Technical Assistance Consultant s Report. REG: Improving the Implementation of Environmental Safeguards in Central and West Asia

Transcription

1 Technical Assistance Consultant s Report Project Number: October 2014 REG: Improving the Implementation of Environmental Safeguards in Central and West Asia Environmental Safeguards Training Consultant and Third Party Auditor - Pakistan Final Report (Environmental Audit of Projects) Prepared by For Asian Development ank This consultant s report does not necessarily reflect the views of AD or the Government concerned, and AD and the Government cannot be held liable for its contents.

2 for Improving Implementation of Environmental Safeguards in Pakistan Final Report HP Ref.: R4AR2IEE October 24, 2014 Asian Development ank (AD) Manila, Phillipines

3 Improving Implementation of Environmental Safeguards in Pakistan Contents 1. Introduction ackground Purpose and Objectives Environmental Audit Scope Ongoing Projects Audit Aproach and Management Aproach and Methdology Pre Audit Visit Tasks Audit Visit Post Visit Tasks Roles and Responsibilities Environmental Audits General Audit Findings Environmental Documentation of the Loan Agreement Tenders and Contracts Project Environmental Unit Project Environmental Documentation On-site Handling of Hazardous Substances Occupational Health and Safety Environmental Monitoring Land Acquisition and Resettlement Issues Sensitivity to Social Issues Staff Training and Capacity uilding Restoration of Construction Camps Recommendations R4AR2IEE: 10/24/14 Contents ii

4 Improving Implementation of Environmental Safeguards in Pakistan Exhibits Exhibit 1.1: Location of Environmental Audited Projects in Pakistan Exhibit 1.2: Inventory of Ongoing AD Projects in Pakistan Exhibit 1.3: List of s Exhibit 2.1: Inventory of Environmental Audit Visit R4AR2IEE: 10/24/14 Exhibits iii

5 Improving Implementation of Environmental Safeguards in Pakistan 1. Introduction The Asian Development ank (AD) aims to improve the implementation of environmental safeguards in Central and West Asia. Personnel from various countries in the Central and West Asian region have been trained to conduct training sessions and environmental audits, per AD standards, of specified projects. Through the engagement of an Environmental Safeguards Training Consultant and Third Party Auditor (the Project), the AD intends to strengthen the capacity of the executing and implementation agencies in the region to improve environmental management and monitoring. A consolidated report on trainings part under the Project has been submitted to AD separately (HP Ref.: R4TL2IIE). This report covers the findings from environmental audits conducted on active projects funded by AD in Pakistan. 1.1 ackground AD helps developing member countries (DMCs) to strengthen their safeguard systems and develop their capacity to address environmental and social issues in development projects. Since the approval of the Safeguard Policy Statement (SPS) in 2009, AD has been providing technical assistance to help strengthen the legal and institutional framework for effectively implementing safeguards. The Safeguard Policy Statement (SPS) 1 of the Asian Development ank introduces a new emphasis on the effective implementation of environmental safeguards. The SPS contains a number of operational principles which include the requirement to ensure that the measures identified during impact assessment are included in the project environmental management plan (EMP), and are implemented in agreement with the borrower. SPS also recognizes that this is not always achieved at the project level and states that while procedural compliance has improved over time, the substantive aspects of compliance integration of findings and recommendations of environmental assessment into project design, borrower/client ownership of EMPs, and effective implementation of EMPs remain challenging. Work undertaken by AD's Central and West Asia Department (CWRD) highlighted a number of deficiencies preventing effective implementation of environmental safeguards. Foremost among the challenges is insufficient capacity in executing agencies to prepare, implement, and monitor the implementation of EMPs. The lack of effective implementation means that there is a credible risk that projects are not in compliance with the SPS. RETA 7548 aims to strengthen the capacity of the executing and implementing agencies in the region to improve environment and monitoring. The project is being implemented in ten countries of Central and West Asia including Afghanistan, Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Pakistan, 1 AD Safeguard Policy Statement, Manila. Introduction R4AR2IEE: 10/24/14 1-1

6 Improving Implementation of Environmental Safeguards in Pakistan Tajikistan, Turkmenistan, and Uzbekistan. In Afghanistan and Pakistan the project is being implemented by. This report covers only Pakistan. 1.2 Purpose and Objectives The purpose of the Project is to strengthen the environmental management and monitoring capability of executing agencies and project implementing organizations, as well as construction contractors and supervision consultants, in the country. To achieve this objective, HP provided services for training to relevant staff and personnel and environmental audits on the selected projects to ensure that the environmental staff within project implementation units (PIUs), contractor companies and consultants develop an adequate capability for the preparation, adoption and implementation of project EMPs. 1.3 Environmental Audit Scope The audit covered the environmental status of the potential negative impacts of the construction phase of the project cycle and not the impacts of the project overall. The audit visit covered document review, waste management, environmental monitoring parameters if any for noise, water quality, air etc., and review of the existing site conditions and OHS practices. The scope broadly covers the survey of the project location, associated facilities and review of the documents prepared to cover the following stages of the construction phase; Loan, Tenders and Contracts Environmental Team, Role and Responsibilities Identification of Construction Impacts, Risk Assessments of the Impacts and Remediation Measures Preparation of Site-specific Environmental Management Plans (SEMP) Implementation- Waste Management, Reporting and Audits 1.4 Ongoing Projects Initially, a list of on-going projects with information on focal contact from Implementing Agency (IA)/ Executing Agency (EA) was obtained from AD s Pakistan Resident Mission (PRM). The projects are spread over country-wide. A generic location on the country s map is provided in Exhibit 1.1 and listed in Exhibit 1.2. In the received list, the majority of the projects were in execution phase. There were also few project were included which are currently in bidding phase. The environmental audit has been conducted on the projects that were in execution phase. A separate environmental audit report was prepared for the each project and submitted to AD. Information on these reports is presented in Exhibit 1.3. Introduction R4AR2IEE: 10/24/14 1-2

7 Improving Implementation of Environmental Safeguards in Pakistan Exhibit 1.1: Location of Environmental Audited Projects in Pakistan Introduction R4AR2IEE: 10/24/14 1-3

8 Improving Implementation of Environmental Safeguards in Pakistan Exhibit 1.2: Inventory of Ongoing AD Projects in Pakistan Country Division Project No. Loan /Grant No. Project Name Milestone Dates Classification Executing Agency Approval Effectively Closing Environment Implementing Agency Focal Person for RETA Phone PAK CWEN L2286/2287 Renewable Energy Dev't Sector Prog - Project I AED Pakhtunkhwa Hydropower Development Organization (PHYDO) - for KP component Wajid Nawaz Khan (Project Director(PD) Ranolia HPP) Zahid Sabri (PD Machai HPP) wajidnawaz63@ yahoo.com zasabri@hotmail.com ; Dec Nov Jun-14 Punjab Energy Department - for Punjab component Liaqat Iqbal (PD) pdppmu@gmail. com PAK CWEN Renewable Energy Dev't Sector Prog - Project III Water and Power Dept., G idding statge Hussain Shigri (PD Shagharthang HPP) Nazakbar Shah (PD Thak Chilas HPP) abdul.khaliqpd@ gmail.com ; ; PAK CWEN L2396 Power Transmission Enhancement Program - Tranche 2 17-Dec Apr Dec-13 National Transmissio n and Despatch Company (NTDC) NTDC Khalid Mahmood (Manager Environment & Social Impact Cell) murshad2007@ yahoo.com (Ext. 2141) PAK CWEN L2846 Power Transmission Enhancement Program - Tranche 3 22-Dec Feb Jun-16 NTDC NTDC idding statge Khalid Mahmood (Manager Environment & Social Impact Cell) murshad2007@ yahoo.com (Ext. 2141) Introduction R4AR2IEE: 10/24/14 1-4

9 Improving Implementation of Environmental Safeguards in Pakistan Country Division Project No. Loan /Grant No. Project Name Milestone Dates Classification Executing Agency Approval Effectively Closing Environment Implementing Agency Focal Person for RETA Phone PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Pakistan Electric Power Company (PEPCO) Islamabad Electric Supply Company (IESCO) Mohd. Imran, Asst. Manager (Environment) iescopmu@hot mail.com, mrnmalak@yah oo.com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 PESCO Masood Shah, Asst. Manager (Environment) masudshah82@ yahoo.com pmupesco@yah oo.com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Lahore Electric Supply Company (LESCO) Mohd. Usman Cheema, Dep. Manager (Environment & Social) uniqueromi@ya hoo.com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Gujranwala Electric Power Company (GEPCO) Fahim Aslam, Asst. Manager (Environment.) fahimkh2000@y ahoo.com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Multan Electric Power Company MEPCO Asif Riaz, Asst. Manager (Environment) envsco@yahoo. com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Faisalabad Electric Power Company (FESCO) Mohd. Sharif Malik, Additional Manager (Env. & Safeguard) cedevfesco@ya hoo.com Introduction R4AR2IEE: 10/24/14 1-5

10 Improving Implementation of Environmental Safeguards in Pakistan Country Division Project No. Loan /Grant No. Project Name Milestone Dates Classification Executing Agency Approval Effectively Closing Environment Implementing Agency Focal Person for RETA Phone PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Hyderabad Electric Power Company (HESCO) Asif Shiraz, Dep. Manager (Environment. & Safeguard) snoopy_ @yahoo.com, cedevhesco@g mail.com PAK CWEN L2727 MFF-Power Distribution Enhancement Program, Tranche 2 14-Dec-10 5-Oct Sep-15 Quetta Electric Power Company (QESCO) Syed Qutub udin, Asst. Manager (Environment.) engrqutub@hotmail. com, qescocedev@ya hoo.com PAK CWEN L2972 MFF: Power Distribution Enhancement Program-Project 3 14-Dec-12 NYE 31-Dec-16 PEPCO DISCOs as for Tranche 2 (listed above) idding statge Same as for Tranche 2 PAK CWEN L2552/2553 MFF - Energy Efficiency Program - Tranche 1 22-Sep Aug Mar-17 Planning Commission - PMO Project Management Units (PMU) in 8 Distribution companies (DISCOs) and Karachi Electric Power Company (KESC) No environment component in Tranche 1 PAK CWER (SF) Sindh Coastal Community Development (Project ended) 15-Jan Feb Jun-13 Introduction R4AR2IEE: 10/24/14 1-6

11 Improving Implementation of Environmental Safeguards in Pakistan Country Division Project No. Loan /Grant No. Project Name Milestone Dates Classification Executing Agency Approval Effectively Closing Environment Implementing Agency Focal Person for RETA Phone PAK CWER L2299/2300 Punjab Irrigated Agriculture Program - Tranche 1: Lower ari Doab Canal Improvement 18-Dec Aug Sep-15 Punjab Irrigation Department (PID) PMO (LDC) Zahoor Ahmed (Director Environment. & Social Safeguard) PAK CWER L2841 Punjab Irrigated Agriculture Sector Development - Tranche 2 22-Dec Feb Dec-16 Punjab Irrigation Department (PID) Same as for Tranche 1 Same as for Tranche 1 PAK CWER L2971 MFF Punjab Irrigated Agriculture Program, Tranche 3 13-Dec-12 NYE 31-Mar-17 Punjab Irrigation Department (PD) Same as for Tranche 1 idding statge Same as for Tranche 1 PAK CWTC L2540 National Highway Development Sector Program - Tranche 2 26-Aug Sep Dec-13 A National Highway Authority (NHA) Fasiah Mumtaz Malik, Deputy. Director Environment PAK CWTC L-2400 National Trade Corridor Highway Program - Tranche 1 17-Dec Jun-14 A NHA Fasiah Mumtaz Malik, Deputy. Director Environment PAK CWUW L2499 Sindh Cities Improvement Inv Program - Tranche 1 19-Dec-08 6-Mar Dec-13 Sindh P&DD North Sindh Urban Services Corporation Limited (NSUSC) Attaullah Athar, Environment. Safeguard Specialist attalangah@hot mail.com Introduction R4AR2IEE: 10/24/14 1-7

12 Improving Implementation of Environmental Safeguards in Pakistan Country Division Project No. Loan /Grant No. Project Name Milestone Dates Classification Executing Agency Approval Effectively Closing Environment Implementing Agency Focal Person for RETA Phone PAK CWUW L2975/2976 Sindh Cities Improvement Inv Program - Tranche 2 18-Dec-12 NYE 31-Aug-17 A Sindh P&DD NSUSC Same as for Tranche 1 Same as for Tranche 1 PAK PRM L2742/2743 Flood Emergency Reconstruction Project 31-Mar May Sep-14 Sindh P&DD NHA (for national roads component) Fasiah Mumtaz Malik, Deputy. Director Environment Introduction R4AR2IEE: 10/24/14 1-8

13 for Improving Implementation of Environmental Safeguards in Pakistan Exhibit 1.3: List of s No. Loan Project Sub-project Name HP Report Reference/Comment 1 National Trade Corridor Highway Program Tranche -1 ( ) 2 Sindh Cities Improvement Program-Tranche 1 ( ) 3 Power Distribution Enhancement Program- Tranche 2 ( ) 4 National Highway Development Sector Program- Tranche 2 ( ) 5 Flood Emergency Reconstruction Project ( ) 6 Flood Emergency Reconstruction Project ( ) 7 Flood Emergency Reconstruction Project ( ) 8 National Highway Development Sector Program- Tranche 2 ( ) 9 Power Distribution Enhancement Program- Tranche 2 ( ) 10 Power Distribution Enhancement Program- Tranche 2 ( ) 11 Power Distribution Enhancement Program- Tranche 2 ( ) 12 Power Transmission Enhancement Program- Tranche 2 ( ) 13 Punjab Irrigated Agricultural Program Tranche 1 ( ) 14 Punjab Irrigated Agricultural Program Tranche 2 ( ) Motorway M4 (Faisalabad - Gojra Section) Multiple Sites for HESCO Projects Sukkur-Jaccababad Road construction, N65, National Highway N5 (Hala - Moro Section) National Highway N-45 (Chakdara ridge Project) National Highway N-95 (Fatehpur-Kalam section Project) of National Highway N-50 (Qilla Saifullah Zhob Section) for MEPCO Projects for PESCO Projects for QESCO Projects of NTDC Projects for alloki arrage and Lower ari Doab Canal Projects - Punjab Irrigated Agricultural Program- Tranche 2 D4A01IIE D4AS1IIE D4AH1IIE D4AN1IIE D4AF1IIE D4AC1IIE D4AK1IIE D4AQ1IIE D4AM1IIE D4AP1IIE D4AQ1IIE D4AT1IIE D4A1IIE D4Nk1IIE Introduction R4AR2IEE: 10/24/14 1-9

14 for Improving Implementation of Environmental Safeguards in Pakistan No. Loan Project Sub-project Name HP Report Reference/Comment 15 Power Distribution Enhancement Program Tranche 2 ( ) 16 Power Distribution Enhancement Program Tranche 2 ( ) 17 Power Distribution Enhancement Program Tranche 2 ( ) 18 Renewable Energy Development Sector Program - Project I ( ) 19 Flood Emergency Reconstruction Project ( ) 20 Flood Emergency Reconstruction Project ( ) for IESCO Projects Environmental Audit Report_PDEIP-T2 ( )_LESCO Projects Environmental Audit Report_PDEIP-T2 ( )_FESCO Projects Environmental Audit Report_REDSIP_Project I ( )_KPK component National Highway N-15 (Mansehra Naran Jalkhad section Project) Kohala - Muzaffrabad S-2 D4IE1IIE No physical activity was underway at the time of visit D4FS1IIE No environmental audit conducted as IA/PMU unable to provide EMP and IEE of the project No environmental audit conducted as this is a category C project as per PRM No environmental audit conducted as this is a category C project as per PRM Introduction R4AR2IEE: 10/24/

15 for Improving Implementation of Environmental Safeguards in Pakistan 2. Audit Aproach and Management The approach and management of environmental audit of ongoing projects is discussed hereunder. 2.1 Aproach and Methdology A three step approach was followed for conducting environmental audit on each project. These include pre visit tasks, audit visit and the post visit tasks Pre Audit Visit Tasks efore environmental audit visits, the implementing organizations were requested to provide necessary environmental documents of the project, required for undertaking the audits. Then, the auditor was tasked to review the project organization s documentation received in the office, such as EMP and site-specific environmental management Plan (SEMP), project reports, records and/or manuals related to meeting AD s Safeguard requirements followed by physical visit to the construction sites of the project Audit Visit The activities of environmental audit visit were; Meeting with the project staff to brief on the visit purpose, Walk through the project sites where the Project activities were either undertaken or closed recently for taking a view of existing site conditions and implementation of environmental safeguards. Then, a closing meeting with project environmental management staff to review the environmental documents available at the sites and discuss the preliminary outcome of the audit Post Visit Tasks The post visit tasks include; Preparation of a draft environmental audit report and submitted to IA/EA for their comments and consent on the content. Finally, submittal to AD after addressing the comments 2.2 Roles and Responsibilities A team of HP environmental auditors, who were trained and certified by AD on Environmental Safeguards, were responsible for the environmental audits. The team was headed by Lead Auditor, Hidayat Hasan, whose responsibility was to ensure the efficient and effective completion of the audit works. The auditors Vaqar Zakaria, Saleem uz Zaman, Aziz Karim and Noor Kamal conducted the audits of the projects. Audit Aproach and Management R4AR2IEE: 10/24/14 2-1

16 for Improving Implementation of Environmental Safeguards in Pakistan In addition, responsibilities and activities of the auditors included: Consulting with the AD and implementing agency, if appropriate, in determining the criteria and scope of the audit Obtaining relevant background information necessary for meeting the objectives of the audit, such as details of the project activities, products, services, site and immediate surroundings, and details of previous audits Determining whether the requirements for an environmental audit as given in the AD Safeguard Policy Statement have been met Forming the audit team, giving consideration to potential conflicts of interest, and agreeing on its composition with the client Communicating the final audit plan to IA and AD, coordinating the preparation of working documents and detailed procedures, and briefing the audit team Seeking to resolve any problems that may arise during the audit, recognizing when audit objectives become unattainable and reporting the reasons to the client and the IA Representing the audit team in discussions with the IA prior to, during and after the audit Notifying the IA, without delay, of audit findings of critical nonconformities, if any are found Reporting to the client on the audit clearly and conclusively within the timeframe agreed with in the audit plan Making recommendations for improvements to the EMP, as agreed, in the scope of the audit. 2.3 Environmental Audits Initially, total 22 projects and sub-projects were planned for audit. Of these, environmental audit visits were conducted on 19 projects and sub projects. The visit on remaining projects was not scheduled due to unavailability of environmental documents including Initial Environmental Examination (IEE) and EMP or the environmental category of these projects was changed to C by AD. The information on audit visit and environmental auditor for the projects is provided in Exhibit 2.1. Audit Aproach and Management R4AR2IEE: 10/24/14 2-2

17 for Improving Implementation of Environmental Safeguards in Pakistan Exhibit 2.1: Inventory of Environmental Audit Visit No. Loan Project Sub-project Name Visit Date Environmental Auditor From To 1 National Trade Corridor Highway Program Tranche -1 ( ) 2 Sindh Cities Improvement Program-Tranche 1 ( ) 3 National Highway Development Sector Program- Tranche 2 ( ) 4 National Highway Development Sector Program- Tranche 2 ( ) 5 Flood Emergency Reconstruction Project ( ) 6 Flood Emergency Reconstruction Project ( ) 7 Flood Emergency Reconstruction Project ( ) 8 Power Distribution Enhancement Program- Tranche 2 ( ) 9 Power Distribution Enhancement Program- Tranche 2 ( ) 10 Power Distribution Enhancement Program- Tranche 2 ( ) 11 Power Distribution Enhancement Program Tranche 2 ( ) 12 Power Distribution Enhancement Program- Tranche 2 ( ) Motorway M4 (Faisalabad - Gojra Section) January 16, 2014 January 16, 2014 Vaqar Zakaria Multiple Sites November 4, 2013 November 5, 2013 Saleem uz Zaman Sukkur-Jaccababad Road construction, N65, of National Highway N-50 (Qilla Saifullah Zhob Section) National Highway N5 (Hala - Moro Section) National Highway N-45 (Chakdara ridge Project) National Highway N-95 (Fatehpur-Kalam section Project) for HESCO Projects for MEPCO Projects for FESCO Projects for PESCO Projects for QESCO Projects January 30, 2014 January 30, 2014 Saleem uz Zaman November 18, 2013 November 22, 2013 Noor Kamal November 20, 2013 November 20, 2013 Saleem uz Zaman April 22, 2014 April 22, 2014 Aziz Karim April 23, 2014 April 23, 2014 Aziz Karim January 26, 2014 January 29, 2014 Saleem uz Zaman November 18, 2013 November 22, 2013 Noor Kamal May 19, 2014 May 22, 2014 Noor Kamal November 6, 2013 November 7, 2013 Noor Kamal February 27, 2014 February 28, 2014 Noor Kamal Audit Aproach and Management R4AR2IEE: 10/24/14 2-3

18 for Improving Implementation of Environmental Safeguards in Pakistan No. Loan Project Sub-project Name Visit Date Environmental Auditor From To 13 Power Distribution Enhancement Program Tranche 2 ( ) 14 Power Distribution Enhancement Program Tranche 2 ( ) 15 Power Distribution Enhancement Program Tranche 2 ( ) 16 Power Transmission Enhancement Program- Tranche 2 ( ) 17 Punjab Irrigated Agricultural Program Tranche 1 ( ) 18 Punjab Irrigated Agricultural Program Tranche 2 ( ) 19 Renewable Energy Development Sector Program - Project I ( ) for IESCO Projects for GEPCO Projects for LESCO Projects of NTDC Projects for alloki arrage and Lower ari Doab Canal Projects - Punjab Irrigated Agricultural Program-Tranche 2 Environmental Audit Report_REDSIP_Project I ( )_Punjab component May 12, 2014 May 14, 2014 Noor Kamal November 18, 2013 November 18, 2013 Hidayat Hasan November 19, 2013 November 20, 2013 Hidayat Hasan November 20, 2013 November 20, 2013 Noor Kamal March 17, 2014 March 22, 2014 Noor Kamal March 21, 2014 March 21, 2014 Noor Kamal January 22, 2014 January 24, 2014 Hidayat Hasan Audit Aproach and Management R4AR2IEE: 10/24/14 2-4

19 for Improving Implementation of Environmental Safeguards in Pakistan 3. General Audit Findings This section presents observations broadly on environmental management of the Project noticed by the auditors during audit of the loan projects in Pakistan. These include, Environmental documentation of the Loan Agreement, Environmental clauses in the bidding documents and contracts, Provision of project environmental unit and its structure in EMP and observations on existing team for the projects, Environmental documentation at construction sites as per the requirement of the EIA/IEE and EMP of the project. Handling and management of the waste and hazardous substances Environmental monitoring requirement and compliance Occupational health and safety (OHS) requirements and compliance Social, land acquisition and resettlement requirements and compliance Training of project staff on OHS and environment Restoration of construction sites and camps 3.1 Environmental Documentation of the Loan Agreement In general, the environmental documentation of the Loan Agreement including EIA/IEE and EMP included well defined instructions to be followed during different phases of the project to ensure compliance with the AD s Environmental Safeguards. However, requirement of preparation of the Site-specific EMP (SEMP) was not listed in the IEEs and EMPs. Thus for the majority of the audited projects, SEMP was not prepared. We recommend that this document should be prepared for the Project for identification of site specific potential impacts and mitigation measures. This will only happen if the requirement of preparation is made a part of the EIA/IEE and EMP. Alternatively, the condition of preparation of SEMP should be made part of bidding document exclusively. AD Environmental Safeguard knowledge products Environmental Safeguards Information Kit, clearly identify structure, role and responsibilities of the Environment Team (ET) including Environmental Unit (EU) and Environmental Manager of the construction contractor. During the audit course, similar hierarchal structure was found at only one project (NTCHIP T1 ( )). EIA/IEE and EMP should have a welldefined ET for all those projects having Category A and as specified in the knowledge products. 3.2 Tenders and Contracts Overall the contract and bid documents covered the clause for environmental compliance and provided the environmental requirements as per the available EMPs. The production of SEMP and hierarchal structure for ET should also be made a part of the EIA/IEE and General Audit Findings R4AR2IEE: 10/24/14 3-1

20 for Improving Implementation of Environmental Safeguards in Pakistan EMP and included in the bids, tenders and contract documents. Further, the documents should describe the organization of staff supporting the Environmental Manager of the construction contractor. 3.3 Project Environmental Unit AD Environmental Safeguard knowledge products clearly identify structure, role and responsibilities of the Environment Team (ET) including Environmental Unit and Environmental Manager of construction contractor. During the audit course, similar hierarchal structure was found at only one project (NTCHIP T1 ( )). All those projects having Category A and for environment should have ET as specified in the knowledge products. Majority of the EMPs did not provide any structural information on project ET. However, for some project EMPs, a structure was given for ET but the staffing of actual team at the construction site was not in compliance with the structure given in EMP. For example, as per the organizational structure of EMP for Project SCIIP-T1 (No ), two environmental staff was required for environmental compliance and monitoring. However, there was only one environmental engineer at site who was also overloaded with other work such as administration and human resource management. This person was not able to fulfill the environmental responsibilities due to over commitment on other tasks 3.4 Project Environmental Documentation EMPs do not specify the requirement of producing monthly environmental monitoring reports by the construction contractor for submittal to EU. However, in the majority of EMPs of the projects, several types of environmental documents were required be developed by the contractor. These included Emergency Response Plan (ERP), Waste Disposal Plan Temporary Drainage Management Plan, Traffic Management Plan, and Hazardous Substances Handling Procedures. While these plans were developed for a few projects (i.e. Project , and ), for majority of the projects these plans were either not developed and or not available at the construction sites. 3.5 On-site Handling of Hazardous Substances The issues related to management of hazardous substances were generally recorded, particularly those associated with fuel oil handling, storage and spills. Procedures were not defined for handling of fuel oil and other chemicals including handling of equipment containing poly chlorinated biphenyl s (PCs). Fuel oil spills were recorded as a common issue on majority of the projects (i.e. FERP ( )), PIAIP ( ), etc.). 3.6 Occupational Health and Safety Workers were observed to be without or with insufficient Personal Protective Equipment (PPE) and engaged in works with unsafe practices. PPEs were generally available but workers were not using these due to lack of awareness and sensitivity on safety. Upon discussion with the workers it was observed that no PPE was provided by the contractors in a few cases. PPE should be available readily at all times at construction sites. The General Audit Findings R4AR2IEE: 10/24/14 3-2

21 for Improving Implementation of Environmental Safeguards in Pakistan attitude of the workers can be improved through basic and refresher trainings on OHS issues. 3.7 Environmental Monitoring Record of environmental monitoring of environmental parameters including noise, air quality and water quality was generally seen at projects where recommendations were given in the EMPs. AD Environmental Safeguard specifies monthly production of environmental report by construction contractor and submittal to EU. No such record found as no such requirement was envisaged in the EMP. However, records for i-annual Monitoring Reports submitted by IA/EA to AD were available for majority of the projects. 3.8 Land Acquisition and Resettlement Issues Land Acquisition and Resettlement Plan (LARP), where required, were available at the construction sites and issues related to land acquisitions and resettlement were generally well managed. 3.9 Sensitivity to Social Issues No issue related to communities living around the projects locations were observed on the construction sites Staff Training and Capacity uilding Trainings on OHS and environmental management practices were assumed to be not conducted as no record was available at the time of audits Restoration of Construction Camps The restoration and complete rehabilitation of construction camp sites was not addressed for the completed projects. For instance, concrete structures made for the camping and construction work sites were left unrestored after completion of the New Chakrara ridge built on National Highway N-45 covered under the FERP Project. General Audit Findings R4AR2IEE: 10/24/14 3-3

22 for Improving Implementation of Environmental Safeguards in Pakistan 4. Recommendations HP recommends the following measures based on observations during environmental audits of the projects. Implementation of these measures will strengthen the environmental management and monitoring capability of executing agencies and project implementing organizations, as well as of construction contractors and supervision consultants. Development of Site-specific EMP for the projects should be made mandatory in the EIA/IEE and EMP or in the bidding document. In majority of EMPs structure of Environmental Team (ET) was not provided. The ET should be made in incompliance with AD Environmental Safeguards i.e., environment unit (EU) within project implementation unit (PIU) and appointment of Environmental Manger by the construction contractor. A proper hierarchal structure of ET should be defined in the project EMP. The ET must be established as per EMP before the commencement of the construction work. In the project EMP, surprise and forewarned environmental audits should be made responsibility of the EU to verify the contents of monthly environmental monitoring reports provided by Environmental Manager of construction contractor. The EU should conduct audits from time to time during the construction period and maintain audit records. Surprise and forewarned third party environmental audits by AD will also be an effective tool for ensuring the implementation of AD s Environmental Safeguards. Environmental documentation at construction sites including monthly environmental reports to be submitted to EU, development of waste management plan, traffic management plan, hazardous substances handling procedures, site emergency plan, etc. should be prepared, where required in the EMP and made available and implemented at construction and camp sites. OHS and environmental training for new staff (including contractors) should be organized as part of an initial training program and refresher courses for staff should be organized frequently. Contractor staff should be given trainings on controlling oil spills and ensuring availability of spill control kits at all sites. Contractors should ensure that proper PPEs are available and all staff are using appropriate PPE and participating in OHS trainings. The majority of the issues were recorded related to the inappropriate solid waste management practices at construction and camp sites. The management of these issues can be improved once an effective and well-staffed ET is available and frequent training sessions for the construction crew are conducted. Adequate fire extinguishers and first aid facilities should be placed at camps, offices and work areas. Recommendations R4AR2IEE: 10/24/14 4-1