City of Bishkek & European Bank for Reconstruction & Development (EBRD) Bishkek Solid Waste Management Project Environmental and Social Action Plan

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1 City of Bishkek & European Bank for Re & Development (EBRD) Bishkek Solid Waste Management Project Environmental and Social Plan ESAP/Final Final 9 November 2016 This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party. Job number Ove Arup & Partners International Ltd The Arup Campus Blythe Gate Blythe Valley Park Solihull B90 8AE United Kingdom

2 Document Verification Job title Job number Document title File reference Document ref Revision Date Filename Bishkek ESAP_26_02_2016.docx Draft 1 26 Feb 2016 Description First draft Name Prepared by Checked by Approved by Olga Skotareva Chris Stocks Colette Curran Signature Draft 2 31 Aug 2016 Filename Description Bishkek SWP ESAP Draft 2_31_08_2016.docx Second draft Prepared by Checked by Approved by Name Olga Skotareva Colette Curran - Signature Final 9 Nov 2016 Filename Description Bishkek SWP ESAP Final_8_11_2016.docx Final Prepared by Checked by Approved by Name Olga Skotareva Colette Curran Helen Davis Signature Issue Document Verification with Document ESAP/Final 9 November 2016

3 City of Bishkek & European Bank for Re & Development (EBRD) Contents Abbreviations 1 1 Introduction Page ESAP/Final 9 November 2016

4 City of Bishkek & European Bank for Re & Development (EBRD) Abbreviations BADS EBRD ESAP ESIA ESMS ESMMP FS KPIs LRP MBT PIU PRs SEP SPV Bishkek Authorised Disposal Site European Bank for Re and Development Environmental and Social Impact Assessment Environmental and Social Management System Environmental and Social Management and Monitoring Plan Feasibility Study (for the proposed Bishkek Solid Waste Management Project) Key Performance Indicators Livelihood Restoration Plan Mechanical Biological Treatment Project Implementation Unit Performance s Stakeholder Engagement Plan Special Purpose Vehicle Bishkek Sanitary Landfill ESAP/Final 9 November 2016 Page 1

5 City of Bishkek & European Bank for Re & Development (EBRD) 1 Introduction The City of Bishkek (the City ) seeks to improve its municipal solid waste ( MSW ) management system and has been working with the European Bank for Re and Development (the EBRD or the Bank ), to invest in a viable development project. The proposed (the Project ) comprises a sovereign loan of EUR 11 million and a grant of EUR 11 million to the Kyrgyz Republic to be on-lent to the City for the benefit of the municipal solid waste management company Tazalyk ( Tazalyk ) and a Special Purpose Vehicle Bishkek Sanitary Landfill (the Company or SPV ). The loan agreement was signed in The Project will priority investments in the waste management segment primarily in waste collection and disposal. The Bank commissioned a Feasibility Study (the FS ) that was completed in 2013, alongside the Environmental and Social Impact Assessment (ESIA) and an (ESAP). The FS determined a priority investment programme (the PIP ), evaluated its benefits, and assessed a proposed site for the new landfill, including assessing its environmental and social impacts. Since then, the City has taken a decision to use a different site for the new landfill to the north of the existing dumpsite, rather than the site assessed in the FS. To the Project, Ove Arup and Partners International Ltd. (the Consultant or Arup ) have been appointed by the City to undertake an Environmental and Social gap analysis for the newly proposed site, and update the necessary technical, environmental, and social studies and plans where practicable. This document provides an updated for mitigation of the environmental and social impacts and to move the Project towards compliance with EBRD s Environmental and Social (E&S) Policy (2014) and its Performance s (PRs). ESAP/Final 9 November 2016 Page 2

6 2 The following environmental and social actions are required to fulfil the requirements of the EBRD s E&S Policy (2014), within the timescale indicated. for discharging ESAP actions will lie with the City of Bishkek ed by the Project Implementation Unit (PIU), Talazyk, Contractor and the Landfill Operator, and will be passed to the relevant sub-contractors, if appropriate. The PIU (with of consultants) will also be responsible for monitoring actions discharged to contractors, and for ensuring completion within the agreed timescale. All actions, documents and plans required by this ESAP will need to be agreed with the Lender. The PIU will be required to report compliance with the ESAP to the EBRD through an Annual Environmental and Social Report (AESR). The AESR template is to be provided by the EBRD. Additionally, compliance with the ESAP will be assured through independent checks and audits undertaken on behalf of the Lenders. When relevant requirements from the ESAP previously developed in 2012 are included in the table below, they are marked as such in column. PR1 Assessment and Management of Environmental and Social (E&S) Impacts and Issues 1.1 Finalise the transfer of land ownership and recategorisation of the proposed site to be appropriate for the Legislative compliance Kyrgyz regulations EBRD PR1 Department of Architecture and Masterplanning of Bishkek City, works Land transfer completed. Documents confirming land ownership are in place. ESAP/Final 9 November 2016 Page 3

7 of a landfill and be under the ownership of the Municipal Council of Bishkek. (Appropriate changes are to be included in the City Masterplan.). PIU 1.2 Obtain necessary, environmental and sanitary permits prior to rehabilitation of the dumpsite, of the new landfill and development of associated sorting and MBT plants as well as additional composting of green waste. Legislative compliance. Kyrgyz regulations EBRD PR1 Contractor works A list of required and obtained approvals and permits is in place alongside the physical evidence of permits obtained. Among others, these to include: (i) formal approval by the Chief Sanitary Officer of the SPZ compliance for the new landfill location; (ii) approval of the State Ecological Expertise for the new landfill location. ESAP/Final 9 November 2016 Page 4

8 1.3 If required for the State Ecological Expertise for the new landfill location, prepare an Addendum to the FS in addition to the prepared updated ESIA documents, and undertake public hearings in accordance with the law. Legislative compliance. Minimise impact on environment and community by identifying and implementing adequate mitigation measures. Kyrgyz regulations PIU with PIU consultants Q works Assessments and documentation required to obtain the State Ecological Expertise for the new landfill location is in place. Evidence of conducted public hearings. Approval by the State Ecological Expertise is in place. 1.4 Secure necessary operational permits and permissions for all new operations. Compliance with local regulations. Local regulations EBRD PR1 PIU with PIU Landfill Operator operation A list of required and obtained permits is in place alongside the physical evidence of permit applications, and permits granted ESAP requirement Conditions of permits incorporated into operational plans and tender requirements. 1.5 Review existing environmental, Health & Safety and social practices to ensure they are fit for purpose and aligned with legal requirements and EBRD standards. Minimise H&S risk to workers. Effective management of environmental and social issues. EBRD PR1, In line with recognised E&S management systems (e.g. ISO and OHSAS 18001). Tazalyk own resources By Q Record of changes implemented as a result of E&S review. Evidence of the E&S review having been undertaken.. ESAP/Final 9 November 2016 Page 5

9 1.6 Develop and implement an E&S Management System. Effective management of environmental and social issues. EBRD PR1, EBRD PR2. EBRD PR4. In line with EBRD PR1, ISO and OHSAS requirements Contractor own resources Develop ESMS 4 months prior to works. ESMS based on the pertinent requirements of ISO14001 and OHSAS in place and operational. Policy, required procedures and plans are in place and implemented. A clear commitment from senior management in the Environmental Policy to ensure adequate resource is provided to enable staff to deliver requirements. An organisational chart clearly shows lines of ESMS responsibility, and reporting. Job descriptions with clear Roles and Responsibilities. Evidence of ESMS monitoring. Evidence of training provided. ESMS Audit Reports. 1.7 Implement the Environmental and Social Management and Monitoring Plan (ESMMP) developed as part of the 2012 ESIA. Minimise impact on environment and community by identifying and implementing adequate mitigation EBRD PR1 Contractor own resources, PIU with PIU consultants As per the ESMMP Plans and procedures required by the ESMMP are in place. Evidence of implementation is in place. Record of monitoring of ESMMP ESAP/Final 9 November 2016 Page 6

10 ESMMP should be seen in conjunction with the Addendum to ESIA prepared by Arup. Should any Project documents be reviewed or any conditions to the Project design and implementation added the ESMMP should be reviewed and amended accordingly. measures. implementation is in place. 1.8 Include appropriate clauses to tender documentation, ESMS and contractor documentation to ensure that national and Lender requirements regarding environmental, social and health and safety are imposed on to the, rehabilitation and, if relevant, operation Minimise impact on environment and community by identifying and implementing adequate mitigation measures. EBRD PR1, Best Practice 1 PIU with PIU consultants, Contractor own resources Relevant contract clauses in tender and contractor-related documentation. 1 The term Best Practice refers to non-legislative procedures and guidelines (may also be legal requirements in other countries) that are internationally recognised and accepted as being correct or most effective. ESAP/Final 9 November 2016 Page 7

11 contractors. Contract clauses for all subcontractors should ensure all relevant management and monitoring requirements included in the ESMMP are binding and enforced. 1.9 Implement actions related to technical requirements for landfill design presented in Appendix A of this ESAP. Safe design, compliance with EU requirements. EBRD PR1, PR3, EU Directives : EU Waste Directive 2008/98/EC, PIU consultants as necessary, Designer, Contractor During design stage and prior to works. Completed design. Record of design checks against actions recommended in technical requirements. Relevant procedures and records of implementation and monitoring are in place. EU Landfill Directive 99/31/EC, EU Industrial Emissions Directive (integrated pollution prevention and control) 2010/75/EU. ESAP/Final 9 November 2016 Page 8

12 1.10 Develop and implement a system of waste transfer and acceptance recording allowing information on the waste collected and received at the landfill to be gathered and reported. Effective system of waste transfer and acceptance. Minimise impact on environment. EBRD PR 1 EBRD PR 3 EU Waste Directive 2008/98/EC, EU Landfill Directive 99/31/EC Contractor own resources, Landfill Operator start of operation A system is in place. Reports on waste collected and received As a part of ESMMP, develop landfill environmental monitoring system including additional groundwater monitoring. The information collected should be in line with the recording and monitoring requirements of the EU Waste and Landfill Directives. Prevent environmental pollution incidents and accidents EBRD PR1, EBRD PR3, EU Waste Directive 2008/98/EC, EU Landfill Directive 99/31/EC PIU consultant operation Environmental monitoring plan is in place. Records of monitoring Develop and implement an Operational Management Plan (OMP) and procedures for its implementation. Effective and compliant management Clear operational procedures enable EBRD PR1 Best Practice Landfill Operator operation. Draft OMP and Operation manuals and plans and procedures completed. Manual and plans linked to job descriptions and necessary training 2012 ESAP requirement ESAP/Final 9 November 2016 Page 9

13 individual staff members to deliver good quality work and achieve desired goals for a new system with limited environmental and social impacts. requirements Document and rank existing waste collection points for improvement measures. Identify new collection points in areas not served at present. Development of improvement plan for collection points in the city and monitoring system Development of maintenance and replacement plan for containers and collection points. Effective waste collection system Reduce waste deposits around collection bins and in other nondesignated locations in the city Best Practice Tazalyk.own resources with PIU consultant as necessary. Commence immediately, Develop by end of Initial assessment of priority sites for investment in new containers and repair work completed. Annual report assessing status of sites and maintenance work undertaken. Quarterly report of inspections, and complaints, if relevant ESAP requirement 1.14 Develop and implement Mitigation of. PIU own Preliminary Draft Draft Plan is in place. ESAP/Final 9 November 2016 Page 10

14 landfill closure plan for the proposed landfill. Disclose the Plan publicly and to local community prior to implementation. landfill closure and impacts on local environmental and communities. resources during operation, ing consultant if necessary. Landfill Operator. to be developed no later than 1 year prior to closure. Final version no later than 6 months prior to closure. Final Plan is in place and disclosed for comments. Evidence of implementation. PR2 Labour and Working Conditions 2.1 Ensure appropriate human resources management system is in place, including procedures and processes related to human resource policies and procedures, non-employee workers, worker grievance mechanism, security personnel and supply chain. Management of human resources in accordance with the law and best practice EBRD PR2 Kyrgyz regulations (Kyrgyz Labour Code etc.) Contractor, PIU consultants Landfill Operator works. Evidence of Human Resources system is in place, i.e. relevant policies, procedures, assigned staff, etc. Human Resources and/or procurement procedures with respect to non-employee workers, worker grievance mechanism, security personnel and supply chain. 2.2 Incorporate provisions for working conditions compliant with national laws and EBRD requirements in tender documentation and contracts for contractors and Risk management and ensuring adequate labour conditions of contractors and EBRD PR 2, Best Practice Tazalyk, Landfill Operator and Contractor with PIU consultants as works. Tender documentation and contractual clauses contain requirements for operating health and safety management system, compliance with requirements on child labour, forced labour, ESAP/Final 9 November 2016 Page 11

15 suppliers. Undertake periodic internal labour conditions checks and audits against EBRD s. suppliers. necessary provision of equal opportunities, Kyrgyz Labour Code etc. Records of compliance checks of contractors and suppliers. 2.3 Review salary scales against job requirements. PIU to collect baseline information on conditions and salary levels of workers in comparable industries in public sector. PIU consultant and Tazalyk to review salary scales required for staffing needs. Ensuring salaries reflect experience and responsibility and are at the level satisfying average living standards to discourage personnel from undertaking waste unauthorised recycling activities. Ensure that there is no discrimination regarding gender, i.e. equal pay for work of equal value. PIU with of PIU consultants, HR department of Tazalyk. operation of the new landfill. PIU, Tazalyk to collate data before Q Evidence of analysis of salaries which considers gender differences and avoids discrimination. Job descriptions at the new landfill complex are attached to a salary scale. Evidence of completed reviews by company directors ESAP requirement 2.4 Include equal opportunity recruitment policy for staff and contract conditions for sub-contractors; and training Promote and facilitate equal opportunities (e.g. diversity and Best Practice PIU with PIU Landfill Operator By end 2016 for Tazalyk. The Equal Opportunity Policy is developed. The Policy as well as job advertisements, job descriptions for 2012 ESAP requirement ESAP/Final 9 November 2016 Page 12

16 for HR personnel on procedures to implement the policy. gender equality) and relevant technical skill mix in each of management, contract management and operational roles. and Tazalyk top management and HR. (Development of policy and procedures undertaken as part of Technical Assistance from EBRD Phase 3 prior to tendering as it forms part of the tender documentation. BADS rehabilitation. all personnel, and contract conditions for sub-contractors clearly state commitment to ensuring the equal opportunity. Recruitment procedures include relevant clauses. Relevant training undertaken. Job descriptions are developed. Annual report showing staffing levels demonstrating gender equality, diversity in relation to remuneration and recruiting. Initial Training modules are to be delivered using EBRD Phase 3 budget.) 2.5 As a part of HR MS, develop and implement a worker Grievance Mechanism (GM) available to direct employees and nonemployee workers during BADS rehabilitation, Project Management of worker relationships. EBRD PR 2 PIU Landfill Operator and Contractor. and reorganisation works on Project. Grievance mechanism procedure is developed. Records of grievances and their resolution are maintained and reported to management. Records of communication with Labour Union, where relevant. ESAP/Final 9 November 2016 Page 13

17 and operation. GM is communicated to subcontractor employees. Records are in place. 2.6 If a dedicated worker accommodation is required during phase, arrange its facilities in accordance with legal requirements and a guidance note by IFC and the EBRD. Ensuring adequate accommodation for workers. Kyrgyz regulations, EBRD PR2, Workers' accommodatio n: processes and standards - a guidance note by IFC and the EBRD 2 Contractor the use of worker accommodation Evidence of assessment in accordance with the EBRD/IFC guidance note. Respective regulatory approvals. PR3 Resource Efficiency and Pollution Prevention and Control 3.1 Implement pollution prevention measures described in the ESMMP (covering air emissions, noise pollution, dust, waste water, hazardous substance Effective environmental management. Minimise impact on environment, local community, and EBRD PR 3, EU Industrial Emissions Directive (integrated pollution Contractor, works The reviewed ESMMP is approved and implemented. All sub-plans, Procedures and Protocols required by the ESMMP are in place. Record of checks on implementation 2 ESAP/Final 9 November 2016 Page 14

18 and materials, pesticide use and management). workers. prevention and control) 2010/75/EU, (for example Inspections, Audits reports). 3.2 Develop and implement BADS Rehabilitation Plan, showing final profiles to shed surface water. Develop and implement technical specifications for final capping of BADS. Rehabilitation plan to include: Develop and implement Leachate Management Plan. Develop and implement Leachate and Water monitoring programme. Effective BADS rehabilitation, leachate and surface water management. EBRD PR3, EU Landfill Directive 99/31/EC, consultant. BADS Rehabilitation Plan showing final contours required to achieve these. Technical specifications for BADS capping (after reaching new profiles). Leachate and Surface Water Management Plan is in place. Leachate and Water Monitoring programme is in place. Water quality monitoring reports. Number of overflow discharges to river meeting discharge consent standards ESAP requirement 3.3 Develop specifications for landfill gas management system for BADS and new landfill. The system should include: Minimise risk of incidents and accidents related to gas emission, and gas migration. EBRD PR3, EU Landfill Directive 99/31/EC Contractor, Landfill Operator Landfill gas collection system installed and connected to flarestack. Monthly gas monitoring results, and record of actions taken in response ESAP requirement ESAP/Final 9 November 2016 Page 15

19 Sealed cells in the new landfill with gas migration layer under the seal; Porous layer beneath final restoration soils in rehabilitated landfill. Install gas collection system according to the specification. Monitor gas emissions at frequency required by developed specification. 3.4 Develop and implement fungal spores control plan to reduce its spreading from MBT plant and from new composting plants for green waste in the town. The plan should include, among others, monitoring programme, and requirements: To make appropriate Minimise risk of health impacts on workers and community. EBRD PR 3, UK Best Practice, Directive 2000/54/EC - biological agents at work Contractor Fungal spores control plan is in place Transmission bunds are constructed and maintained Results of monitoring programme, and record of action undertaken (if relevant). All operational phase actions to be part of the detailed Operational Management Plan 2012 ESAP requirement ESAP/Final 9 November 2016 Page 16

20 dust masks available for site workers. To locate windrows more than 300 metres from residential areas with soil bunds or maturation heaps to form barrier to transmission. To dampen windrows in dry weather. 3.5 Develop and implement pesticide control programme, including monitoring requirements for and operational phase. Ensure that there is compaction of waste in old and new landfill areas to limit availability of burrows for rats and snakes and that all wastes are covered with a metre of other waste or soils within one week to prevent hatching of fly larvae. Minimise risk of spreading diseases. Reduce risk of pests dispersing into the city during the and rehabilitation works. EBRD PR 3, Directive 2009/128/EC, Directive 2012/18/EU Landfill Operator. and operation phases. Pest control programme in place Quarterly review of complaints Monitoring results and record of action undertaken (if relevant) Number of sites with traps or baits for rats ESAP requirement ESAP/Final 9 November 2016 Page 17

21 3.6 Implement bird control measures at new sorting, MBT and landfill facilities. Reduce health impact on local community relating to pathogens transferred by birds. EBRD PR 3, consultant through procurement contract. Upon completion of of sorting and MBT plant Procurement contract includes requirement for netting the new windrows of high organic waste until degradation is well advanced to control birds ESAP requirement Landfill Operator. Netting are installed prior to operation. 3.7 As a part of Operational Management Plan, develop procedures for water management and cleaning process of MBT and the sorting plant(s). To ensure these procedures are implemented, include relevant requirements for sump installed at the sorting/mbt site and pumping system, hoses and sprays to enable cleaning of the hardstanding and spraying the windrows in the procurement contracts. Maintenance of the effective degradation process consultant through procurement contract. Landfill Operator. operation Relevant requirements included in the procurement contracts. Relevant procedures are in place and implemented. Procedures to include requirement for regular cleaning and spraying and to monitor water levels in the sump and top up as necessary. Sump and pump system installed prior to operation Record kept of water levels in sump ESAP requirement ESAP/Final 9 November 2016 Page 18

22 PR4 Health and Safety 4.1 Appoint Health and Safety personnel proportionately to the scope and scale of works within the Project. Effective management of occupational H&S issues Best Practice, EBRD PR1, EBRD PR2. EBRD PR4. Tazalyk, Landfill Operator, Contractor and consultant. first disbursement List of H&S personnel, including their qualification, and job description. 4.2 Ensure OHS management system applies to the works of their sub-contractors by incorporating health and safety provisions in tendering documentation and contracts for contractors and suppliers. Effective management of occupational H&S issues Best Practice, EBRD PR1, EBRD PR2. EBRD PR4. Tazalyk, Landfill Operator, Contractor and consultant. works commencing Tender documents include relevant requirements relating to provision of OHS management system. Relevant clauses in the contracts with contractors and suppliers. 4.3 Develop and implement maintenance programme for waste collection points. Reduce nuisance and risk of safety incidents to residents and users at waste collection points. EBRD PR4, Best Practice Developed and implemented by Tazalyk Sanitary Ecological Inspectorate to monitor During operation Maintenance programme is developed, included in the annual budget and implemented ESAP requirement ESAP/Final 9 November 2016 Page 19

23 implementation. 4.4 As a part of ESMS establish and implement noise monitoring requirements and mitigation measures to control noise problems relating to collection system and to operations at the landfill complex including noise and noise through rehabilitation of the old landfill. Mitigation measures to include: Time restriction for noisy activities during and operation Location of permanent sources of noise to be as far away from residential areas as possible (sorting plant, composting plant, gas flare, site entrance area with weighbridge and Compliance with local and EU regulation Minimise risk of grievances. Kyrgyz regulations, EU Directive 2002/49/EC (EU Noise Directive), EBRD PR3, EBRD PR 4 Contractor, Tazalyk, Landfill Operator. Mitigation measures and monitoring requirements are identified prior to works. Implementation during the whole and operational phase. Limited monitoring programme during pre phase to establish background concentrations Mitigation measures included in the ESMMP. Record of monitoring. Record of grievances ESAP requirement ESAP/Final 9 November 2016 Page 20

24 wheel cleaner); Noise screening bunds and screen planting to be planned in advance of the installation of equipment. 4.5 Develop and implement programme to identify sources of special and hazardous municipal waste and arrange future separate collection system. Effective pollution prevention. Minimise impact of exposure to hazardous substance by community. EBRD PR3 EBRD PR4 Contractor, Landfill Operator. Upon introduction of a new waste system. Sources of hazardous waste are identified by inspectors. Amount of this waste is quantified, and arrangements for collection are in place ESAP requirement 4.6 Develop a detailed traffic management plan (CTMP). Construction arrangement should ensure that the passing of vehicles through informal settlements is avoided. Management of EHS risks to workers, road users and communities from traffic. Local regulations,, EBRD PR 2, EBRD PR 4. Contractor works. The CTMP is in place, approved by the respective authority, appropriately disclosed and implemented. Evidence of relevant information being distributed to the drivers. Evidence of relevant information being distributed to the community. Evidence of internal inspections checking implementation. 4.7 Develop and implement safety and security Management of EHS risks during EBRD PR 4, PIU Relevant procedures are in place and implemented. ESAP/Final 9 November 2016 Page 21

25 procedures for s and phased access to the BADS by waste pickers during its rehabilitation, including fencing. BADS rehabilitation and security during. (e.g. Voluntary Principles on Security and Human rights: luntaryprincipl es.org/ ) Contractor and rehabilitation works. Record of monitoring / checks carried out. 4.8 Develop Emergency Preparedness and Response Plan for Project and operation. Contractor should obtain approvals from respective authority and emergency services. Engage affected communities and agencies about these plans and any subsequent changes made to these. Minimise impact on workers, community and environment arising from emergency situations. EBRD PR4, the Contractor, Landfill Operator. work Emergency Preparedness and Response Plan in place and implemented. Record of consultation with local authorities. Record of approvals by the respective authority. Record of information provided to the community. Record of drills Follow design specification to ensure that all equipment as well as the landfill infrastructure will be designed to meet Kyrgyz Compliance with EU and Kyrgyz standards EBRD PR4, Kyrgyz regulations, EU Waste Directive PIU with PIU consultant to arrange for competent design checkers. Design phase Record of design checks. Record of approvals from local regulators. Issuance of permits. ESAP/Final 9 November 2016 Page 22

26 and EU Standards. 2008/98/EC, This should include considerations of seismicity of the area. EU Landfill Directive 99/31/EC, EU Industrial Emissions Directive (integrated pollution prevention and control) 2010/75/EU, PR5 Land Acquisition, Involuntary Resettlement and Economic Displacement 5.1 Through the Detailed Project Design, avoid the potential for resettlement impact from and operation of the access road, if feasible. Should this not be possible, prepare and implement a Resettlement Plan (RAP) and conduct stakeholder engagement for PAPs in Mitigation of resettlement impacts EBRD PR 5 Designer (detailed design), Contractor Detailed design phase Design drawings demonstrating that resettlement is avoided. Developed RAP (if impact is unavoidable) and evidence of its communication/disclosure and its implementation. Communication records (if relevant). ESAP/Final 9 November 2016 Page 23

27 accordance with the Project Resettlement Framework. 5.2 In case of any additional land acquisition and access needs (permanent or temporary) for the Project, undertake assessment of land acquisition and resettlement impacts and be compliant with resettlement principles set in EBRD PR5. Assessment and mitigation of land acquisition, resettlement impacts. EBRD PR 5 Contractor, consultant On-going before/during Details of affected land or access (e.g. cadastral records). Communication records. Transfer, approval, permit records. Assessment/survey and inclusion into the LRP or RAP, or development of an addendum to LRP/RAP. Records of mitigation/implementation. 5.3 Review if residents of the dormitory may face any impacts following the detailed design specifications, particularly in terms of access to their living areas, or in relation to project activities. Establish the residents socio-economic profile and vulnerability in relation to above issues. Mitigation of livelihood impact Mitigation of major health risks from /rehabil itation activities. EBRD PR 5 EBRD PR 10 consultant 3-4 Q 2016 Survey records. Records of assessment and mitigation measures if such are necessary. Appropriate clauses in a Construction Management Plans and health and safety management procedures. Communication and grievance records, including with PAPs. ESAP/Final 9 November 2016 Page 24

28 5.4 Update the LRP once the assessment and socioeconomic survey of waste pickers is complete to include: (i) provision of training to waste pickers related to accessing finance and business advice to establish SMEs, with a particular focus on such training and programmes tailored for women and young people; Mitigation of livelihood impact and build positive and effective relationship with PAPs. 3Q 2016 Updated LRP inclusive of specified provisions. Reviewed specific stakeholder engagement plan. (ii) updated stakeholder engagement and grievance mechanism for PAPs (considering the updated SEP); 5.5 Implement the updated LRP. Mitigation of livelihood impact. Compliance with the EBRD requirements. EBRD PR5 Contractor and relevant City Departments. first disbursement and as per agreed implementation schedule (scheduled from 4Q 2016.) Updated implementation programme. Developed/reviewed implementation targets and KPIs, budget, resources and responsibilities. Stakeholder engagement log. ESAP/Final 9 November 2016 Page 25

29 Grievance/feedback records. 5.6 Implement monitoring and evaluation provisions of the updated LRP, including independent completion audit and monitoring of stakeholder engagement activities. Effective implementation of the LRP. EBRD PR 5 Independent relevant City Departments as necessary. As per agreed Monitoring and evaluation schedule. Monitoring schedule. Monitoring reports. Mid-term evaluation report (if deemed appropriate). Completion Audit report. PR6 Biodiversity and Living Natural Resources 6.1 Consult with ecologist on the best measures to mitigate impacts on migratory birds, should there be a potential for impacts, and include them in the ESMMP. Protect nesting colony of bee eaters at North east corner of current dumpsite. EBRD PR6 consultant Mitigation measures identified prior to works. If applicable, detailed mitigation measures included in the ESMMP and operation stage plans and demonstrable evidence of their implementation ESAP requirement Implementation throughout and operation. 6.2 When possible enhance biodiversity, through planting and restoration Increase biodiversity values in the area EBRD PR6 The Restoration Plan is prepared prior to Detailed planting / restoration Plan is in place, and includes measures to enhance biodiversity in the area ESAP requirement ESAP/Final 9 November 2016 Page 26

30 schemes. Consult with the ecologist about the proposed solutions. Consider inclusion in the Restoration Plan a high proportion of local vascular plants to enhance the river corridor and increase biodiversity. relevant City Departments work. PR7 PR8 Indigenous People NOT APPLICABLE Cultural Heritage 8.1 Implement archaeological survey requirements of ESMMP. Any findings of this survey will need to be appropriately recorded, reported and further action completed. Adequate and effective management of archaeological and cultural heritage issues. EBRD PR8 Contractor works Record of surveys undertaken. Archaeological finds report (if relevant) Implementation of findings (if relevant) 8.2 Obtain community feedback on any areas of cultural value within the Project Adequate and effective management of EBRD PR8 consultant Record of communication with community. Information obtained from the ESAP/Final 9 November 2016 Page 27

31 area, in conjunction with the recommended archaeological survey or as part of the socio-economic survey for the LRP. archaeological and cultural heritage issues. works community is adequately interpreted by the expert, and when relevant survey requirement are amended. 8.3 Obtain confirmation from the Ministry of Culture confirming that there is no known cultural heritage on the new landfill location. Adequate and effective management of archaeological and cultural heritage issues. EBRD PR8 PIU works Written record of confirmation from the Ministry of Culture. 8.4 Develop and implement a Chance Finds Procedure, in coordination with appropriate authority. Adequate Management of accidental archaeological finds. EBRD PR 8. Contractor and Landfill subcontractor. Procedure is developed prior to works. Chance Finds Procedure is in place. Annual report of any archaeological finds. Implementation during. PR 10 Information Disclosure and Stakeholder Engagement 10.1 Implement the updated SEP. Ensure its regular review and update. Compliance with the EBRD requirements. EBRD PR 10 consultants, Once approved, then on-going. Communication log. Updated information on the website. ESAP/Final 9 November 2016 Page 28

32 Proactive stakeholder engagement. Relevant City Departments, Contractor. Update on SEP implementation in the Annual Environmental and Social Report. Up-to-date SEP Establish and implement a public grievance mechanism in compliance with the EBRD and best practice requirements. Proactive stakeholder engagement and management of impacts to public. EBRD PR 10, Best Practice Contractor and sub-contractors, consultant. Establish prior to activities/ operations. Implementation is on-going Evidence of grievance mechanism is approved. Contractor: GM procedure is disseminated to PAPs. PIU: GM procedure is publicly available. Workers are trained on how to handle/pass public grievances. Grievance records. ESAP/Final 9 November 2016 Page 29

33 ESAP/Final 9 November 2016

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