Bi-annual Environmental Monitoring Report

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1 Bi-annual Environmental Monitoring Report Bi annual Report September 2018 PAK: Flood Emergency Reconstruction and Resilience Project Punjab Communication and Works (C&W) Component Prepared by Punjab Communication & Works (C&W) Department for the Asian Development Bank

2 The Bi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB s Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the terms of use section of the ADB website. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgements as to the legal or other status of any territory or area.

3 Bi-Annual Environmental Monitoring Report Project Number: Pakistan Flood Emergency Reconstruction & Rehabilitation Project (FERRP) Punjab Component Reporting Period: January June 2018 Prepared by Communication & Works Department (C&W) - Punjab for the Asian Development Bank (ADB)

4 Table of Content PART I Background Details of Sub-Projects Project Organization and Environmental Management Team Relationship with the Contractor and the Engineer 10 PART II 11 ENVIRONMENTAL MONITORING Environmental Monitoring Summary Monthly Due Diligence Monitoring Air Quality Health & Safety aspects Noise Ground Water Flora and Fauna Top Soil Erosion Cultural Heritage Sites Waste Disposal 13 PART III Field Visits to the construction sites Trainings Follow up Audits 16 3

5 3.1.4 Safety Provisions EMP Compliance Checklist Conclusions and Recommendations 16 Annexures Annexure I Non-compliances observed during sub-project Works Annexure II Sample Monitoring Sheet List of Tables Table 1.1: Details of Sub-projects under Punjab Component... 7 List of Figures Figure 1.1: Organizational Chart for Implementation of Environmental Management 9 4

6 Acronyms CURRENCY EQUIVALENTS As of 12 th August 2018 Currency Unit Pak Rupees (Pak Rs.) Pak Rs 1.00 = $ US$1.00 = Pak Rs. 120 ADB FERRP C&W SPS EMP GoP IEE NEQS RoW PIU Asian Development Bank Flood Emergency Reconstruction and Resilience Project Communication and Works Safeguard Policy Statement Environmental Management Plan Government of Pakistan Initial Environmental Examination National Environmental Quality Standards Right of Way Project Implementation Unit 5

7 1.0 Background PART I INTRODUCTION 1. Since September 2014, heavy monsoon rains and raised water levels in major rivers across Pakistan have claimed the lives of hundreds of people. In Punjab, the 2014 floods claimed around 300 lives. Furthermore, more than 83,000 houses were damaged in the province and around 3,000 villages, with around 1 million acres of cropland, were affected. The 2014 flood resulted in approximately $ million in reconstruction costs of damage to infrastructure in the social and economic sectors of Punjab province, of which over 75% represents damage to the road and irrigation sectors. 2. The Asian Development Bank (ADB) is supporting the efforts of the Government of Pakistan (GoP) for rehabilitation and reconstruction of infrastructure in the sectors of transport (primarily roads and bridges) under the Punjab C&W component. The assistance will be provided through the Flood Reconstruction and Resilience Project. ADB support will be provided for the rehabilitation and reconstruction of damaged roads and bridges. 3. This document is the bi-annual Environmental Monitoring Report (BAEMR) for the period from January to June 2018 for the road sub-projects across Punjab province being constructed under the Punjab component of FERRP. 4. Each road and bridge sub-project was categorized using Rapid Environmental Assessment (REA) Checklists provided in the ADB s Environmental Assessment and Review Framework (EARF). All sub-projects were categorized as C using REA Checklists with the exception of the Daska-Pasrur and Pasrur-Narowal road sub-projects, which were categorized as B due to considerable scale and scope of these two subprojects. No sub-projects were assessed to be Category A. All environmental due diligence documents for the sub-projects were disclosed on the ADB website as soon as they were ready for disclosure. 5. Only two road sub-projects (Daska-Pasrur and Pasrur-Narowal) are still being undertaken while all remaining sub-projects have been completed. REA checklists were completed for each sub-project and the projects were accordingly categorized. The EMP for each subproject was prepared and included in the relevant bidding documents (BOQ). Environmental approvals were obtained from ADB as well as from the Punjab EPA, being the national environmental regulatory authority. 6. Environmental due diligence visits were conducted by the ADB TA Consultant for the subprojects on a weekly basis to assess the level of compliance with the EMP of each subproject activity and to advise necessary corrective measures to the project Contractor. The Project Management Consultant (PMC) and C&W Punjab are responsible for the environmental monitoring of the sub-projects, however they engaged no environmental staff and the only focal point providing inputs relating to environmental safeguard issues was the TA Consultant. 6

8 7. As part of the environmental monitoring support being provided by ADB, a generic environmental monitoring checklist was prepared by the TA consultant and was provided on site to the PIU, PMC and Contractor staff. The checklist was based on the EMP that was developed for each sub-project. However, apart from the TA Consultant for Environment, there has been no focal point for environmental safeguards from the PMC. Also, the Contractor engaged a focal person for Environmental safeguards a few months ago, although this person has minimal experience and is not well equipped to ensure implementation of the EMP. 8. The TA Consultant has also developed and provided to the Contractor a customized form for obtaining the approval of any location for installation of a batching or asphalt plant. Only once the Contractor provided the complete information for each proposed site, the TA Consultant conducted a due diligence visit and based on the findings of the visit and consultations with the key receptors and local communities in the area, it was decided whether to allow installation of the plant at the proposed site or to advise an alternate site to be proposed. 1.1 Details of Sub-Projects 9. The road sub-projects still under construction under the Punjab component are provided in Table 1.1 below. These two sub-projects are presently under progress with a revised expected date of completion of December Table 1.1: Details of Sub-projects under Punjab Component S/No. Sub-project Name Sub-Project Length (km) Completion Status Road Sub-project 1 Daska-Pasrur road Ongoing (46% physical progress) 2 Pasrur-Narowal road 28 Ongoing (46.5% physical progress) 1.2 Project Organization and Environmental Management Team 10. Punjab C&W is the implementation Agency (IA) for reconstruction of roads and bridges under this project. The basic purpose of the IA is to ensure that the implementation of environmental safeguards and monitoring requirements for FERRP according to the Environmental Assessment and Review Framework (EARF) is carried out. 11. The objective of the EARF is to establish systems and functions that ensure that conditionality is built into each initiative at its design stage in a manner that through reconstruction and rehabilitation, improved and environmentally sustainable structures are built that have improved resistance to natural calamities (such as floods). The conditions stated in the EARF are in line with the ADB SPS 2009 and have been mentioned to ensure 7

9 inclusion of environmental mitigation measures in the proposed developmental activity and to ensure their integration and inclusion in the contract document. 12. The Punjab C&W had established an Environmental and Social Unit (ESU) that was made responsible for environmental and social review based on the selection criteria, preparation, submission, implementation and environmental management & monitoring and evaluation of all the sub-projects. ADB had provided technical support to ESU by providing an Environment and a Social specialist under the Technical Assistance (TA). The TA Environment Specialist has been responsible for explaining policy requirements to ESU, supporting them to meet these requirements, building capacity and monitoring implementation of agreed safeguards. 13. Furthermore, the IA had engaged a Project Management Consultant (PMC) team to strengthen their supervisory capacity, design monitoring and construction supervision services. 14. The PMC had established their offices at each construction site, wherever the Contractor was mobilized. No Environment Specialist (ES) has been engaged by the PMC to date. Both the PIU and the PMC have been solely dependent on the TA Consultants for Environment and Social safeguards for conducting due diligence visits on intermittent basis to the different project sites to assess compliance with the EMP. 8

10 Figure 1.1: Organizational Chart for Implementation of Environmental Management Plan Punjab C&W Implementing Agency (IA) Asian Development Bank (ADB) Project Implementation Unit (PIU) TA Environment Consultant TA Social Safeguard Specialist DO and Design Administration Project Management Consultant Environment and Social Unit (ESU) Resident Engineer of PMC Supporting Staff 9

11 1.3 Relationship with the Contractor and the Engineer 15. A good relationship was observed between Punjab C&W (Implementation Agency), Consultant and Contractor. The Resident Engineer (RE) is the focal person from PMC while the Project Director (PD) from PIU on behalf of Punjab C&W is overall in charge of the entire component. 16. A good working relationship has been maintained so far between the Contractor and the PMC during the execution of each sub-project. During the work site inspection visits, areas of improvement as per standard procedure were mutually discussed with Contractor s representatives and the Contractor was made to rectify any non-compliance issues. 17. The Contractors working on the different sub-projects have generally been observed to possess limited capacities to implement environmental and social safeguards as required by the EMP and ADB SPS However, the Contractor management and staff have been willing to a certain extent to receive and implement any guidance and instructions provided to them by the PMC and TA Consultants. 10

12 PART II ENVIRONMENTAL MONITORING 2.1 Environmental Monitoring Summary 18. Environmental monitoring has been carried out by TA Consultants on a weekly basis using EMP compliance checklists as well as through visual observations to obtain information on the actual nature and extent of key impacts and the effectiveness of mitigation and enhancement measures outlined in the Environmental Management Plans (EMPs) as agreed by the Contractors under their respective contracts. The EMP compliance checklists cover all the aspects mentioned in the sub-project EMPs. 19. The monitoring of different environmental parameters such as air quality, health and safety aspects, noise, surface and groundwater, flora and fauna, top soil erosion, cultural heritage and safety provisions are discussed in this section. The sub-projects were subjected to environmental due diligence audits and inspections to assess EMP compliance and to assess whether any potential negative impacts have resulted from the construction activities in the sub-project areas. 2.2 Monthly Due Diligence Monitoring 20. The Contractors have not been conducting any environmental or social safeguards monitoring using their own staff. In fact, based on repeated insistence and through pressurizing the PIU, the Contractor has a few months ago, engaged an Environmental focal point. However, the Contractor working on these two road sub-projects lacks the awareness and motivation to proactively ensure implementation of environmental safeguards. 21. It should be mentioned that although the Contractor engaged an independent laboratory for monitoring of ambient air quality and noise levels along these two road sub-projects, however this laboratory was not accredited by the Punjab EPA and the monitoring was not conducted as per standard protocols and thus the results were not acceptable. 22. The TA Consultant identified the monitoring locations along the corridor to the Contractor. However, the results of this monitoring have yet to be received from the Contractor and in fact it remains unclear whether this latest monitoring activity has even been conducted till now or not. 23. In such a situation, the TA Consultant has been the only focal point for ensuring safeguards monitoring with weekly due diligence visits being conducted by the Environmental specialist with the report being submitted to ADB and the findings being shared with the PIU for necessary actions. 11

13 2.2.1 Air Quality 24. Potential sources of air pollution during construction were the kick-off dust, asphalt plant, crusher and the movement of dumper trucks transporting construction related material. 25. Water sprinkling in areas vulnerable to dust was visually observed and wherever clouds of dust were observed along different sub-project corridors, it was ensured that the sprinkling frequency was increased. The TA consultant (environment specialist) ensured that the dust should be reduced to minimum possible levels so that it may not affect the workers and the surrounding environment, including the local communities. 26. It should be mentioned that as the asphalting of roads has proceeded along the project corridors, the dust emissions have also been reducing considerably Health & Safety aspects 27. During the due diligence visits, the TA consultant repeatedly observed that the Contractor staff was not implementing the health and safety (H&S) related aspects of the EMP. The key H&S issues which were conveyed to the PIU, PMC and Contractor staff consisted of the following issues: Protective equipment (PPEs) not being used by labor staff Lack of use of safety signboards, safety cones, fluorescent tape, speed limit boards etc. Traffic flow management to prevent accidents by regulating traffic flow Underage labor being employed It was ensured that the Contractor staff implemented all necessary corrective measures relating to H&S aspects as required in the EMP for each sub-project Noise 28. During visits to the sub-project sites, no significant non-compliance issues with regards to high noise levels were observed. No complaints from workers and public were registered during this reporting period. The Contractor was advised to provide workers with proper safety equipment e.g. air plugs and air muffs during working hours to avoid any harm to their hearing ability although the laborers have yet to be observed using the PPEs Ground Water 29. Construction activities have the potential to cause damage to surface and ground water resources. Ground water on sites (where civil work was carried out) was duly monitored and 12

14 found satisfactory. It was also ensured that construction activities near any water bodies should not contaminate the ground water sources. The implementation of the mitigation measures as per EMP were monitored and assessed in the field visits and during the environmental audits Flora and Fauna 30. The implementation of the provisions in the EMP to prevent damage to flora and fauna was defined and mitigation measures were recommended. No mortality of animals was reported during the reporting period. Since both the road sub-projects involve rehabilitation activities along the existing alignments, thus the potential of damage to flora is quite low. 31. The TA consultant (Environment specialist) has been ensuring the compliance of the EMP through weekly site visits with the EMP compliance checklist being duly filled and used in preparation of the due diligence report to ADB project focal points. The PMC has also been strictly advised to ensure the Contractor does not cause any damage to the flora and fauna of the project area and to ensure redressal measures by the Contractor if any noncompliance does take place Top Soil Erosion 32. Borrow areas were visited during the due diligence visits to the sub-project sites in order to assess any potential damage and evaluate the efficacy of the mitigation measures applied for restoration. During the visits and audits, the replenishment of topsoil at borrow sites was ensured. 33. All borrow pits were restored to their natural land profile. The Contractor was also advised to make satisfactory arrangements in the form of restoring borrow land areas or providing compensation to landowners. No observations were made regarding any damage caused by borrow pits and waste material to the sub-project areas Cultural Heritage Sites 34. All sub-projects have involved rehabilitation of the existing roads and thus the TA Environment Specialist has observed during his visits to the different sub-project sites that no cultural heritage sites/wetland/protected area/mangrove/estuarine lie in the RoW of the subproject areas Waste Disposal 13

15 35. Waste from construction and campsite is being disposed away from the populated areas as per the EMP. In certain locations, solid waste was observed lying near the roads and so the TA consultant advised the concerned Contractors to remove and dispose of the waste material in the designated areas. 14

16 PART III ENVIRONMENTAL MANAGEMENT 3.1 Due Diligence Reviews (DDR) 36. Due diligence reviews were conducted by the TA Consultant for Environment on a weekly basis. The Initial IEE reports (IEE) and corresponding Environmental Management Plans (EMPs) for each sub-project were reviewed and referred to as felt necessary and subsequently field visits were carried out Field Visits to the construction sites 37. The field visits to the different sub-project sites were conducted along with the PIU and PMC focal staff and consultations were held with the Contractor s representatives. Visual observations and photographs were obtained during the field visits. Key findings were discussed with the concerned engineering staff and the Contractor. 38. Upon completion of these visits, DDRs were generated on the basis of observations made, clearly stating the non-compliances and the corrective actions required to be immediately taken. 39. In general, it was concluded that the project construction activities have not caused any significant and irreversible environmental impacts during this reporting period. Wherever environmental issues were observed during the visits by the TA Consultant, they were brought to the notice of the PIU for ensuring implementation of necessary corrective measures by the Contractor. 40. In order to ensure safety aspects from both community as well as labor perspectives were addressed, at the areas where safety signs were absent, the Contractors were made to agree to arrange them immediately Trainings The TA consultant was required to provide assistance with respect to the improvement in capability of Punjab C&W and contractors. The TA consultant provided trainings on the following aspects: Trainings and awareness sessions on usefulness of PPEs Trainings on EMP implementation to Punjab C&W, PMC and Contractor staff 15

17 3.1.3 Follow up Audits In case of any adverse findings, the TA consultant carried out follow up visits to verify the efficacy of corrective and mitigation measures. In case repeated non-compliances were observed, harsh warnings with the threat of fines being imposed were clearly conveyed to the Contractor Safety Provisions 41. During project sites visits, TA environment specialist monitored the safety requirements during road construction. Road safety was considered to be the most serious concern along the roads especially broken culverts, road cuts, depressions and eroded road shoulders etc., which may have lead to any serious accident. Many safety lapses were observed and communicated to the Contractors. The Contractors were advised to take road safety as top priority and place safety signs (Safety cautions, Safety cones, Safety tapes etc.). 42. The EMP clearly states the health and safety related measures including use of PPEs by all site staff. However, on subsequent visits, the workers were found to not be using them. The issue was seriously taken up with the Contractor and PMC. The Contractor was advised to provide proper PPEs to their staff. However, no accident at any sub-project was reported during the reporting period EMP Compliance Checklist 43. The TA consultant developed a checklist to list down all possible impacts that may arise during the sub-project construction activities. This checklist was developed to monitor weekly environmental compliance of the two road sub-projects and was based on the mitigation measures provided in the EMP Conclusions and Recommendations 44. Overall, the project compliance during this period is not satisfactory and efforts by both the PMC and TA Consultant need to continue to ensure a higher level of pro-activeness from the Contractor to fulfill the safeguard requirements as per EMP. At present, it is repeatedly felt that if the TA Consultant and ADB staff is not constantly pushing and pressuring the PIU with regards to EMP implementation, the PMC and Contractor are not too concerned about working proactively to identify non-compliances and rectifying them. 45. Furthermore, even when any non-compliance was identified, it was not taken up 16

18 seriously and instead repeated reminders were needed to ensure the required corrective measures would be implemented. 46. Certain significant non-compliances did take place, although no complaints were received under the GRM, which was mainly due to the due diligence visits being conducted by the ADB TA consultants who continued to highlight any non-compliance(s) and ensured their redressal. The presence of TA consultants in the safeguard team enhanced the project acceptability among all project focal points due to their impartial advisory position. 47. The following recommendations are proposed based on the project activities conducted during this reporting period: i. Presence of the TA consultants (Environment and Social) played an important role in the safeguard compliance; due-diligence visits (audits and visits) played an important role in the implementation of ADB safeguards, which ultimately forced project implementers to comply with the safeguard standards. The presence of these consultants ensured that the focus of the project focal points did not only remain on completion of civil works but to also ensure compliance with ADB safeguard requirements. ii. PIU, PMC and Contractor staff benefited from the ADB s inputs and guidance with regards to ensuring the safeguards requirements were met and resulted in the project works being conducted in the most efficient and effective manner possible while ensuring protection of both the environment and social aspects. iii. Follow-up audits and visits played an important role in verification of corrective and mitigation measures if any non-compliance was observed. This also ensured that all project focal points were kept on their toes and were made to realize the importance to ADB of ensuring safeguards compliance during all project works. iv. The TA consultant delivered onsite trainings on safety and environmental requirements, which made quite an impact to the different Contractors and their staff in enhancing their understanding regarding the importance of safeguards and compliance. v. The sub-project works completed thus far on all the projects have not reported any significantly adverse or irreversible environmental impacts. This is a positive achievement as it would also benefit the future projects and enhance acceptability among stakeholders for the ADB funded projects. vi. Contractors were advised to take road safety as a top priority; place safety signs (Safety cautions, Safety cones, Safety tapes etc.). Continuous monitoring in this regard is required. 17

19 vii. Majority of the Contractor site staff is not using PPEs despite repeated instructions to both PMC and Contractor staff to ensure their use. Efforts will need to continue to ensure use of PPEs by the site staff. viii. Piling of raw material such as coarse aggregate, cement etc. along the project corridor and thus further hampering the passage of traffic must be prevented. ix. Traffic management and safety (community and labor) must remain the top most priority along the different sub-project sites and continuous monitoring is required in this regard. x. The non-conformances detected during visits were reflected in the due diligence reports. Some of the identified issues were addressed immediately or during the time period set for improvement while certain non-conformances were improved partially with commitments agreed upon and corrective measures verified through subsequent visits. 18

20 ANNEXURES 19

21 ANNEXURE-I Non-Compliances observed during Sub-Project Works Photographs of Sub Projects 10

22 Photographs of Sub Projects 10

23 Photographs of Sub Projects 10

24 Photographs of Sub Projects 10

25 Photographs of Sub Projects 10

26 Photographs of Sub Projects 10

27 Photographs of Sub Projects 10

28 ANNEXURE-II Sample Monitoring Sheet Photographs of Sub Projects 10

29 Flood Emergency Reconstruction and Resilience Project (C&W Punjab Component) TA 8912 (PAK) Date of Monitoring Visit: 16 th May, 2018 Monitoring sheet Daska-Pasrur road sub-project Sr. No. Key issues Compliance Status Comments 1. Air Quality (Dust Emissions) 2. HSE issues Compliant Non- Compliant Water sprinkling observed on limited locations along the project corridor, which is resulting in high levels of dust in the air. Use of PPEs The Contractor staff was not observed to be using any personal protective equipment (PPEs). Safety signboards Signboards were not observed on the work sites along the corridor to warn incoming traffic. Warning tapes No warning tapes were observed to be in use to segregate the work sites from the traffic corridor. 3. Traffic Management No traffic issues observed during the visit. 4. Dumping of Materials at unauthorized sites, blocking traffic No surplus material dumped at sites along the project corridor. 5. Use of Child Labor No child labor observed taking part in road construction activities during the due diligence visit. 6. Monitoring (Ambient air quality & Noise) by independent laboratory 7. Submission of monthly Environmental compliance monitoring reports to PIU Ambient air quality monitoring was conducted in the month of February. The results were unacceptable as noise monitoring was not conducted and the monitoring did not meet the requirements as per EMP. This monitoring as per recommended protocols has not been conducted till now. Monthly Environmental compliance monitoring report was submitted in the month of February to the PIU but, its report has not been provided by the Environmental Focal person to date. Also, no subsequent monitoring report has been submitted by the Contractor. Photographs of Sub Projects 10