documents for compliance. Where modifications to designs are incorporated at a

later stage, the requirements of the EMP and IEE/EIAs will also be included. Certification to

Supplementary Appendix L

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ADB that the detailed designs comply with IEE/EIAs (including EMP) recommendations will be

required before contracts can be signed and made effective.

4. Preparation of Construction Contracts

23. Early in the implementation period, model construction contracts will be prepared

incorporating general environmental safeguards and practices. Specific, individual contracts will

be based on the model contracts, but will also be checked by the IA to ensure that all special or

particular safeguard requirements and mitigation measures, recommended in the IEE/EIA

(including EMP) for the particular additional subproject, are all incorporated and budgeted within the

contract.

5. Monitoring During the Construction Period

24. Monitoring during construction will be the responsibility of the IA (NSUSC Monitoring

will relate to compliance with construction contracts, the affected environmental resources,

and the effectiveness of mitigation measures).

6. Monitoring of Subproject Operations

25. It is desirable to formulate the EMP in such a way so as to minimize recurrent

responsibilities and costs. However in circumstances where staff, expertise and finances are

limited, some aspects of additional subproject design may require continuous monitoring to

guard against negative environmental impacts.

26. Monitoring of issues related to compensation of landowners for land acquisition and loss of

production, if any, is separately addressed in the Land Acquisition and Resettlement Framework

(LARF) and in Land Acquisition Resettlement Action Plan (LARP).

E. Public Disclosure

27. In disclosing the environmental document to the public, (i) IA is responsible for ensuring

that all environmental assessment documentation, including the environmental due diligence

and monitoring reports, are properly and systematically kept as part of an IA project-specific

record; (ii) all environmental documents are subject to public disclosure, and therefore will be

made available to public; (iii) for category-A and B-sensitive subprojects, the EIA/IEE will be

publicly disclosed through ADB’s websites 120 days prior to PFR submission to ADB. While the

EIA/IEE w i l l be reviewed by ADB prior to disclosure; and (iv) IA will ensure that information

disclosure and public consultations, particularly with project affected persons, are undertaken in

accordance with ADB’s environmental assessment requirements as ADB guidel ines 2003,

safeguard pol icy 2009 and Public Communications Policy (2005) during the IEE/EIA

preparation process for any future subprojects.

Supplementary Appendix L

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F. Institutional Arrangements

28 . The IA will have sole responsibility for the implementation of EARF, as noted in Para 15

above. The IA will retain an environment consultant on an intermittent basis to support

achievement of responsibilities by conducting numerous tasks, including:

(i) Comment on EARF products

(ii) Recommend to the EA when revised EARF products (including, but not

limited to IEEs/EIAs/monitoring reports) should be forwarded to ADB (e.g. for clearance

as part of PFR, as semi-annual monitoring report) and Sindh EPA (e.g., for clearance

as part of PC 1 or government approval).

29. The consultant will report to NSUSC which is responsible for day to day implementation

of the project. The NSUSC has establish a Safeguards Unit to implement key tasks of the EARF,

as noted in Para 11 above.

30. The Safeguards Unit within the NSUSC has a full-time environment specialist/

manager. The specialist/manager is responsible for implementing most aspects of subproject

EMPs; this includes supervising and coordinating with consultants for supervising environmental

monitoring, quality control, and writing and internet posting of EMP progress reports for all

phases of the project including operational phase (Appendix 1 has TOR). The position has

been filled by NSUSC. The position will report to the NSUSC Director Operations and Services

(for all phases EMP tasks).

31. Environment consultant(s) will be hired to support the Safeguards Unit by

(i) Preparing IEEs and EIAs for subprojects,

(ii) Conducting field reviews of the implementation of mitigation measures and monitoring

programs as part of the EMP,

(iii) Training of local environmental safeguard officers of NSUSC’s environmental Unit

and

(iv) Prepare environmental monitoring, compliance and due diligence reports as

per GoS, SEPA and ADB requirements, and

(iv) Other tasks as instructed by the environment specialist/manager.

32. The project costs for tranche-2 have incorporated a budget and resource needed to

(i) Implement the environmental review and screening procedure,

(ii) Undertake the IEE/EIA studies for the follow-up subprojects,

(iii) Undertake environmental mitigation measures as required and

Supplementary Appendix L

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(iv) Monitor the implementation of EMPs.

33. Public disclosure and a complaints contact person within the NSUSC will be identified for

each of the subproject locations to initially receive the concerns and grievances of the local

communities and affected parties, and to ensure that they are properly handled. This NSUSC

representative will work closely with designated TMA staff and with the Provincial Government

Program Support Unit regional office staff, the latter having the role of liaising between the TMA

and NSUSC. The Safeguards Unit of NSUSC will be responsible to disseminate information

about the expected performance of the contractor. The contact person will meet with local

communities if requested or as required, and working in coordination with PSU and PSU

regional office staff and with the TMA staff as appropriate.

Grievance Redress Mechanism

34. In order to receive and facilitate the resolution of affected peoples’ concerns, complaints, and grievances about the project’s environmental performance an Environmental Grievance Redress Mechanism (GRM) will be established for each of the projects. Whilst the GRM is intended for addressing environment related grievances, in reality there is considerable cross over between environmental and social issues in relation to construction activities. Thus, it is recommended that the GRM established for environmental issues is also used to address social issues arising during project implementation.

35. The GRM will be used for addressing any complaints that arise during the implementation of projects. In addition, the GRM will include a proactive component whereby at the commencement of construction of each subproject (prior to mobilization) the community will be formally advised of project implementation details by the IA, the design and supervision consultant (SC) and the contractor (designs, scheduled activities, access constraints etc.) so that all necessary project information is communicated effectively to the community and their immediate concerns can be addressed. This proactive approach with communities will be pursued throughout the implementation of each project.

36. The GRM will address affected people's concerns and complaints proactively and promptly, using an understandable and transparent process that is gender responsive, culturally appropriate, and readily accessible to all segments of the affected people at no costs and without retribution. The mechanism will not impede access to the project’s judicial or administrative remedies.

Grievance Redress Mechanism (GRM) Establishment and Procedure

37. The GRM will be established at each project location as described below:

38. Prior to the contractor’s mobilization to the project site the IA will assist affected communities establish a Grievance Redress Committee (GRC) and identify local representatives to act as Grievance Focal Points (GFP) for that community.

Supplementary Appendix L

Page 18

39. The Grievance Redress Committee (GRC) will comprise representatives from local authorities, affected parties, and other well-reputed persons from health or education sectors, as mutually agreed with the local authorities and affected persons. It will also comprise the Contractor’s Environmental Specialist, SC’s Environment Specialist and the Environment Specialist NSUSC (the IA). The function of the GRC is to address the project related grievances of the affected parties that are unable to be resolved satisfactorily through the initial stages of the GRM procedure.

40. The Grievance Focal Points (GFPs) are designated personnel from within the community who will be responsible for: i) acting as community representatives in formal meetings between the project team and the local community he/she represents and ii) communicating community members’ grievances and concerns to the contractor during project implementation. The number of GFPs to be identified for each project will depend on the number and distribution of affected communities.

41. A pre-mobilization public consultation meeting will be convened by NSUSC and attended by GFPs, contractor, SC, Director Environment NSUSC, and other interested parties (e.g. District level representatives, NGOs). The objectives of the meeting will be as follows:

(i) Introduction of key personnel of each stakeholder including roles and responsibilities, (ii) Presentation of project information of immediate concern to the communities by the

contractor (timing and location of specific construction activities, design issues, access constraints etc.) This will include a brief summary of the EMP - its purpose and implementation arrangements;

(iii) Establishment and clarification of the GRM to be implemented during project implementation including routine (proactive) public relations activities proposed by the project team (contractor, SC, NSUSC) to ensure communities are continually advised of project progress and associated constraints throughout project implementation;

(iv) Identification of members of the Grievance Redress Committee (GRC) (v) Elicit and address the immediate concerns of the community based on information provided

above 42. Following the pre-mobilization public consultation meeting, environmental complaints associated with the construction activity will be routinely handled through the GRM as explained below and shown schematically in Figure E.1:

(i) Individuals will lodge their environmental complaint/grievance with their respective community’s nominated GFP.

(ii) The GFP will bring the individual’s complaint to the attention of the Contractor. (iii) The Contractor will record the complaint in the onsite Environmental Complaints Register

(ECR) in the presence of the GFP. (iv) The GFP will discuss the complaint with the Contractor and have it resolved; (v) If the Contractor does not resolve the complaint within one week, then the GFP will bring

the complaint to the attention of the SC’s Environmental Specialist. The SC’s Environment Specialist will then be responsible for coordinating with the Contractor in solving the issue.

(vi) If the Complaint is not resolved within 2 weeks the GFP will present the complaint to the Grievance Redress Committee (GRC).

(vii) The GRC will have to resolve the complaint within a period of 2 weeks and the resolved complaint will have to be communicated back to the community. The Contractor will then record the complaint as resolved and closed in the Environmental Complaints Register.

Supplementary Appendix L

Page 19

(viii) Should the complaint not be resolved through the GRC, the issue will be adjudicated through local legal processes.

(ix) In parallel to the ECR placed with the Contractor, each GFP will maintain a record of the complaints received and will follow up on their rapid resolution.

Figure E.1 Grievance Redress Mechanism

Gri

evan

ce

Red

ress

ed

C

om

mit

tee

Affected Person through GFP

Contractor

Not Redressed

Resolve through Local Legal Process

Redressed

Resolve with Implementation (SC) Consultant Redressed

Not Redressed

Appeal to Grievance Redress Committee Redressed

Not Redressed

Supplementary Appendix L

Page 20

G. Environmental Management and Monitoring

43. Appendix 2 summarizes an environmental management plan in matrix form that will

apply to future subprojects to be updated following submission of IEEs. Additional requirements

may be necessary for some sub-projects. The matrix is developed on the basis of environmental

assessment for the tranche- 1 & 2 subprojects. The mitigation measures for the additional

subprojects will be developed in the spirit of the principles agreed upon in this EMP. However

the EMP for all subprojects will be a working document and any unanticipated consequence(s) of

the project will be documented in the regular semi-annual reports (Appendix-3 draft table of

contents for semiannual reports) while environmental mitigation measures will be modified to

take account of unexpected impacts as necessary, throughout the implementation period.

Appendix 2 and 3 must be used as a guide for preparing all EMPs and regular semi-annual reports

in this MFF, elements of which should be adopted as appropriate after professional review. The

subproject EMP requirement must be incorporated into contract tendering documents.

Construction bids must estimate costs of compliance with the EMP. Construction contracts

cannot be awarded until EMP is approved by both ADB and the EA.

44. Environmental monitoring will be conducted based on the provisions in the subproject

EMP. Table 2 presents the summary monitoring plan for the subproject. Table 3 presents the

indicative estimated costs for EMP implementation of tranche 2 subprojects.

45. The EMP will have both internal and external monitoring. The Environmental

Specialist/manager of NSUSC will be responsible for internal monitoring of the EMP

implementation. The Environmental Specialist / Manager with assistance of consultants will

e n s u r e preparation of s e m i - a n n u a l r e p o r t s for all subprojects that will contain

progress made in EMP implementation with particular attention to compliance with the principles

and matrix set out in the EMP. The NSUSC will submit semi-annual compliance monitoring

report for category A and B subprojects to ADB. Appendix-3 is draft table of contents for

semiannual reports. ADB will post said monitoring reports on its website, in compliance with its

Safeguard Policy. Monitoring reports would also be submitted to Sindh Environmental Protection

Agency (SEPA) on projects for which regulatory approval is required. The reporting frequency

shall be semi -annual or as required by SEPA.

Supplementary Appendix L

Page 21

Table 2: Key tasks for Environmental Monitoring Plan

Environmental Monitoring Tasks Implementation

Responsibility

Implementation Schedule

Pre-Construction Phase

Receive bidding documents to ensure IEE/EIA

and EMP is included.

Engineering Design

and Construction

Supervision Engineers

Prior to issue of bidding

documents.

Audit detailed designs of Facilities and

alignment of pipeline routes to ensure standard

environmental safeguards/mitigation measures

(as identified in EMP) have been included.

NSUSC Prior to approval of

contractor’s detailed

designs.

Construction Phase

Regular monitoring and Reporting of

contractor’s compliance with contractual

environmental mitigation measures.

NSUSC through

Construction

Supervision

Consultant/Independent

Monitoring Consultant

Continuous throughout

construction period.

Operation and Maintenance Phase

Observations during routine maintenance

inspections of facilities and pipelines and rights

of way. Inspections will include monitoring

implementation status of mitigation measures

specified in EMP.

NSUSC through staff

as in table-3

As per inspection schedules

Note: Monitoring of issues related to compensation of landowners for land acquisition and loss of production, etc. are

addressed in the Land Acquisition and Resettlement Action Plan.

Table 3: Summary of Estimated Costs for EMP Implementation as per Business/Operating Plan

Item Sub Item Total Cost (PRs)

Total Cost ($)a1F

2

Monitoring staffing

Existing NSUSC Staff with additional environmental compliance and two HSE Officers operations and

as Proposed to be budgeted in New Business Plan 2012-2015

2 1$=95PKR

Supplementary Appendix L

Page 22

Item Sub Item Total Cost (PRs)

Total Cost ($)a1F

2

services, one HSE Officer for capital works and Lab Officers

Audits & ISO 140001

Annual audits and ISO 14001 Certification and EMS for Labs at PRs500,000 per audit

1,000,000 10550

Monitoring activities

As detailed under EMP2F

3 as per Bid Price of Each contract

EMP Mitigation measures

As detailed under EMPs for operational phase

As per Operating Plan

Transport Dedicated vehicles of NSUSC for Environmental Compliance of Projects and Operations by Safeguard Unit

Contingency contingency 10% 2000

UTotal U1,000,000 Uand as

per actual/budget

U12,550

3 Includes air, noise and water monitoring cost

Supplementary Appendix L

Page 23

APPENDIX 1: Draft Terms of Reference for Environmental Safeguards Specialist/Manager

A. Qualifications

1. The Environmental Safeguards Specialist/manager shall be a post graduate in

environmental science, environmental engineering or a related discipline with 7-10 years

professional experience in environmental management and monitoring of projects, environmental

assessment and / or implementation of environmental mitigation measures on international

funded projects. It is desirable for the Environment Specialist to have relevant experience with

international donors and their safeguard policies.

B. Reporting

2. The Safeguards Unit leader will report to the NSUSC Director Operations and

Services.

C. Scope of Work

(i) Ensure of environmental assessments, their associated environmental

management plans (EMP) by consultants for all subprojects. This includes both technical (e.g.

report review and comment) and administrative (e.g. consultant TOR, recruitment, and contract

management) functions.

Consultant/ IMC Contractor

Managing Director

NSUSC Safeguards

Unit

Director

(Operation & Services)

Environmental

Safeguard

Specialist/Manager

One Environmental

/HSE Engineers for

projects and two for

operations)

Water Quality Labs

Officers and Staff

Supplementary Appendix L

Page 24

(ii) Check and verify the EMP implementation progress, as reported by consultants and

through site visits. Assess the progress in the subprojects’ EMP implementation

address the gaps to ensure compliance with ADB’s environmental assessment

requirements to warrant submission of the next PFR to ADB;

(iii) Review & Oversight of regular Water Quality Monitoring results and find gaps and ensure

compliance and corrective measures

(iv) Check and verify the progress in EMP implementation of each subproject and every six

months prepare reports for EA and ADB. The report shall include, but not be limited to:

• Major achievements since last reporting period

• monitoring results of this reporting period, comparison of results with agreed-upon

performance standards

• Summary of complaints through random checking at the field level, and actions that

were taken to address complaints

• Unexpected environmental impacts, and actions taken to address those impact, issues

to address in next reporting period

(V) Implement NSUSC Environmental Policy and HSE Policy

Supplementary Appendix L

Page 25

APPENDIX 2: Environmental Management Plan for Tranche-1&2 Subprojects

The below table must be used as a guide for preparing subproject Environmental Management Plans under this Facility, as applicable. Construction

contracts cannot be awarded until the subproject EMP is approved by both ADB and the Implementing Agency, the Urban Services Corporation

(NSUSC)...

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

Subproject

location

All sub

projects

Social and

environmental

nuisances

Careful site /

route selection to

avoid existing

settlements.

Review IEE and

EMP and confirm

findings and

recommendations

.

Site location as

proposed in RRP

and IEE with

respect to nearest

SRs.

Check with

detailed

design

engineers and

land owners –

once during

feasibility

prior to detail

design stage.

NSUSC Integral part of

subproject

detailed design

and project

preparation.

All sub

projects

Loss of productive

agriculture

Minimize need to

acquire

agricultural land.

Site selection in

urban area or on

marginal land on

urban fringe (as far

as possible not

agricultural land).

Consultation

with local

authorities

and land

owners during

feasibility

prior to detail

NSUSC Integral part of

subproject

detailed design

and project

preparation

Supplementary Appendix L

Page 26

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

design stage.

Subproject

location changes

All sub

projects

Non-compliance

with subproject

selection criteria.

Conduct Rapid

Environmental

Assessment to

determine ADB

Category.

Review IEE and

EMP and confirm

findings and

recommendations

.

Categorization and

submission of REA

to ADB.

Prior to or

latest during

detailed

design stage.

NSUSC Integral part of

subproject

detailed design

and project

preparation.

Subproject

boundaries

change.

All

subprojects

EMP insufficient

to control impacts.

Non-compliance

with statutory

requirements

Pakistan

Environmental

Protection Act

Review IEE and

EMP and confirm

findings and

recommendations

.

Disclose

feasibility designs

of subprojects to

SEPA in advance

Submit REA,

revised IEE/EIA

and EMP to ADB.

Obtain waiver for

IEE

from Pak EPA OR

“Environmental

Prior to

signing of

construction

contracts.

NSUSC Integral part of

subproject

detailed design

and project

preparation.

Supplementary Appendix L

Page 27

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

1997. to clarify IEE or

EIA.

Complete the

environmental

assessment

process in line

with SEPA and

ADB Guidelines.

Approval” from

SEPA.

Layout of

facilities.

All

subprojects

Relocation of

potential

nuisances or

exposure to noise

or safety related

risks.

Check setback

and location of

noise sources

with respect to

sensitive

receivers (SRs)

and design in

accordance with

good principles.

Buffer distance to

SRs sufficient as

recommended in

IEE with respect to

nearest SRs.

Check

setback

distances to

nearest

sensitive

receivers –

twice during

design and

when layout

plans are

finalised.

NSUSC Integral part of

feasibility survey

and detailed

design.

Avoid utilities /

interface

All Interruption of Utilities

management

Maintenance of Continuous NSUSC Throughout

design and

Supplementary Appendix L

Page 28

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

management subprojects utility service coordinating

committee

services construction

phases.

Buffer Zone

/distance

encroached

All

subprojects

Buffer distance

reduced creates

potential

nuisances for

neighbors/SRs.

Check setback of

facilities from

sensitive

receivers (SRs)

off site and re

design in

accordance with

proposed buffer

or include

mitigation.

% recommended

buffer distance

achieved. Inclusion

of additional

mitigation. Residual

impacts >

predicted in IEE.

Twice

Feasibility

design and

detailed

design.

NSUSC Integral part of

feasibility survey

and detailed

design.

Equipment

location and

design.

All

subprojects

Exposure to

noise, Nuisance to

neighboring

properties.

Design and

location of

subproject to

comply with

NEQS regulations

and World Bank

guidelines.

Check potential

performance of

proposed

vehicles/equipment

.

Check

proposed

equipment is

actually

included

through

purchase and

usage

inventory.

NSUSC Part of detailed

design,

commissioning

and operational

monitoring.

Supplementary Appendix L

Page 29

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

Involuntary

Resettlement or

land acquisition

(if unforeseen

requirement

emerges).

All facilities. Social inequities Compensation

paid for

temporary/

permanent loss of

productive land as

per land laws and

its process as

specified in RAP.

RAP

implementation

Consultation

with affected

parties – once

in a quarter.

NSUSC Prior to

construction

phase.

Interference with

drainage

patterns/Irrigatio

n channels

All facilities Flooding hazards /

loss of agricultural

production

Appropriate

location of

facilities to avoid

interference with

irrigation channels

Significant distance

to nearest flood

zone, irrigation

channel

Consultation

with local

irrigation

authorities

and design

engineers -

once

NSUSC Part of project

preparation and

site selection,

detailed

alignment

survey and

design

Release of

polluting

materials

All plant

equipment

Environmental

pollution

Plant and layout

designed and

equipment

selected to

ensure

compliance with

NEQS and

Equipment

specifications with

respect to potential

pollutants.

Tender

document to

include

detailed

specifications

- once

NSUSC Part of detailed

equipment

design selection

and design

drawings

Supplementary Appendix L

Page 30

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

prevent runoff.

All

subprojects

New sites and

facilities to

include drainage

and sewage

disposal systems

to avoid offsite

land and water

pollution.

Drainage and

sewage design.

Tender

document to

include

detailed

specifications

- once

NSUSC Part of detailed

equipment

design selection

and design

drawings

Equipment

submerged

under flood

All plant

equipment

Contamination of

land and water

SRs.

Appropriate siting

and facilities

constructed

above the highest

recorded flood

level (HFL) or

design to raise

the foundation

pad (see also

drainage).

Facility design to

account for HFL

(elevation with

respect to HFL

elevation)

Base height

as per flood

design - once

NSUSC Part of detailed

layout and

design /

drawings

Explosions/Fire All facilities Hazards to life Locate and

design facilities to

Design compliance

with fire prevention

Tender

document to

NSUSC Part of detailed

layout and

Supplementary Appendix L

Page 31

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

include fire breaks

/ walls and

modern fire

control

systems/firewalls.

and control codes

(BCOP).

specify

detailed

design

requirements

– once

design /

drawings

Facility location All

subprojects

Visual impact Facilities not to be

located near

critical or

sensitive areas or

national

monuments in

areas with

potential tourist

activities. Soft

landscaping.

Trees and soft

landscaping

included in design.

Meaningful and

appropriate to

mitigate visual

impact.

Trees and

landscaping

planted and

maintained

NSUSC Detailed designs

and

commissioning.

Tree

preservation

All

subprojects

Unnecessary loss

of trees

Tree survey

during detailed

design.

Trees identified

and marked.

Trees to be

retained and

maintained

NSUSC Detailed designs

and

commissioning.

Environmentally

responsible

All

subprojects

Operational

environmental

Choose non

polluting

Checked

equipment

specifications and

During

product

acquisition,

NSUSC Detailed designs

and

Supplementary Appendix L

Page 32

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

procurement pollution equipment performance with

company

certificates /

accreditations.

prior to

purchase.

commissioning.

Environmentally

responsible

procurement

All

subprojects

Impact at

decommissioning.

Specify

equipment not to

contain asbestos,

other hazardous

or toxic

components.

Checked

equipment

specifications and

performance with

company

certificates /

accreditations.

During

product

acquisition,

prior to

purchase.

NSUSC Detailed designs

and

commissioning.

Equipment

layout and

installation

All

subprojects

Noise and

vibration.

Construction

techniques and

machinery

selection seeking

to minimize

vibration through

ground

disturbance and

minimise duration

of works.

Construction

techniques and

machinery in line

with contractual

requirements and

contractors method

statements.

Construction

techniques

and

machinery

creating

minimal

ground

disturbance -

once at the

start of each

construction

NSUSC

(Contractor

through

contract

provisions).

Construction

period

Supplementary Appendix L

Page 33

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

phase.

Physical

construction

All

subprojects

Disturbed

commercial and

community

activities.

Construction

activities timed to

optimise minimum

disturbance and

nuisances.

Timing mitigation

with respect to

community

activities and

requests.

Complaints

Received by local

authorities.

Once every

month include

in progress

reports.

NSUSC

(Contractor

through

contract

provisions).

Construction

period

Mechanized

construction

All

subprojects

Noise, vibration

and operator

safety, efficient

operation

Construction

equipment to be

well maintained

with

noise suppression

/ acoustic

insulation. Erect

local site hoarding

as necessary.

Construction

equipment

– noise levels.

Complaints

received by

local

authorities -

once every

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

All

subprojects

Noise, vibration,

equipment wear

Turning off plant

not in use. Erect

Construction

equipment

Complaints

Received by

NSUSC

(Contractor

Construction

period

Supplementary Appendix L

Page 34

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

and tear site hoarding. – estimated noise

levels and

operating

schedules

local

authorities –

once every

month

through

contract

provisions)

Excavation by

hand tools or

other means

All

subprojects

Dust increases. Erect site

hoarding, damp

down exposed

surfaces and

stockpiles to keep

moist. Cover open

ground /

stockpiles when

construction not

active.

Hoarding

installation,

covering works and

frequent damping.

Site check

weekly /

report

monthly

NSUSC to

check weekly

and report

monthly.

(Contractor

requirement

through

contract

provisions).

Construction

period

Construction of

access roads

and hoardings

All

subprojects

Increase in

airborne dust

particles

Use existing

roads and tracks

for construction

and maintenance

access to the

sites wherever

Access roads,

routes (length and

width of new

access roads to be

constructed).

Use of roads

established in

contract as

suitable –

once every

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 35

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

possible.

All

subprojects

Increased land

requirement for

temporary

access/constructio

n

New access ways

should be minimal

disturbance and

restricted to a

single

carriageway width

with passing bays

and shortest

distance from

existing road to

site.

Disturbance and

access width

(meters) as

agreed with

contractor.

Complaints.

Every month

– include in

progress

report.

NSUSC

(Contractor

through

contract

provisions).

Construction

period

Preparation of

site

All

subprojects

Temporary

blockage of

drainage.

Temporary

placement of

cleared top soil:

N Uot Uplaced to

obstruct

drains/canals.

Temporary fill

placement (m3)

and location.

Check no

impact (e.g.

on sensitive

drainage

areas - every

month –

include in

progress

report.

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 36

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

Site clearance All

subprojects

Vegetation Marking of

vegetation Unot Uto

be removed prior

to clearance, and

strict control on

clearing activities

to ensure minimal

clearance.

Cleared

vegetation Unot U to

be burned.

Vegetation survey,

marking and

clearance control

(area in m2) –

monitor and

inspect.

Clearance

strictly limited

to target

route/site and

minimum

working

areas- every

month when

works are

commencing

on a

particular

route/site.

NSUSC

(Contractor

required in

contracts to

provide “site

clearance

plan” as line

item before

opening new

works) prior to

handover.

Construction

period

Trimming/cutting

of trees within

RoW/site

boundary

All

subprojects

Safety hazards

and conservation

to be balanced.

Retain trees and

maintain trees

unless unsafe to

do so. Trees

allowed to grow

unless posing a

safety hazard.

Number of trees

retained vs

numbers cut.

Retained

trees and

maintained

trees in

RoW/site vs

trees

identified at

design stage

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 37

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

Trimmings

composted Unot U

burned.

– once per

quarter

All

subprojects

Felled trees and

other cleared or

pruned vegetation

to be disposed of

as authorized by

the statutory

authority but not

burned.

Disposal of cleared

vegetation as

approved by the

statutory

authorities (area

cleared in m2)

Use or

intended use

of vegetation

as approved

by the

statutory

authorities –

once per site

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Surplus

earthwork/soil.

All

subprojects

Runoff to cause

water pollution,

solid waste

disposal

Soil excavated

from sites

disposed of by

placement along

roadsides, or at

nearby house /

school / hospital

gardens if

requested by

Soil disposal

locations and

volume (m3).

Acceptable

soil disposal

sites - every

month in

progress

report

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 38

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

landowners.

Storage of

materials

All

subprojects

Contamination of

adjacent receptors

(land, water, air)

Materials securely

stored above high

flood level.

covered when not

in use, at end of

shift and at night

Location of

hazardous material

storage.

Bulk materials

stored on site

extent

covered and

retaining

boards -

every month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

All

subprojects

Increased land

requirement for

temporary

access/constructio

n

New access ways

should be minimal

disturbance and

restricted to a

single

carriageway width

with passing bays

and shortest

distance from

existing road to

site.

Disturbance and

access width

(meters) as

agreed with

contractor.

Complaints.

Every month

– include in

progress

report.

NSUSC

(Contractor

through

contract

provisions).

Construction

period

Storage of All Accidental spillage Fuel and other

hazardous

Record usage. Spill

records (type of

Fuel and

chemical

Storage of All subprojects

Supplementary Appendix L

Page 39

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

chemicals subprojects of chemicals materials securely

stored and above

high flood level.

material spilled,

amount (kg or m3)

and action taken to

control and clean

up

spill)

storage in

appropriate

containers in

appropriate

locations

preferably

bunded or

enclosed –

every month

chemicals

Construction

scheduling

(considerate of

local

circumstances).

All

subprojects

Noise nuisance to

neighbouring

properties.

Interference with

peak traffic hours

on adjacent roads.

Construction

activities only

undertaken during

the day.

If night working

discuss with local

communities to

keep informed of

the construction

schedule. Avoid

school exam

times and

religious festivals

Public consultation

and Timing of

construction (noise

emissions, [dB(a)]).

Complaints and

results feedback

Monthly audit

of day time –

nigh time

construction

scheduling

and feedback

of PC – every

month

Construction

scheduling

(considerate of

local

circumstances

).

All subprojects

Supplementary Appendix L

Page 40

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

near schools and

mosques

Provision of

basic sanitary

facilities for

construction

workers.

All

subprojects

Contamination of

neighborhood,

open defecation,

litter, waste

disposal.

Construction

workforce

facilities to

include portable

lavatories or

arrange proper

access to other

toilets with

adequate

sanitation, water

supply for

washing. Regular

litter collection

and site waste

disposal facilities.

Portable chemical

toilets acceptable.

Adequate

amenities and

cleansable facilities

to

be arranged prior

to

Commencement of

construction for

workforce. Within 5

(five) minutes walk

from all work sites

and kept clean at

all times.

Presence of

proper

sanitation,

water supply

and waste

disposal

facilities - one

for each

facility or one

for each

500m of

pipeline or

BTR

Construction.

Provision of

basic sanitary

facilities for

construction

workers.

All subprojects

Nuisance to

nearby

All

subprojects

Impacts on

property value

losses to

Contract clauses

to specify

acceptable

Monitor and

enforce

implementation of

Incorporating

good

construction

Nuisance to

nearby

All subprojects

Supplementary Appendix L

Page 41

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

properties neighboring land

uses.

construction

practices to

mitigate

nuisances, noise,

vibration and dust

impacts.

contract clauses

versus milestone

payments for

mitigation (e.g. per

m of hoarding

installed effectively.

management

practices

– once per

month for

each site/km

of line

under

construction.

properties

All

subprojects

Use existing

access effectively

as much as

possible.

Construction

operating

procedures and

monitor complaints.

Incorporating

good design

engineering

practices –

once for each

site. Check

monthly.

All subprojects

All

subprojects

Productive land

will be reinstated

following

completion of

construction

Reinstatement of

land status (area

affected, m2) if

necessary.

Consultation

with affected

parties –

twice

– immediately

Supplementary Appendix L

Page 42

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

after

completion of

construction

and after the

first harvest

All

subprojects

Social inequities Compensation

will be paid for

loss of livelihood

due to

construction

disruption in line

with ADB

guidelines.

Prompt

disbursement of

compensation for

lost income in line

with RAP

entitlement matrix.

Monitor amount

paid to whom, how

and when.

Monthly

monitoring

with updated

report – once

in a quarter.

NSUSC Prior to

commencement

of construction

in the relevant

location.

Complaints All

subprojects

Construction

activities

Set up complaints

hot line,

recording,

response and

resolution

monitoring

Response time to

rerecord, respond

and resolve

complaints.

Complaints

Received by

local

authorities –

tally once

every month

NSUSC

(Contractor

through

contract

provisions)

Supplementary Appendix L

Page 43

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

All

subprojects

Nuisances to

surrounding

neighborhood.

Set up complaints

hot line and

response

mechanism

Complaints

number, location,

validity,

fraudulence, review

of mitigation

measures to

improve

environmental

control.

Monitor total

complaints

weekly and

investigate as

soon as

possible after

complaint (call

back within 2

days, site visit

within the

week).

Document

action and

record

resolution

NSUSC

(Contractor

through

contract

provisions)

Throughout

construction and

at least first year

of operation.

Flooding

hazards due to

construction

impediments of

natural drainage

All

subprojects

Flooding and

damage to

property, blocking

of traffic through

roads. Pedestrian

access and

spread of surface

Temporary

drainage

management plan

(TMDP) to be

submitted to CRC

for acceptance by

NSUSC one

Submission of

TDMP as condition

of contract clauses.

Occurrence of

flooding and any

relevant

Check as line

item before

opening for

each

section/area

of the works.

Record

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 44

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

contamination month before

commencement

of construction in

the relevant

sector.

Avoid drainage

pattern facilities

being disturbed /

blocked / diverted

by the on- going

construction

activities.

Other drainage

mitigation

measures,

diversions,

protection of

drains.

complaints.

TMDP to cater for

worst case one in

five (5) year

flooding event.

Review mitigation

id flooding repeats.

flooding

events

monthly and

report

quarterly

TMDP to be

checked by

qualified

drainage

engineer and

accepted.

Incorporating

good

construction

management

practices

– Monthly for

each site.

All

subprojects

Productive land

will be reinstated

Reinstatement of

land status (area

Consultation

with affected

Supplementary Appendix L

Page 45

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

following

completion of

construction

affected, m2) if

necessary.

parties –

twice

– immediately

after

completion of

construction

and after the

first harvest

Health and

safety

All

subprojects

Injury and

sickness of

workers and

members of the

public

Contract

provisions

specifying

minimum

requirements for

construction

camps, if required

Contract clauses

covering (number

of incidents and

total lost- work

days caused by

injuries and

sickness)

Contract

clauses

compliance –

once every

quarter

NSUSC

(Contractor

through

contract

provisions)

Construction

period

All

subprojects

Contractor to

prepare and

implement a

health and safety

plan.

Supplementary Appendix L

Page 46

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

All

subprojects

Contractor to

arrange for health

and safety

training sessions

First aid All

subprojects

Minor injuries to

workforce go

unattended

presenting risk to

worker injured and

co-workers.

First aid posts to

be set up with

adequate

sanitation (at

least washing and

dressing facilities)

with first aid kits,

one for every site

or one for every

2km along the

routes

First aider to be

trained in every

contractor and

sub contractor

group to be

present onsite

every working

Nomination of first

aiders and setting

up facilities.

Contents of first aid

kits. Test run

response from

Mobile clinic.

Check records of

accidents.

Once per

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 47

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

day, or mobile

clinic to be

available onsite

every with driver/

first-aider and

trained nurse to

man the mobile

clinic.

Record cause of

accidents and

investigate if

hospitalisation

required.

Injuries to

workforce

All

subprojects

Avoid severe

head injuries and

foot injuries,

especially in areas

where overhead

construction will

take place.

Exclude public.

Hoard and net

edges of elevated

sections to retain

accidentally

dropped materials

tools.

Provide sufficient

Check hoardings

and safety nets,

Check availability

of hard hats and

hard shoes.

Monitor usage of

hard hats and

Once per

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 48

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

basic protective

equipment to

allow every

worker once per

year including a

hard hat and one

pair hard toe and

sole shoes.

shoes % workforce

using.

Check records of

accidents.

Health and

safety

All

subprojects

Injury and

sickness of

workers and

members of the

public

Contract

provisions

specifying

minimum

requirements for

construction

camps, if required

Contract clauses

covering (number

of incidents and

total lost- work

days caused by

injuries and

sickness)

Contract

clauses

compliance –

once every

quarter

NSUSC

(Contractor

through

contract

provisions)

Construction

period

All

subprojects

Contractor to

prepare and

implement a

health and safety

plan.

Supplementary Appendix L

Page 49

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

All

subprojects

Contractor to

arrange for health

and safety

training sessions

First aid All

subprojects

Minor injuries to

workforce go

unattended

presenting risk to

worker injured and

co-workers.

First aid posts to

be set up wit

adequate

sanitation (at

least washing and

dressing facilities)

with first aid kits,

one for every site

or one for every

2km along the

routes

First aider to be

trained in every

contractor and

sub contractor

group to be

present onsite

every working

Nomination of first

aiders and setting

up facilities.

Contents of first aid

kits. Test run

response from

mobile clinic.

Check records of

accidents.

Once per

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 50

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

day, or mobile

clinic to be

available onsite

every with driver/

first-aider and

trained nurse to

man the mobile

clinic.

Record cause of

accidents and

investigate if

hospitalisation

required.

Injuries to

workforce

All

subprojects

Avoid severe

head injuries and

foot injuries,

especially in areas

where overhead

construction will

take place.

Exclude public.

Hoard and net

edges of elevated

sections to retain

accidentally

dropped materials

tools.

Provide sufficient

Check hoardings

and safety nets,

Check availability

of hard hats and

hard shoes.

Monitor usage of

hard hats and

Once per

month

NSUSC

(Contractor

through

contract

provisions)

Construction

period

Supplementary Appendix L

Page 51

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

basic protective

equipment to

allow every

worker once per

year including a

hard hat and one

pair hard toe and

sole shoes.

shoes % workforce

using.

Check records of

accidents.

Inadequate

construction

stage

environmental

monitoring

All

subprojects

Lack of monitoring

may allow noise

and dust to

escalate,

uncontrolled.

Impacts may

increase.

No quantitative

Feedback

prevents

improvement of

mitigation

Training of

NSUSC

environmental

monitoring

personnel

Training schedules Number of

programs

attended by

each person –

twice per year

NSUSC Routinely

throughout

construction

period

Supplementary Appendix L

Page 52

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

measures

All

subprojects

Implementation of

effective

environmental

monitoring and

reporting system

using checklists

of all contractual

environmental

requirements and

EMP.

Respective

contract checklists

and Remedial

actions taken

thereof.

Submission of

duly

completed

checklists of

all contract

requirements

for each site –

once

All

subprojects

Appropriate

contact clauses to

ensure

satisfactory

implementation of

contractual

environmental

mitigation

measures.

Compliance report

related to

environmental

aspects for the

contract

Submission of

duly

completed

compliance

Report for

each contract

– once

Supplementary Appendix L

Page 53

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

Commissioning All

subprojects

Visual impact Facilities to have

areas with soft

landscaping.

Opportunity spaces

for trees and soft

landscaping to be

included in the

design.

Check trees

and

landscaping

are planted

and have

been installed

and

maintained.

Before last

payment of

contract.

NSUSC Commissioning.

Noise Impacts All

subprojects

Nuisance to

neighbouring

properties

Facility sited and

designed to

ensure noise will

not be a

nuisance.

Noise levels

(dB(A)) to meet

criteria agreed with

SEPA.

Noise levels

at boundary

nearest to

properties at

intervals (or

as agreed

with SEPA –

quarterly in

1st

year of

NSUSC During

commissioning

and

1st year of

operations

Supplementary Appendix L

Page 54

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

operation.

Inadequate

provision of

health and safety

training during

operations to

staff/workers

All

subprojects

Injury and

sickness of staff

/workers

Careful design

using appropriate

technologies to

minimise hazards

Usage of

appropriate

technologies (lost

work days due to

illness and injuries)

Preparedness

level for using

these

technologies

in crisis –

once each

year

NSUSC Design and

operation

All

subprojects

Provide adequate

sanitation and

water supply

facilities

Provision of

facilities

Complaints

received from

staff / workers

Operational

environmental

monitoring.

All

subprojects

Environmental

impacts and

nuisances are

uncontrolled.

Unexpected

impacts go

undetected.

NSUSC staff to

receive

awareness

training in

environmental

monitoring of

project operations

and maintenance

Training/awareness

programs and

mock drills for all

staff.

Number of

programs and

percent of

staff covered

– once each

year

NSUSC Operation

Supplementary Appendix L

Page 55

Project activity

/

stage / issue

Subproject

type of

component

Potential impact

Proposed

mitigation

measure

Parameter to be

monitored

Measuremen

t and

frequency

Institutional

responsibility

Implementation

schedule

activities.

Supplementary Appendix L

Page 56

APPENDIX-3: Semi-annual Environmental Monitoring Report

Table of Contents

Part I Introduction

I. Construction activities and Project Progress during previous 6 months

II. Changes in project organization and Environmental management team

III. Relationships with Contractors, owner, lender, etc.

Part II Environmental Monitoring

Environmental monitoring summary – summarise the previous six months monitoring data and provide explanations

of any instances where environmental standards or guidelines are exceeded. Typically this will cover:

Noise and Vibration

Water Quality

Air Quality

Flora and fauna monitoring

Recommendations are required to show how any exceedences will be prevented in the future.

Graphs can be used in this section to show trends, however large tables of data or multiple graphs should be

attached as an appendix.

Part III Environmental Management

EMS, SSEMP and work plans. Report on delivery of documents, required amendments etc.

Site Inspections and audits – summarise the number and type of site visits

Non-compliance notices – summarise the details on the number of notices given out and the issues covered.

Summarise the ranking of issues.

Corrective action plans - report on timeliness of preparation and completion

Consultation and complaints – report on any consultation undertaken and list any complaints received.

Annexes: i) Monitoring data, ii) Photographs, iii) Implementation report on EIA/IEE mitigation requirements

Reference Requirement Action to date Action required/comment