E810 October 2002 ISLAMIC REPUBLIC OF IRAN. Urban Upgrading and Housing Reform Program. Environmental Management Plan (EMP) A.

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized A. BACKGROUND 1. Introduction ISLAMIC REPUBLIC OF IRAN Urban Upgrading and Housing Reform Program Environmental Management Plan (EMP) E810 October 2002 The proposed Urban Upgrading and Housing Reform Program (UULRP) aims at supporting the government's effort in the housing sector in (a) narrowing the gap in the living conditions between formal and informal settlements with in the capital cities in Iran; and in (b) improving the performance of the housing sector through a long-term program of investment and capacity-building. The UUHRP is composed of three phases of four years duration for a total period of 12 years. 2. Investment Components (A) (B) Phase I of the program will consist of the following two main components: Urban Upgrading and Commuinity Enabling: this Component lays the foundations for launching and sustaining a countrywide community enabling and slum upgrading program. This will be accomplished through: (a) Urban upgrading in participating municipalities consisting of: (i) rehabilitation of roads sidewalks, drainage and street lighting, (ii) rehabilitation of local powver and water distribution networks, (iii) rehabilitation of public building and community civic facilities (schools, clinics, community centers, neighborhoods markets) and, (iv) limited extension of municipal and community infrastructure when deemed essential and within existing public rights of way and approved land use plans; (b) Studies for the preparation of community enabling and urban & institutional upgrading programs; (c) Institutional building in participating municipalities; and (d) Community enabling in participating municipalities. Capacity Building for National Housing Strategy: this component will help implement the Housing Sector Strategy and Action Plans (finance, subsidies, construction, land management, and national upgrading strategy). Technical assistance (TA) and capacity building would be provided to enhance housing affordability and the efficient functioning of housing markets. 3. Institutional Arrangement The Ministry of Housing and Urban Development (MHUD) would be responsible for the overall execution, financial management and coordination of the program. It will rely on a Project Management Unit (PMU), and two Technical Units TUA and TUB to be created and housed at 1~~~~~~~~~~~~~~~ t~~~~~~~~~~~~~~~~~~~~~~~''

2 MHUD, UDRO, and NHC. The division of responsibilities between PMU and the technical units will be as follows: PMU will be responsible for the overall monitoring of the program under the oversight of the ISC. It will submit to the Bank bi-annual investment programs and quarterly progress reports. TUA will be responsible for the day today monitoring of the community enabling and substandard settlement upgrading component and submitting quarterly progress reports to the PMU. TUB will likewise be responsible for the housing reform component. The TUA shall ensure that: * Environmental considerations are included as criteria for selecting activities to be supported by the program; * Environmental assessment would become an integral part of the project cycle of any project; * Environmental guidelines are followed and used. Component A will be implemented by the municipalities and the Provincial Housing and Urban Development Organizations (PHUDOs) benefiting from the proposed Program. The municipalities and PHUDOs will identify local needs in close coordination with local communities, prepare a program consisting of a number of projects, coordinate with concerned ministries, and implement the program. The municipalities and the PHUDOs will ensure the following: * Environmental guidelines are followed and used through out the project cycle; * Environmental issues are introduced to beneficiaries through education and promotion of environmentally beneficial subprojects. * Environmental screening is properly undertaken; * Potential environmental impact associated with each proposed project are adequately identified through site visits; * Mitigation measures during construction and operation are identified; * Environmental management plans are implemented. 4. Environmental Category and Issues Phase-I of the proposed program would contribute to the improvement of the urban environment through rehabilitation of roads, drainage, street lighting, schools, clinics, community centers, water supply and sanitation systems in poor urban settlements. The specific projects will be defined during the course of the program. Potential adverse environmental impacts during construction and operation are expected to be localized and limited in magnitude and severity. The program will not fund any projects that would require resettlement, deforestation, or would adversely affect natural habitats, biodiversity, and cultural heritage sites. Accordingly, Phase-I of the proposed program has been placed in "Category B" in accordance with World Bank Operational Policy (OP 4.01) on Environmental Assessment (January 1999). Although the UUHRP is expected to bring significant environmental and health benefits and no major environmental issues are anticipated, certain projects to be funded under the program may require special mitigation measures to protect the environment and enhance health safety. Environmental guidelines to be used for the various types of projects will be prepared and will enable the identification of all environmental concerns prior to the implementation of each city program through the development of an environmental assessment report that would include 2

3 an EMP consisting of mitigation activities and monitoring procedures for the various projects to be funded under the city program. Phase-II and Phase-III may include investments with more significant environmental impacts, therefore, the environmental category and requirements will be re-assessed during the appraisal of both subsequent phases. 5. Legal and Regulatory Framework for Environmental Assessment Environmental Impact Assessment (EIA) in Iran was enabled by Note 82 of the Law for the Second State Economical, Social and Cultural Development Plan of 1994, amended by Note 105 of the Third Development Plan. The ELA was approved by the Environmental High Council (EHC) through Decree 138 of 12/04/1994. Detailed requirements were then defined in the Code of Practice of 23/12/1997. The EHC has defined seventeen project types subject to EIA, seven in Decree 138, with a further 10 added in EHC may also require an EIA for any other large project. Screening thresholds for the first seven classified types are defined in the 1997 Code of Practice, together with the requirements for the pattern of the assessment. The competent body for EIA as defined in Decree 138 is the Iranian Department of Environment (DOE), under the authority of the Environmental High Council. The Council is composed of senior representatives of government ministries, senior academics and advisers to the Iranian government. The DOE also has offices in each province with at least one member of professional staff who contributes to EIA at the screening stage. Apart from the EIA, there exist a wide range of regulations regarding environmental protection including the Environmental Protection Act of 1974 and its executive by-law dated 1975, the Clean Water Act of 1982 amended in 1994 and the executive by-law on the prevention of water pollution (1994), the Air Pollution Abatement Act of 1995 and its executive by-law dated 1997, the Game and Fish law of 1957 with subsequent amendments made on 1975 and The Department of Environment has also issue a number of standards including: (i) airborne noise pollution standards, (ii) ambient air standards, (iii) exhaust emission standards, (iv) emission standards for factories and workshops and (v) effluent standards. In addition, the Government of the Islamic Republic of Iran has ratified a number of international conventions for Environmental Protection and natural resources conservation including: Convention on Wetlands of International Importance (Ramsar 1971), International Convention on World Heritage Protection (1972), Convention on International Trade in Endangered Species of Wild Fauna and Flora (1973), Vienna Convention for the Protection of the Ozone Layer (1987), Montreal Protocol for the Protection of the Ozone layer (1987), Basel Convention on the Control of Hazardous Wastes and their Disposal (1989), International Convention on Salvage (1989), UN Framework Convention on Climate Change (1992), Convention on Biological Diversity (Rio 1992), Desertification Convention (Paris 1994). 6. Assessment of Environmental Capacities Since its creation in 1997, UDRO has implemented a large number of residential, commercial and cultural projects in the various provinces of the country. In addition UDRO is actively involved in the renovation and restoration of historic places and houses within the country. UDRO implements its projects in close coordination with various public and private organizations. For instance, the renovation of historic places is conducted in close coordination with the Ministry of Cultural Heritage and Islamic Guidance. Furthermore, all projects designed 3

4 by UDRO are discussed, reviewed and approved by a national committee which includes: Ministry of Housing and Urban Development, Ministry of Interior, Ministry of Agriculture, Management and Planning Organization and Mayor of the city. However, UDRO has yet to develop capacities in EA and establish a close coordination mechanism with the DOE. During the implementation of the UUHRP, UDRO's environmental capacities will be strengthened and a coordination mechanism between UDRO and DOE will be established and will cover the various project stages. Environmental awareness is present among the municipalities who according to the Municipality Law of 1965 as amended in 1973 have several environmental mandates such as air pollution, solid wastes collection and disposal, water pollution, noise, etc. However, municipalities do not have environmental specialists within their staff members and it would be necessary to provide them with technical assistance with respect to environmental matters. The Department of Environment (DOE) has established an EIA Bureau under a Director General. The Bureau has limited staff in the national office of Tehran, not all of whom are professionally qualified. Significant implementation of EIA began in 1998; so far several projects have been subject to environmental assessment according to the Iranian legislation. A very small number of donor-funded projects have been undertaken in the country, and there has been little involvement of international organizations in commissioning and approving EIA studies. Few staff members of the DOE have participated at regional EA training workshops organized by the METAP project. Under the Mediterranean Environmental Technical Assistance Program (METAP), the World Bank has financed an assessment of the EIA System in Iran. Among the main findings of this assessment are: (i) a single category of ELA is defined for large projects, broadly equivalent to the World Bank's Category A, without provisions for less intensive studies equivalent to the World Bank's Category B, (ii) evaluation of alternative designs to minimize negative environmental impacts are not evident, (iii) provision for environmental management plans or implementation of monitoring is not clearly defined, and (iv) public participation in the various EA stages is not spelled out. Consultancy firms have limited capacities to carry out full EIA studies of high quality. Most EIA studies are undertaken by individual consultants based in universities or other institutions with the assistance of international specialists. Several academic bodies are beginning to establish a framework capable of supporting more thorough EIA studies. The Iranian Society for Scientists and Engineers has established an EIA section and most Iranian universities now include EIA as a module in their environmental courses. Under the UNDP capacity strengthening project, around 850 persons from various governmental departments, NGOs and the private sector have been trained in EIA across the country. These activities can be expected to have created a fairly wide understanding of the basic principles of EIA. Further strengthening of the national EIA capacities will be achieved through the implementation of the U1HRP and other World Bank projects that are under preparation such as the Water and Sanitation Project and the Environmental Management Support Program. 7. Environmental Review of Subprojects Funded by UUHRP Zahedan has been identified as the first city with four categories of neighborhoods for upgrading. An operating model is being developed in Zahedan and will be replicated in other cities. A rapid environmental review including field visits was conducted to assess impacts that might arise from potential projects that would require funding in Zahedan. The priority program in Zahedan includes roads, drainage, street lighting, small schools, cultural facilities and health centers. None of the proposed projects would have major irreversible environmental impacts; on 4

5 the contrary all projects would contribute to positive environmental impacts. However the cumulative impacts from these projects might be considerable if environmental considerations within each project are not properly addressed. As the projects to be funded by the UUIHRP were not identified prior to appraisal and since these will be demand driven based on needs, the following illegibility criteria and environmental requirements will be observed during the implementation of the program: (i) Projects that can have considerable irreversible negative impacts will not be approved for funding and would include: * Roads on slopes greater than 40%; * Projects requiring deforestation; * Projects adversely affecting natural habitats and biodiversity; * Projects that would have a negative impact on cultural heritage sites. (ii) Depending on the magnitude and the extent of the environmental impacts, the following projects would require an environmental assessment report to be prepared according to the terms of reference (TOR) provided in the environmental guidelines manual: * Wastewater schemes; * Water storage and treatment facility * Roads with more than one kilometer length; * Projects adjacent to critical natural habitats or protected areas; In addition and whenever, the extension of municipal and community infrastructure would necessitate the construction of new schools, clinics or community centers, then the siting of the facility and the physical and sanitary conditions of the selected site will be evaluated according to the details provided in the environmental guidelines manual. (iii) Projects with minor environmental impacts would require the implementation of an environmental management plan (EMP) according to the typical examples provided in the environmental guidelines manual include: * Rehabilitation and upgrading of schools * Rehabilitation and upgrading of clinics * Rehabilitation of roads and drainage * Community potable water supply networks * Rehabilitation of wastewater schemes An environmental assessment report will be prepared for each city's program taking into consideration the above environmental requirements and following the environmental guidelines that will be incorporated in the Operational Manual. In view of the limited environmental capacities within UDRO and the municipalities, the PMU will seek the services of an environmental/safeguards consultant, who will be in-charge of the following: * Reviewing the environmental screening of the subprojects included in the city program; 5

6 * Reviewing and approving the environmental assessment submitted by the consultant; * Conducting periodic monitoring of the projects; * Obtaining the required approvals * Preparing annual report of the environmental situation of the Program. In addition for each city's program an environmental consultant /firm will be hired to undertake the following tasks: * conduct screening and scoping for the various projects included in the program; * prepare an environmental assessment report based on the findings of the screening and following the environmental guidelines; * Supervise the implementation of the environmental management plan (EMP). The environmental assessment report of the programs to be funded in phase I will be subject to review and approval by the World Bank. In parallel, training workshops will be conducted to strengthen national capacities for reviewing and approving environmental assessment reports. During the mid-term review, the World Bank will re-assess capacities for reviewing and approving EAs and will agree with concerned authorities on the process to be adopted for approving EAs. Periodical monitoring of projects will be conducted by PMU to ensure compliance with submitted monitoring plan. Moreover, monitoring and evaluation of projects will be conducted by a local or an international consultant during the midterm review and at the end of the first phase. B. ENVIRONMENTAL MANAGEMENT PLAN (EMP) 8. Objectives and Structure of the EMP The objectives of the EMP are to mitigate the adverse environmental impacts identified in each project. The implementation of the EMP will improve the quality of projects and will ensure the participation of concerned stakeholders. The EMP will consist of three kinds of activities: * Implementation of mitigation measures; * Strengthening the capacities of UDRO, municipalities, DOE regional offices, local communities and contractors; * Monitoring and evaluation of mitigation measures identified during project formulation or within the environmental assessment report. The activities included in the EMP apply to Phase 1 of the program and will be reviewed during the preparation of Phases II and III. 9. Implementation of Mitigation Measures Mitigation measures identified following desk/or field review shall be properly implemented. Typical environmental impacts and possible mitigation measures are given in 6

7 Table I for guidance. Municipalities will be required to adapt mitigation measures for the various projects to be executed. Table 1: Potential Environmental Impacts and Proposed Mitigation Measures for Different Projects Project Potential Impacts Mitigation Measures Responsibility Roads rehabilitation * Clogging of natural * Maintain ditches Contractor drainage channels * Poor storm water drainage * Provide drainage facilities Municipality /contractor * Encroachment on private * Detailed property Contractor/ property boundary surveys and Municipality flagging in field * Dumping of construction * Proper disposal of Contractor wastes and accidental construction wastes spills of machine fuels, etc. * Risk of damage to * Use "chance find" Municipality unknown archaeological procedures and coordinate /Archeology department sites with appropriate Increased noise level in government agency * Increased nolse level m * Plant trees along road Municipality city sides /community * Deterioration of air quality * Implement dust control due to construction dust measures such as wetting of dirt roads Improvements to Water * Cross contamination sewage * Coordinate with appropriate Water and Wastewater Supply and Wastewater and water lines due to agency Company pressure differentials and leaks * Reduction in water * Review of the water balance Water and Wastewater availability to other of the area Company consumers * Improper disposal of * Proper disposal of Contractor construction debns construction wastes * Destruction of historical sites * Use chance find procedures Municipality/ Archeology * Risk of damage to and coordinate with department archaeological sites appropriate agency * Pollution of water courses Municipality/ community * Rehabilitation or provision of new wastewater facility Construction/Rehabilitation * Inadequate site location * Obtain land ownership status Municipality/ community of schools * Ensure that site and school are part of the urban planning and land use scheme * Avoid encroachment / reduction of green areas * Avoid sites prone to flooding or provide appropriate site design measures * Ensure availability and possibility of providing basic infrastructure such as access roads, electricity, water 7

8 supply and sewage * Avoid sites prone to earthquakes or ensure appropriate engineering for seismic resistance * Ensure provision of adequate water quality and quantity * Priority given to rehabilitation * Poor water supply and of toilets sanitation conditions * Installation of sanitation (cesspools) * Proper disposal of solid wastes * Adequate engineering design to avoid odor, contamination of underground water, etc... Construction / Rehabilitation Similar to those encountered with w Containerize infectious of clinics schools in addition to: wastes * Improper disposal of medical wastes.. ~~~* Public health awareness Ministry of Health Construction mitigation measures will be required to minimize inconveniences to the public. Environment-protection provisions for civil works contract documents will be developed in the environmental guideline manual and will be adopted and applied to all projects. 10. Training Program and Capacity Building Environmental expertise within the implementing and executing bodies will be strengthened. Training programs will designed and implemented with the assistance of local or international experts and will target three levels: (i) PMU, municipalities and line ministries: At the initiation of the UtlHRP, a one day workshop will be provided to the staff of the PMU, municipalities and line ministries to raise environmental awareness and to clarify the specific environmental requirements related to design and implementation of the UUHRP. (ii) PMU technical specialists, DOE and national environment consultants: A three days workshop will then be provided to the PMU environmental specialist, DOE and national environmental consultants and will cover the following topics: * EIA techniques * Screening projects for environmental review * Use of practical checklists * Best environmental practices in design and implementation of projects * Effective implementation of mitigation measures * Project supervision 8

9 * Monitoring and evaluation (iii) Local NGOs, Communities and Contractors: Workshops for local NGOs, communities and contractors, focusing on public awareness, case studies of environmental issues experienced in similar projects, use of environmental guidelines and implementation of mitigation measures. 11. Environmental Monitoring Environmental Monitoring will be the responsibility of the municipalities in close coordination with the relevant authorities and will include: * Compliance monitoring during construction * Monitoring of significant impacts during the operation of the subprojects. The PMU environmental specialist will also conduct periodic monitoring by visiting the sites of the various projects at least once a year. Monitoring indicators shall be developed for both the construction and the operation phase of the projects. Monitoring of construction activities will have to ensure that mitigation measures of construction impacts are being implemented properly, while the monitoring of operation is to ensure that no unforeseen negative impacts are arising. Typical examples of monitoring plans are given in Table2. Table 2: Typical Examples of Monitoring Plan for the Operation of Different Projects Project Monitoring Indicators Responsibility Frequency Roads rehabilitation * Drainage channels clean and * Municipalities in close Semi-annual properly maintained coordination with local assessment community Improvements to Water * Distribution network * Water and Wastewater Company Semi-annual Supply and Sanitation without leaks in close coordination with assessment Facilities * No leakage or overflows of municipality and local community manholes or drains * Ministry of Health and Water and Wastewater Company * Water Quality Monitoring Semi-annual assessment Rehabilitation of * Toilet facilities clean and * Municipalities in close Semi-annual schools functioning properly coordination with local assessment * Drinking water faucets clean community and safe from contamination * Adequate quantity and quality of water supply * Municipalities in close Semi-annual coordination with water and assessment wastewater company * Medical wastes separated in Rehabilitation of clinics proper containers * Ministry of Health in close Semi-annual * Availability of guidelines coordination with local assessment for proper disposal of community medical wastes 12. Cost Estimates An estimated amount of US$ 300k will be allocated for meeting the environmental requirements of the UUHRP - Phase I as detailed in the Table below. 9

10 Cost Estimates Component Qty Unit Rate Total Cost in Thousands USS US$ Proiect Management TUA Environmental/safeguards specialist 48 MM 1500/month 72 Assessment of major environmental issues in 28 cities lump-sum 60 Evaluation of Investment Programs 4 MM 2000/month 8 Preparation of Fact Find Procedures for the protection of lump-sum 5 Archeological and Historical sites Environmental Assessment of Phase 11 and updating of lump-sum 25 environmental management guidelines Subtotal 170 EA Preparation/Supervision Environment consultants for preparing and supervising EA 6 cities 8000/city 48 of city's program Subtotal 48 Capacity Building and Training Workshops: PMIU, municipalities, line miniistries and regional organizations: - One day workshop on the use and application of environmental guidelines manual 5 workshops 2000/workshop 10 -Three days workshop Local NGOs, communuities and Contractors: - Awareness workshop for Local NGOs, Communities and 3 workshops 5000/workshop 15 Contractors 5 workshops 5000/workshop Subtotal 12 Operation materials and supplies Monitoring and Evaluation 2MM 5000/month TOTAL I) TUA environmental/safeguards Sc edule of Implem ntation Year I Year 2 Year 3 Year 4 specialist 2) Assessment of major environmental issues in 28 cities 3) Preparation of Fact Find Procedures 4) Consultants to prepare - _ and supervise EA 5) Training _ - PMU/Municipalities _ - - use and application of manual - Awareness workshops for local NGOs,. _. _ communities and contractors 6) Monitoring and evaluation at the program_ level 7) Environmental Assessment of Phase II. - 10