Technical Assistance Consultant’s Report · 2014. 9. 16. · Technical Assistance Consultant’s Report This consultant’s report does not necessarily reflect the views of ADB

Technical Assistance Consultant’s Report

This consultant’s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents.

Project Number: 43333 March 2014

REG: Improving the Implementation of Environmental Safeguards in Central and West Asia

Environmental Safeguards Training Consultant and Third Party Auditor – Uzbekistan and Turkmenistan

Environmental Audit Report (Uzbekistan)

Prepared by NBT

For Asian Development Bank

March, 2014

TA-7548 REG: IMPROVING THE IMPLEMENTATION OF

ENVIRONMENTAL SAFEGUARDS IN CENTRAL AND WEST ASIA

IDCA: ENVIRONMENTAL SAFEGUARDS TRAINING CONSULTANT AND

THIRD PARTY AUDITOR-UZBEKISTAN AND TURKMENISTAN

Report on Environmental Audit was prepared by Consultant for

Asian Development Bank (ADB)

Uzbekistan Environmental Audit Report

TA-7548 REG: IMPROVING THE IMPLEMENTATION OF ENVIRONMENTAL SAFEGUARDS IN CENTRAL AND WEST ASIA

- UZBEKISTAN ENVIRONMENTAL AUDIT REPORT – PAGE 2



TA-7548 REG: IMPROVING THE IMPLEMENTATION OF ENVIRONMENTAL

SAFEGUARDS IN CENTRAL AND WEST ASIA

UZBEKISTAN

ENVIRONMENTAL AUDIT REPORT

For consideration:

Asian Development Bank 6 ADB Avenue, Mandaluong City,

Metro Manila, Philippines

Prepared by:

14 Mavze Abdullaev, Suite 7, Yakkasaroy District Tashkent 100100

Uzbekistan www.nbt.uz

March, 2014

http://www.nbt.uz/



TABLE OF CONTENTS

TABLE OF CONTENTS ......................................................................................................................... 4

ABBREVIATIONS .................................................................................................................................. 7

EXECUTIVE SUMMARY ...................................................................................................................... 10

1. AMU ZANG IRRIGATION REHABILITATION PROJECT ................................................. 18

1.1. BRIEF INFORMATION ON AMU ZANG IRRIGATION REHABILITATION PROJECT (AZIRP) (L2069

30500-013) .............................................................................................................................................. 18

1.2. INSTITUTIONAL ASPECTS ON ENVIRONMENTAL SAFEGUARDS IMPLEMENTATION .............................. 18

1.3. PROJECT DOCUMENT ANALYSIS ................................................................................................... 19

1.4. PROJECT SITE AUDIT ................................................................................................................... 22

1.5. CONCLUSIONS AND RECOMMENDATIONS ...................................................................................... 24

2. WATER RESOURCES MANAGEMENT SECTOR PROJECT .......................................... 26

2.1. BRIEF INFORMATION ON WATER RESOURCE MANAGEMENT SECTOR PROJECT (WRMSP) (L2492/2493 40086-013) ........................................................................................................................ 26


2.3. PROJECT DOCUMENTATION ANALYSIS .......................................................................................... 27

2.3.1. Project Documents on Narpay and Besharyk Pump Stations ............................................ 28

2.3.2. Project Documents of 5 Sub-Projects ................................................................................. 29


2.4.1. “Narpaв” Pump Station, SamarkanН provincО .................................................................... 29

2.4.2. “BОsСarвk” Pump Station, FОrРana provincО ...................................................................... 30


3. LAND IMPROVEMENT PROJECT .................................................................................... 35

3.1. BRIEF INFORMATION ON LAND IMPROVEMENT PROJECT (LIP) (L2245/2246/0080 37536-1) .......... 35





4. WATER SUPPLY AND SANITATION SERVICES INVESTMENT PROGRAM, TRANCHES 1-3 .................................................................................................................. 44

4.1. BRIEF INFORMATION ON WATER SUPPLY AND SANITATION SERVICES INVESTMENT PROGRAM, TRANCHES 1-3 (WSSSIP) (L2564/2633/2825) ......................................................................................... 44

4.2. INSTITUTIONAL ISSUES OF THE SAFEGUARDS IMPLEMENTATION ..................................................... 48


4.3.1. WSSSIP, Tranche-1 ............................................................................................................ 50

4.3.2. WSSSIP, Tranche-2 ............................................................................................................ 55

4.4. PROJECT AREA AUDIT ................................................................................................................. 57

4.4.1. WSSSIP, Tranche-1 ............................................................................................................ 57

4.4.1.1. Project Works in Bukhara province ..................................................................................... 57

4.4.1.2. Project Works in Navoi Province ......................................................................................... 59

4.4.1.3. Project Works in Termez city .............................................................................................. 62

4.4.2. WSSSIP, Tranche-2 ............................................................................................................ 65

4.4.2.1. Water Treatment Facilities – Ming Tut WDS ....................................................................... 65

4.4.2.2. Sewerage Treatment Facilities Kokand City ....................................................................... 67

4.4.2.3. Sewerage and Water Supply Networks in Kokand City ...................................................... 68


5. SURKHANDARYA WATER SUPPLY AND SANITATION PROJECT ............................. 73

5.1. BRIEF INFORMATION ON SURKHANDARYA WATER SUPPLY AND SANITATION PROJECT (SWSSP) (L2466/G0131 40007-013) ...................................................................................................................... 73







6. TALIMARJAN POWER PLANT EFFICIENCY IMPROVEMENT PROJECT .................... 84

6.1. BRIEF INFORMATION ON TALIMARJAN POWER PLANT EFFICIENCY IMPROVEMENT PROJECT

(TPPEIP) (L2629/2630 43151-023) ........................................................................................................ 84





7. MULTITRANCHE INVESTMENT PROGRAM OF REGIONAL ROAD DEVELOPMENT PROJECT. PHASE II and PHASE III. ................................................................................ 93

7.1. BRIEF INFORMATION ON MULTITRANCHE INVESTMENT PROGRAM OF REGIONAL ROAD

DEVELOPMENT PROJECT. PHASE II AND III (RRDP) (L2635/2746/2868/2772/2965) .................................. 93

7.1.1. REGIONAL ROAD DEVELOPMENT PROJECT. PHASE II (L2635/2746/2868) ..................................... 93

7.1.2. REGIONAL ROAD DEVELOPMENT PROJECT. PHASE III (L2772) ...................................................... 94


7.3. “RRDP. PHASE II”, TRANCHE-1 ................................................................................................. 101

7.3.1. PROJECT DOCUMENTATION ANALYSIS ........................................................................................ 101

7.3.2. PROJECT SITE AUDIT “RRDP. PHASE II”, TRANCHE-1 ................................................................. 104

7.3.3. CONTRACTOR’S CONSTRUCTION BASE AND CAMP ...................................................................... 104

7.3.4. TERRITORY OF CONCRETE PLANTS ............................................................................................ 108

7.3.5. INERT MATERIALS QUARRY ........................................................................................................ 110

7.3.6. A-380 HIGHWAY ........................................................................................................................ 110

7.4. “RRDP. PHASE II”, TRANCHES -2 AND 3 ..................................................................................... 111

7.4.1. PROJECT DOCUMENT ANALYSIS ................................................................................................. 111

7.4.2. PROJECT SITE AUDIT “RRDP. PHASE II”, TRANCHES -2 AND 3 .................................................... 111

7.5. “RRDP. PHASE III”, TRANCHE-1 ................................................................................................ 111

7.5.1. PROJECT DOCUMENT ANALYSIS ................................................................................................. 111

7.5.2. PROJECT SITE AUDIT “RRDP. PHASE II”, TRANCHES - 1 ............................................................. 113

7.5.3. CONSTRUCTION BASE AND CAMP OF “ELEKTRTARMOQQURILISH” SUB-CONTRACTOR .................... 114

7.5.4. CONSTRUCTION CAMP OF “ALIANS KAPITAL” SUB-CONTRACTOR .................................................. 115

7.5.5. CONCRETE PLANT ..................................................................................................................... 117

7.5.6. ROAD SECTION ON THE CONSTRUCTION STAGE .......................................................................... 118

7.6. CONCLUSIONS AND RECOMMENDATIONS .................................................................................... 119

7.6.1. INVESTMENT PROGRAM II, TRANCHE 1. KHOREZM, SARIMAY ....................................................... 119

7.6.2. INVESTMENT PROGRAM III, TRANCHE 1. KAMCHIK ....................................................................... 120

8. CAREC CORRIDOR 6 RAILWAY ELECTRIFICATION PROJECT (MAROKAND- ....... 123

KARSHI) 123

8.1. BRIEF INFORMATION ON CAREC CORRIDOR 6 RAILWAY ELECTRIFICATION PROJECT

(MAROKAND-KARSHI) (CCREP) (L2781 45067-005) .............................................................................. 123

8.2. INSTITUTIONAL ISSUES OF THE SAFEGUARDS IMPLEMENTATION ................................................... 123

8.3. PROJECT DOCUMENT ANALYSIS ................................................................................................. 124


9. SECOND SMALL AND MICROFINANCE DEVELOPMENT PROJECT ......................... 127

9.1. BRIEF INFORMATION ON SECOND SMALL AND MICROFINANCE DEVELOPMENT PROJECT PHASE II (SSMDP II) (L2634) ............................................................................................................................... 127

9.2. ENVIRONMENTAL REQUIREMENTS IN THE SSDMII PROJECT DOCUMENTS ..................................... 127

9.3. INSTITUTIONAL STRUCTURE OF ENVIRONMENTAL PERFORMANCE .................................................. 128

9.4. HAMKORBANK ESMS ................................................................................................................ 128

9.5. IPAK YULI BANK ESMS .............................................................................................................. 130

9.6. CONCLUSIONS AND RECOMMENDATIONS ..................................................................................... 132

9.7. HAMKORBANK ........................................................................................................................... 132

9.8. IPAK YULI BANK ......................................................................................................................... 133

10. HOUSING AND INTEGRATED RURAL DEVELOPMENT PROJECT ............................ 134

10.1. BRIEF INFORMATION ON HOUSING FOR INTEGRATED RURAL DEVELOPMENT INVESTMENT

PROGRAM – PROJECT I (HIRDIP I) (L2775) ............................................................................................ 134

10.2. INSTITUTIONAL STRUCTURE OF ENVIRONMENTAL PERFORMANCE ................................................ 134



10.3. ENVIRONMENTAL ASPECTS IN PROJECT DOCUMENTATION ........................................................... 135

10.4. IMPLEMENTATION OF ESMS BY QQB ......................................................................................... 137


11. CONCLUSIONS ................................................................................................................ 142

APPENDIXES ..................................................................................................................................... 144

APPENDIX 1. AMU ZANG IRRIGATION REHABILITATION PROJECT ............................................................. 144

Checklist of Environmental Audit ....................................................................................................... 144

APPENDIX 2. WATER RESOURCES MANAGEMENT SECTOR PROJECT ...................................................... 148


Forms of Reporting on Compliance with Environmental Requirements ............................................ 151

Information Sheet prepared by Project for public acquaintance with project activities ..................... 153

APPENDIX 3. LAND IMPROVEMENT PROJECT .......................................................................................... 155


APPENDIX 4. WATER SUPPLY AND SANITATION SERVICES INVESTMENT PROGRAM, ............ 158

TRANCHES 1-3 .................................................................................................................................... 158

Checklist of Environmental Audit of WSSSIP Project, Tranche-1 ..................................................... 158

Checklist of Environmental Audit of WSSSIP Project, Tranche-2 ..................................................... 161

Contractor’s IntОrnal OrНОr on EcoloРist AppointmОnt ...................................................................... 164

APPENDIX 5. SURKHANDARYA WATER SUPPLY AND SANITATION PROJECT ............................................. 165


SEMP ON TERMEZ CITY OBJECTS APPROVED BY PIU AND CONTRACTOR ................................................... 168

APPENDIX 6. TALIMARJAN POWER PLANT EFFICIENCY IMPROVEMENT PROJECT ...................................... 171


APPENDIX 7. MULTITRANCHE INVESTMENT PROGRAMS OF REGIONAL ROAD DEVELOPMENT PROJECT. PHASE II AND III. ..................................................................................................................................... 175

CСОcklist oП EnvironmОntal AuНit oП “RRDP. PСasО II, TrancСО-1 ..................................................... 175

CСОcklist oП EnvironmОntal AuНit oП “RRDP. PСasО III”, TrancСО-1 .................................................. 178

Certificate Issued by the SES of Khorezm Province on Non-exceedance of the Norms on the Noise Level and Indicators of the Air quality at the Construction Sites ............................................. 181

Contractor’s CСОcklist oП EnvironmОntal AuНit oП “RRDP. PСasО II” ProjОct, TrancСО-1 ................... 182

APPENDIX 8. SECOND SMALL AND MICROFINANCE DEVELOPMENT PROJECT ........................................... 184

Checklist of Environmental Audit on Hamkorbank ............................................................................ 184

Checklist of Environmental Audit on Ipak Yuli Bank .......................................................................... 186

APPENDIX 9. HOUSING AND INTEGRATED RURAL DEVELOPMENT PROJECT ............................................. 188

DATA TO BE COLLECTED IN COLLABORATION WITH DISTRICT HOKIMIYAT ................................................. 188

FORM 1. PROVINCE: SURKHON ............................................................................................................. 188

DATA ON (POTENTIAL) BORROWERS AND HOUSING BLOCKS ................................................. 189

RECORDING FIELD MONITORING ON CONSTRUCTION WORKFLOW ............................................................ 190

HAND OVER ACCEPTANCE DOCUMENT FOR EACH HOUSE (BY STATE COMMISSION) ................................... 192

HAND OVER ACCEPTANCE DOCUMENT FOR EACH HOUSE (BY HOUSE OWNERS) ........................................ 194



ABBREVIATIONS

ADB - Asian Development Bank

CCSD - Construction Civil Structure Department

EA - Executive Agency

EFS - ESMS Field Staff

EIA - Environmental Impact Assessment

EIAF - Environmental Impact Assessment Framework

EIS - Environmental Impact Statement

EMG - Environmental Monitoring Group

EM(M)P - Environmental Management (and Monitoring) Plan

EP - Environmental Protection

ES - Environmental Safeguards

ES(R)MS - Environmental and Social (Risk) Management System

FAM - Facility Administration Manual

FI - Financial Intermediate

FL - Fuels and Lubricants

GWT - Ground Water Table

IA - Implementation Agency

IEE - Initial Environmental Examination

IFC - International Financial Corporation

LA

- Loan Agreement

KMK - Construction Norms and Rules

LLC - Limited liability company

MAWR - Ministry of Agriculture and Water Resources Management

MES - Monitoring and Evaluation Specialist

MNP - Ministry of Nature Protection

MOE - Ministry of Economy

MRT - Ministry of Railway Transport

MSE - Micro and Small Enterprises

OJSC - Open Joint Stock Company



PAM - Project Administration Manual

PCB - Participating Commercial Bank

PIAL - Prohibited Investment Activities List

PIU - Project Implementation Unit

PMCSC - Project Management and Construction Supervision

Consultant

PMU - Project Management Unit

PPTA - Project Preparation Technical Assistance

PPMU - Project Preparation and Management Unit

PS - Pump Station

PSCD - Power Supply and Communication Department

RETA - Regional Technical Assistance

RRF - Republican Road Fund

SE - Safety Engineering

SE(B)MP - Site Environmental (Based) Management Plan

SEPE - Social and Environmental Protection Expert

SES - Sanitarian Epidemiological Station

SIEE - Summary Initial Environmental Examination

SNiP - Sanitarian Norms and Rules

SPS - Safeguard Policy Statement

SRJSC - State Railway Joint Stock Company

SS - Safeguard Specialist

TA - Technical Assistance

TPP - Thermal Power Plant

QQB - Qishloq Qurilish Bank

QQI - Qishloq Qurilish Invest

URM - Uzbekistan Resident Mission

UTY - Uzbekiston Temir Yullari WCA

- Water Consumer Association

WDS/C - Water Distribution System/Center

ADB - Asian Development Bank



CCSD - Construction Civil Structure Department

EA - Executive Agency

EIA - Environmental Impact Assessment

EMP - Environmental Management Plan

ES - Environmental Safeguards

FL - Fuels and Lubricants

IA - Implementation Agency

IEE - Initial Environmental Examination

LA

- Loan Agreement

MNP - Ministry of Nature Protection

MRT - Ministry of Railway Transport

PAM - Project Administration Manual

PPTA - Project Preparation Technical Assistance

PMCSC - Project Management and Construction Supervision Consultant

PSCD - Power Supply and Communication Department

RETA - Regional Technical Assistance

SE - Safety Engineering

SEMP - Site Environmental Management Plan

SES - Sanitarian Epidemiological Station

SPS - Safeguard Policy Statement

TA - Technical Assistance

URM - Uzbekistan Resident Mission



EXECUTIVE SUMMARY

1. The NBT (the Consultant) conducted Environmental Audit of ADB funded projects in Uzbekistan in tСО ПramОwork oП RОРional TОcСnical AssistancО (RETA) “ImprovinР tСО ImplОmОntation oП EnvironmОntal SaПОРuarНs in CОntral anН WОst Asia”. In total 16 projects were audited including 2 which were completed and the rest were on the implementation stage or at the stage of Contractor/Supervision Consultant selection. Brief information on implementation status of audited projects is presented in Table 1.

2. The Environmental Audit was conducted after 3 months of training activities conducted for ExecutinР/ImplОmОntinР AРОnciОs’ (EA/IA), ProjОct ManaРОmОnt Unit/ProjОct ImplОmОntation Units (PMU/PIU)’s, SupОrvision Consultants, anН Contractors involvОН in implementing ADB funded projects. During the training activities, all participants were informed about approach and steps to be taken during the Environmental Audit. In addition, a list of documents, which would be reviewed during the Environmental Audit, was included into the training materials distributed among participants.

3. The main goal of the Environmental Audit was an assessment of execution of environmental safeguards during the project preparation and implementation stages. Based on findings during the Environmental Audit development of recommendations for EA, PMUs/PIUs and ADB to improve environmental performance of the projects. Generally, the Environmental Audit consisted in two parts: (i) review of institutional and regulatory bases of EA/IAs established for safeguards implementation; (ii) assessment of Site Environmental Management Plans (SEMP) implementation by Contractors at the construction sites.

4. As a first part of Environmental Audit, the following projects documents were reviewed to check if environmental requirements are included: Loan/Project Agreements, Bidding Documents, Contracts between Project Management/Implementation Units (PMU/PIU) and Supervision Consultant/Contractors. In addition, the results of environmental monitoring, which needs to be conducted by Contractor/PMU/Supervision Consultant per concerned requirements indicated in each Environmental Management Plan (EMP) and PMU/PIU’s workinР papОrs related to environmental performance were observed.

5. In order to assess SEMP implementation, a joint team comprised from representatives of the Consultant, PMU/PIUs, Supervision Consultant, and Contractors visited construction camps and sites of all projects. During those visits, sites with on-going and recently completed project activities were observed.

6. Review of Project documents showed, that generally, environmental safeguards requirements are included in Loan/Project Agreements and these documents define a frequency of submission of environmental monitoring reports. It was noted that some Loan Agreements (Water Resources Management Sector Project (LoanL2492/2493), Amu Zang Irrigation Rehabilitation Project (AZIRP) (L2069), Land Improvement Project (L2245/2246/0080)) do not include the requirement on submission of environmental monitoring report to ADB which makes procedure on a report preparation and submission unclear.

7. Properly desiРnОН BiННinР DocumОnts sОrvО as a rОРulatorв basО Пor ПurtСОr PMU’s communication with Supervision Consultant who is hired to assist PMU in project implementation and Contractors as an implementer of construction. Examined Bidding Documentation (for Contractors selection) showed, that the bidding documents of the following projects conditionally could be evaluated as projects, having a complete environmental set and requirements1: Land Improvement Project (LIP-L2069), Water

1The bidding documents were considered as an environmentally completed if they included the following requirements: (i) on compliance with ADB and national environmental safeguards, (ii) development SEMP and submission to EA and IA for approval (iii) on conductingenvironmental monitoring and reporting to PIU. In addition, a complete set of documents has to be supplemented by IEE or EMPs attached to the packet of bidding documents.



Resources Management Sector Project (WRMSP-L2492/2493), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), CAREC Corridor 6 – Railway Electrification Project (CAREC-6-REP-L2781), Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775). The remaining projects have incomplete set of environmental documents within the bidding documents. For example, the Consultant observed a situation when the main text of bidding documents refer to attached IEE or EMP, but mentioned IEE or EMP are not attached to the main documents (Surkhandarya Water Supply and Sanitation Project (L2466/G0131), Water Supply and Sanitation Service Investment Program, Tranche 1-3 (L-2564/2633/2825)).

8. All Loan/Project Agreements contain requirement to EA/IAs on creating Environmental Management Unit or at least hiring an environmental expert within PMU/PIUs. Conducted audit showed, that not all EA/IAs meet these requirements. 11 PMUs were established for implementation of 16 projects. Due to different sites location within the country, several PIUs were organized on the sites under one PMU for some projects. The following PMUs engaged full or part time environmental experts - Water Resources Management Sector Project (WRMSP-L2492/2493), CAREC Corridor 2 Road Investment Program, Second Corridor 2 Road Investment Program (L2635/2746/2868/2772/2965/2868), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), CAREC Corridor 6 – Railway Electrification Project (CAREC_6_REP-L2781), Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775). In the remaining projects, environmental duties have been implemented by an expert who combined two tasks, project evaluation/monitoring and environmental safeguards. As result, overloaded experts cannot undertake their duties properly.

9. As known, PMU’s ОnvironmОntal pОrПormancО covОrs wiНО scopО oП activitв: review and approval IEEs developed for EA/IAs as part of a Project Preparation Technical Assistance (PPTA), assessment of bidding proposals in term of biННОr’s ОnvironmОntal capacity, reviewing of Contractors SEMPs on compliance with EMP requirements and etc. Among the reviewed projects, none of bidding committee included an environmental expert, who could assess environmental capability of bidders. Although concerned ADB staff has to review the main project documents, such as Loan/Project Agreements, Bidding Documents and Contracts, it is very important for PMU/PIUs to have qualified Environmental Expert. Lack of experience and knowledge in environmental science makes it difficult to implement national and ADB environmental safeguards at the all stages of the project cycle. Among rОviОwОН projОcts, onlв 2 PMU’s ОnvironmОntal experts have environmental subject background – PMUs of Water Resources Management Sector Project (WRMSP-L2492/2493) and Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630).

10. Active involvement of Supervision Consultant in project implementation could be considered as an option for enhancing environmental capacity and environmental performance of PMU/PIUs. Some of the reviewed projects are assisted by Supervision Consultants, which provide a significant support to PIU/PMUs in term of preparing bidding documents for Contractors selection, monitoring of safeguards implementation during construction, development a template or preparing Environmental Monitoring Reports in accordance with IEE and ADB requirements on behalf of PMU/PIUs. The Consultant noted an appreciable support from Supervision Consultants in term of environmental aspects: Land Improvement Project (LIP - L2069), Water Resources Management Sector Project (WRMSP-L2492/2493) and Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), Surkhandarya Water Supply and Sanitation Project (L2466/G0131), CAREC Corridor 6 – Railway Electrification Project (CAREC_6_REP-L2781), Amu Zang Rehabilitation Project (L2069). At the same time, in some projects Supervision Consultants do not provide a proper assistance to PMU/PIUs. Such, the Supervision Consultant of Water



Supply and Sanitation Investment Program for Tranche 1-3 does not provide support, though its contract with PMU clearly describes all expected services on environmental aspects. Poor professional support from Supervision Consultant side together with situation, wСОn PMU’s ОnvironmОntal activitв is unНОrtakОn bв onО ОxpОrt, wСo combinОs two tasks at the same time, which leads to inefficient environmental performance, non-compliance with ADB environmental safeguards.

11. Another issue related to institutional capacity of PMUs is a limited involvement of PMU/PIUs environmental experts in the projects cycle. For example, CAREC Investment Programs have two PMUs, which are implementing 6 sub-projects in four different provinces of Uzbekistan. One environmental expert works for both PMUs in part time bases, and it is obvious that the duration and period of expert involvement is not enough to conduct proper environmental performance on all stages of the project implementation for all subprojects.

12. Contractors’ SEMPs sОrvО as a rОРulatorв НocumОnt for Contractors environmental performance and after SEMP approved by PMUs. A number of SEMPs developed by Contractors are almost fully complied with IEE requirements, in this regard, SEMPs of the following projects need to be noted especially: Water Resources Management Sector Project (WRMSP-L2492/2493) and Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), CAREC Corridor 2 Road Investment Program Tranche 1 (L2635). In somО casОs SEMPs wОrО НОvОlopОН bв projОct’s SupОrvision Consultants anН НОlivОrОН to Contractors (Land Improvement Project (LIP - L2069), Amu Zang Rehabilitation Project (L2069)). Content and quality of the SEMPs need to be improved in order to meet IEE requirements especially in part of conducting environmental monitoring, reporting, and institutional aspects.

13. The Consultant observed a situation when SEMPs for several sub-projects within Multi tranche Project were copied without taking in consideration specificity of SEMPs of the rest projects need to be revised and updated to put in compliance with environmental requirements described in appropriate IEE/EMPs. PMU/PIUs need to ensure that Contractors are not allowed to start construction works without approval SEMPs by PMU/PIUs.

14. Among audited projОcts, onlв two PMUs СavО rОvisОН anН commОntОН Contractor’s SEMP documents- Water Resources Management Sector Project (WRMSP-L2492/2493) and Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630).

15. The Consultant noted that a quality of Environmental Monitoring Reports submitted by PMU/PIUs to ADB has significantly improved after presenting training materials presented during the training, which was organized by ADB in August 2013. Quality of the reports of the following projects has improved compare with earlier developed reports: Land Improvement Project (LIP - L2069), Water Resources Management Sector Project (WRMSP-L2492/2493) and Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), Surkhandarya Water Supply and Sanitation Project (L2466/G0131), Ferghana sub-project of Water Supply and Sanitation Services Investment Program, Tranche-2, Amu Zang Rehabilitation Project (L2069), Second Corridor 2 Road Investment Program (L2635). The Projects which prepare environmental report on annual base (Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775)) were not evaluated on this matter, since annual reports would be prepared after conducting the current Environmental Audit.

16. Results of environmental monitoring conducted within projects are the key parameters allowing evaluate an effectiveness of environmental safeguards implementation. A proper design and implementation of the environmental monitoring recommended in IEEs would provide a clear picture of how the projects could impact the environment. However, as showed the audit, an executing of environmental monitoring, especially a tool-based (instrumental), during the project implementation stage, is one of the weakness point in PMU/PIU’s ОnvironmОntal pОrПormancО. In somО projОcts, tСО ОnvironmОntal monitorinР



program does not cover parameters, which allow assessing a real project impacts. For instance, environmental monitoring program included in IEE for Water Resources Management Sector Project (WRMSP-L2492/2493), does not include any requirements on conducting instrumental monitoring, though the projects impacts on watercourses and ambient air quality are very likely, especially in the project sites closely located to the settlements. On tСО otСОr СanН, somО projОct’s monitorinР proРrams incluНО monitorinР oП very wide list of parameters to be monitored, but implementation of which is very costly. Some parameters or frequency of monitoring raise doubts on its necessity because of low probabilitв oП projОct’s impact on tСОsО paramОtОrs or location oП projОct sitОs in the remote from settlements areas (Land Improvement Project (LIP - L2069), Second Corridor 2 Road Investment Program (L2635). Recommended as part of IEEs an environmental monitoring proРram nООНs to bО rОvisОН bв PMU/PIU’s ОnvironmОntal ОxpОrt at tСО staРО oП PPTA preparation, or/in addition coulН bО rОvisОН bв PMU/PIU’s ОxpОrt witС SupОrvision Consultant involvement at the beginning of a project implementation. To follow up the results of the revision, necessary corrections/changes in monitoring program could be made with supplement of proper justifications. It should be noted, that all changes in project documents need to be endorsed by ADB. The audit showed that environmental monitoring programs are not reviewed by PMU/PIUs. As a result, only some projects have been implementing an environmental monitoring and the significant part of the projects have not. The following projects undertake an environmental monitoring -Second Corridor 2 Road Investment Program (L2635), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), CAREC Corridor 6 – Railway Electrification Project (CAREC_6_REP-L2781), Land Improvement Project (LIP - L2069). In most of the cases even for these projects, conducting monitoring does not comply with IEE/EMP requirements in part of monitored parameters and frequency of monitoring. The remaining projects have not been conducting environmental monitoring, though IEEs contain such requirements. At the same time, it should be noted there is no need in tool based environmental monitoring in two projects - Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775).

17. As a second part of the Environmental Audit, implementation of SEMPs by Contractors was reviewed during the visit to the construction camps and construction sites. The main issues observed during such visits were related to construction and domestic wastes disposal, oil and fuel handling and providing proper housekeeping facilities for the workers. Several projects have demonstrated examples of good environmental practice on above mentioned waste management and oil handling and disposal matters (Land Improvement Project (LIP - L2069), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), Water Resources Management Sector Project (WRMSP-L2492/2493). The Consultant noted that there are several projects, which need pay more attention on implementing environmental measures during the construction in order to meet national and ADB environmental requirements. More detail information on the findings is provided in the main text of this Environmental Audit report for each project.

18. Based on the findings of projects documents review and conducted site visits the Consultant made the following general conclusions:

i. In general, majority of PMU/PIUs have improved their environmental performance during last few years. Visible changes relate to quality of environmental reports prepared by PMU/PIUs or Supervision Consultants on behalf of PMUs, improved design of bidding and contract documentation in terms of including environmental safeguards, communication between PMUs and Contractors on environmental aspects, keeping records on environmental performance. Training materials delivered by RETA supplemented practical and regulatory supports and provided more clarifications on ADB safeguard requirements.

ii. It is noticОablО tСat PMU/PIU’s attОntion to implОmОntation oП SEMPs bв Contractors and conducting environmental monitoring are increasing. PMU/PIUs are paying more



attention to setting out institutional aspects and submission of the environmental reports by Contractors.

iii. PMUs’ incОntivОs anН intОntions in orРaniгinР projОct works in tСО waв allowinР mООt national and environmental requirements play one of the key roles in providing effectiveness of environmental safeguards during project implementation. PMUs of Land Improvement Project (LIP - L2069), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), Water Resources Management Sector Project (WRMSP-L2492/2493), Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775) projects demonstrate such incentives and as a result, they have environmental performance of these projects is on the higher level. In some cases, PMUs are stronРlв supportОН bв projОcts’ SupОrvision Consultants, wСicС proviНО a vОrв СОlpПul assistance to PMUs in implementing environmental safeguards during project cycles.

19. Along with above-mentioned positive achievements of ADB funded projects in term of environmental compliance, the following issues were identified as important and required consiНОration in orНОr to ПurtСОr improvО PMU’s ОnvironmОntal pОrПormancО anН ОxОcutinР of environmental safeguards during projects implementation:

i. Even quality of project documents in term of environmental safeguards is noticeably improving, there is need for close revision of all project documentation (Loan Agreements, Bidding documents and Contracts) by ADB and PMU/PIUs to ensure that environmental requirements are included in proper content and environmental parts of all project documents are corresponded.

ii. Existing institution capacity of some EA/IA and PMU/PIUs is not enough to implement environmental performance on the satisfactory level. EA/IAs need to pay more attention to institutional aspects of environmental performance, through hiring safeguards experts as indicated in Project/Facility Administration Manuals (PAM/FAMs). Situations, when engaged environmental expert combine another jobs/tasks, which are not related to the safeguards, are need to be avoided. The hired experts should have background in environmental science or enough working experience in related fields.

i. Projects Supervision Consultants play important role in professional supporting PMU/PIUs and providing an efficient environmental performance. However, this source is not fully used by some of the PMU/PIUs and, as a result; those PMUs have difficulties in complying with environmental safeguards.

ii. To ensure that selected bidders will be able to provide services in compliance with national and ADB environmental requirements, the bidding committees have to include environmental experts to properly evaluate an environmental capacity of bidders.

iii. In some PMU/PIUs existing practice on keeping environmental documentations and records, results of conducted environmental audits, communications between PMU, SupОrvision Consultant anН Contractors, rОcorНs on complaints Пrom projОct’s affected people needs to be improved. This documentation is a base for preparing Environmental Monitoring and Project Completion Reports. Existed in several PMU/PIUs well-functioning records keeping system could be introduced to the other projects as example a good practice.

iv. Environmental Monitoring Reports of only 6 projects complies with the main ADB safeguards requirements. The remaining projects need work on revising and improvement of quality of the report in order to meet the requirements.

v. Implementation of environmental monitoring at the project construction stage recommended in IEEs is not satisfactory and it requires more attention from PMU/PIUs anН Contractors’ siНОs. TвpО anН ПrОquОncв oП rОcommОnНОН paramОtОrs



to be monitored need to be revised at the PPTAs preparation and SEMP approval stages by PMU/PIUs in order to optimize and adopt the recommendation to the local natural conditions and project specificity.

vi. Quality of SEMPs which Contractors submitted for revising to PMU/PIUs needs to be carefully checked on compliance with safeguards requirements indicated in relevant IEEs.

vii. The Consultant observed some events when Contractor non-complied with environmental safeguards requirements. The PMU/PIUs have to apply all possible tools to push Contractor to follow their obligations by proper using of relevant contract’s covОnants.

viii. Due to specificity of Second Small and Microfinance Development (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775) projects, conclusions and recommendations for these projects are provided in the appropriate part of current Environmental Audit Report. More detail information on the findings is provided in the full Environmental Audit report.

20. Based on the Environmental Audit findings, the Consultant has developed a summarized table of recommendations for the each reviewed sub-project. The tables provide data on implementer and timing when recommendations should be applied during the project cycle.

21. The Consultant has prepared Environmental Audit Reports for all 16 projects and shared with to each PMU/PIUs for review and comments. Based on the comments provided by PMU/PIUs, the Consultant incorporated necessary clarifications into the final version of Environmental Audit Reports.



Table 1: Brief information on implementation status of ADB funded projects in Uzbekistan

# Project Name Data of project completion Project Location Project Status (Project

Implementation Percentage)

Remarks

1 Amu Zang Rehabilitation Project

(L2069) December, 31 2013 Surkhandarya province 95.64%

2 Water Resources Management

Sector Project (L2492/2493)

December,31 2014 Fergana and

Samarkand provinces 59.7%

2 sub-projects had to be closed by December 31, 2013, and for other 5 sub-projects construction works

had not been started yet

3 Land Improvement Project

(L2245/2246/0080) October 31, 2014

Bukhara, Kashkadarya and Navoi provinces

66.3%

4

Water Supply and Sanitation Services Investment Program,

Tranche 1 (L2564)

June,30 2015 Surkhandarya, Bukhara

and Navoi provinces

83%

From 8 sub-projects 4 have been completed, for others project implementation status was

between 24-95%

5 Water Supply and Sanitation

Services Investment Program, Tranche 2 (L2633)

July, 31 2015 Fergana and Andijan

provinces 61%

From 3 sub-projects only one has started. For others a bidding

process is underway

6

Water Supply and Sanitation Services Investment Program,

Tranche 3 (L2825)

December 31, 2016

Djizak, Khorezm, Andijan provinces and

Republic of Karakalpakstan

0% Works are not started yet

7 Surkhandarya Water Supply and Sanitation Project (L2466/G0131)

April 30, 2014* Surkhandarya province 92% *Original data indicated in Loan

Agreement - December,31 2013

8 Talimarjan Power Plant

Efficiency Improvement Project (L2629/2630 43151-023)

December 31, 2016 Kashkadarya province 5%

9 CAREC Corridor 2 Road

Investment Program, Tranche 1 (L2635)

December 31, 2013* Khorezm province 95% *Original data indicated in Loan

Agreement - September 30,2012





December 31, 2015 Bukhara province 0% Construction works are not started

yetExtended



June 30, 2015 Bukhara province 0% Construction works are not started

yet

12 Second CAREC - Corridor 2

Investment Project, Tranche1 (L2772)

March 31, 2014 Tashkent, Namangan

provinces 12%



June 30, 2016 Namangan province 0%

14 Second CAREC - Corridor 2

Investment Project, Tranche 3 (L2868)

June 30, 2015 Bukhara province 0% Construction works are not started

yet

15 CAREC Corridor 6 - Railway Electrification Project(L2781

45067-005) March 31, 2016

Samarkand and Kashkadarya provinces

5% Bidding process for Contractor

selection is on-going

16 Second Small and Microfinance Development Project (L2634)

December 2013 Within whole country 100%

17 Housing for Integration Rural

Development, Tranche 1 (L2775) December 2013 Within whole country 100%



1. AMU ZANG IRRIGATION REHABILITATION PROJECT

1.1. Brief information on Amu Zang Irrigation Rehabilitation Project (AZIRP) (L2069 30500-013)

22. The institutional issues, project documents and the project sites were reviewed for analysis of performance of environmental safeguards on Amu Zang Irrigation Rehabilitation Project (AZIRP). The project implementation was carried out in Surkhandarya province of the Republic of Uzbekistan, in five districts: Angor, Djarkurgan, Kumkurgan, Muzrabad and Termez (Figure 1). During environmental audit date2, the project progress accounted for 95,64%3, and according to the project documents, the project has been assigned as Environmental Category B. It sСoulН bО notОН, tСat AГIRP’s complОtion НatО is DОcОmbОr 31, 2013.

Figure 1: Amu Zang Irrigation Rehabilitation Project area

1.2. Institutional Aspects on Environmental Safeguards Implementation

23. The Project Management Unit (PMU) was established in Tashkent for the project implementation in the Executing Agency (EA) with mandate to accomplish overall coordination of the project works through the Project Implementation Unit (PIU) based in Termez city of Surkhandarya province (Figure 2). The control over safeguards observance within PMU has been assigned to the Monitoring and Evaluation Specialist (MES). The Supervision Consultant (Consultant Engineer) – consortium of Mott-MacDonald and Temelsu - was hired by the PMU for the project management and monitoring of the implementation. The Consultant Engineer is dealing with preparation of the technical reports containing also the environmental component (Chapter 2, Section 2.4.1. - Environmental Issues). 2 October 30 2013 3 Data were submitted by PMU, September 2013



Figure 2: Institutional Chart of the Environmental Safeguards Arrangement within the AZIRP

24. TСО Contractor’s companiОs assiРnОН tСО ManaРОrs on HОaltС ProtОction, SaПОtв Engineering and Environmental Protection, responsible for implementation of the environmental safeguards at the construction site as well.

1.3. Project Document Analysis

25. According to Schedule 6, Section D, para. 13 of the Loan Agreement No. 2069–UZB (November 2, 2004) between the Republic of Uzbekistan (RUz) anН ADB, “…TСО BorrowОr shall ensure, and cause PFIs4 to ensure that (a) the Project is carried out and all Project facilities are designed, constructed, operated, maintained and monitored in conformity with the existing environmental laws and regulations of the Borrower, and the environmental РuiНОlinОs oП tСО ADB, in particular, ADB’s EnvironmОntal AssОssmОnt GuiНОlinОs, 2003; anН (b) all environmental monitoring and mitigation measures identified in the IEE5, in particular, (i) monitoring of morphology of Amu Darya River; (ii) study of the need for fish exclusion devices at the intake; (iii) proper handling and disposal of hazardous materials by contractors; and (iv) preparation of a plan for a clean-up of existing stockpiles of obsolete agro-chemicals are fully implemented and such monitoring and mitigation measures are incorporatОН into НОsiРn, biННinР НocumОnts anН contracts.”.

26. The Loan Agreement does not specify the deadlines of the environmental monitoring report submission to the ADB by the Borrower.

4 PFIs – Participating Financial Institutions 5 Initial Environmental Examination

MAWR (EA)

PMU (Tashkent city)

M&E Specialist

PIU Termez city 15 people

ADB

International Specialist on HP

and M&E

Local Specialist on HP and M&E

Contractors – 16 Surkhandarya province

Manager on HP, SE and EP

Consultant Engineer (Mott-MacDonald-Temelsu)



27. During Environmental Audit, the Consultant has been provided with IEE6, developed at the technical assistance stage (September, 2003) in the format of ADB requirements adopted by ADB. The Environmental Impact Statement (EIS) was developed during the project implementation at the detailed designing stage (September, 2006)7. Both of these documents contain the EMP approved by ADB.

28. The bidding documents for the bids were prepared based on the standard pattern for all Contractors. Therefore, one set of the bidding document package was examined – construction works fulfillment on three contracts: AZIRP 04, “RОСabilitation oП Amu Zang Pump Station 1”, AГIRP 06, “RОСabilitation oП Amu ГanР Pump Station 2” anН AГIRP 08, “RОСabilitation oП BabataР Pump Station”.

29. The obligations on the environmental safeguards implementation are included in the bidding documents8 in sОction 1.21 “SitО EnvironmОntal ManaРОmОnt Plan”, p.1.21.1-1.21.4. Section 1.21 includes the requirements on the Site Environmental Management Plan (SEMP) preparation in accordance with IEE and meeting requirements of environmental policy. The paragraphs 1.21.1 and 1.21.2 describe potential risks emerging in the course of construction works, which have to be excluded with the SEMP support, as well as construction supervision and environmental requirements observance.

30. The paragraph 1.21.3 describes the requirements on submission of environmental reports by the Contractor to the Project Manager (PMU) on the monthly base. In addition, the procedure and content of reports submitted for the approval by the Project Manager (PMU) is also described, along with the requirements on availability of the electronic and hard copies of the reports with the Contractor.

31. The next paragraph of the Annex (1.21.4) describes the requirements to the Contractor on arrangement of environmental audit of the environmental safeguards Program at the site. According to the requirement, the Program itself has to be submitted along with the work program within 90 days from the contract conclusion date.

32. The ecologists or the specialists dealing with assessment of the environmental competence of the bidding participants were not present in the bidding board composition during the bidding processes9.

33. The contract documents considered10 also comprise the requirement on the Contractor’s compliancО witС tСО ОnvironmОntal rОquirОmОnts. TСО РОnОral rОquirОmОnts on the compliance with the environmental requirements are included in the Section 8 of the Contract Special Terms, p. 22.9 – Environmental Management. This paragraph includes the requirements on formation of the Environmental Management Plan (EMP) at the site with the reference to the p.1.21 Chapter 1 of the General Technical Specifications. It also specifies that the SEMP is subject to tСО ProjОct ManaРОr’s approval.

34. The basic environmental monitoring was accomplished under the EIS prepared at the stage of detailed design on the following indicators: qualitative and quantitative characteristics of the surface water, ground water salinity and table, degree of the land salinity (in per cent against entire area). The monitoring of these indicators was carried out in the course of the project implementation, but not to the full extent which can be proved by environmental monitoring reports. The data on the water quality monitoring for the last 5 years have not been submitted. The data on the soil quality monitoring were presented only by two indicators instead of 24 declared.

6 DHV, Halcrow, September, 2003, Initial Environmental Examination, Supporting Document E, Final Report, Amu Zhang Water RОsourcОs ManaРОmОnt ProjОct, TA № 3908 – UZB. 7 EIS –the document similar to IEE ADB; it development and approval are compulsory for the fulfillment of the project works in line with the national environmental legislation. 8 AZIRP Project, ADB Loan 2069 – UZB - Volume 2. Standard specifications for the contracts AZIRP 04, “RОСabilitation oП Amu-ГanР Pump Station 1”, AZIRP 06, “RОСabilitation oП Amu-Zang Pump Station 2, and AZIRP 08, “RОСabilitation oП BabataР Pump Station”, version as of September 2006. 9 During environmental audit, the bidding board composition approved for accomplishment of the biddings was submitted by the PIU employees. 10 Contract AZIRP 08, Rehabilitation of Babatag Pump Station, between the PMU and MAWR RUz and CUBOTA Corporation (Japan). Section 8, Contract Special Terms.



35. The system of the environmental safeguards documentation was created in the PMU. The Consultant Engineer prepares the monthly technical reports on the project progress for the PMU (Chapter 2, Section 2.4.1 - Environmental Issues). One of the technical report sections provides information on the compliance with the environmental requirements for the reporting period. Moreover, the PMU MES makes the monthly field visits to the construction sites to monitor the compliance with the Environment Protection (EP) requirements. The results of conducted monitoring are documented and submitted in form of inter-office memo to the PMU Manager, followed by the respective measures against Contractors, if necessary.

36. The Consultant Engineer also developed the following working documents: #7 –Environmental Examination, #8 – Project Monitoring System, #19 – Environmental Management Plans and #20 - Monitoring. The working document #19 describes the principal requirements to the SEMP development with specification of indicators for the environmental monitoring.

37. The following environmental documentation is maintained in the PIU (Amu-Zang 1 pump station site): SEMP of Contractors approved by the PIU, Health Protection and Safety Plan. The site with ongoing construction works (Amu-Zang 1 pump station) has the Book of Complaints and Suggestions, wСicС, as oП tСО survОв НatО, СaН а rОcorН maНО bв tСО PIU Manager dates 14.01.2013 on necessity of the timely removal of concrete fragments and remaining waste and their transportation to the specially designated place (Fig. 3, 4). On 21.01.2013 this comment was fulfilled, and the waste was transported to the relevant location. According to the PIU and Contractors, there were no complaints received from the citizens.

Figure 3: Book of complaints and suggestions at the sitО «RОСabilitation oП Amu-Zang pump station of the 1

st

staРО”

Figure 4: Record made by the PIU Manager in the book of complaints and suggestions

38. The PMU prepared two annual reports on environmental monitoring for the ADB for 2012 and 2013, and the first of them, as of the audit datО, publisСОН at tСО ADB’s wОbsitО. The reports contain information on the project progress, the key requirements specified in the SEMP, anН tСО rОsults oП tСО briОП projОcts’ ОnvironmОntal impact assОssmОnt. In tОrms oП environmental monitoring, the report provides the data on the changes of the surface water consumption in Amu-Zang Canal and South-Surkhan Reservoir for 2008-2013, hydrological and climatic indicators at the project area for 2008-2013. The report also contains the data on the results of the soil quality monitoring (2008-2013) and ground water level at the project area (2010-2012).

39. The reports have not been submitted to the communities and central/provincial affiliates of the State Nature Protection Committee. It should be noted, that the loan agreement does not contain these requirements to the Borrower. However, for the contract to comply with requirements of ADB policy on environmental measures (2009) the Consultant recommended PMU to enhance the activities on disclosure of the project information through dissemination of environmental reports among population and other organizations.

40. The Consultant analyzed availability of EMP and the status of its implementation, using as example, the Contract AZIRP 08 – Rehabilitation of Babatag pump station: the



contract between the PIU under the MAWR RUz (Client) and CUBOTA Corporation (Japan) (Contractor). The Contractor developed the Site Environmental Management Plans (SEMPs) basОН on EIS incorporatОН in tСО Contractors’ biННinР НocumОnts (p.1.21.). In the course of the SEMP development, the Consultant Engineer provided consulting support to the Contractors. The SEMPs were approved by the PMUs and ADB. The SEMP draft version was submitted by the Contractor to the PMU in August 2009 (the construction works also started in August 2009). It was recommended to revise the SEMP for observance of all ADB requirements on environmental safeguards and in line with IEE; this revision was carried out in October 2009. The SEMP was submitted to PMU and approved.

41. The delivery and acceptance certificate of the completed work site is prepared after completion of works for each sub-project; and original versions and copies of these certificates are kept with PMU and PIU11. The state acceptance boards comprise representatives from provincial nature protection committees, who certify the fact of compliance with environmental requirements in the course of the project implementation. There was not any final environmental audit conducted after the site commissioning.

1.4. Project Site Audit

42. As it has been mentioned above, the AZIRP is being implemented in Surkhandarya Province of Uzbekistan. The work is coordinated by PMU (Tashkent City) through PIUs located in Termez city Surkhandarya Province. As of the audit date, the project activities were ongoing only at the site Amu-ГanР 1 pump station on tСО contract “AГIRP 04 – Rehabilitation of Amu-ГanР Pump Station 1”.

43. The Consultant conducted construction site environmental audit on October 30, 2013 in presence of representatives from PMU and Contractor (Fig. 5).

44. The Contractor’s base (CNTIC) was surveyed at the Amu-Zang 1 pump station (Fig. 6). TСО Contractor’s oППicО anН tСО prОmisОs Пor tСО tОmporarв accommoНation oП tСО workers are located on surveyed base. According to the PIU anН Contractor’s representatives, due to the constriction work completion, all temporal buildings and equipment will be disassembled (Fig. 9). After construction work completion, canteen will be used by the station workers (Fig. 7).

45. The trailers have the sleeping places; the canteen is located on the second floor in the pump station building. The lavatory is located outside. All domestic waste is kept in the metal container (Fig. 8).

Figure 5: Meeting with PIU Manager and Contractor’s rОprОsОntativОs

Figure 6: Construction base of Contractor at the Amu-Zang 1 pump station

11 As of the survey date, the copy of Certificate of completed works with the list of the state board members was submitted by PMU to the Consultant



Figure 7: PrОmisОs Пor tСО workОrs’ accommodation at the site

Figure 8: Container for construction and domestic

waste

Figure 9: Equipment to be disassembled

Figure 10: Improvement of the pump station territory by the construction and station workers

Figure 11: Building of Amu-Zang 1 pump station

Figure 12: Tank for the construction waste storing

46. As of the audit date, the construction base of visited pump station had the SEMP approved by the Consultant Engineer and PMU; however, there had been no records on the trainings on familiarization with the SEMP.

47. Exhaust oil, diesel fuel and hydrooil are kept on the territory of pump station in the special metal containers and tanks installed on concrete surface (Fig. 14-16).



Figure 13: Personal protection devices and safety engineering in the building of Amu-Zang 1 pump

station

Figure 14: Tank for the storing of the exhaust oil and diesel fuel

Figures 15-16: Tanks for the hydrooil storing

1.5. Conclusions and Recommendations

48. As has already been mentioned above, the present project completion date was December 31, 2013, and indicated recommendations have more informative character, but, in their turn, can be taken into account in preparation and implementation of the next projects.

49. Reviewed project documents: Loan Agreement, bidding documents, contracts between Contractors and PMUs include requirements on the environmental measures implementation. However, in the bidding documents formation, the PIU has to refer to the IEE and SEMP developed at the technical assistance stage. Particularly, this document is reflecting ADB environmental requirements to the fullest extent.

50. In addition, the Ecologist should be included in the Tender Committee or the specialists dealing with assessment of bidders have to be appointed.

51. The SEMPs were developed on audited project and approved by Consultant Engineer and PIU prior to the start of construction works. It is necessary to ensure involvement of the Contractors themselves in this plan development with consideration of specific character of the project sites, based on the SEMP enclosed to the bidding documents. The special forms development for the monitoring of environmental requirements compliance by Contractor (according to the p. 1.21.3 of the Bidding Documents) will help to improve the procedure of reports submission by Contractors to Consultant Engineer, who, in its turn, would transfer them to the PMU.

52. The SEMP implementation is under control of PMU and Consultant Engineer, and implementation observation results are submitted in periodical reports.



53. The control of environmental requirements compliance by the Contractor itself should be ensured, and this has to be documented and submitted to Consultant Engineer and later on – to PMU in form of monthly reports according to the paragraph 1.21.3 of the Bidding Documents.

54. The PMU needs to submit the environmental monitoring reports to the self-governance bodies – neighboring makhallyas and to the provincial nature protection committees, according to the ADB Safeguards Policy Statement (2009) in terms of the project information disclosure.

55. The PMU has been documenting results of environmental monitoring, however the monitoring data do not cover all indicators earlier stated in IEE and Working Document #19 (description is given in the p. 38 of the present document). The monitoring should be conducted on all indicators specified in these documents.

56. Construction works are mainly complied with the EP requirements. Along with that, the disassembled elements of the old equipment should be timely removed from construction site.

57. Completed project works are accepted by the state board comprising the specialist from the local naturО protОction committОО. AltСouРС tСО accОptancО boarН’s opinion comprises the paragraphs on the work completion in line with environmental requirements, the PMU has to accomplish the final environmental audits of all completed sites regarding compliance with EMP and incorporate results of such final surveys in the environmental monitoring reports. Besides, the results the final surveys can be included in the final project completed report as the separate environmental component.



2. WATER RESOURCES MANAGEMENT SECTOR PROJECT

2.1. Brief Information on Water Resource Management Sector Project (WRMSP) (L2492/2493 40086-013)

58. Implementation of the WRMSP Project is carried out in three provinces of Uzbekistan: Samarkand, Fergana and Namangan provinces (Fig. 17). As of the environmental audit date, the Project progress accounted for 59,7%12, and according to the project documents, the Project was assigned the Environmental Category B.

Figure 17: Water Resource Management Sector Project area

59. The Consultant hold the meetings with parties involved in the project implementation studied the number of the project documents and visited the project sites in order to analyze the environmental activity implementation under the project.


60. The MAWR is the project Executive Agency. The main construction works under the project include rehabilitation of 7 pump stations. As of the 2 sub-projects audit date, the project works wОrО unНОr Пinaliгation (“Narpaв” pump station (PS) in Samarkand province anН “BОsСarвk” PS in FОrРana province). The biddings had been conducted on the other five sub-projects and mobilization of Contractors was launched. In this regard, the packet of the bidding documents (bids and contracts) was analyzed on two first sub-projects and the bidding documents on the rest five sub-projects as well.

61. The Project Management Unit (PMU) situated in Tashkent city was established in EA with mandate of overall coordination of the project works through 2 Project Implementation Units (PIU) situated in two project provinces – Samarkand and Fergana

12 The data were submitted by the PMU, October 2013



provinces (Fig. 18). PIU located in Fergana province, provides the management of the project works carried out both in Fergana and in Namangan provinces.

62. The control over compliance with environmental safeguards in PIU has been assigned to the Safeguards Specialist (SS). The SS obligations include conducting of the permanent monitoring on the Environment Protection (EP) and Safety Engineering (SE) requirements implementation, the project sites audit in terms of EP and SE compliance, preparation of the semiannual reports on environmental monitoring to ADB.

Figure 18: Institutional Chart of the Environmental Safeguards Arrangement within the WRMSP

63. The Consultant Engineer from Rhythm Plus13 was hired by PMU for the project management and its implementation monitoring; the staff of this company includes the position of specialist on environmental issues. The job description of the Monitoring Specialist of Consultant Engineer includes the monitoring of environmental requirements implementation by Contactors, preparation of technical reports with environmental component. As of environmental audit date, the company lacked the monitoring specialist; however, such specialist was working since the project implementation launch until April 2013.

64. Contractors’ companiОs СavО vОrballв14 appointed the engineers from the employees of the companies themselves; these employees were responsible for implementation of the environmental requirements at the construction site.

2.3. Project Documentation Analysis

65. The Loan Agreement between the Republic of Uzbekistan (RUz) and ADB of August 24, 2009 is limited to the general requirements to the Borrower on compliance with environmental safeguards at the stage of the sub-projects construction and operation. The paragraph 4.01 of the section 4 of the Loan Agreement specifies requirements to the BorrowОr on ОnsurinР tСat “…tСО projОct will bО implОmОntОН in linО witС administrative, Пinancial anН ОnvironmОntal policiОs”. Almost similar rОquirОmОnts arО imposОН to tСО Borrower to be complied with at the project implementation stage (paragraph 4.07). The

13 Initially, Engineering Consultant was represented by the consortium of the companies - Dongshin Engineering & Consultants Co. Ltd Rhythm-Plus, however, since 2012, only Rhythm-Plus Company has been acting as Engineering Consultant. 14 As of environmental audit date, no official documents on ecologist appointment by Contractors were submitted to the auditors.

MAWR/EA

PMU (Tashkent City) Safeguards Specialist

PIU on Samarkand province

Samarkand City

PIU on Fergana and Namangan provinces

Fergana City

Contractor 1

Contractor 2

Consultant Ecologist (vacant)

ADB



Loan Agreement does not specify the deadlines of the environmental monitoring report submission to the ADB by the Borrower.

2.3.1. Project Documents on Narpay and Besharyk Pump Stations

66. The obligations on the environmental safeguards implementation are included in the biННinР НocumОnts in tСО SОction 8 “SpОcial TОrms”. The Paragraph 9.3 of the bidding НocumОnts НОscribОs Contractor’s obliРations on: (a) ОstablisС tСО activО sвstОm on tСО environmental impact management; (b) implement of all monitoring activities and impact mitigation measures specified in the Initial Environmental Examination (IEE) and EnvironmОntal ManaРОmОnt Plan (EMP), ОnclosОН in tСО SОction 6 (CliОnt’s RОquirОmОnts) and Annex 9 of the Contract Agreement, and ( ) allocatО tСО ПunНs rОquirОН Пor tСОsО measures ensuring. The Contractor has to submit semiannual reports on these measures accomplishment to the Client.

67. The ecologists or the specialists dealing with assessment of the environmental competence of the bidding participants were not present during the bidding processes.

68. EMPs were included in the contract documents of two considered sub-projects (“Narpaв” PS anН “BОsСarвk” PS) (Annex 9 of the contract documents).

69. The basic environmental monitoring was accomplished at the IEE stage; surveyed indicators included: qualitative characteristics of the surface watercourses, soil salinity, ground water table level and their salinity. Currently, the PMU is not carrying out the qualitative monitoring of environment, since requirements on accomplishment of the tool-based environmental monitoring have not been included in the IEE and, respectively, in the Contractor’s contract НocumОnts.

70. The Contractor developed the Site Environmental Management Plans (SEMPs) based on EMPs, included in the contracts. Submitted SEMPs were approved by PMU in January 2012 (prior to the start of construction works).

71. The system of the environmental safeguards documentation was created in the PMU. SS PMU developed the formats on fulfillment of EP requirements at the construction sites. Every week Contractor fills in the formats (Annex 1) and submits them to the PMU for consideration. The formats had been developed in the form of the checklists, but the Consultant suggested their further development in order to submit the clear information on the SEMP requirements implementation.

72. SS PMU carries out monthly inspections of construction sites in terms of environmental safeguards implementation by Contractors. The brief reports are made based on inspection results; in case of incompliance reveal the Contractors are provided with written notifications on revealed shortcomings. The letters also indicate the deadline of the shortcoming elimination. The status of shortcoming elimination is checked by SS during the further visits to the project sites.

73. SEMPs are available in PIUs of both reviewed provinces (Samarkand and Fergana); at that, it should be noted, that only electronic version of the documents was available in Fergana province. However, the SEMPs were not available at the construction sites – survОвОН pump stations. BОsiНОs, tСО PIUs СavО tСО copiОs oП Contractors’ rОports as ПillОН formats, which have not been submitted to PMU. Despite the fact that PIUs are working in close contact with population there are no books of complaints available on the territory of both construction sites. According to the PIU employees of Samarkand and Fergana provinces, received complaints are settled verbally.

74. SES PMU prepared and submitted to ADB two annual reports on environmental monitoring – for 2011 and January 2012 – October 2013, which were published at ADB website. Reports contain the information on the project progress, and SEMP implementation status by Contractors on two projects being completed, as well as on the SEMP availability for the newly starting projects. Reports comprise the table format of the monitoring of



environmental safeguards implementation and SE requirements to be submitted by Contractors every week to PIU and PMU. Environmental monitoring reports provide information on both sub-projОcts (“Narpaв” PS anН “BОsСarвk” PS) and include the table with information on the status of SEMP implementation by Contractors. However, only one table has been made for two sub-projects, which makes it difficult to analyze implementation of environmental safeguards on each sub-project separately.

75. Environmental reports submitted to ADB have not been presented either to the local community, or central/provincial affiliates of the nature protection committee. It should be noted, that the loan agreement does not specify such requirements to the Borrower, but the ADB policy on environmental safeguards (2009) does require it in order to raise the population awareness.

76. However, the WRMSP project developed bulletins in form of brochures in Uzbek with the brief information on the project goals and objectives, and activity planned under the project (Annex 2). Developed bulletins also contain the data on the addresses of PMU (Tashkent) and PIUs (in Samarkand and Fergana Provinces), and contact phone numbers for the citizens to apply to.

77. No one site of two sub-projects under review has been commissioned as completed one. Therefore, the Completion Environmental Audit was not accomplished.

2.3.2. Project Documents of 5 Sub-Projects

78. The contract documents on the rest 5 sub-projects were prepared in the standard form and all of them contain requirements to the Contractor on the environmental safeguards implementation. The paragraphs 9 of the Special Terms of each contract describe requirements detailed in the paragraph 7 of the present report.


2.4.1. “Narpaв” Pump Station, Samarkand province

79. The Consultant was carrying out environmental audit of construction sites from October 30 (Samarkand province) to November 12, 2013 (Fergana province) jointly PMU specialists on safety engineering and environmental issues, PIUs in Bukhara and Kashkadarya provinces, Contractors and Consultant Engineer.

80. “Narpaв” pump station was survОвОН in SamarkanН province. As of the audit date, construction works were under completion at the station – the works on the territory cleaning were underway, the works on the territory improvement were being planned (Fig. 19-20). The major part of construction machinery was moved to the nОw sitО («Suvli” sub-project in Samarkand province) where construction works were supposed to start since 2014.

81. TСО Contractor’s workОrs wОrО mainlв rОprОsОntОН bв tСО local citiгОns, livinР on tСО neighboring territories. In this regard, establishment of the canteens and bathrooms on the tОrritorв oП “Narpaв” PS СaН not bООn ОnvisaРОН. HowОvОr, tСО batСrooms, cantООn anН lavatory, connected to the damp proof pit were constructed under the project for the station employees who will be maintaining the PS at the operation stage.

82. No construction and domestic waste was found on the station site during survey. The fragments of disassembled parts of PS were used after their milling as construction material for construction of access roads to the station (Fig. 21-22).

83. As it has been mentioned above, the major part of construction machinery was alrОaНв rОmovОН Пrom tСО tОrritorв oП “Narpaв” PS to anotСОr construction sitО. DurinР inspection, the FL leakage on the station territory was not revealed. According to Contractor,



the fueling and maintenance of construction machinery was carried out at the specially equipped truck fleet owned by Contractor15.

Figure 19: Consultant is discussing EP issues with representatives of PIU, Consultant Engineerand

contractors

Figure 20: Consultants are analyzing environmental safeguards documentation in PIU on the territory of

“Narpaв” PS (SamarkanН ProvincО)

Figure 21: The trailers for accommodation and containers remained after the project works are

ready for rОmoval to tСО nОw sitО “Suvli” PS (Samarkand Province)

Figure 22: “Narpaв” pump station rОaНв to bО

commissioned

84. In the first quarter of 201216, the Consultant Engineer jointly with SS PMU delivered training courses on compliance with environmental safeguards at construction sites and on SE Пor Contractor’s ОmploвООs.

85. As of the audit date, there were no records (logbook) at the project sites on the training implementation on compliance with environmental requirements, however, according to the Contractor; SS was permanently carrying out outreach activity in verbal form.

2.4.2. “Besharвk” Pump Station, Fergana province

86. TСО rОСabilitation works wОrО also bОinР ПinaliгОН at “BОsСarвk” PS as wОll. As oП the audit date, the concrete works on the station floor and equipment installation were being carried out at the pump station. The site chief engineer was responsible for implementation of environmental safeguards. However, the documentary evidence on assignment of such responsibilities on the engineer in form oП Contractor’s intОrnal orНОr was not submittОН.

87. Construction waste was not found at the station territory. The landfill of Besharyk town was located 800 meters far from the pump station, and according to the agreement

15 Usually such truck feels have necessary facility to maintain all machinery and technics in accordance with national environmental requirements 16 Engineering Consultant has ecologist till the end 2012



between Contractor and respective municipal utilities, domestic and construction waste is disposed there (Fig. 23-24).

Figure 23: “BОsСarвk” pump station tОrritorв

Figure 24: Bin for domestic waste at the station territory

88. The site chief engineer was not able to show the designated place for construction waste storing. It was explained, that the waste is directly kept in bulk at the station territory and then is removed to the landfill.

89. The old concrete pipes remained after the old equipment disassembling will be transferred to the MAWR local departments. Disassembled devices from the old station control point wОrО СanНОН ovОr to tСО “TsvОtcСОrnmОtall”17 processing company for the further processing (Fig. 25).

90. Machine oil and FL were stored in the special premises (Fig. 26-27) in the metal drum and after filling were handed over to the bulk plant.

91. As oП tСО auНit НatО, tСО Contractor’s pОrsonnОl wОrО livinР botС on tСО station tОrritorв anН in tСО oППicО locatОН in “BОsСarвk” rОРional cОntrО. About 10 workОrs wОrО livinР at the station territory. The acceptable living conditions were created for the workers, established the bathroom, lavatory and canteen. All domestic wastewater from the station territory is collected in the dump proof pit with inspection hole (Fig. 28-29).

92. The organic domestic waste (food residues, picking, etc.) are disposed by the neighbors to be used as the fodder for domestic animals.

Figure 25: Old metal pipes will be removed to the “VtorcСОrmОt” Пor procОssinР

Figure 26: Pump station territory

17

National company dealing with retreatment of nonferrous metal



Figure 27: Metal drum for the FL storage

Figure 28: Canteen for construction workers at

“BОsСarвk” PS

Figure 29: KitcСОn, “BОsСarвk” PS

Figure 30: BatСrooms, “BОsСarвk” PS

Figure 31: Dump proof pit where the waste water from canteen, lavatory and bathrooms is discharged

Figure 32: WorkОrs’ bОНrooms

93. Similar to tСО casО witС “Narpaв” PS in SamarkanН ProvincО, in tСО Пirst quartОr oП 2012 the national environmental consultant of Consultant Engineer jointly with SS PMU delivered training courses on compliance with environmental safeguards at construction sites anН on SE Пor Contractor’s ОmploвООs.

94. As of the audit date, there were no records (logbook) at the project sites on the training implementation on compliance with environmental requirements, however, according to the Contractor; SS was permanently carrying out outreach activity in verbal form.




95. Reviewed project documents: bids, contracts between Contractors and PMUs include requirements on the environmental measures implementation, including EMPs. However, during the bidding, no ecologist or the specialist supposed to assess environmental capacity of the bidding participants have not been included in the bidding board committee.

96. The environmental monitoring plan developed under IEE during preparation of the project technical assistance does not envisage any instrumental gauging for the monitoring of environmental quality. The observed parameters need to include the water quality in the neighboring surface and underground sources, air quality and noise (if the works are carried out in the vicinity of the settlements). Their lack does not allow complete evaluating of environmental impact of construction works.

97. The Contractors have developed SEMPs approved by PMU for two of sub-projects under completion. The SEMPs of the rest 5 sub-projects are at the stage of coordination with PMU.

98. The SEMP implementation is under control of PMU through: (i) forms filled in by Contractors and submitted for the PMU consideration, and (ii) field visits by SS PMU. Due to the lack of ecologist, the Consultant Engineer almost is not controlling these issues.

99. The PMU has well-established system of environmental documentation – the Contractor submits environmental reports to PMU. The technical reports of Consultant Engineer on the work progress submitted to PMU also have environmental component. Along with that, the Consultant Engineer has to immediately hire ecologist for ensuring the permanent control at the construction sites and preparation of quarterly environmental reports.

100. The special formats have been developed for Contractor to ease the reporting; these formats are filled in by Contractor every week and submitted to PMU. However, applied reporting format does not allow completely reflecting fulfillment of environmental requirements by Contractor. The SS needs to revise these formats and adapt them to the IEE requirements.

101. SS PMU is accomplishing the certain activity on training of the Contractor's personnel on environmental safeguards. However, such training is to be delivered by Contractor itself on the permanent basis both for the newly hired and existing employees.

102. The PMU is working on the project information disclosure through dissemination of information leaflets among the neighboring makhallyas. This work needs to be enhanced – the reports on environmental monitoring have to be submitted to the local communities and provincial naturО protОction committООs; tСО loР oП citiгОns’ application should be arranged at construction sites, etc.

103. As of environmental monitoring date, there were no completed project sites, and by this reason the final environmental audit was not carried out. The PMU was recommended to accomplish the final environmental audit during the site acceptance as completed one.

104. The Contractors are mainly meeting EP requirements during construction works. Along with that, the attention has to be paid to collection and disposal of domestic and construction waste.

105. More detailed recommendations with indication of the entities responsible for their implementation as well as the terms of recommendations implementation are provided in the Table 2.



Table 2: Recommendation Matrix

# Recommendation Responsible/Actions Implementation

Terms

1

During IEE, specific attention has to be paid to environmental monitoring program and inclusion of the project environmental impact qualitative assessment

ADB At the technical assistance stage

2

During biddings, to include ecologist or the specialist who will evaluate environmental preparedness of the bidding participants in the bidding board composition

PMU – control over fulfillment with coordination with ADB

During implementation

3 To deliver regular training programs on the SEMP implementation for Contractor’s ОmploвООs

Contractor with involvement of Consultant Engineer– training delivery

Introductory training for the new employees and quarterly training for the permanent staff

4

Consultant Engineer has to immediately hire ecologist for ensuring the pОrmanОnt control oП Contractor’s environmental safeguards implementation

Consultant Engineer– hires consultant

Within one month after receipt of the present environmental audit report

5

To improve the reporting formats of Contractors on environmental safeguards implementation in order to meet IEE requirements

Contractor and Consultant Engineer – format finalization PMU – control over fulfillment

Within one week after receipt of the present environmental audit report

6

To submit semiannual reports on environmental monitoring to the local self-governance bodies and nature protection committees

PMU – submits reports

After approval of semiannual report on environmental monitoring by ADB

7

To carry out the final environmental audit at all completed sites in terms of the SEMP implementation and prepare respective report

PMU jointly with Consultant Engineer– accomplishment of the final environmental audits

At the handover of the site of completed project works



3. LAND IMPROVEMENT PROJECT

3.1. Brief Information on Land Improvement Project (LIP) (L2245/2246/0080 37536-1)

106. The institutional issues, project documents and implementation sites of the project activities were reviewed for examination of the environmental safeguards implementation. The LIP Project implementation is being accomplished in the three provinces of Uzbekistan: Navoi, Kashkadarya and Bukhara (Fig. 33). As of the environmental audit, the Project progress accounted for 66,3%18, and according to the project documents, the Project was assigned the environmental category B.

Figure 33: Land Improvement Project area


107. The MAWR RUz is the present project Executive Agency. The PMU based in Tashkent was established for the project implementation in the EA with mandate to accomplish overall coordination of the project works through the PUIs based in Bukhara, Navoi and Kashkadarya provinces (Fig. 34). The safeguards enforcement in PMU has been assigned to the Monitoring and Evaluation Specialist (MES) acting based on the job description approved by the Director General of the Rural Restructuring Agency (RRA) in January 201219. The Project Management Consultant (Consultant Engineer) from Egis International/Islokhatconsaltservice Company was hired by the PMU for the LIP management and its implementation monitoring. The Monitoring Specialist under the Consultant Engineer’s supОrvision is НОalinР witС tСО issuОs oП tСО ОnvironmОntal saПОРuarНs requirements compliance, technical report preparation with environmental component by the Contractors.

18 The data were submitted by the PMU, October 2013 19 The copy of the document was submitted by the PMU to the Consultant



Figure 34: Institutional Chart of the Environmental Safeguards Arrangement in the frame of the LIP Project

108. TСО Contractor’s companiОs assiРnОН tСО ОnРineers from their employees responsible for implementation of the environmental safeguards at the construction site. The EcoloРist’s position witС spОciПication oП tСО proПОssional НutiОs was approvОН bв intОrnal order of Contractor20.


109. The Section 5, paragraph 8 of the Loan Agreement between the Republic of UгbОkistan (RUг) anН ADB oП DОcОmbОr 27, 2007 НОscribОs tСО BorrowОr’s – RUz obliРations as a sОcuritв tСat “… tСО projОct is bОinР implОmОntОН anН all ПacilitiОs arО unНОr construction and operation, the maintenance and monitoring are being accomplished in line witС ОППОctivО ОnvironmОntal laws, norms anН stanНarНs oП tСО BorrowОr anН ADB’s environmental policy. The Borrower guarantees that the MAWR is implementing the monitoring and impact mitigation activities specified in the Initial Environmental Examination (IEE)....and guarantees that the State Nature Protection Committee (Goskompriroda) is also fulfilling its obligations on the monitoring and impact mitigation activities speciПiОН in tСО IEE”.

110. The Loan Agreement does not specify the deadlines of the environmental monitoring report submission to the ADB by the Borrower.

111. The bidding documents for the bids were prepared based on the standard pattern for all Contractors. Therefore, one set of the bidding documents was examined – accomplishment of construction works under the LIP-SW–ICB-304-304 Contract “RОСabilitation oП tСО Main anН IntОr-farm Collectors of the D-2 System in Guzar and KamasСin RОРions oП KasСkaНarвa ProvincО”.

20

The copies of the documents were submitted by the PMU to the Consultant

MAWR/EA

RRA/PMU (Tashkent City) M&E Specialist

PIU – 3 persons (Bukhara City) 1. PIU Manager

2. Irrigation and Drainage Engineer 3. WCA Specialist

Contractor 1 - 3 Bukhara Province

Environmental Engineer

PIU – 3 persons (Navoi City)

1. PIU Manager 2. Irrigation and Drainage Engineer

3. WCA Specialist

PIU – 3 persons (Karshi City)

1. PIU Manager 2. Irrigation and Drainage Engineer

3. WCA Specialist

Contractor 4-6 Kashkadarya Province


Contractor 7-9 Navoi Province


Consultant Engineer Bukhara City and Project sites

(Egis International/IKS) M&E Specialists

ADB



112. The obligations on the environmental safeguards implementation are included in the bidding documents21 in tСО SОction 8 “Contract SpОcial TОrms”, p.63-64. Thus, the p.63 НОscribОs tСО Contractor’s obliРations on: (i) ОstablisСmОnt oП tСО activО sвstОm on the environmental impact management; (ii) implementation of the monitoring and impact mitigation activities (with the reference to IEE22, presented in the Annex 1 to the bidding documents); (iii) allocation of required budget for implementation of activities specified in the items i and ii. The paragraph 64 of the bidding documents provides for the Contractor to submit the quarterly reports to the Client (PMU), including ones on the environmental safeguards activity, described in the p.63.

113. The ecologists or the specialists dealing with assessment of the environmental competence were not present during the bidding processes23.

114. The Contract documents considered24 also comprise the requirement on the Contractor’s compliancО witС tСО ОnvironmОntal rОquirОmОnts. The general requirements on the compliance with the environmental requirements are included in the Section 8 of the Contract Special Terms in the same wording as in the bidding documents with the reference to the Annex 8 – EIS document. Enclosed EIS includes the requirements on formation of the Environmental Management Plan25 (EMP) at the site, description of the pollution control means, environmental monitoring and the relevant training program for the workers (p.1.21.1). The paragraph 1.21.3 of EIS describes the requirements on submission of environmental reports by the Contractor to the Project Manager (PMU) on the monthly basis. Here, the procedure and content of reports submitted for the approval by the Project Manager (PMU) is described as well, along with the requirements on availability of the electronic and hard copies of the reports with the Contractor.

115. The next paragraph of the Annex (1.21.4) describes the requirements to the Contractor on arrangement of environmental audit of the environmental safeguards Program at the site. According to the requirement, the Program itself has to be submitted along with the work program within 90 days from the contract conclusion date.

116. The comparison of the bidding and contract documents (paragraphs 8 and 10 of the present report) demonstrates discrepancies in the item on the frequency of environmental report submission – on the monthly and quarterly basis.

117. The basic environmental monitoring was accomplished under the EIS prepared at the stage of detailed design on the following indicators: qualitative characteristic of irrigated lands, degree of the land salinity (in per cent against entire area), GWT. Currently, the PMU M&E Specialist is continuing the monitoring of these indicators as part of the project monitoring and evaluation activities.

118. The Consultant pointed out that it was feasible to revise the list of pollutants recommended in the Annex 5 of EIS for the monitoring of the water quality. Since the specific character of the works to be implemented under the project will not lead to the increase of concentration of some pollutants specified in the EIS, the accomplishment of the qualitative monitoring on all indicators makes the procedure extremely costly. The Consultant Engineer jointly with the PMU Monitoring Specialist have to revise the water quality indicators and select for the monitoring those that will let assessing the project environmental impact the most efficient way. Revised list of pollutants should be coordinated with ADB.

119. The system of the environmental safeguards documentation was created in the PMU. The Consultant Engineer prepares the monthly technical reports on the project progress for the PMU. One of the technical report sections provides information on the compliance with the environmental requirements for the reporting period. Moreover, the PMU M&E Specialist 21 LIP Project ADB Loan 2245/2246 (SF) – UZB - Volume 1. Documents for the competitive bidding on the construction works procurement, Contract LIP-SW-ICB-304-304, Version of July 2010. 22 In the Russian version the document was translated as Environmental Impact Statement. 23 The bidding commission composition approved for the conducting of the bidding was submitted by the PMU members during environmental audit. 24 Contract LIP-SW–ICB-302-302 betwООn tСО AРОncв on RОstructurinР oП AРricultural EntОrprisОs anН “KoРonsuvkurilisС” OJSC. Volume 2. Standard Technical Specifications. 25 In original wording in the contract this document title is Environmental Safeguards Plan.



makes the monthly field visits for the construction site survey in terms of compliance with the environment protection (EP) requirements. The results of conducted monitoring are documented as well and submitted in form of inter-office memo to the PMU Manager, followed by the respective measures against Contractors, if necessary.

120. The on-site PIUs (Bukhara, Kashkadarya provinces) are maintaining the following environmental documentation: SEMP of Contractors approved by the PIU, the monitoring results for 2007-2012 on: GWT (in brОakНown oП tСО WatОr ConsumОrs’ Associations (WCA)), saline land areas, ground water salt content, cropping capacity, life stock production (in regional breakНown). TСО PIU’s builНinР oП botС provincОs is maintaininР tСО customОr feedback book, and there were no any records as of the survey date (Fig. 35-38). As it turned out, the PIU, Consultant Engineer’s anН Contractors’ ОmploвООs kООp tСО pОrmanОnt contact with the community; the issues, complaints and suggestions emerging from the population are settled verbally through khokimiyats, and the conference calls are conducted every week as well with involvement of the farmers from the neighboring farms.

Figure 35: Action Plan of Contractor on the Safety Engineering and Occupational Safety (Bukhara Province)

Figure 36: Customer Feedback Book on the Site “Rehabilitation of the Main and Inter-Farm CollОctors” in Bukhara Province

Figure 37: The Logbook of Instructions on SE at the Workplace (Kashkadarya Province)

Figure 38: Book of Complaints on the Site “Rehabilitation of the CC Main and Inter-Farm

Collector and Drainage Systems in Kasan Region KasСkaНarвa ProvincО”

121. The PMU prepared two annual reports on environmental monitoring for the ADB Пor 2010 anН 2012 publisСОН at tСО ADB’s wОbsitО. TСО rОports contain inПormation on tСО project progress, the key requirements specified in the SEMP, and the results of the brief projОcts’ ОnvironmОntal impact assessment. In terms of environmental monitoring, the report provides the GWT data for 2010-2012 and comparative analysis of the saline land areas in 2007 (prior to the start of design activities) and in 2012. The report also contains the results of the soil salinity degree analysis at the pilot sites in three provinces for 2010.

122. The report has not been submitted to the communities and central/provincial affiliates of the State Nature Protection Committee. It should be noted, that the loan agreement on the present project does not contain these requirements to the Borrower. However, for the



contract to comply with requirements of effective policy of ADB on environmental measures (2009) the Consultant recommended PMU to enhance the activities on disclosure of the project information through dissemination of environmental reports among population and nature protection committees.

123. The Consultant analyzed availability of EMP and the status of its implementation on example of the Contract LIP-SW–ICB-302-302: the Contract between the Agency on RОstructurinР oП AРricultural EntОrprisОs (CliОnt) anН “KoРonsubkurilisС” OJSC (Contractor). The Contractor developed the Site Environmental Management Plans (SEMPs) based on EIS incorporatОН in tСО Contractors’ biННing documents. In the course of the SEMP development, the Consultant Engineer was providing consulting support to the Contractors. SEMP were approved by the PMUs. The SEMP draft version was submitted by the Contractor to the PMU in December 2012 (prior to the start of construction works launched in January 2013).

124. The delivery and acceptance certificate of the completed work site is prepared after completion of works for each sub-project; and original versions and copies of these certificates are kept with PMU and PIU26. The state acceptance boards comprise representatives from provincial nature protection committees, who certify the fact of compliance with environmental requirements in the course of the project implementation. Neither PMU/PIU employees nor Consultant Engineer are accomplishing the final environmental audit after the site commissioning.


125. As it has been mentioned above, the LIP project is being implemented in the 3 provinces of Uzbekistan. The work is coordinated by PMU (Tashkent City) through PIUs located in respective provinces – Bukhara, Kashkadarya and Navoi. As of the audit date, the project activities in Navoi Province in fact have not been under way due to the contract termination with Contractor. Therefore, the on-site SEMP implementation survey was accomplished only in Bukhara and Kashkadarya Provinces.

126. The Consultant accomplished construction site environmental audit from October 30 to November 1, 2013 in presence of representatives from PMUs, PIUs in Bukhara and Kashkadarya Provinces, Consultant Engineer and Contractors.

127. TСО basО oП Contractor (“KoРonsubkurilisС”) was survОвОН in BukСara rОРion, BukСara ProvincО. TСО Contractor’s oППicО anН sОvОral slООpinР accommoНations arО locatОН on surveyed base. The base with construction equipment and part of construction materials is located Kogon region, Bukhara Province. In parallel, the similar survey of construction site was accomplished in Kasan region, Kashkadarya Province. Construction camp here also comprises several mobile trailers (Fig. 38-41).

128. TСО botС Contractors’ pОrsonnОl (in BukСara anН KasСkaНarвa ProvincОs) mainlв consist of the local citizens who are living in the neighboring settlements. On the project sites located far from the settlements, the workers live in mobile trailers transported to the construction work territories with the help of machinery.

129. The trailers have the sleeping places and small kitchen for the cooking. The conveniences – bathroom and lavatory – are located outside of the premises. All domestic waste is kept in the metal container (Fig. 42-43) or plastic one.

26 The copy of Certificate of completed works with the list of the state board members was submitted by PMU to the Consultant



Figure 38: Meeting of Engineer and Contractor with PIUs managers in Bukhara Province

Figure 39: Contractor’s construction basО locatОН in Bukhara region Bukhara Province

Figure 40: Trailer of accommodation of construction workers at the remote sites

Figure 41: Washbasin at the construction site

Figure 42: Sleeping places for the workers at the construction site (Bukhara Province)

Figure 43: Unloading of the released container for the

domestic waste from construction site

Figure 44: Meeting between PMU representative, Figure 45: Fuel tank



PIU Manager in Kashkadarya Province and Contractor and Specialist on Construction

Supervision

Figure 46: Container with potable water for construction workers

Figure 47: Waste bin at the construction site in Kasan

region, Kashkadarya Province

130. As of the audit date, the construction bases of both surveyed areas had the SEMPs approved by the Consultant Engineer and PMU, however, there had been no records on the trainings on familiarization with the SEMPs.

131. The FLs are not kept on the territory of surveyed construction sites, the machinery maintenance and oil replacement are carried out at the truck fleets located in Kogan region, Bukhara Province and Kasan region, Kashkadarya Province, specially equipped for the maintenance of agricultural machinery (Fig. 48). TСО Contractors’ ОmploвОО’s rОport tСat tСО machinery fueling is carried out with the help of fuel tankers at the construction sites of both provinces with the use of the special metal trays and at the distance from the water sources.

Figure 48: Construction machinery base for the oil replacement, machinery fueling and maintenance

(Kasan region Kashkadarya Province)

Figure 49: Machinery fueling place in Kasan region Kashkadarya Province

132. The truck fleet owned by Contractor was surveyed in Kasan region, Kashkadarya Province. As of the moment of the province survey, the base territory and adjacent road was dampened for prevention of the dust formation. Based on the audit results, the Contractor was made a comment on prevention of the FL spread on the truck fleet territory and taking the relevant actions on its elimination, if any (Fig. 49).


133. Reviewed project documents: bids, contracts between Contractors and PMUs include requirements on the environmental measures implementation. The bidding boards have to comprise the ecologist or the specialist has to be appointed for assessment of the environmental effectiveness of the bidding participants.



134. The SEMPs were developed on surveyed project and approved by Consultant Engineer. In future, it is necessary to ensure involvement of the Contractors themselves in this plan development with consideration of specific character of the project sites, based on the SEMP enclosed to the bidding documents. The special forms development for the monitoring of environmental requirements compliance will help to improve the procedure of reports submission by Contractors to PMU.

135. The SEMP implementation is under control of PMU and Consultant Engineer, and implementation observation results are submitted in periodical reports.

136. It is necessary to clearly determine periodicity of environmental reports submission by Contractors, since the documents have discrepancies mentioned in the paragraph 95 of the present report.

137. The control of environmental requirements compliance by the Contractor itself should be ensured, and this has to be documented and submitted to PMU in for of monthly reports.

138. The PMU needs to submit the environmental monitoring reports to the self-governance bodies – neighboring makhallyas and to the provincial nature protection committees, according to the ADB policy on environmental safeguards of 2009 in terms of the project information disclosure.

139. The PMU is documenting results of environmental monitoring. However, regarding the monitoring of the water qualitative indicators, it is feasible to revise the parameters recommended in EIS and adapt the list of the parameters under observation and analysis frequency on some of indicators. Thus, such parameters as the heavy metals, pesticides and herbicides can be observed much rarely.

140. In accomplishment of construction works, mainly the EP requirements are complied with. Along with that, attention should be paid to the FL storing and handling on the truck fleet territory, prevention these materials spread into the soil and ensuring their elimination in such cases.

141. Completed project works are accepted by the state board comprising the specialist Пrom tСО local naturО protОction committОО. AltСouРС tСО accОptancО boarН’s opinion comprises the paragraphs on the work completion in line with environmental requirements, the PMU has to accomplish the final environmental audits of all completed sites regarding compliance with EMP and incorporate results of such final surveys in the environmental monitoring reports. Besides, the results the final surveys can be included in the project final report as the separate environmental component.






Terms

1

To include the ecologist in the bidding commission composition during the bidding or appoint the specialist who will carry out assessment of environmental capacity of the bidding participants

PMU – control over involvement of ecologist or the specialist in the bidding commission

At the stage of the bidding preparation

2 To conduct the regular trainings on the SEMP implementation for the Contractor’s ОmploвООs

Contractor with involvement of Consultant Engineer – training conducting

Introductory training for the new employees and quarterly training for the permanent staff

3 To develop the special reporting forms on the environmental safeguards implementation for the Contractor

Contractor and Consultant Engineer – form development PMU – implementation control

Within one week after receipt of the present environmental audit report

4

To strengthen control over compliance of environmental safeguards from Contractor’s siНe (especially, in terms of handling the solid domestic waste and FL) and submit the monthly reports

27 to

PMU/Engineer on their implementation at the construction site

Contractor – compliance with EMP requirements, submission of monthly reports Contractor and Consultant Engineer – control

Within one month after receipt of environmental audit report and by the completion of the project works

5

To revise the parameters and frequency of the water quality monitoring at the project sites and make the necessary corrections with the parameters under observation, to coordinate the environmental monitoring plan with ADB

PMU jointly with Consultant Engineer – revision and preparation of revised plan on environmental monitoring ADB – plan consideration and approval

Within one month after receipt of the present environmental audit report

6

To submit semiannual reports on environmental monitoring to the local self-governance bodies and nature protection committees

PMU – submits reports

After approval of semiannual report on environmental monitoring by ADB

7

To carry out the final environmental audit at all completed sites in terms of the SEMP implementation and prepare respective report

PMU jointly with Consultant Engineer – accomplishment of the final environmental audits

At the handover of the site of completed project works

27

In linО witС p.1.21.3 “RОportinР” oП tСО SpОcial TОcСnical SpОciПications oП tСО BiННinР DocumОnts



4. WATER SUPPLY AND SANITATION SERVICES INVESTMENT PROGRAM, TRANCHES 1-3

4.1. Brief Information on Water Supply and Sanitation Services Investment Program, Tranches 1-3 (WSSSIP) (L2564/2633/2825)

143. The project implementation is funded by Governmental funds and ADB loan, mobilizing of which has been stipulated by three tranches. The project covers the improvement of water supply and sanitation services of the regional centres in seven provinces of Uzbekistan and the Republic of Karakalpakstan (Figure 50).

144. Reconstruction of Damkhodja interregional water pipeline with connection of the regional centres of Navoi and Bukhara province, rehabilitation of the sewerage system in Termez city are being implemented under the Tranche 1. The Loan Agreement of the Tranche 1 was signed on December 1, 2009.

145. Rehabilitation of the water supply and sewerage systems in Kokand and Andijan cities as well as Fergana, Margilan cities and Rishtan has been planned under the Tranche 2. The Loan Agreement of the Tranche 2 was signed on May 1, 2010.

146. The following activities have been planned under the Tranche 3: water supply improvement in the settlements of the Republic of Karakalpakstan; Khorezm province; rehabilitation oП “KoвtasС” watОr intakО ПacilitiОs, WDS anН nОtworks in tСО rОРional cОntrОs and rural settlements of Zafarabad and Arnasay regions of Djizzak province; rehabilitation and construction of sewerage networks in Andijan City. The Loan Agreement of the Tranche 3 of the project was signed on February 16, 2012.

147. Initially, it had been planned to implement the program under 3 tranches, however, later on, it was decided to develop the separate projОct “RОСabilitation oП tСО SОwОraРО Systems of Fergana, MarРilan anН AnНijan citiОs”. As a rОsult, currОntlв, tСО InvОstmОnt Program consists of 4 tranches.

148. Since the works on each tranche are being carried out in several regions and cities, several packages of bidding documents have been prepared for each tranche. The project implementation status on each bidding package is presented in the Table 4.

149. As of the Environmental Audit date (November 2013), the project works under the first tranche were under completion in some regions, and the project works in the other regions were planned to be started the next year.

150. The works under the second tranche started only on two packages – Contracts 2633/ICB/3-1 and 2633/ICB/3-2 “RОСabilitation oП tСО WatОr PipОlinО anН SОwОraРО TrОatmОnt FacilitiОs, KokanН Citв” anН “Rehabilitation of the Water Pipeline and Sewerage NОtworks, KokanН Citв”. In 2012 rО-tender was announced on the third package of the tranche 2, and as of the audit date, the process of bid submission was underway. The preparation of the materials for publication of the Decree by the President RUz on this project implementation was ongoing on the fourth tranche.

151. In view of the above, the bidding documents were analyzed on all three tranches of WSSSIP project. Entire package of bidding documents was analyzed in the projects where the construction works were in progress or completed. For this purpose, institutional issues of environmental safeguards and project documents were analyzed and inspection were made to the project activities implementation sites with respect of meeting the environmental requirements.



Figure 50: Project Areas of “ImprovinР tСО WatОr Supplв anН Sanitation” InvОstmОnt ProРram28

28

Materials of ADB PapОr “RОport anН RОcommОnНations oП tСО BoarН oП DirОctors”, SОptОmbОr 2009



Table 4: Project Implementation Status on Three Tranches of “Improving the Water Supply and Sanitation ServicО” InvОstmОnt ProРram

Tranche 1

Project Location

Site Name/Ongoing Works/Project Status Note/Project

Implementation Per Cent Province Region City

1

Surkhandarya Termez Sewerage networks and sewerage treatment

facilities 24%

Bukhara

Galasiya Water distribution station (WDS) Galasiya city and

water supply networks 87%

Gijduvan WDS Gijduvan city and water supply networks 23%

Vobkent WDS Vobkent city and water supply networks 56%

Shofirkon WDS Shofirkon city and water supply networks 60-80%

Romitan WDS Romitan city and water supply networks /

Completed 100%

Navoi

Karmana WDS Karmana city and water supply networks 80-90%

Kiziltepa and

Novbakhor WDS Kiziltepa city and water supply networks 80-90%

Beshrabad WDS Beshrabad city and water supply networks

Completed 100%

Konimekh WDS Konimekh city and water supply networks

Completed 100%

Yangirabad WDS Yangirabad city and water supply networks 99%



Tranche 1

Project Location

Site Name/Ongoing Works/Project Status Note/Project

Implementation Per Cent Province Region City

2

Fergana

Rishtan Reconstruction, expansion and upgrading of existing water supply and sewerage networks

Works have been started. Re-tОnНОr on Contractor’s

selection is underway

Kokand

Reconstruction, expansion and upgrading of existing water supply and sewerage networks

30%

Andijan Andijan Reconstruction, expansion and upgrading of existing water supply and sewerage networks

Works have been started, bidding is underway

3

Djizzak Water supply system in Kuytosh

Bidding has been completed, the documents are under consideration by

ADB for approval

Karakalpakstan Water supply system of the Republic of

Karakalpakstan Works have been started,

bidding documents are under preparation

Khorezm Water supply system of Khorezm Province Works have been started,

bidding documents are under preparation

4 Andijan, Fergana Andijan,

Fergana - Margilan

Sewerage treatment facilities and networks in Andijan and Fergana – Margilan cities

The Decree by the President on the Project implementation is under

preparation



4.2. Institutional Issues of the Safeguards Implementation

152. “UгkommunkСiгmat” AРОncв is tСО projОct ExОcutivО AРОncв. TСО Project Preparation and Management Unit (PPMU) based in Tashkent was established for the projОct implОmОntation unНОr tСО “UгkommunkСiгmat” witС manНatО to accomplisС ovОrall coordination of the project works. The monitoring of environmental safeguards implementation in the PPMU and preparation of the semiannual reports on the safeguards in ADB were assigned to the Environmental Specialist (ES).

153. The PPMU hired the Consultant Engineer – consortium – Eptisa Company (Spain) and UBI Consulting (Uzbekistan) for support to the Investment Program Implementation. According to the Terms of Reference, the Consultant Engineer provides technical support to PPMU in the bidding documentation preparation, project management and PPMU reports development to ADB. The monitoring of environmental safeguards and assistance in the reports preparation are included in the technical support.

154. The Consultant EnРinООr’s team is supposed to comprise ecologist supervising the issues of environmental requirements incorporation in the bidding documents at their preparation stage as well as their further implementation monitoring. However, as of environmental audit date, the Consultant EnРinООr’s team lacked the ecologist and this participant of the project cycle has not presented any documentation on environmental issues either.

155. 5 of 8 project areas were surveyed during the audit, since in the rest 3 provinces either the bidding processes were underway, or preparation activities were ongoing, and Contractors had not been hired yet. Surveyed provinces included: Bukhara, Navoi, Surkhandarya, Fergana and Andijan.

156. One PIU was established in each project area. Each PIU has the specialists in its composition with the obligations to monitor all safeguards implementation during construction (environmental, social, gender), specified in the project documents as well as preparation of rОports on tСО saПОРuarНs Пor tСО PPMU. HowОvОr, in somО provincОs tСО ОcoloРist’s position is combined with the other specialties – procurement specialist, water supply specialist, sewerage specialist and others (Fig. 51).

157. As the audit has showed, such practices of the combining of the specialist – ecologist with the other specialties is not efficient one. In these cases, the specialist does not have the adequate professional qualification in environmental field, combining of two specialties leads to the time deficiency and, respectively, to the quality degradation of the professional duties (at least, on environment-related issues, since the Consultant has analyzed only this component).

158. In 3 provinces (Bukhara, Fergana and Surkhandarya) from 5 surveyed ones, ОcoloРists wОrО oППiciallв appointОН in tСО Contractors’ composition; tСОв wОrО rОsponsible for environmental safeguards implementation at construction sites (Annex 4). Thus, the contractinР orРaniгation “SСinНonР EnОrcom Inc” (SoutС KorОa) is actinР as Contractor in Surkhandarya Province (Termez city). Here, implementation of environmental safeguards has been assigned to the Procurement Specialist. The other Contractors have not appointed the ecologists.



Figure 51: Institutional Chart of the Environmental Safeguards Arrangement on the WSSSIP Project

EA / Uzkommunkhizmat

PPMU

Ecological Specialist

PIU Bukhara

Water Supply

Specialist/ Safeguards Specialist

PIU Termez

Sewage Specialist /

Specialist on Environmental and

Social Issues

PIU Khorezm

Procurement Specialist /

Specialist on Environmental and

Social Issues

PIU Karakalpakstan

Specialist on Monitoring of Project

Implementation / Specialist on

Environmental and Social Issues

PIU Djizzak

Specialist on


PIU Andijan

Specialist on


PIU Fergana

Specialist on


PIU Navoi

Monitoring Specialist / Safeguards Specialist

Consultant Engineer

Ecological Specialist




4.3.1. WSSSIP, Tranche-1

159. As it has been mentioned above, the WSSSIP project areas are located in 8 various regions of RUz, and the monitoring is carried out through the PPMU based in Tashkent and 8 PIUs based in the project areas. The Loan Agreement (LA) # 2564 between the Republic of Uzbekistan (RUz) (Borrower) and the Asian Development Bank (ADB) of December 1, 2009 includes provisions on implementation and operation of the project sites through PPMU and PIUs with consideration of WSSSIP specific character.

160. TСО paraРrapС 1, SОction 5 LA НОПinОs “UгkommunkСiгmat” as ExОcutivО AРОncв responsible for the overall project coordination and implementation, as well as for communication between ADB and respective governmental organizations. Each provincial self-governance authority involved (khokimiyats) will be acting as implementing agency responsible for the project activity in its province.

161. The next paragraph of thО samО sОction З НОПinОs “UгkommunkСiгmat” responsibilities on establishment of the Program Preparation and Management Unit (PPMU) which is supposed to comprise divisions, each of them has to include several specialists (Fig. 52).

Figure 52: PPMU Organizational Chart29

162. TСО paraРrapС 3 oП sОction З НОПinОs PPMU НutiОs, incluНinР its rОsponsibilitв Пor “ОnsurinР compliancО witС saПОРuarНs rОquirОmОnts” (i), “summariгinР anН prОparation oП pОrioНical rОports” (k).

163. TСО paraРrapС 4 З НОscribОs “UгkommunkСiгmat” rОsponsibilitв Пor PIU establishment in each province for the daily management of the project implementation in respective provinces. It also indicates that each PIU should comprise 7 specialists, including environmental specialist (Fig. 53).

29

MatОrials takОn Пrom “ProjОct AНministration MОmoranНum”, ADB, SОptОmbОr 14, 2009, p.8



Figure 53: PIU Organizational Chart30

164. TСО PIU rОsponsibilitiОs НОscribОН in tСО paraРrapС 5 З incluНО “tСО monitorinР oП ОnvironmОntal, social anН РОnНОr impact oП tСО projОct activitв” (О) anН “prОparation anН summariгinР oП invoicОs (accounts) anН rОports to bО submittОН to PPMU” (Р).

165. Besides, the Interagency Council has been assigned with responsibilities to ensure tСО mООtinР oП ОnvironmОntal anН social rОquirОmОnts (З , sОction 2, p.7,).

166. In terms of compliance with environmental requirements, the paragraph 13 section З НОПinОs tСО BorrowОr’s rОsponsibilitiОs on: (i) НОsiРn, construction, manaРОmОnt anН monitoring of sub-projects in line with ADB Safeguards Policy (200231), (ii) under the present project, on funding only of sub-projects related to the category, (iii) development of Initial Environmental Examination (including Environmental Management Plan (EMP) and its implementation budget in public hearing arrangement) according to the requirements of the Environmental Impact Assessment Framework Document (EIAFD) and submission of such IEEs for consideration and approval by ADB, (iv) inclusion of all activities on environmental protection (EP) and monitoring specified in IEE, detailed design (such EMPs have to be revised and adapted according to the project site), and their compliance during construction and operation as well as disclosure to the stakeholders; these activities are also to be included in the bidding documents and contracts on construction works, (v) accomplishment of additional environmental examination in line with ADB Safeguards Policy (2002) and EIAFD; in cases of changes on project location or components after IEE works completion or changes in detailed design which environmental impact has not been preliminary assessed tСО ADB’s approval sСoulН bО obtainОН Пor tСО ПurtСer project implementation, (vi) receipt of all nОcОssarв pОrmits bв “UгkommunkСiгmat”, rОquirОН accorНinР to applicablО laws anН statutory documents RUz, (vii) submission of semiannual progress reports on implementation of impact mitigation measures and monitoring for all sub-projects.

167. The environment protection requirements were included in the bidding documents (sОction – Special Terms, paragraph 63). The documents describe requirements to the Contractor on observance of the environment-related national laws and statutory instrumОnts. TСО Contractor’s rОsponsibilitiОs incluНО rОquirОmОnts on: (а) approval oП tСО

30

MatОrials Пrom “ProjОct AНministration MОmoranНum”, ADB, SОptОmbОr 14, 2009, p.8 31

Consultant is pointing out, that ADB Safeguards Policy was adopted in 2003, however, the information in the present report is given as it is stated in the project documents



functional system on environment impact management, (b) accomplishment of the monitoring and mitigation measures specified in EMP, enclosed as the Annex 1, and required cash distribution. They also include the requirements on submission of semiannual reports on these measures implementation.

168. The bidding documents do not include requirements on the Site Environmental Management Plan (SEMP) development, though this requirement has been included in the loan aРrООmОnt (rОquirОmОnt “Н”, p.13, sОction 2 oП tСО Loan AРrООmОnt).

169. The documents analysis demonstrated that the bidding documents package missed Annex 1, in the despite of the reference to such Annex in the master document.

170. According to PPMU practice, the bidding documents are prepared by the PPMU specialists, the biddings are accomplished with involvement of the managers and specialists of PIUs from the project provinces. The bidding board composition is provided in the Annex 2. The construction works contracts are concluded between PIUs of the project provinces and Contractors. The ecologist or the specialist supposed to analyze the environmental performance of the bidding participants is not presented in the bidding board composition.

171. The Supervision Consultant was hired to provide consulting support on WSSSIP implementation (Consultant Engineer): EPTISA Servicios de Ingenieria S.L. (Spain) in association with UBI Consulting LLC (Uzbekistan). The Contract between PPMU and Consultant Engineer was concluded on December 5, 2012. According to the PAM32 materials, the core functions of Consultant Engineer include rendering of consulting services required for support: (i) implementation and management of the projects approved under Investment Program, (ii) preparation and assessment of suggested projects to be funded under Investment Program, including development of these projects DFS and respective periodical financial requirements.

172. The Consultant Engineer’s tОam was supposОН to incluНО tСО national ОcoloРist familiar with the domestic environmental legislation and ADB environmental safeguards. This spОcialist’s rОsponsibilitiОs incluНО: (i) prОparation oП ovОrall work plan, (ii) iП nОcОssarв, improvement of requirements to the water supply and waste water standards, (iii) monitoring and evaluation of compliance with the project environmental guarantees, (iv) training on environmental issues for the PPMU, PIU and various project consultants, (v) assistance to PIU in development of environmental monitoring program, (vi) submission of information on environmental guarantees for preparation of quarterly progress report, (vii) capacity analysis anН ПurtСОr ОnСancОmОnt anН assistancО to “UгkommunkСiгmat” AРency in environmental strategies implementation.

173. However, as it has already been mentioned above, as of the environmental audit date, Consultant Engineer did not have ecologist staff-member and no consulting support in establishment of environmental activity, environmental monitoring and the other requirements of terms of reference was provided.

174. The contracts between PIUs of the project provinces and Contractors have been concluНОН on tСО moНОl basis. TСО sОction “Contract SpОcial TОrms” worН-for-word repeats EP requirements with similar reference to the Annex 1 which has not been included in the contract documents either.

175. No basic monitoring of environmental quality has been conducted. The project documents do not contain requirements on the monitoring of environmental quality at the project implementation stage either.

176. 2 SEMPs approved by the PIU Manager and prepared on the basis of EMP included in IEE were available in PIU of Bukhara city. All SEMPs were identical, but separately approved for each contract: 2564/ICB/3.2 of December 19, 2012, 2564/ICB/3.6 of November 14, 2011 and 2564/ICB/3.4 of October 26, 2011. However, Contractors implementing construction works did not have such SEMPs. Environmental report to be submitted on the

32

Project Administration Manual (PAM), Annex 14, Terms of Reference Description, section А, paragraph 2, p.54



semiannual basis according to the contract documents have not been submitted by Contractors either.

177. Similar SEMP was submitted to the PIU Navoi city, but without indication of the contract it was applicable to. As of the present audit date, the PIU Navoi city Monitoring and Evaluation SpОcialist was ПulПillinР tСО ОcoloРist’s Пunctions. TСО spОcialist НirОctlв Нealing with environmental and social issues was working in PIU till June 2013. However, due to completion of his project involvement period, starting from June 2013, this specialist was not available. Similar to the case with PIU Bukhara city, Contractors did not have SEMP and reports were not submitted to PIU.

178. PIU Termez city had SEMP for the Contract 2564/ICB/3.3, approved by the Deputy PIU Manager of October 24, 2013 and prepared on the basis of EMP included in IEE. The representatives from the contract anН subcontract orРaniгations («TОran» anН «Alqur»), fulfilling construction works did not have such EMP. Environmental report to be submitted on the semiannual basis according to the contract documents have not been submitted by Contractors either. However, they are submitting monthly reports on the basis of the special checklist developed by the PIU Specialist on environmental, gender and social issues.

Figure 53: Water Supply Specialist/Specialist on Environmental, Gender and Social Issues

PIU Bukhara city

Figure 54: Monitoring and Evaluation Specialist / Specialist on Environmental, Gender and Social Issues

PIU Navoi city

Figure 55: Sewerage Specialist / Specialist on Environmental, Gender and Social Issues

PIU Termez city

Figure 56: Consultant is discussing the issues of EMP implОmОntation witС Contractor’s manaРОr in Navoi

province

179. It is necessary to consider the fact, that the national experts were mainly involved for the project works implementation under this Investment Program (except for construction works in TОrmОг citв, wСОrО SoutС KorОan Companв “SСinНonР EnОrcom Inc” is tСО GОnОral Contractor). As a rule, such experts have lack of experience in SEMP development, and environmental safeguards implemented by them were limited to requirements on fulfillment the works described in the national construction regulations (SNiPs, KMK, etc.)33. Contractors also are not enough qualified in environmental report preparation.

33

SNiP – Sanitarian Norms and Rules, KMK – Construction Norms and Rules



180. The system of environmental activity documentation in PIU Bukhara city consists of:

EMP approved by PIU Manager for each contract separately;

Minutes of the seminar on Gijduvan city population awareness on the project gender and environmental policy at the project implementation stage;

Contractors’ intОrnal orНОrs on appointment of the person responsible for environmental issues. However, the orders do not contain the job description of appointed environmental specialists.

181. The PIU Bukhara city had the book of complaints; however there were no records in this book available.

182. The system of environmental activity documentation in PIU Navoi city consists of:

EMP approved by PIU Manager;

Correspondence between ADB and PIU Navoi city, and correspondence between PIU and Contractors on the issues of EMP implementation and reporting. The Contractors’ reports on environmental requirements implementation have the single character and do not meet EMP requirements.

183. There was no book of complaints available in PIU Navoi city.

184. The system of environmental activity documentation in PIU Termez city consists of:

EMP approved by PIU Manager;

Minutes of the meeting of the representatives from khokimiyat, makhallyas and road servants of July 23, 2013 devoted to ensuring the road traffic safety during construction works;

“Surkhan Sunrise” Newspaper, issues of September 25 and October 3, а а 2013 witС tСО articlО “For ImprovОmОnt oП LivinР ConНitions” on tСО issuОs oП improvement of the municipal sewerage system and brief introduction of the project under implementation;

Correspondence between PIU Termez city and PPMU on submission of Annex 1 to PIU (EMP and IEE) to be included in the Contract according to the requirements of the Contract itself. The letter was dated by August 28, 2013;

Correspondence between PIU Termez city and Contractor of October 25, 2013 with requirement on submission by Contractor of EMP/SEMP, monthly, quarterly and annual reports to PIU Termez city, according to the requirements of the Contract terms. The PIU has also notified, that the Contractor’s company and UBI Consulting LLC should provide the specialists to be responsible of the above assignments fulfillment;

CD with the record of the program (September 2013) of the local TV channel “IsСoncС” witС tСО projОct introНuction;

Comparative table of the treated wastewater in Termez city before and after rehabilitation of the sewerage treatment facilities submitted by SES laboratory to the PIU;

Environmental monitoring report for October 2013 not approved by ADB at that moment. This report requires improvement in order to meet ADB environmental policy requirements.

185. The Consultant made several recommendations in terms of the report format, inclusion oП Contractor’s rОports, traininР componОnt, Нata on tСО outrОacС activitв anН compliance with environmental safeguards implemented at the site with the project documentation. The report has not been submitted to the local community and the nature protection committee. Though the project documents do not contain such requirements, the procedure has to be observed to meet requirements of ADB environmental policy.



186. There was no book of complaints available in PIU Termez city.

187. As of the audit date, Consultant Engineer has not submitted environmental reports neither to PPMU nor to PIU.


188. The Loan Agreement (LA) # 2633 between the Republic of Uzbekistan (RUz) (Borrower) and the Asian Development Bank (ADB) of May 1, 2009 includes provisions on implementation and operation of the project sites through PPMU and PIUs with consideration of WSSSIP specific character.

189. The paragraph 5, Section 4 of the Loan Agreement specifies the terms for the contract award. Subparagraph (d) defines, that the contract cannot be concluded with any sub-project which may have the negative environmental impact, till the Borrower conducts environmental examination in line with the requirements and gets ADB approval for environmental examination.

190. The paragraph 1, Section 5 З is statinР: tСО BorrowОr will ОnsurО anН takО actions Пor tСО “UгkommunkСiгmat” AРОncв to ОnsurО tСО projОct implОmОntation accorНinР to tСО detailed implementation modality established in PAM34.

191. The scheme of the project implementation according to the PMM is provided on the figures 3 and 4, section 2 of the present report. The PMM contains the project data and information enabling the Beneficiary, EA, PPMU, PIU and the other stakeholders and ADB to monitor the project implementation and accomplish the project impact assessment.

192. In terms of compliance with environmental requirements, the paragraph 6 section 5 НОПinОs tСО BorrowОr’s rОsponsibilitiОs on: (a) НОsiРn, construction, manaРОmОnt anН monitoring of sub-projects in line with ADB Safeguards Policy Statement, EIAFD, respective IEE and EMP, (b) including of all activities on environmental protection (EP) and monitoring indicated in IEE in detailed design (such EMPs have to revised and adapted according to the project site), compliance during construction and operation and disclosure to the stakeholders; also, these activities need to be included in the bidding documents and construction contracts, ( ) accomplisСmОnt oП aННitional ОnvironmОntal Оxamination in linО with ADB Safeguards Policy Statement and EIAFD in cases of changes on project location or components after IEE works completion or changes in detailed design which environmental impact has not bООn prОliminarв assОssОН tСО ADB’s approval sСoulН bО obtainОН Пor tСО ПurtСОr projОct implОmОntation, (П) rОcОipt oП all nОcОssarв pОrmits bв “UгkommunkСiгmat”, required according to applicable laws and statutory documents RUz, (g) submission of semiannual progress reports on implementation of impact mitigation measures and monitoring for all sub-projects

193. The environment protection requirements were included in the bidding documents (section – Special Terms, paragraph 63). The documents describe requirements to the Contractor on observance of the environment-related national laws and statutory instrumОnts. TСО Contractor’s rОsponsibilitiОs incluНО rОquirОmОnts on: (а) approval oП tСО functional system on environment impact management, (b) accomplishment of the monitoring and mitigation measures specified in EMP, enclosed as the Annex 1, and required cash distribution. They also include the requirements on submission of semiannual reports on these measures implementation.

194. The bidding documents do not include requirements on development of the Site Environmental Management Plan (SEMP), though such requirement has been included in tСО loan aРrООmОnt (rОquirОmОnt “Н”, p.13, sОction 2 oП tСО Loan Agreement).

195. The documents analysis demonstrated the lack of Annex 1 in the bidding documents packages prepared before conducting of the ADB trainings on environmental safeguards

34

PAM – Project Administration Manual



(August 2013), despite of the reference to such Annex in the master document. The bidding documents prepared starting from October 2013 contain EMP in the Annex 1.

196. As of the audit date on the second tranche WSSSIP, two contracts have been concluded between the PIU of the project areas and for the construction work fulfillment in Kokand city. Both contracts between PIUs of the project provinces and Contractors have bООn concluНОН on tСО moНОl basis. TСО sОction “Contract SpОcial TОrms” worН-for-word repeats EP requirements with similar reference to the Annex 1 which has not been included in the contract documents either.

197. The baseline environmental monitoring has not been conducted. The project documents do not contain requirements on the monitoring of environmental quality at the project implementation stage either.

198. 7 SEMPs approved by the PIU Manager and prepared on the basis of EMP included in IEE were available in PIU Fergana city. SEMPs were developed for each site separately and included 5 WDSs (Water Distribution Systems), water treatment facilities and sewerage treatment facilities.

199. Though all SEMPs had been developed by the PIU ecologist, they all were transferred to Contractor for implementation at the project sites. As of the audit date, Contractors have not submitted reports on the SEMP implementation. The Consultant recommended Contractor and ecologist to develop the special reporting formats in order to simplify the process of report preparation by Contractors and their analysis by PIU ecologist.

200. The system of environmental activity documentation in PIU Fergana city consists of:

EMP approved by PIU Manager for each project site separately;

Minutes of the seminar on introduction of Kokand city population with environmental safeguards under the WSSSIP Tranche-2;

Correspondence between the PIU ecologist with Contractors on arrangement of environmental safeguards;

Results of the PIU ecologist’s audit of the project sites, information letters to the Contractor and official responses to Contractor on the issues of situation remediation.

201. The PIU Fergana city had the book of complaints; however, there were no records available.

202. As of the audit date, Engineering Consultant has not submitted environmental reports on Tranche-2 neither to PPMU nor to PIU.

203. The PIU ecologist of Fergana city prepared two environmental reports – in June 2013 and October 2013. Prepared reports were submitted to PPMU. Environmental report for the 3rd quarter 2013 consists of two volumes (on two effective contracts) and contains the general information on the project, environmental safeguards implemented by Contractor, outreach activity and results of the project sites inspection made by the PIU ecologist. The annexes to reports provide the SEMPs on construction sites and the status of their implementation, the minutes of the PIU meeting with the project area population and the site pictures.

204. In general, the report for October 2013 has been prepared in the format recommended by ADB during the training and meets the principal requirements. The Consultant made several recommendations in terms of the report format, inclusion of Contractor’s rОports, traininР componОnt, Нata on tСО outrОacС activitв anН compliancО witС environmental safeguards implemented at the site with the project documentation. The report has not been submitted to the local community and the nature protection committee. Though the project documents do not contain such requirements, the procedure has to be observed to meet requirements of ADB environmental policy.



205. The M&E PPMU Specialist prepared environmental monitoring report for the first half of 2013 and submitted it to the Project Manager from the ADB side. Currently, the second report for the second half of 2013 is under preparation. No one report has been published at ADB official site.

4.4. Project Area Audit


206. Environmental audit of construction sites was accomplished on October 31 (Bukhara, Termez) and November 1 (Navoi) 2013. The project works mainly included rehabilitation of the Water Distribution Stations (WDS), rehabilitation/laying of the water supply networks in each region as well as rehabilitation of the sewerage networks and sewerage treatment facilities in Termez city.

207. In 4 of 5 regions of Bukhara Province the works were underway, and in one region – Romitan the project works had been completed and the site was commissioned. The project works in Gijduvan, Vobkent and Romitan regions were surveyed on the sample basis.

208. In 4 of 5 regions of Navoi Province the works were almost completed, and as of the audit date, construction works were ongoing only in Karmana region. In this regard, construction works were surveyed in Karmana and Novbakhor regions.

209. As of the audit date, 3 months have passed since the project implementation start in Termez city. The inspections were made at the sewerage treatment facilities with capacity 25 thousand m3/Нaв, bОinР on tСО books oП “Suvokava” UE TОrmОг citв, as wОll as sОwОraРО network located in Al-Termeziy St., Termez city.

4.4.1.1. Project Works in Bukhara province

210. Two Contractors were hired for the WSSSIP project works implementation in Bukhara Province – “Obi KСaвot EnРinООrinР” LLC anН “KimвoСimoвta’minot” LLC.

211. The WDS audit in Gijduvan city was accomplished by Consultant jointly with PIU EcoloРist anН Contractors’ rОprОsОntativО. TСО works on WDS rОСabilitation and water supply networks replacement have been planned under this contract. The construction works at surveyed WDS and water supply networks of Gijduvan city were completed by 23%35. Since construction works were carried out by the local Contractor, the Companв’s workОrs were living in the neighboring area, and there was no construction camp available. The construction materials required both for the WDS and municipal water supply networks rehabilitation were stored on the territory of WDS itself.

212. The construction machinery was kept and maintained on the territory of municipal truck fleet partially rented by Contractor. The machinery fueling was carried out there. The trees cut-off was not carried out under these works.

213. The bulk materials were not placed on WDS territory; the workers were mainly using the sanitary facilities and canteens available on WDS territory. During inspection, Contractor was given comment on necessity of arrangement of collection and disposal of the solid domestic and construction waste. The heavy workloads were not carried out on WDS territory, and machinery was mainly used only at the stage of rehabilitation of existing and construction of new clean water reservoir (CWR). The cases of the oil products and oils spreading at construction site have not been revealed.

35 The data were submitted by PIU specialist on water supply, environmental and social issues



Figure 57: Book of complaints in PIU Bukhara city

Figure 58: Pump station of WDS under rehabilitation

Figure 59: Storing of equipment for the water supply networks on WDS territory

Figure 60: Information stand with the data on the project under implementation in WDS Gijduvan city

214. New WDS construction in Vobkent city was the next audit target. As of the audit date, 56%36 of works in this region was completed. The construction machinery has already been removed from the WDS territory, and the part of construction materials was kept over there.

215. WDS was provided with the sanitary facilities connected to the pit which was cleaned bв tСО local communal sОrvicОs wСОn it was Пull. TСis Contractor’s workОrs wОrО mostly local citizens as well and were living in the neighboring settlements. The WDS territory has the box for the storing of solid domestic waste; according to the PIU Bukhara city specialist, this waste was disposed to the landfill by the communal services.

216. The residential facilities were located close to WDS Vobkent city (approximately 200 m far) and they had the kitchen and resting place for the workers. According the audit, the wastОwatОr Пrom cantООn anН workОrs’ wasСinР Сas not bООn trОatОН anН НiscСarged directly to the local landscape.

217. The Consultant made a comment to Contractor on necessity of arrangement of the catering facilities and washstands according to the domestic sanitary and hygienic legislation and EMP requirements as well.

36

The data were submitted by PIU specialist on water supply, environmental and social issues



Figure 61: Tank used for the water spraying in the dry weather

Figure 62: Box used for the collection of domestic waste on WDS territory

Figure 63: Sanitation facilities and construction materials on WDS territory

Figure 64: Washstand on the territory of rОsiНОntial ПacilitiОs wСОrО Contractor’s workОrs

have lunch

218. WDS Romitan city was the third surveyed site on the territory of Bukhara Province – completed construction; the site was handed over to the local authorities in June 2013. The representatives oП PIU BukСara citв, “Suvsoг” opОratinР orРaniгation anН Contractor siРnОН the delivery and acceptance certificate. There were no representatives present from the nature protection committees among the officials carrying out the sites handover.

219. The territory of inspected WDS was cleaned, and the places of storing of unused construction materials or cases of the oil product spreading were not revealed.

4.4.1.2. Project Works in Navoi Province

220. According to the above, Contractors did not have the EMP. WDSs and water supply nОtworks wОrО inspОctОН on tСО tОrritorв oП Karmana rОРion. TСО “Navoiв KisСlok KurilisС” LLC was selected as a Contractor for this contract. Construction works on WDS were practically completed – accomplishment of improvement works remained.

221. WDS inspection revealed availability of small piles of construction waste, residues of construction materials on the territory, which, according to Contractor, would be removed after completion of all construction works. Some FL spreading was also revealed on WDS territory, and it was recommended to Contractor to remove it in the nearest time.



Figure 65: Remained construction materials on WDS territory

Figure 66: FL spreading on WDS territory

222. The works on construction of water supply networks in Karmana region were completed. Survey of the sites demonstrated that there had been no vegetation cut-off during construction; and light machinery was used during the laying fuelled and maintained at the truck fleet specialized on the machinery maintenance (Fig. 67-68).

223. The territory of construction works was cleaned from construction and domestic waste; the FL spreading signs were not revealed.

Figures 67-68: Sites of completed works on construction of water supply networks

224. The next targets for survey were the construction sites on WDS (rehabilitation of existing WDS) and water supply networks of Novbakhor region (replacement of existing and construction oП nОw onОs). TСО “TОmir-Malik” LLC was Contractor of this contract package. Percent of the project works completion at this site accounted for 92%. The works o WDS were mainly completed – the works remained on installation of equipment on the pump station, and the territory cleaning and improvement.

Figure 69: WDS laboratory building Novbakhor city

Figure 70: Pump station building ready for the pumps installation



225. In WDS inspection, small pile of construction waste was found on the territory, which, according to Contractor, would be removed during the territory cleaning before the site commissioning. Small spots of FL spreading were revealed as well and the comments were made in these terms to the Contractor on their immediate liquidation (Fig. 71-72).

226. The separate storing of the waste – metal, wiping and wooden ones – has been arranged on WDS territory. Later on, this waste was removed to respective organizations for recycling.

227. Construction waste was store in the specially designated place which was clean as of the audit date. The Contractor had official agreement with the local communal services on removal of construction and domestic waste to the municipal landfill (Fig. 73-74).

Figure 71: FL small spreading on WDS territory Figure 72: Place for the domestic waste storing

Figure 73: Construction waste on WDS territory Figure 74: Collection of used metal subjected to recycling

228. The water supply networks lying were under completion in Novbakhor region as well. The works were carried out by several workers along existing highways. Machinery was not used for the pipeline lying due to the small pipe diameter – 14 sm (Fig. 75-76).

229. The work areas were not fenced during construction works on the pipeline lying, and there were no special warning signals arranged. The Consultant has noticed the availability of difficulty with access to the residential premises due to the excavated earth storing in front of the residential building.



Figure 75: Water supply networks laying is carried out without use of heavy-duty equipment

Figure 76: Excavated earth hampering access to the residential building

Figure 77: Workers are laying water supply pipeline

Figure 78: Storing of temporarily disassembled road structures

230. The works were not causing much noise pollution; the workers are watering the territory during the dry and hot weather.

231. There were no books of complaints available either in PIU Navoi city or at construction sites. The log on the training delivery at the construction site was not observed either.

4.4.1.3. Project Works in Termez city

232. The General Contractor - “SСinНonР EnОrcom Inc” (SoutС KorОa) – and several subcontractors were hired for the WSSSIP project works implementation in Termez city.

233. The audit of the sites in Termez city was accomplished by Consultant jointly with the PIU Specialist on environmental, gender and social issues, deputy PIU manager and representatives of subcontractors – “TОran” anН “Alqur” companiОs. TСО works on rehabilitation of the sewerage treatment facilities with capacity 25 thousand m3/day, being on tСО books oП “Suvokava” UE TОrmОг citв, anН rОСabilitation of 8.86 km and construction of 9.14 km of the sewerage network have been planned under this contract. Construction works under this sub-project were completed on 24%37.

234. The sewerage treatment facilities became the first target of survey. Since the works were carried out by the local subcontractor organizations, the workers were living outside the site and there were not construction camp. Construction materials required for the rehabilitation of the sewerage treatment facilities and municipal networks are not stored on the sites, since it is prohibited by requirements of the Sanitary Epidemiologic Station (SES).

37 Data were submitted by PPMU specialist



235. Construction equipment was stored and maintained on the territory of municipal truck fleet, where its fueling took place. The trees cut-off has not been envisaged under implemented works.

236. Consultant did not find any bulk materials on the territory of the treatment facilities; the workers were using the sanitation facilities. There is no canteen on the territory of the treatment facilities since the workers are local citizens and have lunch at home. During inspection, Contractor was given comment on necessity of arrangement of collection and disposal of the solid domestic and construction waste. In some places on the territory small piles of construction waste were observed (Fig. 81-82). The cases of the oil products and oils spreading at construction site have not been revealed.

Figure 79: Building of the pump station under construction on the territory of treatment facilities

Figure 80: Information stand with the data on the project under implementation on treatment facilities Termez city

Figures 81-82: Construction waste on the territory of treatment facilities

237. The construction site has the metal containers for the construction waste storing (Fig. 83). AccorНinР to tСО Contractor’s rОprОsОntativОs, tСО wastО is rОmovОН ОvОrв Нaв Пrom tСО territory of treatment facilities to the places specially designated by SES and provincial nature protection committee. Old metal pipes are collected and disposed by enterprise of water supply and waste water treatment (Vodokanal) (Fig. 84).

238. WDS was provided with sanitation facilities connected to the pit which was cleaned bв tСО local communal sОrvicОs wСОn it was Пull. TСis Contractor’s workers were mostly local citizens as well and were living in the neighboring settlements. The WDS territory has the box for the storing of solid domestic waste; according to the PIU Bukhara city specialist, this waste was disposed to the landfill by the communal services.

239. The residential facilities are located in the immediate vicinity of construction works implementation site (Fig. 85). However, according to the subcontractors and PIU, there were no any complaints by the local citizens regarding the noise or specific smell from construction site. It should be noted that there were no book of complaints and suggestions available either on the territory of treatment facilities and in PIU.



Figure 83: Metal container for construction waste storing

Figure 84: Metal pipes subjected to removal from the site area

Figure 85: Residential building located in the immediate vicinity of the site

Figure 86: Improvement of the treatment facilities territory

240. The territory improvement and planting is underway on the territory of surveyed treatment facilities (Fig. 86).

241. The work site on the laying and rehabilitation of the sewerage networks in Al-Termeziy St. (Fig. 87) was the second surveyed site on the territory of Termez city.

242. The Consultant noticed that during construction works on the trench laying the work sites did not have the proper fences and lacked the warning signals (Fig. 88). According to the PIU representatives, there are reflective tags available in the night along the borders of construction site to avoid the entering the excavated trenches by the people or animals.

Figure 87: Construction site during laying and rehabilitation of the sewerage networks in Al-Termeziy

St. Termez city

Figure 88: Absence of the fencing along the borders of construction site; free movement of people in direct

vicinity of excavated trench

243. The old pipes and construction waste are removed by construction workers from the territory of the sewerage networks rehabilitation while their accumulating (Fig. 89).



244. The Consultant noticed the necessity of watering of access roads to the construction site during the dry weather to avoid the dust spreading through the roads of the city (Fig. 90).

Figure 89: Removal of disassembled pipes and construction waste from construction site

Figure 90: Necessity of watering the access road to the construction site

245. According to the report on environmental monitoring for October 2013 submitted by PIU to Consultant during environmental audit, the construction supervision commissions will be established for complete presentation of all ongoing construction works, including environmental issues. The groups of water consumers had already been established under makhallyas, and there were no significant comments made by these groups in terms of construction works fulfillment.


246. Only in one from five WSSSIP project regions of the second tranche the project works were launched – Kokand city. The project sites inspection on the second tranche was carried out on November 22, 2013. As of environmental audit date on the second tranche, the implОmОntation oП works was onРoinР onlв on two projОct packaРОs: “RОСabilitation oП WatОr Treatment Facilities and Sewerage TrОatmОnt FacilitiОs in KokanН Citв” anН “Construction anН RОconstruction oП tСО WatОr Supplв anН SОwОraРО NОtworks in KokanН Citв”.

247. Consultants inspected:

Ming Tut WDS – water intake facilities

Sewerage treatment facilities in Kokand city

Water supply and sewerage networks on the territory of Kokand city

248. TСО “KuvasoвtamirkurilisС” LLC was tСО Пirst projОct Contractor, anН “ГСuвНamtamircСi” LLC – on the second one. The construction sites inspection was accomplished by Consultant jointly with PIU Fergana city specialist on environmental and social issuОs anН Contractor’s rОsponsiblО pОrson on ОnvironmОntal issuОs. TСО Ecologist of two Contractors was represented by one specialist.

249. The workers involved in the works are transported to construction sited by the buses; they use arranged catering in cafes and canteens of Kokand city.

4.4.2.1. Water Treatment Facilities – Ming Tut WDS

250. As of environmental audit date, the project works on Ming Tut WDS in Kokand city have been completed on 30%. Construction materials used both for rehabilitation of WDS itself and for construction of the water supply and sewerage networks in Kokand city were stored on the territory of WDS.



251. The storing, maintenance and fueling of construction machinery is not carried out on the territory of WDS. All FL-related works are carried out at the truck fleet of Contractor specially equipped for the machinery storing and maintenance.

252. As of the audit date, residues of cut-off trees were located on the WDS territory; and Contractor was planning to give them to the citizens of the neighboring houses to be used for the household needs. The places of uncontrolled storing old construction materials and waste were found on WDS territory. The Consultant made comment to Contractor on necessity of storing of solid domestic and construction waste and their further utilization. AccorНinР to tСО Contractor’s ОcoloРist, all soliН НomОstic wastО anН construction wastО arО transported to the municipal landfill located 300 m far from WDS (Fig. 91-92).

Figure 91: Residues of cut-off trees subjected to utilization

Figure 92: Construction waste on the territory of Ming Tut WDS

Figure 93: Construction and domestic waste on the territory of Ming Tut WDS

Figure 94: Construction materials on the territory of Ming Tut WDS

253. The SEMP was not available at the construction site itself, but it was available in the Contractor’s СОaНquartОrs - Fergana city. There were no records on delivered trainings on environmental safeguards compliance at construction site either. The Consultant was provided with the records on delivered trainings on the health protection and safety engineering. The first-aid kit was available at construction site (Fig.95-96).



Figure 95: List of participants of the training on safety engineering and occupational safety

Figure 96: First-aid kit

254. There was no book of complaints and suggestions available at construction site. However, according to the data of environmental report for July – October 2013 submitted by the PIU ecologist, the seminar was conducted in October 2013 with involvement of representatives from PIU Fergana city and makhallya committees of the project regions. According to the minutes of the seminar #4 of October 24, 2013, during the seminar the PIU Manager Fergana city provide brief information on planned works and environmental safeguards to be complied with in the course of the project implementation.

255. The Consultant noticed as the positive experience the PIU Fergana city activity on population involvement in the monitoring of environmental safeguards implementation by Contractor. According to the agreement reached during the seminar, each makhallya will establish the monitoring group from volunteers supposed to carry out monitoring and cooperate with PIU.

4.4.2.2. Sewerage Treatment Facilities Kokand City

256. Inspection of sewerage treatment facilities in Kokand city showed that the metal waste after disassembling of the outdated equipment was stored and transferred to “VtorcСОrmОt” latОr on. TСОrО is no concrОtО wastО available since the project works have not envisaged disassembling of concrete structures. The other construction material in form of the used bags for the bulk materials, pipe cuttings etc. is stored and removed by Contractor to the municipal landfill (Fig. 97-98).

257. The sand and silt removed from the sand-silt collectors, mud settlers and aerotanks are stored on the territory of treatment facilities and removed later on by the local farmers for the use as fertilizers in the fields. The Consultant recommended carrying out periodical analysis of the qualitative composition of removed sand and silting in terms of the heavy metals presence, since the farmers who were using this material as fertilizers could have applied it for the food crop cultivation.

258. As it has already been mentioned in the previous section, all workers are brought to the treatment facilities in the morning and taken home in the evening; the lunch for the workers is arranged in canteens of Kokand city.

259. The summer shower rooms had been established on the territory of the treatment facilities for the workers, who were not working, as of the audit date (Fig. 99-100). The garbage had been removed from the territory of the treatment facilities; however, Contractor was not able to show the places of storing the solid domestic waste.

260. Though the places of the FL spreading had not been observed during the audit, the Consultant recommended to the Contractor implementing of the action plan on liquidation of the spreads in line with SEMP.



Figure 97: Place of collection of metal items formed after disassembling

Figure 98: Summer shower rooms on the territory of treatment facilities

Figures 99-100: Summer shower rooms and sanitation facility on the territory of treatment facilities

261. There were no EMP and the book of complaints available at construction site.

4.4.2.3. Sewerage and Water Supply Networks in Kokand City

262. As of the audit date, the Contractor was implementing the works of the water supply network lying in residential areas of Kokand city. During the works at the project sites, the Contractor was using the special light reflecting signs and safety tapes. The excavated earth was immediately placed again after the work completion (Fig. 101-102).

263. There was no FL spreading revealed at construction site, and construction waste in form of cuttings of the plastic pipes formed after welding every day was immediately removed after the works completion.

264. During environmental audit, the Consultant team and PIU were approached by the representatives of makhallya where the works were carried out. Makhallya representative expressed satisfaction with the quality of ongoing works and desire of possibility to expand the water supply network (Fig. 104).



Figure 101: Welding operations in pipe laying Figure 102: Installation of the warning signs and safety tapes along the route

Figure 103: View of the street where construction works are carried out

Figure 104: Makhallya representatives are expressing desire on expansion of ongoing works


265. Based on the accomplished environmental audit, the overall conclusions and recommendations have been made for the PPMU, in general, and on each tranche separately, and Consultant hopes that they will facilitate the efficient implementation of the project works on the tranches under implementation and planned ones as well in terms of the ADB environmental safeguards fulfillment.

266. During the bidding documents preparation it is necessary to pay more attention to inclusion of environmental requirements. The audit showed that analyzed bidding documents contained requirements to the Contractor on meeting of environmental Also it is recommended for the PPMU to revise the deadlines of the quarterly reports submission by Contractors to PIU. The Consultant believes it is more efficient to submit the monthly reports in the formats developed by Contractor or WSSSIP Consultant Engineer.

267. During the biddings, the bidding boards of PPMU and PIU need to comprise ecologist who will evaluate environmental capacity of the bidding participants.

268. The practice of combination of ecologist position with the other specialties (specialist on water supply, sewerage, monitoring and evaluation, etc.), existing in the PPMU and PIU decreases efficiency of coordination the safeguards measures. PPMU and PIUs in the project provinces have to employ the separate specialist on environmental and social issues, as specified in PAM.

269. The partial involvement of the safeguard specialists in PPMU and PIU activity significantly reduces the work efficiency as well. Given the scope of implemented works, the combination of the social and environmental sectors, number of the contracts of Investment Program and the project specific character, the Consultant believes it is reasonable to involve such specialists on the permanent basis.

270. PPMU needs to urgently involve Consultant Engineer for consulting support of environmental safeguards implementation, bidding documents preparation, monitoring system establishment and preparation of reports for ADB. As of the audit date, Consultant Engineer was not providing support to the PPMU and PIU, which significantly complicated implementation of environmental requirements at all stages of the project cycle.

271. PPMU, with the help of consulting support from Consultant Engineer, has to deliver additional trainings for PIU ecologists on the issues of environmental safeguards implementation under the Investment Program projects implementation. Though such training has been delivered from ADB side, the consulting support from PIU is required at least at the initial stages of the projects implementation.



272. In most of the cases, the local companies are the project Contractors and frequently lack the experience of the SEMP development in the format required by ADB. Therefore, Consultant believes it is reasonable to involve not only Contractor but Engineering Consultant and PIU specialists to the SEMP development as well.

273. According to the bidding and contract documents, Contractor is supposed to submit environmental reports on semiannual basis. The Consultant recommends PPMU to revise the frequency of report submission and to do it on the monthly/quarterly basis.

274. PIUs of the project provinces with consulting support from Consultant Engineer are recommended to develop reporting formats for Contractors on the SEMP implementation at construction sites.

275. The trainings on the safeguards implementation delivered by ADB provided positive effect and significantly improved the quality of environmental safeguards, and environmental reports prepared by some PIUs. Thus, the report by ecologist of Fergana city prepared in October 2013 meets the principal ADB requirements, though requires minor improvement.

276. The same PIU, as well as in Termez city, has the positive experience in the outreach activity through establishment of commissions on the monitoring of environmental safeguards implementation by Contractor and in construction works fulfillment from the local makhallyas.

277. Among surveyed project sites, within the project works on tranche-2 of Investment Program environmental safeguards are implemented to the fullest extent in Kokand city. However, Contractors need to arrange reporting on the monitoring of EMP requirements implementation at construction sites.

278. PPMU and PIU need to prepare environmental reports on the semiannual basis in line with ADB and submit them for information to the local makhallya committees and nature protection committees. PPMU should involve Consultant Engineer in the report preparation for consulting support.

279. PPMU and PIU need to enhance the work with local communities on the issues of meeting environmental requirements. It is useful to analyze existing experience on these issues in PIUs of Fergana, Bukhara and Termez cities. All PIUs should create the book of complaints and suggestions at construction sites.

280. Upon completion of works on each project, PIU needs to accomplish the final environmental audit in terms of meeting by Contractor of all EIA requirements after completion of construction works. It is recommended to PPMU to make the final payment to Contractor under the contract only after fulfillment of all requirements. In case of unfulfillment, PPMU itself has to carry out the works at the expense of this final payment with involvement of outside companies.

281. MorО НОtailОН inПormation on Consultant’s rОcommОnНations witС inНication oП tСО entities responsible for their implementation as well as the terms of recommendations implementation is provided in the Table 5.





Terms

1

To include entire package of environmental requirements in the bidding documentation (description of the IEE principal provisions, requirements on SEMP development). To pay attention on EMP inclusion in the bidding documentation

Consultant Engineer – assists in the bidding documents preparation PPMU – analyzes and includes EnРinООrinР Consultant’s suggestions in the bidding documents

At the stage of the bidding documents preparation

2

When preparing the bidding and contract documents, to pay attention to requirement on periodicity of environmental report submission by Contractor and recommend the use of approved formats for reporting

PPMU – considers these requirements in the bidding documents preparation for the new projects; To consider possibility of respective amending in effective contracts

For new biddings – at the preparation stage For effective contracts – within one month after receipt of the present report

3

To hire the safeguards specialist under PPMU and all local PIUs on the permanent basis without combination with the other PPMU or PIU specialties

PPMU – ensures implementation of this requirement of PMM

Within two months after receipt of the present report

4

To improve coordination among ecologists of Consultant Engineer, PPMU, PIUs and Contractors

PPMU – ensures implementation of part 2 of Investment Program on capacity building Consultant Engineer – ensures implementation of the contract terms with EA PIU – ensures participation of environmental specialists in the trainings on ecology arranged by Consultant Engineer, carries out the environmental monitoring program recommended by Consultant Engineer, etc.

Through the project implementation

5

To involve Contractors themselves in the SEMP development with consideration of specifics of the project works and their sites

Contractor – prepares SEMP Consultant Engineer – analyzes and approves SEMP PIU – approves SEMP of Contractors, carries out control over timely submission of SEMP

After the contracts award, prior to start of construction works

6

To enhance the training activity among PIUs and Contractors on the issues of environmental requirements implementation

PPMU – arranges trainings with involvement of Consultant Engineer PIU – assists PPMU in the training arrangement, ensures participation of the relevant specialists in the trainings Consultant Engineer –



develops training materials, delivers trainings Contractor – ensures participation of the relevant specialists in the trainings

7

PPMU to revise the format and content of prepared semiannual environmental reports to ADB in terms of meeting the EMP requirements and ADB safeguards

Contractors – submit monthly reports to PIU PIU – prepares semiannual reports in line with IEE requirements PPMU – summarized PIU’s reports and submits the overall report to ADB Consultant Engineer – assists PIU, PPMU and Contractors in preparation of reports in ADB format


8

After submission of semiannual report to ADB to submit reports to makhallyas and provincial nature protection committees

PIU – after submission of environmental reports by PPMU to ADB submits reports to makhallyas and nature protection committees


9

To ensure the meeting of all EMP requirements by Contractors. To pay attention to the issues of collection and recycling of construction and domestic waste, ensuring the population access to the real estate, noise and dust management during construction works

Contractor – delivers trainings on EMP implementation for its employees, ensures EMP observance at construction sites and construction base Consultant Engineer – carries out the monitoring of the training delivery on EMP implementation PMU – analyzes reports submitted by Contractor and Consultant Engineer on delivered trainings and carries out the monitoring of EMP implementation


10

To carry out the final environmental audit for each completed project with respective documentation

PIU – carries out the final environmental audit and prepares report submitted to PPMU PPMU – carries out control over the timely accomplishment of the final environmental audit Consultant Engineer – participates in accomplishment of the final environmental audit and assists PIU in report preparation

Within one month after completion of the works on each project



5. SURKHANDARYA WATER SUPPLY AND SANITATION PROJECT

5.1. Brief Information on Surkhandarya Water Supply and Sanitation Project (SWSSP) (L2466/G0131 40007-013)

282. Uzbekistan Communal Service Agency (UCSA) is an Executing Agency of Surkhandarya Water Supply and Sanitation Project (SWSSP). This project has been marked as Category B project. Project implementation progress as on the moment of Environmental Audit conduction has been stated as 92%38. The Project under consideration is realized for 9 districts, which are Angor, Kizirik, Muzrabad, Sariasiya, Shurchi, Kumkurgan, Djarkurgan, Surkhan districts and Termez city in Surkhandarya province. (Figure 105).

Figure 105: Project area of Surkhandarya Water Supply and Sanitation Project

283. The environmental audit has been conducted on November 22, 2013. Data on each subproject are given in Table 6.

Table 6: Subprojects of SWSSP39

No. Subproject Name Location Contractor Name Subproject Status

1 Kizirik subproject

Kizirik district, the northern part of Surkhandarya region in 80 km from the Termez city

Private Enterprise “SantОСРaгmontaj”

The subproject has been finished at 16.01.2012, the certificate on completion of construction works was issued on February 20, 2013

2 Angor subproject

Angor district, the northeastern part of Surkhandarya region in 30 km from the Termez city

Trading and Manufacturing

EntОrprisО “Parvina”

The subproject has been finished at 20.08.2012, the certificate on completion of construction works in process of issue

38 Data about percentage of SWSSP progress have been provided by Senior Environment Protection Expert from Consulting EnРinООr’s tОam (EnvironmОntal Monitoring Report, November 2013) 39 Environmental Monitoring Report, November 2013



No. Subproject Name Location Contractor Name Subproject Status

3 Djarkurgan subproject

Djarkurgan district, the northern part of Surkhandarya region in 40 km from the Termez city

PC “TuronIrsuvqurilisС”

Construction works are still continuing. The works on establishment chlorination plant, distribution network development, water meter installation, territory improvement, reconstruction of water pump station, toilet block construction at schools are being conducted.

4 Surkhan subproject

Surkhan district, the northern part of Surkhandarya region in 40 km from the Termez city

“278-HKMJ” LtН

Construction works are still continuing. The works on water source development, transmission main, service reservoirs, chlorination plant, distribution network development, water meter installation, structural improvement in office building, chamber (wells), pump station combined with water electrolysis, toilet block construction are being carried out.

5 Muzrabad subproject

Muzrabad district, the western part of Surkhandarya region in 60 km from the Termez city

MCPC “TОrmiг Ta’minot” The subproject has been finished and certificate is issued on March 19, 2013

6 Kumkurgan subproject

Kumkurgan district, the northern part of Surkhandarya region in 80 km far from the Termez city

JV “KimвoСimoвata`minot”


7 Shurchi subproject

Shurchi district, in the northern part of Surkhandarya region in 110 km from the city Termez

Private Firm “HuНoвnaгar”


8 Sariasiya subproject

Sariasiya district, the northern and the northeastern part of Surkhandarya region in 180 km from the Termez city

LLC “TonР Suv QurilisС”


9

Termez subproject

WDC “ManРuгar”

Termez city PC “Muborak Ta`minot

Baгasi”

Construction works are still continuing. The works of water source development, transmission main, service reservoirs, chlorination plant, distribution network development, structural improvement in office building, chamber/wells, pump station combined with water electrolysis are being carried out.

WDC “NortСОrn”

WDC “Micro Нistrict 4”



“Micro Нistrict 5”

Construction works are still continuing. The works service reservoirs, structural improvement in office building, chamber/wells, pump station combined with water electrolysis, landscaping are being carried out


284. The Executing Agency (EA) of SWSSP is USCA. The Project Steering Committee (PSC) under the Cabinet of Ministers of Republic of Uzbekistan, which has been set up to give overall direction and guidance to the SWSSP. The Project Management Unit (PMU) witСin UCSA is implОmОntinР, manaРinР, anН coorНinatinР all projОct activitiОs. PMU’s oППicО is situated in Tashkent city. The Project Implementation Unit (PIU) has also been set up for directly responsibility of day-to-day subprojects implementation in Surkhandarya Province. PIU’s oППicО is situatОН in TОrmОг citв (FiРurО 106).

Figure 106. Institutional scheme of the organization on environmental safeguards within the SWSSP

285. The environmental safeguards control at PMU is entrusted with Monitoring and Evaluation Specialist, who is dealing with all environmental issues under the SWSSP during whole years of project implementation. There is Environmental Specialist at PIU, who is involvОН in НОcision oП ОnvironmОntal saПОРuarНs issuОs on subprojОcts’ sitОs. TСe Monitoring and Environmental Specialist of PMU works in close cooperation with the Senior Environmental Protection Expert (SEPE), who is represented Supervision Consultant (Consultant EnРinООr). TСО ConsultinР EnРinООr’s tОam, wСicС is Eptisa SОrvicious de Ingenieria S.L. & UBI Consulting LLC, manages and monitors the SWSSP implementation.

286. The Environmental Impact Assessment (EIA) was done by “ISLOHOTKONSALTSERVIS” LLC in tСО FОasibilitв StuНв staРО, in 2008. LatОr, in 2009, tСО contract agreement was signed between the PMU and "Loyiha Maslahat" company for



consulting services for preparation of detailed design and construction documentation, as well as IEE, Summary Initial Environmental Examination (SIEE) and Environmental Monitoring and Management Plan (EMMP).

287. As it was said above, the SWSSP consists of 9 subprojects and each subproject has different Contractors (Table 7). For more information about subprojects see Table 6.

Table 7: SubprojОcts’ Contactors oП SWSSP

No. Subproject Name Contractor Name

1 Kizirik subproject PrivatО EntОrprisО “SantОСРaгmontaj”

2 Angor subproject Trading and Manufacturing Enterprise

“Parvina” 3 Djarkurgan subproject PC “TuronIrsuvqurilisС” 4 Surkhan subproject “278-HKMJ” LtН 5 Muzrabad subproject MCPC “TОrmiг Ta’minot” 6 Kumkurgan subproject JV “KimвoСimoвata`minot” 7 Shurchi subproject PrivatО Firm “HuНoвnaгar” 8 Sariasiya subproject LLC “TonР Suv QurilisС”

9

Termez subproject

WDC “ManРuгar”

PC “Muborak Ta`minot Baгasi” WDC “NortСОrn”

WDC “Micro Нistrict 4” “Micro Нistrict 5”

288. With the words of the SEPE, in each subproject there were appointed the specialist, mostly Construction Supervisor, to coordinate the works on environmental protection and implementation of EMMP in the subproject, as well as preparation and submission of quarterly progress reports on implementation of EMMP to PIU, PMU and the SEPE.


289. The paragraph 10, Schedule 5 of the Loan Agreement between Republic of Uzbekistan and Asian Development Bank on Surkhandarya Water Supply and Sanitation ProjОct НatОН 20 April, 2009 statОs ПollowinР “…TСО BorrowОr sСall, anН causО UCSA to ensure that (a) the Project facilities are constructed, operated, maintained and monitored in conformity with all applicable laws and regulations and standards for environmental protection, health, labor and occupational safety, ADB Environmental Policy (200240), the IEE, and the SIEE for the Project; (b) any adverse environmental impacts during construction and operation are minimized by implementing mitigation measures and monitoring program detailed in the EMMP set forth in the IEE; (c) the progress on the EMMP implementation and any violations of environmental standards are reported to ADB semi-annually in accordance with the specifications set forth in the IEE; and (d) the EMMP is incorporated in the bidding НocumОnts…”

290. In the Section 7, General Conditions of Contract documents, the clause 63. “EnvironmОnt” mОntions about tСО obliРatorв oП contractors in tОrms oП IEE, SIEE, as well as EMMP. But the Consultant identified that these documents were not attached to contract НocumОnts (itОm 63.2 “..TСО Contractor sСall…(b) carrв out all oП tСО monitorinР anН mitigation measures set forth in Initial Environmental Examination (IEE), Summary Initial Environmental Examination (SIEE) and Environmental Management and Monitoring Plan (EMMP) attached in Appendixes 1 – 3..”). PMU, as it turned out, was informed by the

40 The Consultant noticed that ADB Environmental Policy has been approved at 2003, but in this report the Consultant used data in such view as it is done in project documents.



Consulting Engineer (Letter from the Consulting Engineer to PMU, Ref. EU-028, dated on 18.08.2010) about necessity to include IEE, SIEE and EMMP to bidding and contract documents and arrange with design consultant to get updated version of these documents and submit to the ADB for reviews and approval. With words of the SEPE, there was no any conformed information mentioned above Пrom PMU’s siНО. Therefore, after some time left, the SEPE of Consulting Engineers’ tОam Сas prОparОН РОnОral НocumОnts oП tСО contract agreement regarding IEE, SIEE and EMMP. The notification of this activity has been stated in next letter to PMU with attached IEE, SIEE and EMMP in it (Letter from the Consulting Engineer to PMU, Ref. EU-029, dated on 23.08.2010).

291. The item 63.2 (c) of Contract documents includes part of Reporting on all monitoring anН mitiРation mОasurОs sОt ПortС in IEE, SIEE anН EMMP: “…TСО Contractor sСall submit quartОrlв rОports on tСО carrвinР out oП sucС mОasurОs to tСО EmploвОr..”.

292. As it has been found during the Environmental Audit, Bidding documents for each subproject have been done at the same principle. The Consultant has been provided of the Bidding documentation on Contract 2466/NCB/02 - Construction of Water Supply and Sanitation Systems in Angor district of Surkhandarya province, issued on 16 March 2010. The Bidding НocumОnts’ analвsis sСowОН tСat ОnvironmОntal saПОРuarНs part is absolutОlв the same as in Contract documents – Section 7, General Conditions, the clause 63. “EnvironmОnt” (sОО para. 290 – 291 of given report). The Appendixes 1-3 (IEE, SIEE and EMMP), which are noticed about in this clause, have been also not attached.

293. The Environmental Specialists were not present during the bidding processes.

294. With the words of the SEPE, the IEE, SIEE and EMMP in its original versions have bООn prОparОН bв “ISLOHOTKONSALTSERVIS” LLC anН "LoвiСa MaslaСat" companв. As it has been noticed, by the SEPE, data included in original IEE were outdated till the moment of starting the project implementation (2010), so it was recommended to update them. Also, original versions of these documents were not included into Contract and Bidding documents (see para. 290). The revised by the SEPE versions of IEE, SIEE and EMMP were attached now to updated Contracts and Bidding documents and sent to Contractors. These revised versions were given to the Consultant by the SEPE during the meeting at PMU office.

295. However, during the reviewing Contract and Bidding documents at PIU and Contractor’s basО, tСО Consultant was РivОn oriРinal vОrsion oП tСОsО НocumОnts witС all updated Appendixes and approved by PIU and Contractor, what means that Contractors are informed and agreed with environmental safeguard requirements concerning SWSSP.

296. There was not any baseline monitoring within the Environmental Impact Assessment prepared at project design stage (Feasibility Study stage).

297. As to environmental documentation during project implementation, it is presented by Environmental Monitoring reports (EMRs) on semiannual base and monthly reports on implementation of measures on environmental protection and monitoring plan for each subproject. The SEPE prepared semiannual EMRs, from the period of July 2010 to July 2013, wСicС Сas bООn publisСОН on ADB’s wОbsitО on DОcОmbОr 27, 2013. TСО EMR contains information on project progress implementation, environmental monitoring quality as well as implementation of EMMP and such.

298. EMRs were not provided to local communities and relevant government agencies. It should be noticed, that this kind of requirements was not included to the Loan Agreement.

299. Contractors prepare monthly reports, which contain monitoring form on implementation of EMMP in subproject. At the same time, the SEPE from Consulting EnРinООr’s tОam prОparОs spОcial monitorinР cСОcklist oП implОmОntation oП EMMP on all subprojects.

300. Quarterly Progress Reports, which are prepared by Consulting Engineer on a regular basО, contain ОnvironmОntal saПОРuarНs part, wСicС callОН “EnvironmОntal ProtОction”, Пor each subproject separately. Besides that, the SEPE on his own initiative visits sites on a quarterly base for reviewing Environmental Safeguards implementation there.



301. The monitoring on sites has been conducted on such parameters as noise, dust, vibration, soil quality, air quality, surface and groundwater protection, but only on visually base. The instrumental analysis on all these parameters has not been carried out due to lack of provision with specific equipment and uncreated Environmental Monitoring Group (EMG) as it is required by IEE41. The notification of preferable establishment of EMG has been stated also in official letter to PMU from the SEPE (Ref. EU-018, dated on 20.07.2010). The answer on this letter was given with creation of this group, but only on October 2013.

302. Created EMG should conduct monitoring of EMMP implementation at the subprojects sites under the process as well as for finished subprojects on the quarterly base and report to PMU, PIU and the State Nature Protection Committee of Surkhandarya province.

303. The SEPE has conducted several trainings, presentations and study lessons for PMU, PIU as well as local authority representatives and teachers and teens.42 The main information about conducted trainings is presented in Table 8.

Table 8: Trainings and meetings within SWSSP regarding to Environmental Safeguards issues

No. Training Date Training Place Participants Purpose

1 July 8, 2010 The Khokimiyat of

Angor district

Representatives of local administration, heads of rural citizens' gatherings, school directors, heads of preschool institutions and citizens (40 people)

Give the brief information about environmental impact by project activity, description of environmental management and monitoring plan as well as to establish EMG.

2 July 9, 2010 The Khokimiyat of

Kizirik district

Representatives of local administration, heads of rural citizens' gatherings, school directors, heads of preschool institutions and citizens (30 people)

Give the brief information about environmental impact by project activity, description of environmental management and monitoring plan as well as to establish EMG.

3 December 17,

2010

TСО scСool № 1 in d/c Sarik of Kizirik

district

More than 60 pupils of the 6-8th classes and teachers of this

school

Presentation about the SWSSP and EMMP implementation

4 December 17,

2010 TСО scСool № 1 oП

Angor district

About 200 pupils of the 8-9th classes and teachers of this

school

The matter of approaches, methods, results and recommendations of EMMP, as well as sanitation program under the project.

5 December 18,

2010 PIU of SWSSP

The Contractors of subprojects of Angor, Djarkurgan, Muzrabad and

Kumkurgan districts

Presentation on ADB Environmental Policy, ADB Safeguard Policy Statement, Environmental situation in Uzbekistan, as well as the Environmental policy of the SWSSP, request and rules under EMMP

41

Initial Environmental Examination for Surkhandarya Water Supply and Sanitation Project (June 2008), Section F. Institutional Requirements and Environmental Management and Monitoring Plan, Chapter 1, para. 43. 42 Data on conducted trainings have been provided by Senior Environment Protection Expert to the Consultant during the Environmental audit



6 August 3, 2011 Uzkommunkhizmat The Contractors

Presentation on Implementation of EMMP in the sub-projects with recommendation about mitigation of impact to environment

304. The Consultant has reviewed the Site Environmental Management Plan (SEMP) existence and founded that there are no any requirements in project documentation regarding to SEMP preparation by Contractor. However, SWSSP documentation (Loan Agreement, Contracts and Bidding documents) in the part of Environmental safeguards contains statements about necessity of carrying out all of the monitoring and mitigation measures set forth in IEE, SIEE and EMMP.

305. Since civil, earth and construction works in the rest subprojects (Sariasiya, Shurchi, Kumkurgan, Djarkurgan, Surkhan) are at final stage and main works have been almost finished. After completion of works the Acceptance Certificate of completed works on site must be issued. The original and copies of this document should be sent to PMU and PIU. As a part of the State Acceptance Committee, it must be included representatives of the Nature Protection Committee, which certify the fact of compliance with environmental requirements during the project implementation. Also, according to the requirements of ADB Environmental Policy, should be conducted separate final environmental audit after the project completed. The Acceptance Certificate of the subproject in Kizirik district was given to the Consultant according to completed works. It was found that there has been representative of the Nature Protection Committee as required.


306. As it has been mentioned above, the SWSSP is being implemented in Surkhandarya province of Uzbekistan. The work is coordinated by PMU (Tashkent City) through PIU located in Termez city of Surkhandarya province.

307. The Consultant accomplished construction site environmental audit on February 4, 2014 in prОsОncО oП rОprОsОntativОs Пrom PIU anН Contractor anН survОвОН Contractor’s base and 2 objects, one of them is under construction and the other has been already finished.

308. The base of Contractor (PC “Muborak Ta’minot Baгasi”) was survОвОН in TОrmОг citв. It sСoulН bО noticОН tСat tСis Contractor is carrвinР out works in 4 objОcts: WDC “ManРuгar, WDC “NortСОrn”, WDC “MicroНistrict 4” anН WDC “MicroНistrict 5”. TСО Consultant Сas bООn rОviОwОН WDC “ManРuгar” anН Contractor’s sitО itsОlП.

309. TСО Contractor’s oППicО, construction ОquipmОnt anН part oП construction matОrials arО located on surveyed base (Fig. 107-108). There are several organizations which lease this basО Пor tСОir oППicОs bОsiНОs PC “Muborak Ta’minot Baгasi”. TСО Contractor usОs tСis basО as service station, construction technique keeping and its maintenance.

310. TСО Contractor’s staППs mainlв consist oП tСО local citiгОns wСo arО livinР in tСО neighboring settlements and nobody from them is living at sites.

311. BОsiНОs oППicО, Contractor’s basО Сas kitcСОn Пor tСО cookinР anН НininР room Пor workers and first aid kit as well (Fig. 109-110). The WC is located outside of the premises and presents existent cesspool. All domestic and construction wastes are kept in the metal containers (Fig. 112) and taken out by community facilities as required.



Figure 107: Meeting with PIU Manager and Contractor’s rОprОsОntativОs

Figure 108: Contractor’s base, PC “Muborak Ta’minot Baгasi”, in Termez city

Figure 109: Dining room for workers and kitchen for cooking

Figure 110: First aiН kit at Contractor’s basО

Figure 111: Registration Journal of instruction at work place

Figure 112: Containers for domestic ad construction

wastes at Contractor’s basО

312. As oП tСО auНit НatО, tСО survОвОН Contractor’s basО oП PC “Muborak Ta’minot Baгasi” СaН tСО SEMP approvОН bв tСО Contractor anН PIU (AppОnНix 5). Also, the Chief Engineer mentioned about Registration Journal of instruction at work place, where they note records on the trainings concerning the Health and Safety Engineering (Fig. 111).

313. TСО nОxt rОviОwОН objОct Сas bООn WDC “ManРuгar” situatОН in TОrmОг citв as wОll (Fig. 113). Unfortunately, there were not workers on construction site as on the audit date, because of adverse weather conditions. So, the site visit was accomplished in presence of PIU Manager only.

314. NowaНaвs, WDC “ManРuгar” is still unНОr construction anН as coulН bО sООn Пrom photos, construction works are conducted on reconstruction of the machine hall (Fig. 115-116) and chlorination plant, as well as on replacement of old wells and pipes. The new equipment is mostly situated at construction site (Fig. 114).



315. According to the PIU Manager, the construction site has the metal containers for the construction waste storing. The waste is removed every day from the territory of treatment facilities to the places specially designated by SES and provincial nature protection committee. The workers from enterprise of water supply and waste water treatment (Vodokanal) take the old metal pipes and recycle them, when necessary.

316. The settlements are located in the immediate vicinity of construction works implementation site. However, according to the PIU Manager, there were no any complaints by the local citizens regarding the noise from construction site. It should be noted that there were no book of complaints and suggestions available both at the WDC territory and in PIU. At tСО PIU’s oППicО tСОrО is tСО ПolНОr Пor incomО lОttОrs, wСicС coulН bО usОd also as Grievance Redress Mechanism.

Figure 113: WDC “ManРuгar”

Figure 114: Keeping of a new metal pipes and wells for

replacing the old one

Figure 115-116: TСО macСinО Сall unНОr rОconstruction at WDC “ManРuгar”

317. The cases of the oil products and oils spreading at construction site have not been revealed.



Figures 117-118: NОw WC constructОН at tСО WDC “ManРuгar”

318. WDC “KunРraН” was tСО sОconН survОвОН sitО on tСО tОrritorв oП SurkСanНrвa province, but located in Muzrabad district. This is the completed construction; the site was СanНОН ovОr to tСО local autСoritiОs on MarcС 19, 2013. TСО rОprОsОntativОs oП PIU, “Suvsoг” operating organization and Contractor signed the delivery and acceptance certificate. There were representatives from the nature protection committees present among the officials carrying out the sites handover.

319. The Consultant reviewed chlorination plant, machine hall and administrative office for WDC staffs (Fig. 119-121, 124). The WC has been also reconstructed as required (Fig. 122).

320. The territory of inspected WDC is surrounded by fence (Fig. 123). There was clean on site, and the places of storing of unused construction materials or cases of the oil product spreading were not revealed.

Figure 119: Constructed building with chlorination plant and machine hall inside

Figure 120: The chlorination plant at the WDC “KuРraН” in MuгrabaН Нistrict

Figure 121: TСО macСinО Сall at tСО WDC “KuРraН” in Muzrabad district

Figure 122: New WC constructed at the WDC

“KunРraН”

Figure 123: The fence surrounded the WDC “KunРraН”

Figure 124: Administrative building for WDC

“KunРraН” staППs




321. Reviewed project documents (tender documents, contracts between the IA and the Contractors) include requirements to comply the environmental measures with reference to Appendixes 1-3. However, these Appendixes were not included in the above mentioned documents (see para. 290 -292 of this report). Updated versions of the IEE, SIEE and EMMP (e-copies) provided to the Consultant during the environmental audit, were not approved by the PMU and ADB. But, even so, during the audit of the construction site and PIU office, has been founded that all contracts of the subprojects contain updated versions of IEE, SIEE and EMMP, because PIU provides it. In this case and for future projects, the Consultant was recommended to PMU to stress the importance of the detailed reviewing of project documentation in terms of including all necessary parts and Appendixes.

322. The Environmental Specialists were not present during the bidding processes.

323. According to ADB Safeguard Policy Statement (2009) in terms of the project information disclosure, the Consultant has recommended to PMU to submit EMR to the local authorities (khokimiyat and nearby makhallas), as well as to the local Nature Protection Committee (see also para. 298 of given report).

324. Completed project works are accepted by the state board comprising the specialist from the local Nature Protection CommittОО. AltСouРС tСО accОptancО boarН’s opinion comprises the paragraphs on the work completion in line with environmental requirements, the PMU has been recommended to accomplish the final environmental audits of all completed sites regarding to the compliance with EMMP and incorporate results of such final surveys in the environmental monitoring reports. Besides, the results of final surveys can be included in the Completion Report on the project as the separate environmental component. The SEPE has noticed that the Head of the EMG is also the head on Inspection of Water objects Control and Protection in the State Nature Protection Committee of Surkhandarya province.



6. TALIMARJAN POWER PLANT EFFICIENCY IMPROVEMENT PROJECT

6.1. Brief Information on Talimarjan Power Plant Efficiency Improvement Project (TPPEIP) (L2629/2630 43151-023)

325. To study the implementation of environmental requirements for this project institutional aspects of environmental performance, design documents were considered and the place of project activities was examined for compliance with environmental requirements. TPPEIP project is implemented in Kashkadarya region (Fig. 125). Progress of the project at the time of the environmental audit was about 5%43. According to the project documentation environmental category of the project – A.

Figure 125: Talimarjan Power Plant Efficiency Improvement Project area


326. The Executing Agency of for TPPEIP project is State Joint Stock Company (SJSC) "Uzbekenergo", Unitary Enterprise «Talimarjan TPP". To implement the project PMU is created within EA, located in Tashkent, the task of which is the overall coordination of the project through the Working Group (PIU) "Talimarjan TPP" is located in Kashkadarya region, in the village of Nuristan (Fig. 126). Monitoring compliance with environmental issues in PIU is entrusted to Specialists on Environmental Protection. Also there is an Environmentalist at the TPP, who is also responsible for carrying out environment protection activities at the station. To manage TPPEIP project and undertake monitoring of project implementation Project Management Consultant (Consultant- Engineers) work with PIU. «Corporate Solutions Consulting Limited and Mott MacDonald» are Consultants for the Project. Experts on Environmental Protection (International and National experts) from Consultant- Engineers team deal with monitoring the implementation of environmental

43 Data is provided by Manager of ETTPP Project, October 2013



requirements by the Contractors, preparation of technical reports, which in turn contain the environmental component.

Figure 126. Institutional chart of environmental protection activities under the TPPEIP

327. GОnОral Contractor oП tСО ProjОct is tСО companв «HвunНai EnРinООrinР anН Construction and Daewoo International Consortium» oП (SoutС KorОa). TСО companв Сas appointed Engineer in Health Protection, Technical Safety and Environmental Protection from company staff member, who is responsible for the implementation of environmental protection requirements on the construction site, along with issues of health and safety.

328. Subcontractors are represented by three organizations: JSC "TupalangSuvGesKurilish" responsible for the construction part of the project, JSC of "TuronElektroMontaj" – carries out Electrical Installation and JV of Electroizolit" – is responsible for thermo-mechanical works. All three subcontractors are local (Uzbekistan).


329. Section 5, Clause 3 of the Loan Agreement between the Republic of Uzbekistan (Uzbekistan) and ADB dated May 1, 2010 describes the obligations of the Borrower – Republic of Uzbekistan, represented by SSC "Uzbekenergo" to ensure that "... the potential adverse environmental impacts arising from the implementation of the project will be mitigated through the implementation of mitigation measures presented in the Environmental Impact Assessment (EIA) and Environmental management Plan (EMP ) ... " . It also mentions that "... The Borrower shall ensure that" UZBEKENERGO " ensures that (i) during



the construction contractor has a primary responsibility for implementation of mitigation measures and activities of the EMP, and that the PMU will have access to sufficient resources to ensure that all environmental measures included in the contract; (ii) The PMU will monitor and record performance of the EMP developed for the project, under the leadership of the State Committee ..".

330. Loan agreement specifies deadlines for submission of reports on environmental monitoring to ADB prepared by the Borrower. In accordance with this, "..PMU, with the support of Consultant Engineer develops semiannual environmental reports and provides them to ADB within three months after the end of each half of the calendar year, from the beginning of the project and to completion of the project". Loan Agreement also mentions that the report "will also include reviewing the implementation of the project, based on the environmental activities described in detail in the EIA and EMP, and existing problems, and adopted mitigation measures ...".

331. Contractor's obligations on the implementation of environmental requirements are included in the bidding documents in section 6.2 "Technical Specifications (Section A", Chapter 16. Environmental and other legal requirements in the site, clauses 16.1-16.6. Thus, clause 16.1 describes the Contractor's obligation to develop and submit to the Client the Site Based Management Plan - SBMP at a time agreed with the Client. It is specified that SBMP should among others include elements of environmental management, including : (i) a plan for noise control; (ii) a plan to combat dust; (iii) a plan for controlling emissions of harmful substances into the atmosphere; and others. Clauses 16.3-16.5 determine compliance requirements by the Contractor related to air, noise and flora and fauna. The following subparagraph describes the measures taken on the construction site related to soil and erosion control.

332. Clause 19.4. Chapter 19: Project Implementation Plan of Tender documents determines that the Contractor shall submit monthly progress reports to the Client (PMU), including issues related to the environment protection.

333. WСОn tОnНОr biНs wОrО carriОН out, tСО BiН Evaluation CommittОО НiНn’t СavО Environmentalists or Specialists for assessing ecological competency of bid participants44.

334. The reviewed Contract Agreement45 also contains requirement for Contractor to implement environmental requirements. Chapter 2 - Specifications, Section 6 – Client Requirements, with reference to the tender documentation 2/3 - Specifications, states that "Technical Specification 6.2 . is an integral part of the Contract and shall be executed except for deviations of the Contractor, who was approved the Client".

335. According to the Contract Agreement No. SJSC/UzbekEnergo/ICB-2010- 001 of 07.03.2013, Annex 7 (A), clauses 25, 27, 39, the Contractor shall prepare and submit for review the SBMP, and also provides an Assessment of risks for all environmental issues.

336. Clause 22.7 – Clearing construction site in Section 7 of the General Conditions of the contract describes the requirements for the Contractor to maintain construction site in good condition during and after the execution of the contract.

337. Section 8 - Special Conditions of Contract contains the clause 9 - Obligations of the Contractor, which reflects the requirements of the Contractor "(a) to establish operational control system for management of impacts on environment , (b) to carry out all measures for monitoring and mitigation outlined in environmental impact assessment (EIA) and Environmental Management Plan (EMP), which are presented in Appendix 1, the Contractor shall submit to the Client semiannual reports on the measures carried out . "Further, in this Section there is Appendix 1 - Report of the environmental assessment, the content of which is not in the document.

44 Protocol of the Tender Committee approved for bidding, dated 12.11.2010 was provided by PMU staff during environmental audit. 45 Contract agreement for designing, procurОmОnt anН construction “turnkОв” (Contact No. SJSC/Uzbekenergo/ICB-2010-001) bОtwООn UE “Talimarjan TPP” SSC UГBEKENERGO anН Consortium oП Hyundai Engineering and Construction and Daewoo International, March 7, 2013



338. As part of the EIA, prepared in December 2009, baseline environmental monitoring was conducted with indicators such as: qualitative characteristics of Talimarjan water reservoir and Karshi Main Canal, water temperature indicators, greenhouse gas emissions. Currently Environmental specialists of the PMU continue to monitor these and other indicators, as part of the monitoring and evaluation of the project.

339. At the PMU a system for documenting environmental activities is created. Quarterly technical progress reports of the project are prepared by Consultant - Engineer for the PMU. So far one progress report is developed for the period from 1 July to 30 September 2013. Several sections of the technical report provide information on the implementation of environmental requirements for the reporting period (Section 4.6. Report on Environmental Protection and Section 6.5. Environmental monitoring). In addition, Environmentalist from PMU conducts visits to the construction site for assessing the compliance with the requirements on environment protection. The assessment is conducted together with the Environmental Protection Specialist of the TPP within PIU. The results of the monitoring are well documented and submitted to the Head of PMU in the form of "Information on work supervision and environmental monitoring on the construction site for Combined Cycle Gas Turbine Units 450 MW", and then, if necessary, appropriate action is taken with respect to the work performed by the Contractor.

340. From the words of Consultant-Engineers and representatives of the PMU, the International Consultant on Environmental Protection began working with the PIU staff on environmental issues, but no records showing participants, date and venue of trainings was prОsОntОН. In aННition, HSE EnРinООr Пrom tСО Contractor’s tОam submits montСlв rОports to PMU on Health Protection, Technical Safety and Environmental Protection; the repots contain information on instruction on Technical Safety and Environmental Protection46.

341. Chemical laboratory station carries out monthly analyzes of water samples from Karshi main canal and sewage treatment facilities, as well as analyzes of air samples for such chemicals as NO, NO2, CO and SO2 and sources of emissions. This data is submitted to the PMU. At the entrance point in the station building there is the announcement that there is a Book for Complaints, Recommendations, Gratitude that can used by UE "Talimarjan TPP" and residents Nuristan town (Fig. 127, 128). It also contains contact information, to contact with PMU and address any questions regarding this project. At the time of the survey tСО Book НiНn’t СavО anв rОcorНs.

Figure 127: Announcement for the Book for Complaints, Recommendations and Gratitude in entrance to the Station

Figure 128: The Book for Complaints, Recommendations and Gratitude

342. The PMU has prepared six annual reports on environmental monitoring for the ADB in 2009 and during the period from April 2012 to July 2013, which are published on the ADB website. The reports contain information on the project, the essential requirements specified in the EMP, the results of a brief environmental impact assessment of projects on the environment. The Environmental Monitoring section in the last report (July 2013) informs that the chemical laboratory of the station carries out monthly analyzes of water samples from Karshi Main Canal (KMC) and wastewater treatment plants. It was also noted that air quality 46 Consultant received two Monthly reports on completed work for October and November 2013.



has not changed and there were no any complaints from the residents of Nuristan town. International Environmental Specialist from of Consultant-Engineer team in its report on the environmental protection, which is part of the "Progress Report" for the period July- September 2013 undertook to develop international standard reporting form and to assist in the preparation of midyear reports on the Environmental Protection. In this regard, the International Environmental specialist prepared the first report on "Environment check" for November 2013, in which the data obtained through visits and specialist construction site meetings with contractors and subcontractors are reflected. International Environmental specialist plans to carry out an environmental inspection twice a year, as well as a monthly examination.

343. Report for the first half of 2013 was submitted to Kashkadarya Nature Conservation Committee. It should be noted that the Loan Agreement for this report does not contain such requirements to the Borrower. But to meet the project requirements of the current ADB policy on protection measures (2009), the Consultant recommended PMU strengthen disclosure of project information also through the dissemination of environmental reports to the population.

344. The Consultant examined the presence of EMP and its implementation status on the basis of a contractual agreement between the "Uzbekenergo" (Client) and the company «HвunНai EnРinООrinР anН Construction anН DaОwoo IntОrnational Consortium» (SoutС Korea), (Contractor). Contractor developed Site Specific Management Plan for the construction site based on EIA, which was included in the tender documents of the Contractor. Consultant-Engineer rendered support during the preparation of SEMP47 to the Contractor. The original version of the SSMP was not approved by the PMU at the time of the audit. The Contractor will have to reconsider the SSPM in accordance with the requirements of the PMU and Consultant-Engineers by 08.11.2013. After the audit, the Consultant was given corrected version of the SSMP, but as it turned out, this document also required improvements according to the PMU and Consultant-Engineers. For the time being the final version of the SSMP is still in process of development (according to the requirements of PMU the document was to be submitted by the end of 2013) for the approval by the PMU.

345. At the time of audit the TPPEIP project was in the preparatory work stage. Upon completion of the project an acceptance certificate for completed work area should be issued, originals and copies of which must be submitted to the PMU and PIU. The committee that accepts completed works should include representatives of the Regional Committee for Nature Protection, which certifies the fact of compliance with environmental requirements during project implementation. Also, according to the requirements of ADB's environmental policy, separate final environmental audit to be carried out after the completion of the construction works.


346. As mentioned above, the TPPEIP project is being implemented in Nuristan town of Nishan district of Kashkadarya region in Uzbekistan. Work is coordinated by the PMU (Tashkent) through PIU and a working group located in the town of Nuristan.

347. Environmental audit of construction sites was undertaken by the Audit Consultant on November 1, 2013 in the presence of representatives of the Contractor and PIU (Fig. 129).

348. Consultant examined the construction base of the Contractor where Contractor's office is located and repairing works were being undertaken to improve the facility. At the construction base there are several cabins where builders live (Fig. 131), meanwhile construction was in process to build accommodation facility for workers (Fig. 133).

349. Canteen is also located on the territory of the construction base (Fig. 132), which was also undergoing reconstruction and repair work to make it for 300 seat canteen.

47 In the case of TPPEIP project, SEMP document is called HSE Plan



350. Shower rooms for workers are located in trailers and there are outdoor pit toilets. The project envisages the construction of new shower room (Fig. 134). From the words of representatives of the PIU and all solid and household waste collected in containers and are taken off-site to special reserved location for this purpose twice a week. However the Audit Consultants found small trash dumps at the construction base at a small distance from canteen and recreation facility for workers (Fig. 135). PIU representatives noted that they were assuming to start separate storage of waste, the construction of a special site for separate waste storage has already begun (Fig. 136).

351. PIU and TPP staff are assuming to improve landscape before building site (Fig. 137). It should be noted that the area of construction works is equipped with special guards and warning signs (Fig. 138). Workers and employees work in special uniforms and shoes, and they are also equipped with personal protective equipment (helmets, gloves, respirators).

Figure 129: Meeting with Head of Construction Department, Head of Site, Environmentalist of the

Station and representatives of Contractor with HSE Engineer

Figure 130: Contractors Construction Base

Figure 131: Cabins for workers living on construction site

Figure 132: Canteen and washer at construction base



Figure 133: Accommodation facility for workers under construction

Figure 134: New shower rooms for workers under construction

Figure 135: Construction waste at construction base territory

Figure 136: Expected new place for separate waste

storing

Figure 137: Site for expected landscape improvement before construction site

Figure 138: Fence and warning signs before

construction site

352. At the time of auditing at construction base there was an EMP in electronic form, not approved by the Engineer - Consultant of PMU.

353. Petroleum products in the territories of construction sites are not properly stored; repair and change of oil are done in local motorpool. From the words of contractor employees, refueling appliances are done using oil containers using special metal pallets. At the time of carrying out environmental audits, spills of petroleum products were not found.


354. Project documents to review: bids, contracts between the Agency and the Contractor with requirements to comply with environmental measures. However, tender commission should have an ecologist or appoint an expert who assesses the ecological capacity of project tenders.

355. According to Section 5, paragraph 3 of the Credit Agreement of TPPEIP ".. The PMU will monitor and record performance of the EMP developed for the project, under the leadership of the Nature Committee ..". In accordance with this, Nature committee should be involved periodically to the joint environmental monitoring, as well as to provide semi-annual reports on environmental monitoring within province Nature Committee (see paragraph 359 of this document).

356. The initial version of SEMP was not approved during the auditing. The contractor should have had to review SEMP in accordance with the requirements and comments of PIU



and Consultant Engineer and submit it for consideration and approval by the PMU till the end of 2013.

357. As mentioned earlier, the International Consultant on Environmental Protection began working with the PIU staff regarding issues related to the Environment on the construction site, but working records showing participants, date and venue of training was not presented. It is recommended to organize training and seminars for the PIU staff and Contractor on a regular basis with maintaining work records.

358. Implementation of SEMP should be monitored by the PMU and Consultant Engineer, results of observations on the implementation are provided in prepared periodic reports.

359. PMU must submit reports on environmental monitoring to local governments such as khakimiyat and makhallas and continue reporting to the Committee for Nature Protection, as required by ADB policy on conservation measures from 2009 on project information transparency.

360. During construction works contractors comply with the requirements of Environmental Protection. However, it should be paid attention to the preservation and handling of domestic and construction waste, preventing wastes storage in non-designated areas.

361. Completed project work will be accepted by the state commission, where specialist from the local Committee for Nature Protection should be included. PMU should prepare the final environmental audits on completed site that complies with the EMP and include the results of such surveys in environmental monitoring reports. In addition, the final results of the survey can be written in the final project report as a separate environmental component.

362. More detailed recommendations with responsible personals for project performance and period to implement are given in Table 9.



Table 9: Recommendation matrix

# Recommendations Responsible

personals/activities

Implementation period

1

Provide PMU with SEMP prepared by Contractor with corrections and comments from PMU and Consultant Engineer and approved version of SEMP to provide constructors and all representatives of the Contractor and the PIU

Contractor involves Consultant Engineer PMU – control on implementation

Till the end of 2013

2 Provide regular training for employees of the Contractor to implement the approved SEMP

Contractor involves Consultant Engineer PMU – conduct trainings

Introductory training for new employees and quarterly training for permanent staff

3

Develop to Contractor a special form of reporting on the implementation of environmental protection measures

Contractor and Consultant Engineer – develop a special format PMU - control on implementation

Within one week after receiving the Environmental Audit report

4

Strengthen enforcement of environmental control activities by the Contractor and the PIU regarding municipal solid waste and construction waste and submit monthly reports to PMU / Engineer on their performance about the construction site

Contractor – implementing EMP requirements, provide reports every month PMU and Consultant Engineer – take control

Within one month after receiving Environmental Audit report and till the end of project activities

5

Submit to PMU semi-annual reports on environmental monitoring to local governments and committees on Environmental Protection

PMU - submits reports

After approval of the semi-annual report on environmental monitoring of ADB

6

Upon completion of work on the project, prepare final environmental audit for compliance with EMP and prepare relevant report

PMU with Consultant Engineer – conduct final Environmental Audits

During submitting of the completed portion of project works



7. MULTITRANCHE INVESTMENT PROGRAM OF REGIONAL ROAD DEVELOPMENT PROJECT. PHASE II and PHASE III.

7.1. Brief Information on Multitranche Investment Program of Regional Road Development Project. Phase II and III (RRDP) (L2635/2746/2868/2772/2965)

7.1.1. Regional Road Development Project. Phase II (L2635/2746/2868)

363. The project implementation is carried out at the expense of Government and ADB loan, with procurement under three tranches. Rehabilitation of 222 km of the section of A-380 road has been planned under three tranches (50 km under first tranche, 85 km under second tranche and 87 km under third tranche).

364. Rehabilitation and construction of 50 km (440-490 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road are carried out under Tranche 1. The loan agreement on the project first tranche was signed on 01.05.201048.

365. Rehabilitation and construction of 85 km (355-440 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road are carried out under Tranche 2. The loan agreement on the project second tranche was signed on 12.04.201146.

366. Rehabilitation and construction of 40 km (315-355 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road are carried out under Tranche 3, alonР witС proviНinР tСО “Daut-ata” customs point of SCA on Republic of Karakalpakstan with the fixed large-sized scanning equipment for the vehicle searching. The loan agreement on the project third tranche was signed on 30.08.201246.

367. As of environmental audit date (November 2013), the project works under the first tranche were under completion, the biddings had been carried out for the second and third tranches, but the project activities were not started. The brief information on selected project executing entities is provided in the Table 10.

Table 10: Information on Executing Entities of the Multitranche Investment Program of Regional Road Development Project. Phase II

Tranche #

Date of Signing the Loan Agreeme

nt, #

Supervision

Engineer (Engineeri

ng Consultan

t)

Date of Signing

the Contra

ct

between RRF

and Engine

er

Contractor

Date of Signing

the Contract

between RRF and Contract

or

Project Works

Status of the Project Works

Implementation

1

01.05.2010

Loan Agreement

# 2635

«DOHWA» (South Korea)

October 28, 2010

GP Papenburg Baugesellschaft mbH (Germany)

October 18, 2010

Rehabilitation and construction of 50 km (440-490 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road

Project works are under completion

2 12.04.2011

Loan

Sambo Engineering

August 09, 2012

Construction contractor

. Rehabilitation and

Project works have not been

48 Data from official site of the Ministry of Finance RUz, https://www.mf.uz/ru/mf-about/2013-05-29-12-10-48/respublikanskij-dorozhnyj-fond.html?hitcount=0

https://www.mf.uz/ru/mf-about/2013-05-29-12-10-48/respublikanskij-dorozhnyj-fond.html?hitcount=0




Agreement

# 2746

& Construction Co. Ltd (Spain)

has not been selected

49

(retender has been announced)

construction of 85 km (355-440 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road

started

3

30.08.2012

Loan Agreement

# 2868

«RОnarНОt S.A.» (Switzerland) and «RСвtСm plus consulting companв» (Uzbekistan)»

18.02.2013

Contractor has not been selected (retender has been announced)

Rehabilitation and construction of 40 km (315-355 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road and providing the “Daut-ata” customs point of SCA on Republic of Karakalpakstan with equipment

Project works have not been started

368. Due to the above, the bidding documents were analyzed on all three tranches of the “RRDP. PСasО II” projОct anН ОntirО packaРО oП projОct НocumОnts was analвгОН on TrancСО 1. For this purpose, the institutional issues, project documents and the project activities implementation sites were reviewed for analysis of observance of environmental requirements.

7.1.2. Regional Road Development Project. Phase III (L2772)

369. The project implementation is carried out at the expense of Government and ADB loan, with procurement under three tranches. Rehabilitation and construction of the sections oП A373 “TasСkОnt-OsС”, A373/4 -112 “FОrРana RinР” anН A-380 “Guгar-Bukhara-Nukus-BОвnОu” roads with entire length 220 km has been planned under the project.

370. RОСabilitation anН construction oП 58 km oП A373 “TasСkОnt-Osh road on the section 116-190 km passing through Kamchik mountain crossing are carried out under first tranche. The loan agreement on the first tranche was signed on December 1, 201150.

371. RОСabilitation anН construction oП 4 112 “FОrРana RinР” on tСО sОction 0-75 km with the length 75 km with transition to the 4-lane road with asphalt concrete pavement on Namangan Province territory are carried out under second tranche. The loan agreement on the second tranche was signed on April 16, 201351.

372. Rehabilitation and construction of road on the section 228-315 km of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road with the length 87 km have been planned under third tranche. Preparatory works are ongoing under this tranche, and the loan agreement has not been signed yet.

373. As of environmental audit date (November 2013), similar to the previous investment program, construction works are ongoing only under the first tranche, the bidding was

49 Data as of environmental audit date – November 2013. 50

Data from official site of the Ministry of Finance RUz, https://www.mf.uz/ru/mf-about/2013-05-29-12-10-48/respublikanskij-dorozhnyj-fond.html?hitcount=0 51

www.adb.org





announced for the second tranche and preparatory works are ongoing under the third tranche. The brief information on selected project executing entities is provided in the Table 11.



Table 11: Information on Executing Entities of the Multitranche Investment Program on the Regional Road Development. Phase III

Tranche #

Date of the Loan

Agreement Signing, #

Supervision Engineer

(Engineering Consultant)

Date of the Contract Signing

between RRF and Engineer

Contractor

Date of the Contract Signing

between RRF and Contractor

Project Works Status of the Project

Works Implementation

1 01.12.2011

Loan Agreement

# 2772

Consortium Sambo Engineering Co., Ltd. With Namanganyul-loyikha and Info Capital Group LLC

9.08.2012. Consortium «Corsan Corviam Construccion SA» and "Elektrtarmoq-qurilish" OJSC

18.09.2012 Rehabilitation and construction of 58 km oП A373 “TasСkОnt-Osh road on the section 116-190 km passing through Kamchik mountain crossing

Construction is ongoing at the project sites

2

16.04.2013

Loan Agreement

# 2965

- - - -

Rehabilitation and construction of 4 112 “FОrРana RinР” on tСО section 0-75 km with the length 75 km with transition to the 4-lane road with asphalt concrete pavement on Namangan Province territory

Bidding is underway on selection of Engineering Consultant

3

- - - - -

Rehabilitation and construction of road on the section 228-315 km of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road with the length 87 km

The project documents preparation on the tranche is ongoing. The loan agreement has not been signed



374. Implementation of “RRDP. PСasО III” projОct is carriОН out in TasСkОnt, NamanРan (Tranche 1 and Tranche 2) and Bukhara (Tranche 3) provinces (Fig. 139). The table shows, that, as of environmental audit date, the loan agreement of Tranche 3 have not been signed, and, respectively, the bidding documents were not prepared.

375. In this regard, the project documents and field visits were carried out only under Tranche 1. For this purpose, the institutional issues, project documents and the project activities implementation sites were reviewed for analysis of observance of environmental requirements.

376. As oП ОnvironmОntal auНit НatО, tСО proРrОss oП “RRDP. PСasО II” projОct accountОН for 95%52. According to the project documents, the project has been assigned environmental category – .

377. As oП ОnvironmОntal auНit НatО, tСО proРrОss oП “RRDP. PСasО III” projОct accountОН for 12%53. According to the project documents, the project has been assigned environmental category – .


378. The Republican Road Fund (RRF) is acting as Executive Agency for both projects “RRDP. PСasО II” anН “RRDP. PСasО III”. TСО ProjОct ManaРОmОnt Unit (PMU) (principal) based in Tashkent City was established under RRF with mandate to accomplish overall coorНination oП tСО projОct works in tСО ПramО oП “RRDP. PСasО II”, TrancСОs 1-3. Control over environmental issues observance in PMU has been assigned to the Specialist on Environmental issues (EI).

379. The additional PMU subordinate to the Principal PMU and being the separate legal entity, in parallel, was established under the PMU for coordination of project works in the ПramО oП “RRDP. PСasО II”; tСis Оntitв Сas its own spОcialists – engineers. Additional PMU is dealing with coordination of the project works under the Tranches 1-3.

380. The consultants on social and environmental issues of the Principal PMU are carrying out environmental safeguards for Additional PMU as well (Fig. 140).

381. The PMU employed the Supervision Consultant (Engineering Consultant) – “DOHWA” Companв (SoutС KorОa) Пor tСО manaРОmОnt oП tСО “RRDP. PСasО II” projОct, Tranche 1 Rehabilitation and construction of 50 km (440-490 km) of A-380 “Guгar-Bukhara-Nukus-BОвnОu” road and its implementation monitoring. The Specialist on Environmental Issues of the Engineering Consultant is dealing with the monitoring of environmental safeguards implementation by Contractor and preparation of environmental component of the technical reports.

382. TСО Contractor’s companв - GP Papenburg Baugesellschaft mbH (Germany) also has the Specialist on Environmental Issues and Safety Engineering (EISE) responsible for environmental safeguards implementation at the construction site and preparation of monthly environmental reports.

383. The Consortium of Sambo Engineering Co., LtН witС “NamanРanвul-loвikСa” anН InПo Capital Group LLC was СirОН as EnРinООrinР Consultant Пor “RRDP. PСasО III” projОct. TСis company has ecologist as well whose duties include the monitoring of SEMP implementation by Contractor along with preparation of quarterly environmental reports.

384. TСО “Corsan Corviam Construccion SA” tСО GОnОral Contractor Пor construction works fulfillment under this project with involvement of sub-contractors - "Elektrtarmoq-qurilisС" OJSC anН “Alians-Kapital” OJSC. TСОrО is EcoloРist in tСО GОnОral Contractor’s staffs who are supposed to control over the EP activities implementation, develop environmental documentation and prepare the monthly environmental reports. Moreover,

52 Data were submitted by PMU, October 2013 53 Data were submitted by PMU, October 2013



sub-contractors also have ecologist staff member responsible for environmental issues at the construction site and continuous monitoring of activity of two sub-contractors.



Figure 139: Regional Road Developments Project map54

54

The map was provided by PMU



Figure 140. Institutional Chart of the Environmental SaПОРuarНs ArranРОmОnt in tСО ПramО oП tСО “RRDP. Phase II” and “RRDP. Phase III” Projects

Republican Road Fund

PMU (Principal)

Tranche-1

Tranche-2

Tranche-3

Engineering Consultant


Contractor

Specialist on IESE


Contractor - TBD


PMU (Additional)

Tranche -1


General Contractor Ecologist

Tranche -2

Engineering Consultant TBD

Contractor TBD

Tranche -3

Engineering Consultant TBD

Contractor TBD

ADB

PMU Specialist on EI

Contractor - TBD

Sub-contractor -1

Sub-contractor -2




385. Further, the project documents analysis and results of inspection at the construction site are provided in two programs breakdown.

7.3. “RRDP. Phase II”, Tranche-1

7.3.1. Project Documentation Analysis

386. The Section 5, paragraph 8 of the Loan Agreement between the Republic of Uzbekistan (RUz) and ADB of May 1, 2010, describes the Republican Road Fund (RRF) as ExОcutivО AРОncв (EA). AccorНinР to З , EA is supposОН to Оnsure the project implementation and communication with ADB and the other governmental institutions.

387. The next paragraph of the same section describes the RRF responsibilities on establishment of the Project Management Unit (PMU) and employment of procurement specialist, environmental safeguards specialist and social issues specialist for the project support within 3 months from PMU operation start.

388. TСО paraРrapС 10 oП tСО samО sОction НОscribОs tСО BorrowОr’s obliРations (tСrouРС RRF) as a security that the project design, construction and management is being implОmОntОН in linО witС ADB’s ОnvironmОntal policв (2009), ОППОctivО laws anН rОРulations oП Uzbekistan, Framework Document on Environmental Examination and Initial Environmental Examination.

389. Further, the Borrower (through) RRF has to ensure minimization of potential project negative impact through application of all measures on these impacts mitigation and prevention specified in the Environmental Management Plan (EMP). Also, according to the loan agreement, the Borrower (through RRF) is to ensure the following: (i) EMP consideration and approval prior to start of construction works, (ii) availability of adequate funds for implementation and documenting of the Project EMP fulfillment, (iii) submission of semiannual reports to ADB. The reports have to include the survey of the progress of EMP and IEE environmental requirements fulfillment, the monitoring of these measures, identified problems and corrective measures, (iv) control over observance of IEE and EMP requirements during construction works fulfillment by Contractors.

390. EMP was included in the bidding documents – section 6.5, part 255.

391. In accordance with existing in Road Fund procedure, the bidding packages assessment is carried out in three stages. At the first stage, the bidding board under PMU carries out the technical assessment of the bids and based on its results it prepares the engineering opinion. This assessment board comprises the Engineer on the Road Construction and Machinery who carries out assessment of environmental parameters of competitors. The next stage of the bid assessment is accomplished by the interagency working commission which is working with materials of assessment board and the bids themselves. The third stage of consideration and approval is carried out by interagency bidding board which analyzes the opinions of two previous commissions and makes the final decision on the bidding winner. Commissions of the second and third level do not include ecologists or representatives who carry out assessment of environmental capacity of the bidders. Therefore, during the biddings, the ecologists or representatives who carry out assessment of environmental capacity of the bidders are involved at the first assessment stage.

392. The Annex A “SОrvicОs DОscription/ScopО oП SОrvicОs” oП tСО contract bОtwООn RRF and Engineering Consultant Dohwa) includes requirements for the monitoring of environmental safeguards observance. Environmental requirements include the obligations

55 As of environmental audit date, the bidding documents on this tranche have not submitted. The conclusion of presence of ОnvironmОntal rОquirОmОnts in tСО biННinР НocumОnts was maНО bв Consultant basОН on PIU’s ОnvironmОntal rОport Пor April 2011.



on: (i) ensuring of inclusion of all environmental safeguards in the contract documents, (ii) management and monitoring of EMP implementation, (iii) to recommend the mitigation measures to EA and ADB in case of the unpredictable environmental impact in cooperation with PMU.

393. The Section 8 – “Contract SpОcial TОrms”, part B “SpОcial TОrms” oП tСО Contract between RRF and Contractor (GP Papenburg Baugesellschaft) specifies amendments to subparaРrapС 4.18 oП tСО SОction 7: “Contract GОnОral TОrms”. TСО amОnНmОnt maНО in subparagrapС 4.18 “EnvironmОntal ProtОction” НОscribОs tСО Contractor’s obliРations on: (i) establishment of the active system on the environmental impact management, (ii) fulfillment of all EP and monitoring activities specified in IEE and EMP (with reference to the Section 6.5, part 2 of the bidding documents), (iii) allocation of required funds for implementation of these activities, and the actual cost of activities has to be covered by the Client from Provisional sums. This paragraph of the Contract also includes requirements on Environmental Action Plan development (same as Site Environmental Management Plan is - SEMP) – in terms of complete observance of the articles of EMP included in the bidding documents.

394. Along with subparagraph 4.18, environmental requirements are specified in the SОction 106 “EnvironmОntal ProtОction” anН НОscribО tСО kОв impacts anН mitiРation activities on their influence on air, water and soil. This paragraph also provides detailed description of the tool-based monitoring to be implemented by Contractor in the course of works, rОquirОmОnts to EMP to bО submittОН to tСО EnРinООr’s consiНОration.

395. In terms of submission of reporting by Contractor to the Client, the contract obliges the Contractor to submit two types of reports (paragraph 4.18 “Contract GОnОral TОrms”) – (i) on implementation of environmental safeguards at the construction site and (ii) on environmental monitoring. At that, the report on environmental safeguards is submitted on semiannual basis, and report on environmental monitoring – on the monthly basis.

396. The analysis of the contract documents and IEE materials, including EMP, demonstrated that such activity as pilot planting of the roadside with the width 50 meters and lОnРtС 5 km (activitв E “RОvОРОtation ProРram MonitorinР”, EMP) СaН not bООn incluНОН in the contract documents. Consultant thinks, that including or non-including of the particular items into the contract documents should be monitored both – PMU and ADB. Though, according to the IEE, these activities were supposed to be implemented by Contractor, and Engineering Consultant had to supervise their implementation efficiency at the project implementation stage, and further, by RRF itself during 3 years. At that, the paragraph 106.8 of the Contract contains the requirement of restoration of all sections with the natural vegetation, but does not mention anything about the pilot section. Recommendations on carrying on such works had been included in IEE; however, expenses related with conducting such activity were not included into the contracts. In accordance with data provided by PMU, conducting such revegetation activities are planning within the next tranches on the road with similar natural conditions. Requirement on conducting revegatation works and their costs are included in concluded contracts on construction of such sites.

397. The IEE describes the necessity of accurate water metering, since the problem of the potable water is rather crucial in the project region. In this regard, the IEE and EMP, respectively, contained the requirements on the monitoring of the taken water amount for the concrete production.

398. In the frame of IEE prepared at the technical assistance stage, the data on the ambient air quality in Bukhara and Nukus cities – on suspended particles, nitrogen dioxide and carbon dioxide are provided as the baseline data on environmental quality with the reference to the national catalogue of air quality. The tool-based monitoring of the water quality and noise level has not been accomplished.

399. Contractor had submitted SEMP to the approval by Engineering Consultant in February 2011, however, as of environmental audit date, the PMU had only the SEMP draft version (February, 2011). The SEMP submitted for consideration contains the key EP requirements, included in IEE, the detailed action plan and impact monitoring plan as well.



400. Two documents - (i) Environmental requirements of the Contract between Contractor and RRF, and (ii) SEMP developed by Contractor - include requirements on accomplishment of the basic and continuous environmental monitoring – water, air and noise level on the monthly basis (paragraph 106.2 of the Contract and section 4 in the SEMP). The documents contain recommendations of the measuring points and testing parameters. Moreover, the IEE and EMP developed at the technical assistance stage include requirements on quantitative monitoring of water taken for the concrete production.

401. As of the present audit date, Contractor submitted results of accomplished tool-based monitoring of the air dust content at the construction sites as well as noise level in the vicinity of construction equipment, the quality of potable water used for the drinking purposes at the Contractor’s construction basО, as oП AuРust 2012.

402. The representatives from the laboratory of the Sanitary Epidemiologic Station (SES) of Khorezm Province were invited upon the official request of Contractor for accomplishment of the measurements (the laboratory was accredited in 2012). This laboratory also carried out the measurements of particulate level in two points – near the traffic police point and on 490 km – in the vicinity of the settlement. The measurements results did not show the excess of the levels set up by the national legislation which is confirmed in official certificate issued by SES (Annex 7). The measurements were carried out three times through the project period. The water quality monitoring was accomplished once.

403. The environmental safeguards documentation system contains:

Monthly technical reports containing environmental section and submitted by Contractor;

Monthly technical reports containing brief environmental part and submitted by Engineering Consultant;

Quarterly environmental reports containing more expanded environmental part and submitted by Engineering Consultant;

Semiannual environmental reports submitted by PMU to ADB;

Work correspondence of PMU with Engineering Consultant and Contractor on the issues of implementation of the SEMP requirements;

Regulatory documentation on EP (consists of the national, ADB and international documents).

404. The annexes to these reports contain the correspondence between Contractor and Engineering Consultant related to various issues, including notifications on environmental noncompliance revealed during environmental audit. One of the quarterly reports (3rd quarter 2012) contains information on the results of the tool-based monitoring.

405. During environmental monitoring at the construction site, Contractor submitted to the Consultant the monthly reports on environmental issues and safety engineering which were delivered to Engineering Consultant (Annex 3). Reports were prepared in the standard format with the brief information on environmental safeguards implemented during reporting period and do not contain the information on environmental monitoring.

406. Engineering Consultant prepared the last report in September 2013, few months before completion of construction works. Environmental report was submitted as the part of the overall technical report. Its content summarizes all environmental safeguards carried out by Contractor through construction period. However, the final environmental report does not describe the condition of construction sites, bases, concrete plants and quarries after completion of construction works, since at that moment they were far from completion. Engineering Consultant did not manage to prepare this report due to the temporal schedule of environmental engineer, since his last contribution was scheduled for September 2013.

407. Moreover, the ecologist of Engineering Consultant is quarterly preparing reports on environmental monitoring where the results of implemented audit are presented to the full



ОxtОnt. TСО rОports oП EnРinООrinР Consultant’s ОcoloРist arО incorporatОН in tСО tОcСnical reports which are submitted to PMU later on.

408. PMU also prepares environmental reports submitted to ADB. The first report was prepared in April 2011, the next one was submitted in March 2013 and the final report was prepared in November 2013.

409. As it has been mentioned, according to the loan agreement requirements, the PMU is supposed to submit environmental reports to ADB on semiannual basis starting from the date of the loan agreement signing. However, according to PMU, the joint with ADB decision was made on submission of annual environmental reports instead of semiannual ones, which, in principlО, НoОs not contraНict tСО ADB policв spОciПвinР tСat “rОРarНinР tСО projОcts witС potential environmental damage (A) the monitoring reports has to be submitted on semiannual basis. In terms oП tСО otСОr projОcts, tСО annual rОport is prОparОН”. – SPS 2009, Requirements on environmental safeguards: Environment, paragraph 22, page 43. With that, no documentary evidence of this decision in form of official letter, agreement, etc. has been presented to Consultant.

410. It should be noted, that due to nonoccurrence of involvement of the PMU ecologist anН EnРinООrinР Consultant’s ОcoloРist in tСО projОct works, coorНination bОtwООn tСОsО experts was imperfect. Due to the different periods of involvement in the project works, these experts were not able to carry out joint audits, and their cooperation was performed only in the form of submission of quarterly reports by Engineering Consultant and their review by the PMU ecologist. The PIU was recommended to more thoroughly analyze information on the cases of noncompliance of environmental requirements by Contractor, which was submitted by Engineering Consultant, and to timely take respective actions.

7.3.2. Project Site Audit “RRDP. Phase II”, Tranche-1

411. The Consultant carried out environmental audit of construction site 50 km (440-490 km) A-380 highway on November 30, 2013 in presence of PMU ecologist and manager of Sub-contractor’s companв. As oП ОnvironmОntal auНit НatО, tСО rОprОsОntativОs oП tСО General Contractor (GP Papenburg Baugesellschaft mbH) have already been absent at the project site. Since the core construction works under the project had been completed, the Sub-contractor (Long Sight Construction) was completing the minor finishing operations.

412. As has already been mentioned in the section 2 of the present report, the Contractor submitted the SEMP for consideration by Engineering Consultant. According to the acting manager of Sub-contractors, demobilization was ongoing at the date of audit and main documents (including SEMP) had already been delivered to Tashkent.

413. The road under rehabilitation is located in Khazarap region Khorezm Province. The following section of construction site were surveyed in order to analyze the status of environmental safeguards application at the construction site:

Contractor’s construction basО anН camp

Territory of 2 concrete plants

Inert materials quarry

A-380 highway

7.3.3. Contractor’s Construction Base and Camp

414. Construction base of Contractor was located on the territory of former truck fleet on 490 km of A-380 highway, near Sarymai settlement. The filling station, fuel tanks, machinery maintenance shops, boiler-house and administrative building with the office, bedrooms and canteen were located on the territory of construction base.



415. Construction works were carried out by consortium – General Contractor (P Papenburg Baugesellschaft mbH Company) and Sub-contractor (local construction company LonР SiРСt Construction). TСО GОnОral Contractor’s ОmploвООs wОrО livinР on tСО territory of construction base, and Sub-contractor’s construction workОrs wОrО mainlв Пrom tСО citiгОns of neighboring settlements (only one settlement is available – Sarymai) and every day were coming by bus. In 2011-2012 the trailers were installed for the workers – non-residents, and these trailers were disassembled in the fall 2013.

416. The comfortable living conditions were created for the workers living on the territory of construction base – bedrooms, canteen, and shower rooms (Fig. 141-144). As of environmental audit date, the shower rooms were dismounted. The sanitary requirements were met in the canteen; the drinking water was brought to the site and passes the secondary treatment through the filter.

Figure 141: Canteen for the workers, Sarymai construction base

Figure 142: Foodstuff storing place

Figure 143: Drinking water filter in the kitchen Figure 144: Pit and lavatories location on the territory of construction base – and what?

417. According to the EMP, included in the contract documents (section 106); the waste burning is not allowed. However, it was revealed during the audit that the waste storing and disposal did not meet the EMP requirements – i.e., the waste was collected in the earth pit and burned (Fig. 145-146). It should be notОН, tСat tСО EnРinООrinР Consultant’s ОcoloРist made the comments on inadmissibility of the waste storing and disposal in such manner, and Contractor issues the relevant internal order officially stating on prohibition of the waste burning. However, according to the audit results, the Contractor did not meet this requirement.



Figure 145: Waste container and actual place for collection and storing of domestic waste

Figure 146: Domestic waste is stored in the pit and burned later on

418. Except for the domestic waste, the dispersed construction waste in form of polyethylene bags for the construction materials, construction materials themselves and domestic waste were located on the territory on surveyed base (Fig. 146). Wastewater from the kitchen and shower rooms was discharged to the concrete pit located behind the fencing of construction base. As of the audit date, the pit was overfilled and the wastewater was leaking away outside the pit (Fig.147).

Figure 146: Concrete pit outside of construction base (3 meters far from the fence)

Figure 147: Wastewater overflow from the pit

419. The SEMP submitted by Contractor himself clearly describes the requirements on the FL storing and handling. The FL tanks are available on the territory of construction base. The mobile machinery fueling (cars, trucks) was carried out on the territory of construction base, and the fueling of the road construction machinery – at the construction sites, which is permitted in observance of required environmental safeguards.

420. The territory of construction base where the machinery fueling and maintenance took place had been specially equipped for such kind of operations – most of the territory has concrete cover, the FL tanks are available along with the shops for the maintenance and oil replacement, fuel-filling columns, and fire appliances (Figures 148-149). The shop for the machinery maintenance and oil replacement has the metal reservoir for the exhaust oil storing (Fig. 150-151).



Figure 148: Construction base section for machinery fueling

Figure 149: FL tanks and fire appliances

Figure 150: Shop for machinery maintenance and oil replacement

Figure 151: Metal reservoir in the shop for exhaust oil storing

421. According to Sub-contractor, the major part of construction machinery has been removed from the territory of construction base; only some mobile machinery remained and will be shortly redislocated to the new work site in Namangan Province (Fig.152-153).

Figures 152-153: Machinery remained on the territory of construction base

422. The inspection of territory where machinery was and still is kept demonstrated some facts on nonobservance of the SEMP requirements in terms of FL handling. The FL spreading was observed on the territory of construction base, including sections without concrete cover. The empty packaging materials and wipes were spread. The earth pit with exhaust oil was revealed on one of the sections which were the gross violation of the SEMP (Fig. 154-155).



Figure 154: The used oil tanks and wipes are

spread on the territory of construction base

Figure 155: Exhaust oil discharged to the earth pit

423. Sub-contractor’s rОprОsОntativОs involvОН in inspОction oП tСО construction basО territory explained that this spread would be removed together with polluted soil layer. However, no one managed to indicate the place of such oil storing and method of its disposal.

424. There were no books of complaints available on the territory of construction base. The log of the records on the training delivery at construction site was not available either, botС Contractor’s rОports containОН inПormation on НОlivОrОН traininРs. TСО rОcorНs in rОports indicate systematic delivery of the trainings but they do not indicate the training topic and participants.

425. Therefore, inspection of construction base of Contractor showed non-compliance with requirements of EMP included in the contract documents, as well as with requirements of the SEMP developed by Contractor himself and approved by Engineering Consultant. The Consultant recommended to the Contractor to clean up the territory by Sub-contractor who is completing the finishing works at the construction site.

7.3.4. Territory of Concrete Plants

426. During the project implementation, two concrete plants were used for construction materials manufacturing. The first plant was located on 490 km, and the second one – on 440 km of A-380 Road.

427. As of environmental audit date, the first plan has been almost completely disassembled, and some equipment remained on the territory of the second plant, which Contractor was shortly planning to remove.

428. The territory of the first concrete plant had been practically completely cleaned, and the pile of inert materials remained over there along with the fragments of pipes and concrete items. According to the sub-contractor, all this stuff will be shortly removed from the plant territory (Fig. 156-157). This site of the project territory can be considered as completed one only after full cleaning of the territory.



Figure 156: Pile of inert materials and pipes on the territory of the first plant

Figure 157: Building remained after completion of construction works which can be used in future

429. The second plant was located on 440 km of the highway close to the traffic police point. As of survey date, construction equipment still remained on the territory of the plant along with some fragments of concrete plant and construction materials (Fig. 158-159).

Figure 158: Machinery and some equipment of the second concrete plant

Figure 159: Construction materials on the territory of the second concrete plant

430. Domestic and construction waste was spilled on the territory of the second concrete plant, and FL spreading was observed on the ground under machinery as well as concrete. Moreover, on the territory the Consultant found the section 3 meters diameter with strongly polluted soil, where, apparently, the FLs and domestic waste were burned out (Fig. 160-161).

Figure 160: Polluted soil where the oil products were burned out

Figure 161: The fragments of the set concrete to be removed from the plant territory

431. The results of inspection of these two sites demonstrated the partial compliance with the SEMP requirements. These sections can be considered only after completion of works on full cleaning of the territory, including from concrete items, domestic and construction waste and polluted soil.



7.3.5. Inert Materials Quarry

432. 3 quarries were used during the road rehabilitation for the inert materials extraction. The Consultant inspected one of them located on 460 km of A-380 highway and 5 km far from the road.

433. As of the audit date, all works in quarry were completed. There were no signs of the FLs spreading on the territory of quarry and construction or domestic waste was not found. Entire territory of quarry was presented by the slightly leveled area which was not spoiling the overall view of the landscape (Fig. 162-163).

434. TСО rОlОvant positivО opinions wОrО issuОН bв tСО “OblkompriroНa” oП KСorОгm Province for the quarry operation, submitted to the PMU and Engineering Consultant.

Figures 162-163: Quarry for Construction Materials Extraction

435. Based on carried out inspection, it is possible to conclude that this quarry operation was fulfilled in line with the SEMP applicable requirements.

7.3.6. A-380 Highway

436. Along with the sites surveyed above, the Consultant analyzed the project site condition of the section of A-380 road, where the works had been practically completed. In general, the construction waste and fragments of construction materials were not found on the road border (Figures 164-165).

Figures 164-165: Completed Section of A-380 Road



437. Since, as of the environmental audit date, the construction works under the project have not been completed, the sub-contractor will have to carry out the final works on construction site cleaning up which is planned in the nearest future.

438. As the paragraph 396 describes, revegetation activities had not been included in the Contractor’s contract НocumОnts anН, subsОquОntlв, in tСО SEMP Оither, therefore Contractor did not carry out revegetation works. Explanation on this fact is provided above into para 396.

439. Therefore, the results of construction site review showed the SEMP approved by Engineer-Consultant coulН bО consiНОrОН as “satisПactorв implОmОntОН” witС conНitions tСat after works completion all sites will be cleaned.

7.4. “RRDP. Phase II”, Tranches -2 and 3

7.4.1. Project Document Analysis

440. As it has been mentioned in the section 7.2, as of the present audit date on Tranches 2 and 2, retenders wОrО announcОН anН tСО procОss oП Contractors’ sОlОction was unНОrwaв. The Engineering Consultants were selected for both tranches.

441. The bidding documents for both tranches were prepared by the standard pattern – environmental issues were included in the sОconН part oП tСО biННinР НocumОnts “CliОnt’s RОquirОmОnts”, sОction 6.6 – Environmental Management Plan (paragraph 106).

442. Content of this section requirement is practically repeating the bidding documents requirements on the Tranche-1 described in the paragraph 393 of the present report.

443. Both Contracts between RRF and Engineering Consultant on both tranches also include EP requirements – AnnОx A “SОrvicО DОscription”. IncluНОН rОquirОmОnts complОtОlв repeat the terms of reference for consultants described in the FAM to this loan of July 2011.

7.4.2. Project Site Audit “RRDP. Phase II”, Tranches -2 and 3 444. As of the environmental audit date, construction works on Tranches 2 and 3 have not been started.

7.5. “RRDP. Phase III”, Tranche-1

7.5.1. Project Document Analysis

445. The Section 5, paragraph 1 of the Loan Agreement between the (RUz) and ADB of December 1, 2011 provides for the Borrower Republic of Uzbekistan through RRF to ensure the project implementation as specified in the Project Administration Memorandum (FAM56). According to the part A second section, the RRF should establish the Project Management Unit (PMU) and employ procurement specialist, environmental safeguards specialist and social issues specialist for the project support within 3 months from PMU operation start.

446. TСО paraРrapС 10 oП tСО samО sОction НОscribОs tСО BorrowОr’s obliРations (tСrouРС RRF) as a security that the project design, construction and management is being implemented in line with (i) effective laws and regulations of the Borrower (RUz), (ii) environmental safeguards, (iii) Framework Document on Environmental Examination and (iv) all activities and requirements included in IEE and EMP, and any corrective or preventive actions included in the safeguards monitoring reports.

56 Project Administration Facility, Project Number: 44483-026, Loan Number: MFF 0059, November 2012



447. According to tСО paraРrapС 10 oП З , tСО BorrowОr (tСrouРС) RRF Сas to ОnsurО availability of adequate funds for implementation and documenting of the Project EMP fulfillment.

448. The separate subparagraph provides the obligation on inclusion in the bidding and contract documents of the requirements to the Contractor on: (i) implementation of all activities and requirements included in EP and EMP, any corrective or preventive actions included in the safeguards monitoring reports, (ii) ensuring of budget for these measures and requirements implementation, (iii) submission to the Borrower of the written notification on any unpredictable environmental and social risks emerging during the project construction, implementation or operation which have not been considered in EP and EMP, (iv) records of condition of the roads, agricultural lands and other infrastructures before start o transportation of materials and construction, (v) on completion of construction and full rehabilitation of the roads, the other local infrastructure and agricultural lands, at least, up to pre-project condition.

449. TСО paraРrapС 12 oП З spОciПiОs tСО НОaНlinОs oП ОnvironmОntal rОports submission by the Borrower to ADB – the reports should be submitted on semiannual basis. Also, according to this paragraph, the Borrower has to inform the Client on any unforeseen environmental impacts not described in EP and EMP, occurred at the stage of the project construction, implОmОntation anН opОration. TСО nОxt BorrowОr’s obliРation is to inПorm ADB on revealed cases of non-meeting the EMP requirements.

450. EMP was included in the bidding documents – section 6.5, part 257.

451. The bidding packages assessment is carried out similar to Investment Program 2 (section 7.3, paragraph 391 of the present report). The PMU Engineer on the Road Construction and Machinery is dealing with environmental issues.

452. TСО AnnОx A “SОrvicОs DОscription/ScopО oП SОrvicОs” oП tСО contract bОtwООn RRF and Engineering Consultant (Sambo Engineering in association (Table 2) describes requirements for the monitoring of environmental safeguards observance. Section D of Annex A describes requirements on the problem identification as well (Due Diligence) on the following tranches - 2 and 3. This includes conducting environmental examination, preparation of the report on Environmental Impact Assessment (EIA), arrangement of the public hearings according to the requirements of ADB Safeguards Policy (2009).

453. During analysis of the project documents on Tranche 2 of Investment Program 2, the Consultant identified that IEE for the Tranche 2 has already been accomplished and published on ADB site.

454. TСО AnnОx B “RОportinР RОquirОmОnts” НОscribОs rОportinР rОquirОmОnts Пor tСО Engineering Consultant to the Executive Agency. The section does not contain the requirements on submission of the separate environmental reports; most likely, they will be included in the technical reports submitted on the monthly and quarterly basis. Besides, this section contains requirements to the Engineering Consultant on providing assistance to the PMU in preparation of reports on the safeguards observance.

455. The requirements on observance of environmental safeguards are included in the sОconН volumО; sОction 6.6 “EMP” oП tСО Contract bОtwООn RRF anН Contractor (JV Corsan Corvian Construccion S.A. (Spain) and JSC Elektrotarmoqqurilish (Uzbekistan)). The rОquirОmОnts arО prОsОntОН in Пorm oП tСО TablО “EnvironmОntal ManaРОmОnt Plan” alonР with the monitoring program and submission deadlines of the reports on various parameters.

456. As it is obvious from the documents analyzed earlier, the project documents, including EMP and EP do not contain requirements of the SEMP development by Contractor.

457. The basic environmental monitoring has not been accomplished. The EMP included in EP does not contain requirements on the basic monitoring fulfillment prior to construction

57 As of environmental audit date, the bidding documents on this tranche have not submitted. The conclusion of presence of ОnvironmОntal rОquirОmОnts in tСО biННinР НocumОnts was maНО bв Consultant basОН on PIU’s ОnvironmОntal rОport Пor April 2011.



start either, along with continuous tool-based monitoring during construction. The exception is presented by requirement on the monitoring of the noise level during first two months of construction works, provided that such measurements will be stopped in case of non-exceedance.

458. Since the project documents do not contain requirements to Contractor on SEMP development and its submission to approval by Engineering Consultant, the plan has not been submitted. However, in March 2013 Contractor submitted the Work Plan containing environmental safeguards to approval by Engineering Consultant.

459. Environmental issues submitted by Contractor just indirectly cover the EMP requirements included in IEE. The document does not contain the information on institutional arrangement of environmental safeguards, reporting and monitoring. Due to the lack in the contract documents of requirement to Contractor on submission of SEMP prior to start of construction works to approval by Engineering Consultant, the EMP included in IEE was taken as the basis.

460. As of environmental audit date on this project, the environmental activity documentation was presented by Initial Environmental Examination developed at the technical assistance stage.

461. During environmental audit, Contractor submittОН tСО НocumОnt “EnvironmОntal MonitorinР ProРram Пor NovОmbОr 2013” siРnОН bв Contractor’s rОprОsОntativО anН addressed to the RRF Director. The document contained the brief information on activities carried out by Contractor during construction for the reporting period – November 2013. However, Consultant believes the document requires improvement and should be brought in line with all requirements of EMP included in the contract. According to Contractor, such monthly reports have been submitted since the project start, i.e. since April 2013 (totally 8 reports were submitted).

462. However, neither Engineering Consultant nor PMU managed to provide information on these reports.

463. As of the audit date, semiannual report on Tranche 3 on the safeguards implementation has not been submitted by PMU to ADB.

Figures 166-167: Meeting of Consultant with representatives of Engineering Consultant, General Contractor and Sub-contractor

7.5.2. Project Site Audit “RRDP. Phase II”, Tranches - 1

464. The construction works on this tranche are carried out by Consortium consisting of Corsan Corvian Construccion S.A. JV (GОnОral Contractor), “ElОktrtarmoqqurilisС” JV (Sub-contractor) anН “Alians Kapital” (Sub-contractor). On December 10, 2013 Consultant carried out environmental monitoring of construction site 74 km (116-190 km) of A-380 highway in the presence of ecologist of Engineering Consultant, ecologist of General Contractor and ecologist of Sub-contractors (“ElОktrtarmoqqurilisС” anН “Alians Kapital”).



465. As it was mentioned in the section 5.1., there were requirements on the SEMP development by Contractor. Due to the fact, that all project documents (biddings, contracts) refer to the SEMP from IEE, this document was used by Consultant as the basic one during environmental audit. Neither Contractor nor Engineering Consultant had EMP at the construction sites.

466. From ОnvironmОntal НocumОntation, tСО Contractor’s ОcoloРist prОsОntОН ОlОctronic version of environmental issues included in the Work Plan. The Work Plan was submitted in March 2013, and Engineering Consultant did not have comments on environmental issues.

467. The road under rehabilitation is located in Tashkent and Namangan Provinces. The following construction sites were surveyed in order to analyze environmental safeguards application at the construction site:

Construction base of Sub-contractor “Elektrtarmoqqurilish”

Construction base of Sub-contractor “Alians Kapital”

Concrete plant territory

Inert materials quary

A-380 highway

7.5.3. Construction Base and Camp of “Elektrtarmoqqurilish” Sub-contractor

468. Construction base of Contractor was located on the road border of A-380 road 5 km far from Namangan crossing point, on the territory of former truck fleet. Construction equipment, construction material, kitchen for the workers, shower rooms and lavatories were located on the territory of construction site (Fig. 168-169).

Figure 168: Construction base of “ElОktrtarmoqqurilisС” Sub-contractor

Figure 169: Mobile kitchen trailer on the construction base

469. According to the Sub-contractor’s rОprОsОntativО, construction workОrs Нo not livО on the territory of construction base, but just have lunch over there. The workers are transported from the neighboring settlements.

470. The wastewater was discharged without treatment to the gorge with Rezaksay river running along the bottom.

471. No places for the storing of domestic waste were arranged at the construction site. As of the audit date, the solid domestic waste was directly disposed to the gorge polluting environment and spoiling landscape (Fig. 170-171).



Figure 170: The pipes with wastewater discharge to relief

Figure 171: Storing of domestic waste outside the construction base

472. Two sections of the shower rooms are located on the base territory. No one of them is connected to the septic pit for the wastewater disposal. One of the shower rooms had never been functional; and as of environmental audit date, the second section of the shower rooms was not functional (Fig. 172).

473. AccorНinР to tСО Contractor’s rОprОsОntativО, tСО macСinery maintenance is not carried out on the territory of construction base; therefore the shops for machinery maintenance are not present over there. In case of breakdown, machinery is transported to the main technical base of Sub-contractor for the maintenance and repair.

474. The fueling of machinery is also carried out at the neighboring filling stations. The road construction machinery is fueled locally with the help of tankers. However, during the territory inspection, Consultant found the places of FL storing requiring the measures on liquidation of oil products spreading to meet their storing conditions (Fig. 173).

Figure 172: Nonfunctional shower room Figure 173: Place of FL storing

475. Therefore, inspection of construction base of Sub-contractor “ElОktrtarmoqqurilisС” showed non-compliance with EMP requirements in terms of domestic waste, wastewater management and FL handling.

7.5.4. Construction Camp of “Alians Kapital” Sub-contractor

476. Construction Camp oП “Alians Kapital” Sub-contractor is located on the natural site 75 meters far from A-380 highway. The comfortable living conditions – bedrooms, canteen and shower rooms were created for the employees living on the territory of construction base (Fig. 174-177).

477. The bins for collection of domestic waste were installed on the territory of construction base, and container for the waste collection was located on the outskirts of the territory. The



sanitary and hygienic requirements were met in canteen and shower rooms; the water was brought for the drinking purposes and was repeatedly treated through the filter.

478. The domestic waste is disposed to the territory designated by the local authorities based on agreements concluded by Sub-contractors with the communal services.

479. The sewage runoff from the shower rooms and kitchen are collected in the waterproof pit provided with observation window. When the pit is full the runoff will be transported to municipal treatment facilities based on agreements Sub-contractor and local authorities.

Figure 174: Construction basО oП “Alians Kapital” Sub-contractor

Figure 175: Container for domestic waste collection

Figure 176: Bins on the base territory for domestic waste collection

Figure 177: Canteen for the workers

Figure 178: Sub-contractor’s kitcСОn Figure 179: Shower rooms provided with uninterrupted hot water supply



Figures 180-181: Storing of construction materials and equipment on the territory of construction base

480. According to ecologist of the site under survey, machinery is not kept on the territory of construction base and is fueled by the tankers at the construction sites.

481. Analвsis oП situation on tСО tОrritorв oП construction basО oП “Alians Kapital” Sub-contractor showed compliance with the key requirements of EMP included in IEE.

7.5.5. Concrete Plant

482. The plant on concrete production was located on 172 km of A-380 highway close to concrete plant owned by the state road organization. In the vicinity of the plant, there were no settlements at the distance less than seven kilometers.

483. The EMP contained requirements on measurement of the noise levels in the first months of construction works at concrete plant (paragraph B, construction stage, EMP). However, until environmental audit date, such measurements have not been carried out, since the settlements are located at the distance more than one kilometer58

484. The Consultant recommended installation of protective screen at the ramps to the watercourse located close to concrete plant, for prevention of pollutants and concrete washout to the water body. Rezaksay river is running along the foot slope where concrete plant is located (Fig. 182-185).

Figure 182: Concrete plant territory Figure 183: Construction material storing

58

EMP prescribes conducting of the noise measurements in case of the settlements location within a radius of less than one kilometer



Figures 184-185: Rezaksay river on which bank concrete plant is located

485. Analysis of concrete plant condition showed compliance with the EMP key requirements. However, the Contractor needs to carry out additional measures on prevention of watercourse pollution and the noise level monitoring in the neighboring settlements.

7.5.6. Road Section on the Construction Stage

486. The analysis of the road condition during construction was carried out on the section with length 5 km. According to the project design, all asphalt removed from the road will be recycled and used as the road body after its milling into the small fractions.

487. Surveyed section of rehabilitated road was in satisfactory condition. Due to the humid weather, no construction site watering was carried out. According to Contractor, the section watering is carried out over 3 times a day in dry weather.

488. Removed concrete barriers were placed on the border of rehabilitated road, and after completion of construction works they will be placed back. No idle machinery was observed at the construction site along with FL spots spreading (Fig. 186-187).

Figure 186: Road body widening Figure 187: Tamping operations

489. Therefore, survey of the construction site of A-380 road showed compliance with the EMP requirements.

490. The Consultant also carried out inspection of the places of inert materials extraction. Rezaksay River running along A-380 highway was one of such places. However, as of the audit date, the operations on inert materials extraction were suspended due to the lack of official permission from the local authorities and nature protection committee.



Figure 188: Place of inert materials extraction in the bed of Rezaksay river

Figure 189: Construction material used for the road rehabilitation


7.6.1. Investment Program II, Tranche 1. Khorezm, Sarimay

491. This Tranche 1 had to be completed by end of 2013. Therefore, most of provided recommendations could be useful for further tranches. However, some of the recommendations have to be implemented before closing of the Project.

492. PMU with ADB assistance should pay more attention on keeping a consistence of Project documents. The Consultant noted some differences in environmental requirements in IEE, Loan Agreement and Contracts (e.g. LA includes requirements on conducting pilot re-vegetation, but Contract between Road Fund not, water quality monitoring). In case of some changes of implementing between LA and Contracts, PMU has to inform ADB and get approval on proposed changes.

493. Contractor should ensure that SEMP is delivered to all sub-contractors and is being implementing by all of them.

494. Environmental experts have to be included into the Bidding commission.

495. InvolvОmОnt oП PMU’s ОnvironmОntal ОxpОrt - duration and timing - needs to be revised.

496. PMU has to pay more attention to conducting environmental monitoring program inНicatОН in tСО IEE (wСat monitor, wСОrО anН Сow oПtОn). Contractor’s anН SupОrvision EnРinООr’s rОports СavО to incluНО inПormation on its rОsults. RОsults oП conНuctОН monitorinР have to be properly documented and all records should be attacСОН to Contractor’s rОports.

497. Contractor provided satisfactory living conditions for workers. After completion construction works, Contractor cleaned construction site and repaired on satisfactory level pit borrowers.

498. PMU has to pay more attention to implementation of some main requirements of EMP: handling and disposal of oil, disposal solid and liquid wastes. In case of non-compliance with EMP, PMU should consider this situation as non-performance of Contract covenants and apply appropriate sanction to Contractor.

499. Upon completion of works, the PMU (or with assistance of Supervision Engineer) has to conduct completion environmental report, which will be useful for preparing general project completion report.

500. PMU has to improve work with local community, ensure of functioning of Grievance Redress Mechanism included into IEE. Information on this activity needs to be included into the Environmental Monitoring Reports.



7.6.2. Investment Program III, Tranche 1. Kamchik

501. CoorНination bОtwООn PMU’s, SupОrvision EnРinООr’s anН Contractor’s ОnvironmОntal experts needs to be improved. Currently communication between them on conducting site observation, reporting, approval documents is not on the satisfactory level that negatively impacts on effectiveness of environmental performance within this project. Consultant noted poor communication even between environmental experts of General Contractor and Sub-Contractors.

502. PMU should pay more attention to preparing ToR for Supervision Consultant and Contractors. Contract with Sambo (Supervision Engineer) includes task to develop EIA/IEE Project II, Program III which already had been published at the ADB website. At the same timО, nОitСОr SupОrvision Consultant’s nor Contractor’s contracts Нo not incluНО anв information on reporting – timing and content.

503. Supervision Consultant and PMU should carefully revise content of SEMP/Work program (which includes environmental program) submitted for approval to PMU in terms of mООtinР EMP’s rОquirОmОnts. CurrОnt Contractors EnvironmОntal Program does not fully comply with IEE / EMP requirements.

504. PMU has to carefully review submitted by Contractors and Supervision Consultant environmental reports. They have to include reporting on all aspects included in IEE/EMP monitoring program.

505. General Contractor has to ensure implementing of Environmental program by their sub-contractors. Sub-contractor (Elektrtarmoqqurilish) must organize proper housekeeping facility for workers, collection and disposal solid and liquid wastes from construction camp.

506. PMU has to ensure that Contractor received official permission borrow pit from nature protection committee especially when inert materials is going to be taken from the river. Contractor should not be allowed to start working without this permission.

507. Applying mitigation measures is needed in area close to Concrete plant since these plants are located at river bank.

508. PMU has to improve work with local community, ensure of functioning of Grievance Redress Mechanism included into IEE. Information on this activity needs to be included into the Environmental Monitoring Reports.


# Recommendation Responsible/Actions Implementation Terms

1 To establish coordination among ecologists of PMU, Engineering Consultant, General Contractor and both Subcontractors on the issues of implementation and monitoring of environmental issues.

PMU – ensures coordination of works, arranges periodical meetings of environmental specialists, carries out joint field visits Engineering Consultant – carries out the monitoring of requirements implementation, timely submits environmental reports to PMU, assists PMU ecologist in preparation of semiannual reports or, in coordination with ADB, the annual ones Contractor – ensures




implementation of environmental requirements at the construction sites, timely submits environmental reports to PMU and Engineering Consultant

2 More accurately prepare the terms of reference for Engineering Consultant in terms of safeguards implementation

PMU – revises the schedule and duration of ОnvironmОntal spОcialist’s involvement Engineering Consultant - revises the schedule of ОnvironmОntal spОcialist’s involvement

At the stage of preparation of bidding and contract documents

3 More clear requirements on environmental safeguards without limitation with just EMP need to be included in the contracts between RRF and Contractor

PMU – ensures inclusion of all requirements in the contracts Engineering Consultant – provides support in preparation of documents

At the stage of preparation of contract documents

3 The work program of Contractor containing environmental issues has to be thoroughly analyzed

Contractor – to improve the program in terms of environmental issues to cover all EMP requirements Engineering Consultant – reviews and approves the program PMU – approves the program

Within one month after receipt of this report on environmental audit

4 The Engineering Consultant is to pay attention to content of environmental reports and review all environmental issues described in IEE. The reports have to be timely submitted PMU with copy to Contractor

Engineering Consultant – prepares reports in line with IEE requirements PMU – analyzes reports submitted by Engineering Consultant and, if necessary, takes the relevant actions


5 General Contractor needs to arrange implementation of environmental safeguards by his Sub-contractors. General Contractor has to deliver training for his workers on the issues of implementation of environmental safeguards presented in the Work Program amended with consiНОration oП Consultant’s recommendations

Contractor – delivers training for his employees on EMP implementation at the construction sites and construction base Engineering Consultant – carries out the monitoring of the training delivery and EMP implementation PMU – analyzes reports of Contractor and Engineering Consultant on delivered training and carries out the monitoring of EMP implementation


6 Sub-contractor “Elekttarmokkurilish” needs to

Contractor – ensures implementation of




cardinally change the situation with collection and disposal of domestic waste and wastewater at the construction bases, FL storing and bring it in line with requirements of EMP, domestic environmental and sanitary epidemiologic legislation

requirements of EMP and national legislation Engineering Consultant – carries out the monitoring of EMP implementation PMU – analyzes reports of Contractor and Engineering Consultant and carries out the monitoring

7 Contractor needs to obtain official permission of the local authorities and nature protection committee for the quarry development for inert materials extraction

Contractor – ensures work in the quarries only upon receipt of the relevant permission Engineering Consultant – carries out the monitoring of EMP implementation PMU – analyzes reports of Contractor and Engineering Consultant and carries out the monitoring

Within one month after receipt of this report on environmental audit



8. CAREC CORRIDOR 6 RAILWAY ELECTRIFICATION PROJECT (MAROKAND-

KARSHI)

8.1. Brief Information on CAREC Corridor 6 Railway Electrification Project (Marokand-Karshi) (CCREP) (L2781 45067-005)

509. The institutional issues, project documents and the project activities implementation sites were reviewed for analysis of observance of environmental safeguards on this project. The EMRKS implementation is carried out in Samarkand and Kashkadarya Provinces (Fig. 190). As of environmental audit date, the project progress accounted for about 5%. According to the project documents, the project has been assigned environmental category –

.

510. The ADB loan funds will be used to the equipment procurement (package 1) and “turnkОв” installation (packaРО 2). TСО minor construction works arО proposОН unНОr tСО package 2 on the equipment delivery and cable laying.

Figure 190: “Electrification of Marokand – Karshi Railway Section” Project

8.2. Institutional Issues of the Safeguards Implementation

511. Uzbekistan Temir Yullari State Joint-Stock Railway Company (UTY SRJSC) is the EMRKS Project Executive Agency. As of environmental audit date, the PIU on Electrification (PIU-E) was established for the project implementation, comprising the Deputy Head of PIU-E, combining his duties with obligations of Environmental Specialist59. The Supervision Consultant (Engineering Consultant) has also been selected – SYSTRA (France) in association with Corporate Solutions Consulting (Great Britain), whose team comprised the

59 According to the Project Administration Memorandum (April, 2012), the PIU-E is supposed to have the separate staffing position – Environmental Specialist (Section III, Chapter , paragraph 11, chart – the Project Management Structure).



Construction Engineer who was also fulfilling the duties of Environmental Specialist (Fig. 191).

512. This project will be implemented under the technical interface mode with close cooperation between the Directorate of the Capital Building Department (NDCBD/ К ) of SRJSC UTY and PIU EMRKS. The NDCBD will carry out all preparatory works for installation of electrification and signalization equipment – trench excavation, installation of the supports for the cable laying.

513. The bidding documents, contracts and technical reports developed by Engineering Consultant are submitted to PIU-E consideration and to the NDCBD – as recommendations.

Figure 191. Institutional Chart of the Environmental Safeguards Arrangement in the frame of the EMRKS Project

514. TСО Contractor on tСО Пirst packaРО “EquipmОnt oП ProcurОmОnt” Сas alrОaНв bООn sОlОctОН, anН on tСО sОconН “turnkОв” packaРО, as oП tСО auНit НatО, tСО biННinРs wОrО onРoinР on Contractor’s sОlОction Пor tСО work Пulfillment.


515. The Section 5, paragraph 3 of the Loan Agreement between the Republic of UгbОkistan (RUг) anН ADB oП FОbruarв 16, 2010 НОscribОs tСО BorrowОr’s – RUz obligations tСrouРС “UгbОkiston TОmir Вullari” SRJSC (SRJSC UTВ) as a sОcuritв tСat “...prОparation, design, construction, implementation, operation and decommissioning of the Project and its associate structures are meeting (a) effective laws and regulations of the Borrower regarding environmental protection, health protection and safety engineering; (b) the measures on ОnvironmОntal saПОtв; anН ( ) all mОasurОs anН rОquirОmОnts spОciПiОН in IEE, EMP as wОll as the other corrective and preventive measures stipulated by the Report of the Monitoring of Applied Safety MeasurОs”.

516. The paragraph 12 of the same section of the Loan Agreement describes the requirements to the Borrower on providing and/or arrangement of providing required



monetary and human resources for complete implementation of EMP and PP through the hiring of EP issues consultant for the EMP implementation monitoring (paragraph 12).

517. Also, according to the Loan Agreement, the Borrower is supposed to ensure inclusion to the bidding documents and contracts the provisions requiring from Contractors the IEE and EMP observance, providing of resources for these measures implementation, and submission oП tСО writtОn notiПication to tСО BorrowОr on anв risks oП ОnvironmОntal impact… or the impact emerging during the Project construction, implementation or operation not considered in the EP and EMP (paragraph 13).

518. The next (14) paragraph of the Loan Agreement specifies the deadlines of the environmental monitoring report submission to the ADB by the Borrower. According to this paraРrapС, “tСО BorrowОr will ОnsurО submission of semiannual reports on the safeguards monitoring on the EMP implementation and immediate disclosure of relevant information to tСО aППОctОН pОoplО”. Also, tСО BorrowОr Сas to inПorm ADB on all rОvОalОН unПorОsООn risks and impacts as well as on identified cases of EMP requirements nonobservance.

519. The Contractor's obligations on the environmental safeguards implementation are included in the bidding documents60 in SОction 6 “TСО CliОnt’s RОquirОmОnts”, CСaptОr 1.3. General Specifications, paragraph 1.3.4 Environmental Management Plan. This paragraph is stating that the Contractor has to develop detailed EMP and submit it to the Employer along witС НОtailОН НОsiРn. It ПurtСОr НОscribОs tСat “EMP Сas to incluНО tСО mОasurОs to bО takОn by Contractor for environmental impact mitigation/environmental protection from all impacts in the course of the contract works fulfillment. The EMP needs to reflect the standards on environmental protection set up by the State Environmental Protection Agency (SEPA) or its analoРuО..”. TСО p. 1.3.4. is also mОntioninР tСat EMP Сas to contain tСО sОparatО sОctions devoted to individual environmental issues, and submitted in the special format comprising such sections as goal, work plan, implementation schedule, human resources needs and monitoring procedures. It is stating that the EMP measures have to be carried out by Contractor since start of the works implementation. Further, the requirement is provided on tСО ПollowinР: “tСО Contractor nООНs to takО into account tСО EnvironmОntal Assessment RОport incluНОН in aННitional inПormation unНОr tСО paraРrapС 4».

520. TСО sОction 6 “TСО CliОnt’s RОquirОmОnts” oП tСО Book 2 oП 3 oП tСО biННinР documents actually contains the paragraph 4 Additional information (subparagraph 4.1.), specifying that in case of the contract award to the participant, he/she is supposed to submit the statement on observance of the measures on environmental protection and social security.

521. The paragraph 22.7 – Cleaning of construction site, Section 7 of the Contract General Terms Book 1 of the Bidding documents61, describes the requirements to the Contractor on the proper maintaining of construction site during the contract implementation and after its completion.

522. The bid assessment is carried out by the Interagency Commission approved by the Cabinet of Ministers. This Commission comprises the representatives from the various agencies. The team of ecologists is functioning under the SRC UTY which is also analyzing the bids. Along with that, the initial bid assessment is made at the PIU level with involvement of Engineering Consultant who has ecologist.

523. The Section IV – Annexes, Annex A (paragraph 3.3 – Construction supervision, subparagraph 3.3.1), of analyzed Contract62 contains the requirements on fulfillment of construction contracts supervision and control inspecting by Engineering Consultant. In

60 Bidding documentation, Book 2 of 3. Electrification of Marokand – Karshi Railway Section Project. Contract 02 - Design, manufacturing, delivery, installation and commissioning of the railway substations, sectioning points, contract network, system of SCB, communication and SCADA. April, 2013 61 Bidding documentation, Book 2 of 3. Electrification of Marokand – Karshi Railway Section Project. Contract 02 - Design, manufacturing, delivery, installation and commissioning of the railway substations, sectioning points, contract network, system of SCB, communication and SCADA. April, 2013. 62 Contract А01 among the Engineer for the Electrification of Marokand – Karshi Railway Section Project and Consortium “UгbОkiston TОmir Вullari” SJSC anН SВSTRA (France) in association with Corporate Solutions Consulting (Great Britain), August, 2012



addition, the scope of services on construction supervision will include supervision of environmental monitoring plan.

524. The subparagraph 3.3.5., paragraph (x) of the same Annex is stating that Engineering Consultant has to fulfill the duties associated with environmental impact mitigation in the course of construction with the reference to the technical requirements of the environmental standards on the basis of ADB Environmental Guidelines regarding the separate projects on inПrastructurО НОvОlopmОnt, as: (а) a РuarantОО tСat all ОnvironmОntal impact mitiРation measures to be implemented have been included in the contract documentation; (b) fulfillment of implementation supervision and monitoring, required measures on ОnvironmОntal impact mitiРation; anН ( ) coorНination oП tСО actions witС ExОcutivО AРОncв and ADB in case of any unforeseen environmental impacts.


525. The environmental safeguards were practically fully implemented at the stage of the project cycle under analysis.

526. The requirements on environmental safeguards have been included in the Loan Agreement, the bidding documents for selection of Engineering Consultant and Contractors and the contract between the Uzbekistan Temir Yullari SRJSC and Engineering Consultant SYSTRA (France) in association with Corporate Solutions Consulting (Great Britain).

527. The Engineering Consultant accomplished the basic monitoring and assessment of unforeseen impacts at the project sites; the periodical environmental reports are prepared and submitted to the PIU and SES Kashkadarya Province.

528. The Consultant is recommending PIU submitting the environmental monitoring semiannual reports to the self-governance bodies (makhallyas, khokimiyat) and to the provincial nature protection committees.

529. To establish and ensure efficient operation of the mechanism of examination of the local population complaints and suggestions through the project implementation.

530. In preparation of the contracts between the SRJSC and selected Contractor, to pay attention to inclusion of requirements on observance of IEE and reporting on implementation of environmental safeguards.



9. SECOND SMALL AND MICROFINANCE DEVELOPMENT PROJECT

9.1. Brief Information on Second Small and Microfinance Development Project Phase II (SSMDP II) (L2634)

531. TСО SSDMII ProjОct’s aim is in support oП the government program to develop micro and small enterprises (MSEs) in Uzbekistan, especially, in rural areas. In accordance with Loan Agreement between ADB and the Republic of Uzbekistan dated May 1, 2010 the SSMDII Project is being carried out by the Participating Commercial Banks (PCB) (Fig. 192).

Figure 192: General Institutional structure of the SSMD II Project implementation63

532. Initially, the SSMDII Project was executing by three Participant Commercial Banks (PCB) – Hamkorbank, Ipak Yuli Bank and Agrobank. After one year of the Project implementation only two PCBs – Hamkorbank and Ipak Yuli Bank have been carrying out the Project. In this regards, implementation of environmental safeguards by these two PCBs was reviewed within conducted audit. To assess efficiency of implementation of environmental safeguards, Consultant reviewed institutional aspects of environmental management and project documents related to environmental performance in each PCBs.

533. Based on ADB environmental categorization Project and in accordance with Project Administration Manual (PAM), (2010) SSMDII belongs to FI (Financial Intermediate) category. Since sub-loans will be provided for the activities which have minimal or no adverse environmental or social risks, the FI project is treated as category C project and need not apply any other specific requirements64.

534. Based on above mentioned, the main purpose of the environmental audit is to review a procedure of sub-loan selecting in regards of proper implementation of environmental safeguards.

9.2. Environmental requirements in the SSDMII Project documents

535. Environmental safeguards requirements during the Project implementation are mainly described in three project documents: (i) Loan Agreement (LA) between Republic of Uzbekistan and ADB (May 1, 2010), (ii) Project Agreements between ADB and Hamkorbank (May 1, 2010) and (iii) Project Agreement between ADB and Ipak Yuli Bank (May 1, 2010).

63 The Organizational chart, Project Administration Manual, March 2010 64ADB Safeguard Policy Statement (2009), para 64.

Loan Agreement

ADB MOF

Project Agreemen

Subsidiary Loan

Agreements

Hamkorbank,

PIU

IpakYuli Bank,

PIU

Agrobank,

PIU

Project

Agreements



536. The first document – LA bОtwООn ADB anН RUг statОs, tСat “…BorrowОr will makО available to the proceeds of the Loan provided for herein upon terms and conditions satisПactorв to ADB”65.

537. Schedule 3 of this LA also describes Criteria for Qualified Subproject and type of activities allowed for funding. Particularly, clause 11 of the schedule 3 of Loan Agreement saвs tСat: “BorrowОr will causО tСО PCBs to ОnsurО tСat QualiПiОН SubborrowОrs will bО Пor activities that: (a) are excluded in the list of prohibited investment activities which set out in the table to this Schedule66 and (b) have a minimal or no adverse environmental or social risks. Activities that fall under categories A or B of ADB Safeguard Policy Statement (2009) and /or require environmental assessment clearance from the Borrower shall not be financed under the Project.

538. The next clause of this Schedule oП LA proviНОs rОquirОmОnts on “complвinР oП QualiПiОН SubborrowОrs witС ADB’s SPS (2009) and applicable environmental, health and saПОtв anН social laws oП tСО BorrowОr”.

539. The Project Agreements between ADB and Hamkorbank, ADB and IpakYuli Bank (both dated May 1, 2010) have exactly the same Criteria for Qualified Subborrowers67.

9.3. Institutional structure of environmental performance

540. In accordance with LA68 provision, the Ministry of Finance is the Project Executing Agency with responsibility of overall Project implementation and coordination with PCBs. The PCBs will be an Implementing Agency of the Project. Each PCB will establish a Project Implementation Unit (PIU).

541. Signed at the same day Project Agreements between ADB and Hamkorbank, ADB and Ipak Yuli Bank also state that both banks will establish PIU and the banks will ensure that the Project is implemented in accordance with the detailed arrangements set forth Project Administration Manual (PAM)69.

542. TСО PAM НОscribОs rОsponsibilitiОs oП all projОct’s aРОnciОs involvОН in tСО projОct executing. There are not any requirements to establish separate safeguard unit in the PIUs, and no special requirements on environmental safeguards monitoring in the PAM. There is onlв РОnОral statОmОnt: “SubprojОcts will complв witС UгbОkistan’s labor anН ОnvironmОntal, health and safety, and social law and regulations and conform to ADB safeguards policy” (PAM, clause 6).

543. At the same time, both Banks have own internal Bank Credit Policies, which include requirements on complying to national environmental legislation. According to Regulation of the Central Bank of the RОpublic oП UгbОkistan # 429 on “RОquirОmОnts oП CrОНit Policв oП CommОrcial Banks (nОw ОНition)” НatОН Пrom 22 FОbruarв, 2000, ОacС Bank Сas to НОvОlop and implement own Credit Policy, which approved by Bank Council (Board). Members of Board and Administration and other banks officials are responsible for their development and implementation.

544. As for audit date, each PCB has ESMS approved by Board of Council. The following chapters describe organizational structure of environmental management and provide brief description of ESMS in each PCBs bank.

9.4. Hamkorbank ESMS

65 Loan Agreement between RUz and ADB (May 1, 2010), Ordinary Operation, Section (B) 66 Schedule 3 of Loan Agreement (May 1, 2010) 67 Project Agreement, Schedule: Execution of Project; Financial Matters, clauses 10 and 11 (May 1, 2010) 68Loan Agreement, Schedule 3, clauses 1-3 69

Project Administration Manual, March 2010, V. Financial Management, March 2010



545. Requirements on applying of ESMS for all investment are included in the Agreement between International Financial Organization and Hamkorbank70 (dated from 2010).Hamkorbank’s ESMS was aНoptОН in 2010 and amended in 2012. The ESMS presents organizational structure of environmental performance in the Hamkorbank (Fig. 193).

Figure 193: Organizational structure of environmental performance

546. Environmental Manager is responsible for development and submission of ESMS to Bank’s ExОcutivО BoarН Пor approval. In aННition, tСО EnvironmОntal ManaРОr prОparОs an annual rОport on ОnvironmОntal pОrПormancО anН submits it to Bank’s ExОcutivО BoarН anН IFC (as Bank’s sСarОСolНОrs). TСО ОnvironmОntal manager oversees implementation of all environmental and social aspects71.

547. Appointed Senior Environmental Coordinator is responsible for the implementation of ESMS in all bank branches and he/she is responsible for implementing environmental requirements for each loan and for maintaining records on environmental reviews.

548. Heads of front office (senior credit officer) 72is Environmental Coordinator in the bank branches. He/she is responsible for all investment decisions supported by appropriate due diligence documentation.

549. Hamkorbank ESMS procedure consists of 4 stages: (i) Sub-project Review and Categorization; (ii) Identification of Applicable Environmental Standards (iii) Environmental and Social Assessment (iv) Related Conditions and Responsibilities.

550. TСО ESMS statОs: “At an initial staРО oП inquirв, tСО EnvironmОntal CoorНinator will applв Bank’s Exclusion List (AppОnНix 1 oП ESMS) to tСО projОct (sub-loans). If the project involves an excluded activity, the prospective client will be informed, and further

70 Since 2010 IFC has been one of the c0ofounder of Hamkorbank 71Hamkorbank’s ESMS, (2012) 72 Departments within each branches of Hamkorbank working directly with clients

Head of Front Officer

of Branch 1

Head of Front Officer

of Branch -2

Credit Inspectors -1 (Environmental

Coordinator)

Credit Inspectors -2 (Environmental

Coordinator)

Environmental Manager

Senior Environmental

Coordinator

Bank’s Eбecutive Board



consiНОration oП ПinancinР Пor tСО projОct will bО tОrminatОН”73. The Exclusion List is presented in Appendix 1 of this report.

551. ESMS Exclusion List fully complies with List of Prohibited activities provided in Appendix 1 of the Project Agreement between ADB and Hamkorbank.

552. TСО nОxt para oП ESMS statОs: “tСО traНО transactions arО onlв scrООnОН aРainst tСО Exclusion List, micro finance clients only Exclusion List and Uzbek environmental and social laws”. BorrowОrs oП loans witС amount lОss tСan 1000 minimal wages ($43,600) are considered as a micro finance client74. In accordance with Loan Agreement75, each sub-loan has not to exceed the maximum sub-loan amount of $20,000 (50% of this amount has to be provided by PCB76).Therefore, carrying out of the next stages of ESMS is not required. It means that sub-loans providing within SSMD II Project has being reviewed only on compliance with Exclusion List.

553. However, Consultant thinks that, some type of activities funded through micro-credits (up to 1000 wages) may have an adverse impact on environment (for example construction of small size poultry or cattle farms near to water bodies or settlement area, small vehicle repairing workshops and etc.). In spite of small portion of sub-loans providing within the SSMD II Project for construction activities (around 3-5% of all provided sub-loans), Hamkorbank should re-consider using approaches for micro-credit environmental categorization.

554. In accordance with ESMS, Hamkorbank prepares and submits an Annual Social & Environmental Performance Report to Executive Board and IFC for consideration. The report provides general information about all loans granted during the reporting year.

555. Since SSDM II Project documents do not contain any requirements on reporting on environmental compliance, Hamkorbank does not prepare the separate environmental monitoring report for ADB.

556. According to information provided by Hamkorbank, Senior Environmental Coordinator annually conducts internal trainings on ESMS implementation for environmental coordinators from all branches. Moreover, during 2012-2013 five rОprОsОntativОs’ of the Head Office and branches participated in several trainings related to the Environmental and Social aspects in crediting. The trainings were organized by the World Bank and IFC.

9.5. Ipak Yuli Bank ESMS

557. Ipak Вuli Bank aНoptОН Пirst vОrsion oП “RОРulation on ОnvironmОntal anН social risks manaРОmОnt” in 2012, anН in 2013 upНatОН vОrsion oП tСis RОРulation was rО-adopted. In accordance with this regulation, all loans (including sub-loans funded through SSDM II Project) have to comply with Environmental and Social Risk Management System (ESRMS77) system, particularly all loans have to be screened and categorized.

558. The First version of Ipak Yuli Bank ESRMS was prepared with assistance of international environmental consultant. Bank Council (Board) approved ESRMS in 2012 and in 2013 the second revised version of the document with amendments was re-approved.

559. ESRMS consists of 3 chapters and 11 appendixes, describes Ipak Yuli Bank’s environmental and social risk management policy and applicable requirements, management procedure. The ESRMS fully complies with ADB Safeguard Policy and includes Prohibited Investment Activities List (PIAL) which is the same as ADB PIAL.

73Hamkorbank’s ESMS (2012), Procedures, page.3 74

Minimal wage in Uzbekistan is 96,105 sum (as for January 2014), that equivalents $ 43,6 and 1000 min wages is $ 43,600 75

Loan Agreement, Schedule 3, clauses 4 (b) 76

Loan Agreement, Schedule 3, clauses 5 77 ESRMS is the same as ESMS and fully complies with ADB requirements



560. ESRMS also includes Organizational Chart describing institutional aspects of the environmental performance in Ipak Yuli Bank (picture 3). Each credit specialist who works on preparing set of documents for credit receiving conducts Environmental Screening and Categorization. Monitoring of ESMS requirements implementation is being carried out on the pОrmanОnt basО. All proviНОН loans СavО bОinР ОntОrОН in tСО NCI Bank’s Нata basО. TСО rОsponsiblО Пor ESMS Bank’s oППicОr (E&S Risk ManaРОmОnt OППicОr) Сas accОss to tСis data base. E&S Risk Management Officer checks conclusions of credit experts provided during the period. Conclusions for checking are selected on a sample base. Results of this review are being presented as a report to Chairman of Credit Committee.

Figure 194: Organizational Chart of Environmental performance in Ipak Yuli Bank

561. In accordance with ESRMS procedure, all projects for financing have to be screened anН catОРoriгОН. ESRMS statОs: “At an initial staРО oП iНОntiПвinР anв projОct for financing, Responsible Staff of Ipak Yuli Bank employed in the relevant structural units of the Bank undertaking lending/investment operations, will apply ADB's Prohibited Investment Activities List (Attachment 1). If the project involves a prohibited investment activity, the borrower will bО inПormОН tСat tСО projОct will not bО consiНОrОН”.

562. FurtСОr, ESRMS НОscribОs nОxt stОps: “IП tСО proposОН projОct compliОs witС tСО ADB‘s PIAL, tСО RОsponsiblО StaПП will classiПв wСОtСОr tСО projОct bОlonРs to category A, B or C (AttacСmОnt 1a. InНicativО EnvironmОntal anН social risk catОРoriгation РuiНО)”.

563. However, the procedure of environmental categorization of projects is based on the EBRD classification. Using this approach for project classification makes this process difficult for use and not always suitable for implementation in the local cases due to different natural conditions and types of categorized activities. Consultant recommends to revise the

Deputy Chairman of the Board

Council of the Bank

Risk Management Committee

Management Board of the Bank

Chairman of the Bank

Risk Management Division

First Deputy

Chairman of the Board

E&S Risk Management

Credit risk management and

compliance-control department

Market, operational and liquidity risk



categorization list and to adopt more simplified categorization procedure, which fully compliОs witС local natural conНitions anН is Оasв to implОmОnt bв bank’s crОНit oППicОrs. In addition, Consultant has to note that the issues on difficulties with implementing the environmental categorization procedure were raised anН ADB ОxpОrt’s assistancО in rОvisinР of categorization procedure was requested by Ipak Yuli Bank officers during ADB environmental training in August 2013.

564. The Results of environmental screening and categorization of each considered application for loan is recorded by Credit officer as a part of set of necessary documents. The results are entered into the format included in ESRMS and are submitted to E&S Risk Management Officer (maв bО “wОrО” instОaН oП “arО”).

565. Since SSDM II Project documents do not contain any requirements on reporting on environmental compliance, Ipak Yuli Bank does not prepare a separate environmental monitoring report for ADB.

566. According to official information provided by IpakYuli Bank, during 2013 information a number of worksСops anН traininРs on tСОmО: “ESRMS I Ipak Вuli Bank” wОrО conНuctОН bв staff of Department Risk Management. Representatives of microcredit departments of Head oППicО anН bank’s brancСОs participatОН in tСО traininР. TСО Total numbОr oП trainОН oППicers is 64.

9.6. Conclusions and recommendations

567. Based on the results of conducted audit the following conclusions and recommendations have been made by Consultant:

9.7. Hamkorbank

568. Requirements on compliance with environmental safeguards indicated in the Loan AgrООmОnt, ProjОct AРrООmОnt anН PAM arО incluНОН in tСО Bank’s aРrООmОnts anН intОrnal management documents.

569. Hamkorbank has ESMS, which allows reviewing all potential loans (including sub-loans within SSDM II Project) on compliance with environmental safeguards requirements indicated in the Project Loan agreement. However, Consultant recommends re-consider approaches used for environmental categorization of micro-credit in part of requested activitiОs Пor projОcts classiПiОН as “minimal risk”. In aННition, tСО “List oП activitiОs risks” nООНs to be extended due to not including some common types of activity.

570. All sub-loans funded through the SSDM II Project are screened and categorized based on the ESMS. The appropriate records on results of screening and categorization are carrying out as a part set of documents submitting for receiving loans.

571. Hamkorbank conducts internal trainings on ESMS implementation for environmental coordinators from all branches and this practice should continue.



9.8. Ipak Yuli Bank

572. Requirements on compliance with environmental safeguards indicated in the Loan AРrООmОnt, ProjОct AРrООmОnt anН PAM arО incluНОН in tСО Bank’s aРrООmОnts anН intОrnal management documents.

573. Ipak Yuli Bank has ESRMS78 which allows reviewing all potential loans (including sub-loans within SSDM II Project) on compliance with environmental safeguards requirements indicated in the Project Loan agreement. However, Consultant recommends to revise approaches used in environmental categorization of loans and to adopt more simplified categorization procedure which fully complies with local natural conditions and is easy to implОmОnt bв bank’s crОНit oППicОrs.

574. All sub-loans funded through the SSDM II Project are screened and categorized based on the ESRMS. Appropriate records on results of screening and categorization are carrying out as part set of documents preparing for receiving loans.

575. Ipak Yuli Bank conducts regular trainings on ESRMS implementation for Micro Credit Department officers from Head Quarter and all branches and this practice should continue.

78

Ipak Yuli Bank adopted ESMS as ESRMS



10. HOUSING AND INTEGRATED RURAL DEVELOPMENT PROJECT

10.1. Brief Information on Housing for Integrated Rural Development Investment Program – Project I (HIRDIP I) (L2775)

576. The Housing for Integrated Rural Development Program (HIRDP I) is a multisector program for achieving more inclusive growth through improved rural living standards and livelihood opportunities. The program focuses on increasing access to improved rural housing and improving the investment climate in rural areas, as a catalyst for improving living conditions and creating new job and livelihood opportunities in rural areas79.

577. The Program consists of three outputs: (i) Housing loans by PCBs to targeted creditworthy subborrowers to purchase new residential housing in rural areas (Output 1); (ii) Improved capacity of local governments (hokimiyats) to prepare and implement integrated rural development plans and investment promotion strategies (Output 2); (iii) Improved enabling environmental for MSEs to expend or establish new business in rural areas.

578. The loan is categorized as FI (treated as C) for all safeguards components based on ADB Safeguard Policy Statement (SPS) (2009), it requires establishing an Environmental and Social Management System (ESMS).

579. Based on abovementioned, the main purpose of the environmental audit is to review a procedure of sub-loan selection in regards of proper implementation of environmental safeguards. To assess implementation of environmental safeguards during the Project executinР, Consultant rОviОwОН tСО ProjОct’s institutional structurО oП ОnvironmОntal management, the Project documentation and status of ESMS implementation by Participating Commercial Bank (PCB). All reviews related to Output 1 of the Program since Output II and III are soft components of the program and do not have impact on an environment.

10.2. Institutional Structure of Environmental Performance

580. In accordance with Loan Agreement between Asian Development Bank (ADB) and the Republic of Uzbekistan dated from February 16, 2012, the HIRDIP I Project is being carriОН out bв OpОn Joint Stack CommОrcial Bank “QisСloq QurilisС Bank” (QQB) (Пor Output 1of the Project) and the Ministry of Economy (MOE) (for Output 2 and 3 of the Project). Organizational structure of program is presented in the Fig. 195. Para 1 of Schedule 5 of Loan AРrООmОnts also statОs, tСat: “TСО BorrowОr anН QQB sСall ОnsurО tСat tСО ProjОct is implementing in accordance with the detailed arrangements set forth in the Facility AНministration Manual” (FAM).

Figure 195: Program Organizational Structure80

79 Facility Administration Manual (FAM), Republic of Uzbekistan: Multitranche Financing Facility for the Housing for Integrated Rural Development Program, August 2011 80 FAM, August 2011

ADB

Ministry of Economy (EA) Program Implementation Unit

Participating Commercial Bank (IA)



581. FAM dated from August 2011 defines the Ministry of Economy (MOE) as the ProРram’s ExОcutinР AРОncв. FurtСОr, tСО НocumОnt saвs tСat tСО MOE woulН also “ОstablisС a ProРram ImplОmОntation Unit (PIU), satisfactory to ADB that has to provide technical support for implementation and monitoring and evaluation of the Program (and ОacС ProРram trancСО…)”. DОscribОН in FAM MOE’s rОsponsibilitiОs Нo not incluНО anв special requirements on executing or monitoring of environmental safeguards.

582. In accordance with the FAM, PCBs act as an Implementing Agencies for Output 1 of the Program. PCBs are responsible for establishing and maintenance of Environment and Social Management System (ESMS) and submission of annual reports to ADB on compliance with safeguards requirements.

583. To fulfill responsibilities of PCB on environmental safeguards indicated in FAM, the QQB designated an Expert on ESMS from International Financial Investment (IFI) Department of Head Quarter. The expert duties include establishing, maintenance of ESMS and collecting reports on ESMS executing from all branches, preparing and submission of annual reports to ADB on compliance with safeguards requirements.

584. In turn, officially appointОН ESMS FiОlН StaПП (EFS) oП ОacС QQB’s brancСОs arО responsible for implementing ESMS at stage of site selection and monitoring of compliance with the respective national and ADB environment regulations. Example of official order about appointment of EFS in one of the QQB branch is presented in Attachment 9.

585. In addition, one of the former departments of QQB, currently the separate entity – Qishloq Qurilish Invest (QQI) concludes agreements with Contractors on construction of houses through its provincial branches. QQI also conducts routine technical supervision of construction activities within concluded agreements through its branches (Fig. 196). There is no special appointed person responsible for ESMS implementation in QQI.

Figure 196: Project Organizational Structure

10.3. Environmental Aspects in Project Documentation

586. Para 8 of Schedule 5 of the Loan Agreements describes responsibility of Borrower (the Republic of Uzbekistan) and QQB to ensure that: (i) the ESMS is used to screen the Qualified Subproject from the environmental, indigenous peoples or involuntary resettlement impact associated with such Qualified Subproject. The Borrower will cause QQB to ensure that each Qualified Subproject is not in category A or in category B in terms of environmental, involuntary resettlement and/or the ethnic minority or indigenous people impact, within the meaning of the SPS; (b) the environmental clearance from the Nature Protection Committee of the Borrower for the rural housing site for the Qualified Subproject has been obtained.

587. The next para of schedule 5 the Loan Agreement specifies responsibility of QQB on ensuring that the preparation, design and construction of each Qualified Subproject comply with all applicable laws and regulations of the Borrower relating to the environment, health

ADB QQB (IA) Head Quarter

ESMS

QQI (Technical

Supervision)

IFA, ESMS Expert

QQB Branch-1 QQB Branches 2,3…

Contractor 1

Contractor 1



and safety, the SPS, the ESMS and any corrective or preventative actions in the Safeguards Monitoring Reports.

588. Loan Agreement also describes the responsibilities of QQB in terms of Safeguards Monitoring and Reporting. QQB must submit reports annually and in case of any unanticipated environmental and/or social risks and impacts arising during Qualified Subproject implementation, promptly inform ADB about the occurrence of such risks81.

589. The next paragraph НОscribОs rОsponsibilitв oП QQB to ОnsurО tСat “...no procООНs oП the Loan is used to finance any activity included in the list of prohibited activities provided in AppОnНix 5 oП tСО SPS anН as sОt ПortС in tСО ESMS”.

590. The Project Agreement between ADB and QQB dated from 16 February 2012 fully repeats requirements to QQB on screening, categorization and environmental and social assessment82, reporting and compliance with Prohibited Investment Activities List.

591. Facility Administration Manual (2011) also provides detailed information on safeguards requirements and institutional structure of ESMS implementation. Particularly, para 2, SОction VIII “SaПОРuarНs” statОs tСat ОacС PCB will НОsiРnatО a unit to bО rОsponsiblО for implementation in its ESMS. Appointed ESMS Specialist will have to coordinate ESMS implementation including monitoring and reporting activities under the ESMS. In addition, ESMS specialist will maintain environments/permits related to the housing sites, and conduct regular site visits.

592. In part of PIU’s rОsponsibilitiОs, tСО НocumОnts inНicatО tСО rОsponsibilitiОs amonР otСОrs, ОnsurО “aНoption oП lanН sОlОction procОss anН PCB ESMS in accorНancО witС ADB saПОРuarН rОquirОmОnts…”83.

593. AttacСmОnt 9 oП tСО FAM is tСО QQB’s ESMS prОparОН in accorНancО with ADB safeguards for Financial Intermediates. The QQB Executive Board officially approved and accОptОН ESMS Пor usinР bв all QQB’s brancСОs in FОbruarв 2011. TСО ESMS НОscribОs in detail a procedure of screening process and verification of selected housing, monitoring, reporting, public disclosure procedures, and institutional aspects of ESMS executing and training program. Basic procedures and agencies involved in site selection are presented in the Table 1 of ESMS. In accordance with this table and statement in para 23 of ESMS, a Regional Nature Committee is the agency responsible for making the final decision on site selection for construction of rural housing.

594. The Consultant notes that in accordance with national legislation84 a land acquisition procedure consists from two steps: (i) approval on site selection and (ii) proceeding resolution on land acquisition for selected site. Prior to site approval by district government, a proposing site and conditions of its withdrawing need to be endorsed by several state agencies including nature protection committee85. Representative of a district nature protection committee, as a member of official District Commission, has to sing a Statement on land acquisition and to confirm that a proposing site meets environmental requirements.

595. Moreover, article 23 of Cabinet Ministries Resolution #146 states that an entity designated for preparing site selection materials (QQI in this case) has to provide a Conclusion of State Environmental Expertise as a part of set of documents submitted to a District Commission. After revising and assessment all requested documents, the District Commission issues a Statement on site selection, which has to be approved by a District Governor. This Statement serves as a basis for further actions on land acquisition procedure (second stage).

81 Loan Agreement, Schedule 5, para 14-15. 82 Project Agreement, Housing for Integrated Rural Development Investment Program – Project 1), 16 February 2012 83 FAM, Part C “OrРaniгational StructurО”, para “c”, paРО 10 84 CabinОt MinistriОs RОsolution on “ProcОНurО Пor РrantinР lanН Пor Urban НОvОlopmОnt anН otСОr non-aРricultural activitiОs” #146, 25 May 2011 85

ArticlО 21, SОction II oП CabinОt MinistriОs RОsolution on “ProcОНurО Пor granting land for Urban development and other non-aРricultural activitiОs” #146, 25 Maв 2011



596. Therefore, it is recommended to revise ESMS in the part of site selection procedure (table 1 and para 23) and update it in order to meet a national legislation and ADB safeguards requirements.

597. ThО ESMS incluНОs Пormats, wСicС sСoulН bО ПillОН bв QQB bank’s EFS at tСО different stages of project cycle: during collecting general data for each residential block for rural construction (Form 1), summariгinР Нata on rОsiНОntial blocks tСat mООt tСО QQB’s selection criteria to be eligible for ADB funds (Form 2) and during the monitoring of construction workflow (Form 3). Two documents need to be attached to the Form 3 – (a) Act of the Regional Selection Committee on the selected site and (b) Environmental Opinion Пrom RОРional NaturО ProtОction CommittОО. In aННition, tСО QQB’s EFS is rОsponsiblО Пor verifying data provided by QQI branches on eligible massifs (para 28 of ESMS).

598. QQI acts on a basis of the Charter approved by QQB Council of Board in 2009. QQI executes a Technical Supervision of all construction works including works conducted within the HIRDP I in accordance with national construction regulation – KMK 1.03.07-96 “RОРulation on works supОrvision”. TСО RОРulation НoОs not contain anв rОquirОments on environmental monitoring. In addition, there is no any official document between QQB and QQI, which regulates ESMS compliance during construction activity86.

599. SОction 8 “Particular ConНitions” oП moНОl Contracts bОtwООn QQI brancСОs anН Contractors (Пor construction СousОs) incluНОs rОquirОmОnts on submission “an Action Plan for Safety, Health and Environment Protection for the approval of the Project Manager before startinР anв construction activitiОs” (GCC 18.2, Part A. GОnОral oП SОction 8).

600. The nОxt para oП tСО samО clausО statОs: “tСО Contractor sСall at all timОs takО all rОasonablО prОcautions to maintain tСО СОaltС anН saПОtв oП tСО Contractor’s pОrsonnОl anН to proviНО a saПО work ОnvironmОnt”.

601. In aННition, tСО contract’s clausОs GCC 48.1, Part D. Cost Control of Section 8 НОПinОs tСat “TСО aНvancО paвmОnt sСall bО paiН to the Contractor not later than 28 days after submission of the Work Programme, the Plan for Ensuring Quality of Works, and the Action Plan for Safety, Health and EnvironmОnt ProtОction”.

602. General requirements to the Contractor on compliance with all applicable national, provincial, and local environmental laws and regulations are included in Part E of the Contract agreement. Finishing the Contract (section PCC 63) of the same Section 8.

10.4. Implementation of ESMS by QQB

603. Conducted analyze of Project documentation and Project organizational structure showed that generalized environmental safeguards requirements consist of: (i) screening the qualified subprojects on complying with selection criteria in terms of environmental requirements, (ii) checking existence of environmental clearance from the State Nature Protection Committee for the rural housing sites and (iii) ensuring a compliance of preparation, design and construction of each qualified subprojects with the applicable national environmental legislation and ADB SPS. All these requirements are fully reflected in QQB’s ESMS.

604. In accordance with ESMS procedure, screening of potential sub-projects on compliance with environmental safeguards is conducted by two entities: QQB and QQI. At the first stage a QQI as a Technical Supervision initiates site selection procedure and getting an approval from a District Government Authority (District Governor).

605. Upon receiving an approval from the District Government Authority (Government), the QQI branches (subunits) start a process of preparing control-executive documentation through recruiting an eligible organization necessary for a land acquisition. As part of this process, the QQI branches has to engage expert/organizations for conducting environmental assessment for construction of houses blocks in accordance with national environmental

86

QQI is newly set up entity, which was established in 2012 on the basis of QQB.



legislation87. Environmental assessments are reviewed and approved by Provincial Nature Protection Committee (NPC). Providing a clearance on construction housing blocks, NPC provides no-objection not only to construction activities but also to location of massifs.

606. According to data provided by QQI and PMU, environmental clearances were obtained for all constructed housing massifs.

607. QQI branches send lists of sites approved by Province Government Authority for construction houses to QQB branches. After receiving sites proposing for construction, the QQB BrancС’s EFS Пills Form 1 anН 2 attacСОН to ESMS using data gathered from the District Hokimiyat, the Nature Protection Committee, and the District Cadastre and from own observations of proposed sites. Based on collected data, the EFS make decision on which sub-projects comply with all ADB requirements and could be funded through the HIRDIP and which are not comply and could be funded through QQB reserve funds. Information on projects complying with ADB safeguards requirements is entered into the Form 2. Based on the data provided by QQB all sites complied with ESMS requirements and there was no case on non-complying with ADB safeguards requirements.

608. In addition, a National Safeguard Specialist engaged by PMU conducts a Due Diligence Review of 100% of massifs. This includes a desk review where all land documents are checked and field visits to each massif to ensure compliance with selection criteria including existing clearance from the NPC.

609. Revision of Forms 1-3 showed that EFSs of each QQB branches fill Forms 1 are filled for all housing blocks (example of filled form is attached – Attachment 1 and 2) based on information collected from relevant agencies. Forms 2 also is filled by EFS and it should provide information on name and location of only those massifs, which comply with national and ADB environmental safeguards and the data on total area of housing blocks within whole province. Third column of the Form 2 – “aННitional inПormation rОlatОН witС otСОr sОlОction critОria” is not ПillОН. Consultant suРРОsts to rОvisО tСis Form anН to makО a НОcision on a format of information providing in Column 3. One of the possible options is to provide requested information in contracted notations (abbreviation) in order to simplify a process of collection and presentation of materials. In this case, the Form 2 could be considered as a summarized table, which provides information on all selection criteria and in further, the information from this Form could be used for preparing Specialized Project Reports, which Executing Agency has to submit to ADB88.

610. On the other hand, a completion of the Form 2 will depend on availability of data on other criteria which collected by other project departments/experts. In this case, there is no need to provide additional information on other selection criteria in Column 3 of Form 2. Therefore, in order to avoid duplication, the Consultant recommend re-check information РatСОrОН bв НiППОrОnt projОct’s НОpartmОnt/ОxpОrts anН makО a Пinal НОcision on inПormation presenting in Form 2.

611. As states ESMS, implementation of the environmental measures during the construction has to be monitored by technical experts from QQI and EFS from QQB. EFSs of respective QQB branches have to conduct periodic field audits of implementing environmental measures during construction as a cross check of information provided by QQI. Monitoring results are entered into the Form 3 of ESMS.

612. Filling the Form 3 stipulates conducting environmental audit with inviting a representative of district Nature Protection Committee (to fill line 2 of the Form 3) and representative of QQI as a technical supervision engineer (to fill lines 3 and 4 of the Form 4). Reviewing of the forms showed that information provided into the Form 3 is too general and does not allow evaluating implementation of the environmental requirements by Contractor. Information on presence staff from District NPC and technical QQI during the environmental audit is missed.

87 QQB ESMS, paragraph 27-28 88 FAM, 2011, A. Program Design and Monitoring Framework, Outcome, page 31



613. Consultant accepts situation when participation of NPC staff for each housing observation could be difficult. In this case, to conduct environmental monitoring by EFSs themselves a simplified check-list could be developed.

614. Consultant also recommends provide a brief description of the main findings for each monitored housing block within submitting Form 3. Adding some pictures from the observed construction sites would support the findings and observation.

615. In aННition, all QQB’s ESMS rОquirОmОnts inНicatОН in para 32 СavО to bО mОt as well, particularly information providing with Form 1 and Form 2 needs to be supplemented with: (i) information on amounts paid for renting areas for temporary storage of construction materials of any and (ii) brief description of complaints from affected people related to construction works. Reviewed by Consultant forms did not contain information on these two topics. The Consultant was informed by PMU that, complaints from affected people are monitorОН bв tСО QQI’s staПП, but rОsults oП monitorinР arО not bОinР rОcorНОН. TСОrОПorО, tСО Consultant recommends keep records on monitoring of above-mentioned parameters.

616. Paragraph 30 of ESMS requests QQI as TSE submission a compliance report after completion of construction works. In accordance with the national requirements89, a special procedure on completed works acceptance is implemented after finishing construction works. Each block is reviewed by special designated state commission90, which includes representatives of a number of government organizations such as Provincial NPC, “Suvoqova”91, road agency and etc. Based on the results of review each member of the commission signs official Certificate on compliance which confirms that constructed housing blocks meet environmental, sanitarian-epidemiological, fire prevention requirements, and it also confirms proper operation of water supply and sanitation system. Examples of such documents are presented in Attachment 9.

617. Concluding a hand-ovОr accОptancО oП inНiviНual СousО bОtwООn QQI brancС’s director and house owner is mandatory document prepared at the stage of put house in commission. Example of this document is provided in Attachment 9.

618. QQB had prepared the annual report for 2012 on implementation of ESMS and submitted it to ADB and PMU. At the stage of conducting current environmental audit, a draft version of the annual report for 2013 was submitted to PMU for review.

619. No data was available to assess of Grievance Redress Mechanism functioning within reviewed project. PMU assured that, no complaints were received since beginning of the Project, and therefore no records. To comply with ADB safeguards requirements and Loan agreements covenants, the Consultant recommends QQB pay more attention on implementing these ESMS requirements (paras 32-34), keep appropriate records, and include information about this activity in the semi-annual reports.

620. Since beginning of the HIRDIP I only one training on ESMS implementation has been done. Senior Safeguard Officer from URM ADB conducted the training for PMU and QQB staff. In addition to this, they received technical guidance from URM ADB Senior Safeguard Officer. However, there is a high demand in additional trainings for QQB head quarter and branches staff on ESMS implementation.

10.5. Conclusions and Recommendations 621. After revising the environmental performance within HIRDIP I, Consultant made the following conclusions and recommendations which hopefully would improve implementation of the environmental safeguards for current and future tranches within HIRDIP:

622. ADB environmental safeguards are fully described in the project documents: FAM, Loan Agreement and Project Agreement. FAM contains ESMS policy, which have been used by PCBs as example to develop their own ESMS. 89 Resolution of Cabinet Ministries of RUz # 280 dated from 26 October 2009 About measures on organizing of construction in rural arОas basОН on tвpО НОsiРn witС participation oП ОnРinООrinР companв “QisСloq qurilisС invОst”(QQI) and Norms and Rules of Civil Engineering (ShNK) 3.01.04-04 “AccОptancО Пor opОration oП complОtОН construction objОcts” 90 The state commission is designated by Resolution of the each district governor - Hokim 91 Organization responsible for drinking water supply and sewage water treatment



623. As part of screening process requested in ESMS, Environmental clearances from the Provincial Nature Protection Committee were received for all sub-loans provided within HIRDIP I. Original and copies of the clearance are kept in QQB and QQI branches.

624. QQB has developed and officially approved the ESMS and currently the system is being implemented. However, to improve efficiency of ESMS performance, it needs to be clarified in some parts, particularly:

625. CСaptОr 2, Para 27 oП QQB’s ESMSs, nООНs clariПications/amОnНmОnts on description of a site selection procedure. The ESMS says that the final decision on site selection of rural housing is responsibility of State Nature Protection Committee. However, in practice Districts Hokimiyat makes the final decision based on a set of documents, which have to include Environmental clearance as well.

626. There is no any legal agreement, internal regulation documents between QQB and QQI, which regulates ESMS compliance during construction activity. Development such document, which clear defines responsibilities of QQI in terms of monitoring and reporting of environmental safeguards implementation would improve ESMS implementation by both: QQB and QQI. There is a need on clarifying an order and a content of certificate, which need to be submitted by QQI to QQB as requested by para 29 of ESMS.

627. Requirements on complying with environmental safeguards are included in Contracts between QQI and Contractors. However, QQI has to enhance monitoring of implementation oП Contract’s covОnant, particularlв, in part oП proviНinР aНvancО paвmОnt onlв aПtОr submission an Action Plan for Health, Safety and Environment by Contractors. This Action Plan will serve as: (i) a tool for QQI and QQB staff for conducting environmental monitoring during construction of houses and (ii) a basis for development Form 3 in proper format.

628. Included in ESMS Forms 1 and 3 needs to be supplemented with additional information. Providing names of canals and protected areas in the Form 1 or submission a map with indicated location of house blocks and sensitive environmental receptors, if any, alone with forms, would provide a more clear view of situation in term of evaluation of possible impacts on environment.

629. In addition to paragraph 43 of this report, updating Form 3 and including a checklist on Contractors compliance with environmental requirements into the Form 3 will provide comprehensive view of situation on construction site. Based on this data and covenants incluНОН into tСО Contractor’s contracts, QQB woulН bО ablО to ОnsurО tСat conНuctinР construction activities meet environmental safeguards requirements as indicated in the Project Agreement (clause 9 of Project Agreement between ADB and QQB).

630. Clarify purpose of Form 2 to avoid duplication of collecting data. In case of collecting Нata rОquОstОН into Form 2 bО otСОr ProjОct’s НОpartmОnt/ОxpОrt, a possibilitв oП rОПormattinР the Form 2 from ESMS should be considered.

631. Prior to releasing mortgage, QQB has to ensure a timely submission of periodic compliance records with description of the items indicated in ESMS (chapter 4, para 32) by QQI. Prepared by QQB form 3 are not provide enough information to assess compliance with

632. QQB has to prepare annual reports on ESMS implementation in format, which covers all ESMS requirements as defined in PAM.

633. PMU and QQB have to improve functioning of Grievance Redress Mechanism (GRM) as indicated in the ESMS. Keep records, organizing logbooks at the project sites and including data on RGM implementation in the QQB annual reports will contribute a public disclosure process as requested by Loan Agreement and Project Agreement.

634. Additional trainings on ESMS implementation need to be conducted for all EFSs from QQB HОaН QuartОr anН BrancСОs. QQI’s ОxpОrts workinР on conНuctinР tОcСnical supervision of construction sites also need such training due to QQI has to provide compliance records prior every releasing mortgage.





# Recommendation Responsible/Actions Implementation Terms

1 ESMSs need to some clarifications/amendments on description of a site selection procedure.

ADB – provides assistance in revising ESMS PMU - ensures that ESMS was adopted by each PCB QQB – reviews and adopts ESMS

At the stage of ESMS revising and adopting by PCB

2 QQB has to ensure that an Environmental Clearance from the State Nature Protection Committee is received prior adoption of Resolution of Hokimiyat on land acquisition

QQB - compare data of adoption of District Hokimiyat Resolution and Environmental Clearance PMU – supervises implementation on randomly selection base

Prior to approving mortgage

Adopt agreement/regulation on implementation of relevant ESMS requirements by QQI

QQB – develops appropriate agreement/regulation QQI – adopts and provide implementation of agreement/regulation PMU - monitors implementation

Within two months after receipt of the present environmental audit report

3 Include requirements on complying to environmental safeguards in Contracts between QQI and Contractors

QQIs – includes appropriate covenants in contracts between QQI and Contractor QQB - supervises including appropriate covenants PMU - monitors implementation

At stage of contract agreement conclusion

4 Supplement Forms 1 and 3 of ESMS with additional information. Revising Form 2

ADB - provides assistance in revising ESMS QQB – reviews and adopts ESMS PMU - monitors implementation

Within one month after receipt of environmental audit report

5 QQB has to ensure a timely submission of periodic compliance records by QQI as requested in ESMS

QQB – supervises submission of the periodic compliance records in requested format QQI – submits periodic reports in provided format PMU - monitors implementation


6 QQB has to prepare annual reports on ESMS implementation in format, which covers all ESMS requirements

QQB – develops format of annual report ADB – provides assistance in development format PMU - monitors implementation

Within one month after receipt of environmental audit report

7 QQB have to establish working Grievance Redress Mechanism (GRM) as indicated in the ESMS

QQB – ensures organizing of GRM at the construction site through QQI PMU - monitors implementation


8 Conduct trainings on ESMS implementation

ADB – provides assistance in organizing training by providing/recommending trainers PMU, QQB and QQI – provides participation of EFS and relevant staff

Within two-three months after receipt of the present environmental audit report



11. CONCLUSIONS

636. Based on the findings of projects documents review and conducted site visits the Consultant made the following general conclusions:

i. In general, majority of PMU/PIUs have improved their environmental performance during last few years. Visible changes relate to quality of environmental reports prepared by PMU/PIUs or Supervision Consultants on behalf of PMUs, improved design of bidding and contract documentation in terms of including environmental safeguards, communication between PMUs and Contractors on environmental aspects, keeping records on environmental performance. Training materials delivered by RETA supplemented practical and regulatory supports and provided more clarifications on ADB safeguard requirements.

ii. It is noticОablО tСat PMU/PIU’s attОntion to implОmОntation oП SEMPs bв Contractors and conducting environmental monitoring are increasing. PMU/PIUs are paying more attention to setting out institutional aspects and submission of the environmental reports by Contractors.

iii. PMUs’ incОntivОs anН intОntions in orРaniгinР projОct works in tСО waв allowinР mООt national and environmental requirements play one of the key roles in providing effectiveness of environmental safeguards during project implementation. PMUs of Land Improvement Project (LIP - L2069), Talimarjan Power Plant Efficiency Improvement Project (TPPEIP-L2629/2630), Water Resources Management Sector Project (WRMSP-L2492/2493), Second Small and Microfinance Development Project (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775) projects demonstrate such incentives and as a result, they have environmental performance of these projects is on the higher level. In some cases, PMUs are stronРlв supportОН bв projОcts’ SupОrvision Consultants, wСicС proviНО a vОrв СОlpПul assistance to PMUs in implementing environmental safeguards during project cycles.

637. Along with above-mentioned positive achievements of ADB funded projects in term of environmental compliance, the following issues were identified as important and required consiНОration in orНОr to ПurtСОr improvО PMU’s ОnvironmОntal pОrПormancО anН ОxОcutinР of environmental safeguards during projects implementation:

i. Even quality of project documents in term of environmental safeguards is noticeably improving, there is need for close revision of all project documentation (Loan Agreements, Bidding documents and Contracts) by ADB and PMU/PIUs to ensure that environmental requirements are included in proper content and environmental parts of all project documents are corresponded.

ii. Existing institution capacity of some EA/IA and PMU/PIUs is not enough to implement environmental performance on the satisfactory level. EA/IAs need to pay more attention to institutional aspects of environmental performance, through hiring safeguards experts as indicated in Project/Facility Administration Manuals (PAM/FAMs). Situations, when engaged environmental expert combine another jobs/tasks, which are not related to the safeguards, are need to be avoided.. The hired experts should have background in environmental science or enough working experience in related fields.

i. Projects Supervision Consultants play important role in professional supporting PMU/PIUs and providing an efficient environmental performance. However, this source is not fully used by some of the PMU/PIUs and, as a result; those PMUs have difficulties in complying with environmental safeguards.

ii. To ensure that selected bidders will be able to provide services in compliance with national and ADB environmental requirements, the bidding committees have to



include environmental experts to properly evaluate an environmental capacity of bidders.

iii. In some PMU/PIUs existing practice on keeping environmental documentations and records, results of conducted environmental audits, communications between PMU, SupОrvision Consultant anН Contractors, rОcorНs on complaints Пrom projОct’s affected people needs to be improved. This documentation is a base for preparing Environmental Monitoring and Project Completion Reports. Existed in several PMU/PIUs well-functioning records keeping system could be introduced to the other projects as example a good practice.

iv. Environmental Monitoring Reports of only 6 projects complies with the main ADB safeguards requirements. The remaining projects need work on revising and improvement of quality of the report in order to meet the requirements.

v. Implementation of environmental monitoring at the project construction stage recommended in IEEs is not satisfactory and it requires more attention from PMU/PIUs anН Contractors’ siНОs. TвpО anН ПrОquОncв oП rОcommОnНОН paramОtОrs to be monitored need to be revised at the PPTAs preparation and SEMP approval stages by PMU/PIUs in order to optimize and adopt the recommendation to the local natural conditions and project specificity.

vi. Quality of SEMPs which Contractors submitted for revising to PMU/PIUs needs to be carefully checked on compliance with safeguards requirements indicated in relevant IEEs.

vii. The Consultant observed some events when Contractor non-complied with environmental safeguards requirements. The PMU/PIUs have to apply all possible tools to push Contractor to follow their obligations by proper using of relevant contract’s covОnants.

viii. Due to specificity of Second Small and Microfinance Development (SSMDP-L2634) and Housing for Integration Rural Development (HIRD-L2775) projects, conclusions and recommendations for these projects are provided in the appropriate part of current Environmental Audit Report. More detail information on the findings is provided in the full Environmental Audit report.



APPENDIXES

APPENDIX 1. Amu Zang Irrigation Rehabilitation Project

Checklist of Environmental Audit

Country : Uzbekistan Audit Date :

Project Data

Project Title: Amu Zang Irrigation Rehabilitation Project Project progress (%): 95,64% Categories of Environmental Safeguards

A B C

X++

Overall Compliance Status

Does not comply – Required remedial measures and monitoring

X Mostly complies – minor correction

measures and monitoring are required

Completely complies

A. Loan Guarantee/Grant Obligations # О я ель о С оо е я

Annex 6, section D, paragraph 13

MAWR ensures implementation of environmental requirements included in the IEE

Yes

B. Environmental Safeguards Plan (Prior to Start of Construction Works)

Name Status (Y/N)

The Further Control is Required (Y/N)

Comments/Required Actions

Environmental Department was established under the Project Implementation Unit (PIU)

No Yes

Control over environmental issues compliance in PMU was assigned on the Monitoring and Evaluation Specialist

Environmental Department created the system on the environment condition monitoring (PIU)

No Yes

The system of the environmental activity documentation was established in PMU. Consultant Engineer prepares the monthly technical reports for PMU on the project progress (Chapter 2, Section 2.4.1. - Environmental Issues). One of the sections of the technical report contains the information on the environmental requirements implementation for the reporting period. Moreover, the PMU M&E Specialist makes the monthly field visits for the construction site survey in terms of compliance with the environment protection (EP) requirements. The results of conducted monitoring are documented as well and submitted in form of inter-office memo to the PMU Manager, followed by the respective measures against Contractors, if necessary. The monitoring Is carried out partially and does not cover all indicators stated in the Loan Agreement and Working Document # 19



The basic monitoring of environment condition was accomplished.

Yes No

The basic environmental monitoring was accomplished under the EIS prepared at the stage of detailed design on the following indicators: qualitative and quantitative characteristics of the surface water, ground water salinity and table, degree of the land salinity (in per cent against entire area). The monitoring of these indicators was carried out in the course of the project implementation, but not to the full extent which can be proved by environmental monitoring reports

The requirements of the “Environmental Management Plan (EMP)” wОrО incorporatОН in tСО brief working documentation (confirmation by the Environmental Department of Verification of the Brief Working Documentation in terms of its compliance with EMP requirements)

No Yes

EMP and requirements on compliance with environmental safeguards have not been included in the bidding documents. However, the contracts concluded between EA and Contractors contain requirements on compliance with EMP

EMP requirements are included in the bidding documents

Yes Yes

Obligations on implementation of environmental safeguards are included in the bidding documents in the section 1.21 “SitО EnvironmОntal ManaРОmОnt Plan” The p.1.21.1-1.21.4. The Section 1.21 includes the requirements on SEMP preparation by Contractor in line with IEE and observance of environmental policy requirements. The paragraph 1.21.3 described the requirements on environmental reports submission by Contractor to the Project Manager (PMU) on the monthly basis

Involvement of Environmental Department in the bids assessment

No Yes Ecologist was not involved during bidding

PIU analyzes and approves the “Site Environmental Management Plan” (SEMP) prior to start of the works fulfillment by Contractor

Yes Yes

The Contractor developed the Environmental Management Plans on Construction Sites (SEMPs) based on EIS incorporatОН in tСО Contractors’ biННinР documents (p.1.21.). In the course of the SEMP development, the Consultant Engineer was providing consulting support to the Contractors. The SEMPs were approved by the PMUs and ADB. The SEMP draft version was submitted by the Contractor to the PMU in August 2009 (the construction works also started in August 2009). It was recommended to revise the SEMO for observance of all ADB requirements on environmental safeguards and in line with IEE; this revision was carried out in October 2009. The SEMP was submitted to PMU and approved.

C. Compliance with Environment Protection Requirements in the Course of

Construction (to be filled, if necessary)



Name Status (Y/N)



Monitoring data according to the EMP requirements.

2

Yes Yes

The PMU M&E Specialist is carrying out the monitoring on hydrological and climatic indicators at the project area in terms of the soil and groundwater quality at the project site. The monitoring does not cover all indicators

Unpredictable factors of environmental impact were identified and assessed; the evaluation of their solution options was carried out

No Yes Assessment of unpredictable effects has not been accomplished

The report on the cases of significant violations in the field of environment protection, health and safety was submitted

No Yes The cases of serious violations of environmental requirements have not been revealed

EMP was considered and corrected.

Yes Yes EMPs are submitted by Contractors prior to start of constructions works, Consultant Engineeranalyzes and approves them

Records during site inspection (Form of the report on the measures implemented on environment impact mitigation and monitoring)

Yes Yes

No special forms are used for inspections. It was recommended to the PMU and Consultant Engineerto develop the formats

Notifications on incompliance with environmental requirements based on the inspection results and requirements on its elimination

Yes Yes

M&E Specialists of Consultant Engineerand PMU are carrying out the permanent inspections of construction sites in terms of compliance with EMP

Book of complaints Yes Yes Construction sites have the books of complaints with records

Data on compliance of the environment protection are included in the project progress reports

Yes Yes

The reports of Consultant Engineerinclude the section on implementation of environmental safeguards

Training/activities on capacity building are carried out according to EMP requirements (training records)

No Yes Contractor has not delivered the trainings on health protection and safety engineering for the workers

Overall current status of EMP/SEMP implementation (All measures on environmental impact mitigation specified in approved SEMP have to be described point by point and evaluated in line with implementation status)

Yes Yes

EMP has to be improved in terms of the training arrangement, appointment of the entities/persons responsible for activities implementation at the construction sites and ensuring of the reports submission to the of Consultant Engineerand PMU

Semiannual reports on environmental monitoring were submitted to ADB and published on ADB site

Yes No Two semiannual reports for 2012 and 2013 were submitted to ADB and report for 2012 was published on official site

Reports on environmental monitoring were presented to the local community and respective governmental authorities

3

No Yes

Report on environmental monitoring has not been submitted neither to the central/local affiliates of the State Nature Protection Committees, nor to makhallyas

The Final Audit Opinion was submitted after completion of construction.

No Yes

The delivery and acceptance certificate of the completed work site is prepared after completion of works for each sub-project; and original versions and copies of these certificates are kept with PMU and PIU or respective provinces. The state acceptance boards comprise representatives from provincial nature protection committees, who certify the fact of compliance with environmental requirements in the course of the project implementation. Neither PMU/PIU



Name Status (Y/N)



employees nor Consultant Engineerare accomplishing the separate final environmental audit after the site commissioning.



APPENDIX 2. Water Resources Management Sector Project



Project Data

Project Title: Water Resource Management Sector Project Project progress (%): 59,7% Categories of Environmental Safeguards

A B C

X++





Completely complies

A. Loan Guarantee/Grant Obligations N# Obligation Compliance Status

Section 4 Paragraph 4.01


Yes


Name Status (Y/N)

The Further Control is Required

(Y/N)



Yes No

Control over environmental issues compliance in PMU was assigned on the Social and Environmental Issues Specialist


Yes Yes

The system of the environmental activity documentation was established in PMU. SEIS PMU developed the formats on fulfillment of EP requirements at the construction sites. Every week Contractor fills in the formats (Annex 1) and submits them to the PMU for consideration. The formats had been developed in the form of the checklists, but the Consultant suggested their further development in order to submit the clear information on the SEMP requirements implementation

The basic monitoring of environment condition was accomplished

Yes No

Basic environmental monitoring was accomplished at the IEE implementation stage; surveyed indicators included: qualitative characteristics of the surface watercourses, soil salinity degree, groundwater occurrence level and its salinity degree. Currently, the PMU is not carrying out the qualitative environmental monitoring since the requirements on accomplishment of the tool-based environmental monitoring have not been included in IEE and, respectively, in the contract documents of Contractor




Yes No EMP and requirements on compliance with environmental safeguards were included in the bidding documents


Yes Yes

Obligations on environmental safeguards implementation are included in the bidding documents – section 8 – Special Terms




Yes Yes

PMU analyzes and approves the SEMPs submitted by Contractors. As of the audit date, 2 SEMPs had been approved and 5 SEMPs were under consideration by PMU.

C. Compliance with Environment Protection Requirements in the Course of Construction (to be filled, if necessary)

Name Status (Y/N)


(Y/N)



2

Yes No

Contractors are carrying out the monitoring of SEPM implementation based on the formats and field visits. Tool-based monitoring is not being carried out since it has not been included in the IEE developed at the technical assistance stage

Unpredictable effects of environmental impact were identified and assessed; the evaluation of their solution options was carried out

Yes Yes Contractors carried out assessment of unpredictable effects under SEMP


No Yes

According to the Contractor’s reports, the cases of serious violations of environmental requirements have not been revealed


Yes Yes EMPs are submitted by Contractors prior to start of constructions works; SEIS PMU is considering and approving them


Yes Yes SES PMU Specialist developed reporting forms currently applied by Contractors


Yes Yes

SES PMU Specialist is carrying out the permanent inspections of construction sites in terms of compliance with EMP. In case of reveal of incompliance, report to the PMU Manager is prepared. Contractor receives the written notification on revealed shortcomings with the deadlines of their elimination

Book of complaints No Yes There are no books of complaints available at the construction sites

Compliance with environmental requirements is included in the project progress reports

No Yes

The technical reports prepared by the Consultant Engineerdo not include the section on implementation of environmental safeguards

Training/activities on capacity building are carried out according to EMP requirements (training

Yes Yes SES PMU Specialist and ecologist of Consultant Engineerdelivered the training on compliance with environmental



Name Status (Y/N)


(Y/N)


records) requirements and ES requirements. The further training Пor Contractor’s employees has not been delivered.


Yes Yes Mitigation measures are implemented


Yes No Two environmental reports were submitted to ADB and published on official site


3

No Yes

Reports on environmental monitoring have not been submitted neither to the central/local affiliates of the State Nature Protection Committees, nor to makhallyas. However, information bulletins with general project information were disseminated among the neighboring communities


No Yes

No one of two sub-projects under review was commissioned as completed one. Therefore, the final environmental audit has not accomplished.



Forms of Reporting on Compliance with Environmental Requirements

# Natural Resources Impact Harm Source Mitigation Measures Note

1. Air Pollution

Dust

Exhaust

Welding

Painting

2. Water

Surface

Pollution

Waste

Oil

Underground Oil

3. Soil

Surface

Erosion Water

Pollution

Waste

Oil

Corrosion Mechanisms

Flooding Water

Underground Pollution Oil

4. Flora

Forest cut-off Workers

Trample Workers



# Natural Resources Impact Harm Source Mitigation Measures Note

5. Fauna

Devastation Workers

Extermination Workers

6. People

Workers

Pollution Dust

Intoxication Exhaust

Irritation Noise

Local citizens

Pollution Dust

Intoxication Exhaust

Irritation Noise



Information Sheet prepared by Project for public acquaintance with project activities





APPENDIX 3. Land Improvement Project



Project Data

Project Title: Land Improvement Project Project progress (%): 66,3% Categories of Environmental Safeguards

A B C

X++





Completely complies

A. Loan Guarantee/Grant Obligations

# Obligation Compliance Status

Section 5 Paragraph 8


Yes


Name Status (Y/N)


(Y/N)



No Yes

Control over environmental issues compliance in PMU was assigned on the Monitoring and Evaluation Specialist


No Yes

The system of the environmental activity documentation was established in PMU. Engineering Consultant prepares the monthly technical reports for PMU on the project progress, containing information on the environmental requirements implementation. Documentation is also maintained on the results of the monitoring carried out by the PMU M&E Specialist and submitted in form of internal memo to the Project Manager, after that the relevant actions are taken against Contractors, if necessary.


Yes No

The basic monitor of environment condition was accomplished under the EIS prepared at the stage of detailed design, on such characteristics as qualitative characteristics of irrigated lands (in per cent against entire territory), GWT. Currently, the PMU is continuing the monitoring of these indicators as a part of works on the project monitoring and evaluation. However, the monitoring is not being accomplished on several of indicators



included in EIS. The revision and update of the parameters are required


No Yes

EMP and requirements on compliance with environmental safeguards have not been included in the bidding documents. However, the contracts concluded between EA and Contractors contain requirements on compliance with EMP


Yes Yes

Obligations on implementation of environmental safeguards are included in the bidding documents - p.63-63. P.63 of the bidding documents describes Contractor’s obliРations on: (i) establishment of the active system on the environmental impact management; (ii) implementation of the monitoring and impact mitigation activities (with the reference to IEE

92, presented in the Annex

1 to the bidding documents); (iii) allocation of required budget for implementation of activities specified in the items i and ii. The paragraph 64 of the bidding documents provides for the Contractor to submit the quarterly reports to the Client (PMU), including ones on the environmental safeguards activity, described in the p.63.

Involvement of the Environmental Department in the bids assessment



Yes Yes

Contractor developed SEMPs based on the EIS included in the bidding documentation in selection of Contractors. Engineering Consultant was providing consulting support to the Contractors. Submitted SEMP was approved by the PMU in January 2013 (prior to start of construction works, which started in February 2013)


Name Status (Y/N)


(Y/N)



Yes Yes

PMU M&E Specialist is carrying out the GWT monitoring (in breakdown of Water Consumers Associations (WCA)), saline land area, groundwater salinity, cropping capacity, life stock production (in regional breakdown)


No Yes

Assessment of unpredictable effects has not been accomplished. Contractor needs to carry out assessment of unpredictable effects


No Yes The cases of serious violations of environmental requirements have not been revealed


Yes Yes EMPs are submitted by Contractors prior to start of constructions works, Engineering Consultant analyzes and

92 In the Russian version the document was translated as Environmental Impact Statement.



Name Status (Y/N)


(Y/N)


approves them а ч а

Records during site inspection (For of the report on the measures implemented in environment impact mitigation and monitoring)

Yes Yes

No special forms are used for inspections. The formats were recommended to the PMU and Engineering Consultant


Yes Yes

M&E Specialists of Engineering Consultant and PMU are carrying out the permanent inspections of construction sites in terms of compliance with EMP

Book of complaints Yes Yes

Construction sites are running the books of complaints, however, as of the audit date, there have not been any records in these books

Data on compliance of the environment protection are included in the reports during the project implementation

Yes Yes The reports of Engineering Consultant include the section on implementation of environmental safeguards

Training/activities on capacity building are carried out according EMP requirements (training records)

Yes Yes

Contractor delivered the trainings on health protection and safety engineering for the workers. However, Contractor needs to provide on-the-job-training on EMP for the workers

to Overall current status of EMP/SEMP implementation (All measures on environmental impact mitigation specified in approved SEMP have to be described point by point and evaluated in line with implementation status)

Yes Yes

EMP has to be improved in terms of the training arrangement, appointment of the entities/persons responsible for activities implementation at the construction sites and ensuring of the reports submission to the of Engineering Consultant and PMU


Yes No Two semiannual reports for 2010 and 2012 were submitted to ADB and published on official site


3

No Yes

Report on environmental monitoring has not been submitted neither to the central/local affiliates of the State Nature Protection Committees, nor to makhallyas


No Yes

The delivery and acceptance certificate of the completed work site is prepared after completion of works for each sub-project; and original versions and copies of these certificates are kept with PMU and PIU or respective provinces. The state acceptance boards comprise representatives from provincial nature protection committees, who certify the fact of compliance with environmental requirements in the course of the project implementation. Neither PMU/PIU employees nor Engineering Consultant are accomplishing the separate final environmental audit after the site commissioning.



APPENDIX 4. WATER SUPPLY AND SANITATION SERVICES INVESTMENT PROGRAM, TRANCHES 1-3

Checklist of Environmental Audit of WSSSIP Project, Tranche-1


Project Data

Project Title: Water Supply and Sanitation Improvement. Investment Program. Tranche -1

Project progress (%): 83% Categories of Environmental Safeguards

A B C

X





Completely complies



Uzkommunkhizmat ensures implementation of environmental safeguards included in the IEE

Yes


Name Status (Y/N)


(Y/N)


Environmental Department was established under the Program Preparation and Management Unit (PPMU)

Yes Yes

Control over environmental issues compliance in PPMU was assigned on the Environmental Specialist In PIU Bukhara city the monitoring of the safeguards was assigned on the Water Supply Specialist.

In PIU Navoi city the monitoring of the safeguards implementation was assigned on the Monitoring and Evaluation Specialist

Environmental Department created the system on the environment condition monitoring (PPMU)

No Yes

In PPMU and PIUs of Bukhara and Navoi cities the system of environment condition monitoring has not been established. Requirements on the environment condition monitoring had not been included in the bidding documents


No Yes

The basic monitoring of environment condition was not accomplished since such requirements had not been included in the project documents

The requirements of the “Environmental Management Plan (EMP)” wОrО incorporatОН in tСО brief working documentation (confirmation by the Environmental Department of Verification of the Brief Working

No No

The requirements of EMP observance were included in the bidding documents – section 6.5, part 2. However, the EMP itself was not included in the bidding documents as the Annex 1 referred to in the master document



Documentation in terms of its compliance with EMP requirements)


Yes Yes

The requirements of EMP observance were included in the bidding documents – section 6.5, part 2. However, the EMP itself was not included in the bidding documents as the Annex 1 referred to in the master document

Environmental Department involvement in the bids assessment

No Yes There is no ecologist in the bidding board composition


No Yes

SEMPs were developed by the PIU specialists after environmental training delivery in Tashkent. Developed SEMPs practically completely repeat the EMP and IEE. All SEMPs were developed after the start of construction works


Name Status (Y/N)


(Y/N)



No Yes

EMP incorporated in IEE contains the requirements on the visual monitoring; there are no requirements on the tool-based monitoring accomplishment, except for the tap water quality


No Yes Assessment of unpredictable effects has not been carried out. Requires accomplishment.


No Yes According to the Contractor, there have not been such cases through the project implementation


Yes Yes EMP was submitted to the Contractors and PIU


No Yes No records on carried out inspections


No Yes No records on carried out inspections

Book of complaints No Yes

The book of complaints is available in PIU Bukhara city, but it does not contain any records. The PIU Navoi city does not have a book of complaints


No Yes Reports have not been completed to the Consultant


No Yes No training has been delivered

Overall current status of EMP/SEMP implementation (All measures on environmental impact mitigation specified in approved SEMP have to be described point by point and

Yes Yes

There were no obvious violations observed. The EMP was mainly observed during construction works at the sites. However, some violations exist in terms of construction and domestic waste storing and recycling



Name Status (Y/N)


(Y/N)


evaluated in line with implementation status)


No Yes

As of the audit date, one semiannual report for the first six months 2013 has been submitted by PPMU to the Project Manager from ADB side. As of the audit date, the drafting of the second semiannual report was underway. But, no one version of the report has been published on the site


No Yes Semiannual reports were submitted to the local communities and nature protection committees


No Yes The final environmental audits have not been accomplished.



Checklist of Environmental Audit of WSSSIP Project, Tranche-2


Project Data

Project Title: Water Supply and Sanitation Improvement. Investment Program. Tranche -2

Project progress (%): 61% Categories of Environmental Safeguards

A B C

X





Completely complies



RRF ensures implementation of environmental safeguards included in the IEE

Yes


Name Status (Y/N)


(Y/N)



Yes Yes Control over environmental issues compliance in PIU was assigned on the Environmental Specialist э гии.

The Safeguards Specialist was hired in PIU Fergana city


No Yes In PPMU and PIUs of Bukhara and Navoi cities the system of environment condition monitoring has not been established. Requirements on the environment condition monitoring had not been included in the bidding documents


No Yes The basic monitoring of environment condition was not accomplished since such requirements had not been included in the project documents


No No The bidding documents and contract documents do not contain requirements on SEMP development, however, such requirement is specified in the Loan Agreement on WSSSIP


Yes Yes The requirements of EMP observance were included in the bidding documents – section 6.5, part 2. However, the EMP itself was not



included in the bidding documents as the Annex 1 referred to in the master document


No Yes There is no ecologist in the bidding board composition


Yes Yes SEMPs were developed by the PIU specialists after environmental training delivery in Tashkent. Developed SEMPs practically completely repeat the EMP and IEE. All SEMPs were developed after the start of construction works


Name Status (Y/N)


(Y/N)



No Yes EMP incorporated in IEE contains the requirements on the visual monitoring; there are no requirements on the tool-based monitoring accomplishment, except for the tap water quality


No Yes Assessment of unpredictable effects has not been carried out. Requires accomplishment


No Yes According to the Contractor, there have not been such cases through the project implementation


No Yes EMP was submitted to the Contractors and PIU


Yes Yes Contractor is using reporting form to be filled in on the monthly basis (Annex 3)


No Yes The ecologist of PIU Fergana city is carrying out the permanent monitoring and audit of environmental safeguards implementation. Revealed shortcomings and requirements on their elimination are submitted to the PIU Manager and Contractor in the form of inter-office memorandum

Book of complaints Yes Yes The book of complaints is available in PIU Fergana city, but it does not contain any records


Yes Yes The ecologist of PIU Fergana city has prepared two reports. However, the Engineering Consultant has not submitted the technical reports


Yes Yes Contractors had delivered the trainings on EP for the workers. However, the records on their arrangement, topics and participants were not submitted to the Consultant


No/Yes Yes There were no obvious violations observed. The EMP was mainly observed during construction works at the sites. However, some violations exist in terms of construction and domestic waste storing and recycling



Name Status (Y/N)


(Y/N)



No Yes As of the audit date, one semiannual report for the first six months 2013 has been submitted by PPMU to the Project Manager from ADB side. But, no one version of the report has been published on the site. The ecologist of PIU Fergana city also prepared 2 quarterly reports


3

No Yes Semiannual reports were submitted to the local communities and nature protection committees


No Yes The final environmental audits have not been accomplished.



Contractor’s Internal Order on Ecologist Appointment



APPENDIX 5. Surkhandarya Water Supply and Sanitation Project



Project Data

Project Name: Surkhandarya Water Supply and Sanitation Project Project Progress (%): 92% Environmental Safeguards Categorization

A B C

X

Overall Status of Compliance

Not compliant – Remedial action and monitoring required

X- Mostly compliant - Minor remedial

action and monitoring required

Fully compliant

A. Safeguards Loan/Grant Covenants

Item No. Covenant Status of Compliance The paragraph 10, Schedule 5

UCSA ensures implementation of environmental requirements included in the EMMP and IEE

Yes

B. Environmental Management Planning (Preconstruction)

Item Status (Y/N)

Follow up required

(Y/N)

Comments/Actions required

Environment Unit (EU) established within Project Implementation Unit (PIU)

No Yes

In each subproject there were appointed the specialist, mostly Construction Supervisor, to coordinate the works on environmental protection and implementation of EMMP in the subproject, as well as preparation and submission of quarterly progress reports on implementation of EMMP to PIU, PMU and the Senior Environmental Protection Expert.

Environmental recording system established in EU

Yes Yes

As to environmental documentation during project implementation, it is presented by Environmental Monitoring reports (EMRs) on semiannual base and monthly reports on implementation of measures on environmental protection and monitoring plan for each subproject.

Baseline monitoring completed No Yes

There was not any baseline monitoring within the Environmental Impact Assessment prepared at project design stage

EMP design requirements included in design brief. (Evidence that EU has checked design brief in this regard)

Yes Yes

In the Section 7, General Conditions of Contract documents, the clause 63. “EnvironmОnt” mОntions about tСО obligatory of contractors in terms of IEE, SIEE, as well as EMMP. The original version of Contracts documents did not contain necessary Appendixes 1-3 with



IEE, SIEE and EMMP requirements. However, during the construction site audit it has been found that all contracts with Contractors include mentioned Appendixes.

EMP requirements included in tender documents

Yes Yes

TСО BiННinР НocumОnts’ analвsis sСowОН that environmental safeguards part is absolutely the same as in Contract documents – Section 7, General Conditions, tСО clausО 63. “EnvironmОnt”. The Appendixes 1-3 (IEE, SIEE and EMMP), which are noticed about in this clause, have been also not attached in original version of the Bidding documents. However, during the construction site audit it has been found that all bidding documents for all contracts include mentioned Appendixes.

EU involvement in bid evaluation No Yes The Environmental Specialists were not present during the bidding processes.

Contractor’s SEMP(s) rОviОwОН anН approved by PIU prior to contractor commencing work

Yes No The Consultant reviewed SEMPs approved by PIU

C. Construction Environmental Management Compliance (to be completed as relevant)

Item Status (Y/N)

Follow up required

(Y/N) Comments/Actions required

Monitoring data as per EMP monitoring plan requirements.

No Yes

The monitoring on sites has been conducted on such parameters as noise, dust, vibration, soil quality, air quality, surface and groundwater protection, but only on visually base. The instrumental analysis on all these parameters has not been carried out due to lack of provision with specific equipment and uncreated Environmental Monitoring Group (EMG). The notification of preferable establishment of EMG has been stated in official letter to PMU from the Senior Environment Protection Expert (Ref. EU-018, dated on 20.07.2010). The answer on this letter was given with creation of this group, but only on October 2013.

Unanticipated environmental impacts identified and assessed and options to address them evaluated.

No Yes Assessment of unpredictable effects has not been accomplished.

Significant EHS incidents reported No Yes The cases of serious violations of environmental requirements have not been revealed

EMP reviewed and updated Yes Yes

Site inspection records ( Mitigation Compliance & Inspection Monitoring Forms)

Yes Yes

Contractors prepare monthly reports, which contain monitoring form on implementation of EMMP in subproject. At the same time, the Senior Environment Protection Expert from Consulting EnРinООr’s tОam prОparОs spОcial monitoring checklist of implementation of EMMP on all subprojects.

Site inspection non-compliance notifications and corrective action requests.

Yes Yes

The SEPE on his own initiative visits sites on a quarterly base for reviewing Environmental Safeguards implementation there. Besides that, specialists from PIU also surveys sites on a regular base.



Item Status (Y/N)

Follow up required


Complaints log No Yes There are no any Compliance books on sites

Environmental safeguard compliance included in project progress reports

Yes Yes

Quarterly Progress Reports, which are prepared by Consulting Engineer on a regular base, contain environmental safeguards part, which called “EnvironmОntal ProtОction”, Пor ОacС subproject separately.

Training/Capacity building activities undertaken as per EMP requirements. (Training records)

Yes Yes

The Senior Environment Protection Expert has conducted several trainings for PMU, PIU and Contractors and participated in meetings.

Overall current status of project EMP/SEMP implementation (All mitigation measures identified in approved SEMP(s) to be itemized and evaluated as per implementation status)

Yes Yes

Contractors prepare monthly reports, which contain monitoring form on implementation of EMMP in subproject. At the same time, the SEPE from Consulting EnРinООr’s tОam prОparОs spОcial monitoring checklist of implementation of EMMP on all subprojects.

Six monthly Environmental Monitoring Reports submitted to ADB and posted on ADB website

Yes Yes

The Senior Environment Protection Expert prepared semiannual EMRs, from the period of July 2010 to July 2013, which Сas bООn publisСОН on ADB’s wОbsitО on December 27, 2013. The EMR contains information on project progress implementation, environmental monitoring quality as well as implementation of EMMP and such.

Monitoring reports disclosed to local communities and relevant government agencies

No Yes EMRs were not provided to local communities and relevant government agencies.

Final post construction Audit Report completed

No Yes

Completed project works are accepted by the state board comprising the specialist from the local Nature Protection Committee. Although the acceptance boarН’s opinion comprisОs tСО paragraphs on the work completion in line with environmental requirements, the PMU has been recommended to accomplish the final environmental audits of all completed sites regarding to the compliance with EMMP and incorporate results of such final surveys in the environmental monitoring reports. Besides, the results of final surveys can be included in the Completion Report on the project as the separate environmental component.



SEMP on Termez city objects approved by PIU and Contractor







APPENDIX 6. Talimarjan Power Plant Efficiency Improvement Project



Project Data

Project Name: Talimarjan Power Plant Efficiency Improvement Project Project Progress (%): 5 Environmental Safeguards Categorization

A B C

X

Overall Status of Compliance

Not compliant – Remedial action and monitoring required

X++ Mostly compliant - Minor

remedial action and monitoring required

Fully compliant

A. Safeguards Loan/Grant Covenants Item No. Covenant Status of Compliance

Schedule 5 Item 3

SJSC UzbekEnergo ensures implementation of environmental requirements included in the EMP

Yes

B. Environmental Management Planning (Preconstruction)

Item Status (Y/N)

Follow up required


Environment Unit (EU) established within Project Implementation Unit (PIU)

Yes Yes

Monitoring compliance with environmental issuОs put to PMU’s Environmental Specialist responsibility. Within PIU the working group is established such as Station Ecologist who is responsible for environmental compliance at the site.

Environmental recording system established in EU

Yes Yes

In PMU a system of documenting environmental practices is established. Quarterly technical progress project reports prepared by Consultant Engineer for the PMU. Currently it is developed one progress report covering the period from 1 July to 30 September 2013. Several sections of the technical report provide information on the implementation of environmental requirements for the reporting period (Section 4.6. Statement of Environmental and Section 6.5. Environmental monitoring). In addition, PMU Ecologist conducts visits to the construction site for seeing whether it is complied with the requirements on environment protection. The survey is conducted with the station ecologist with PIU. The results of the monitoring as well as documented and presented in the form of



"information on surveillance and environmental monitoring works on site 2x CCGTU-450 MW" to the Head of PMU, and then, if necessary, appropriate action is taken with respect to the Contractor.

Baseline monitoring completed Yes Yes

Within the framework of EIA, which was prepared in December 2009, was conducted baseline environmental monitoring indicators such as: qualitative characteristics Talimarjan water reservoir and KMC, water temperature indicators, greenhouse gas emissions. Currently specialist from PMU on Environmental Protection continues to monitor these and other indicators, as part of the monitoring and evaluation of the project.

EMP design requirements included in design brief. (Evidence that EU has checked design brief in this regard)

Yes Yes

EMP and requirements to comply with environmental protection measures were included in the tender documents. According to the contractual agreement No. SJSC/UzbekEnergo/ICB-2010-001 of 07.03.2013, Annex 7 (A), paragraph 25, 27, 39, Contractor will prepare and submit to the Site Based Management Plan (SBMP)

EMP requirements included in tender documents

Yes Yes

Contractor's obligation on the implementation of environmental requirements are included in the bidding documents in section 6.2 "Technical Specifications (A)," Chapter 16. Environmental and other legal requirements in the area, paragraphs 16.1-16.6. TСus, § 16.1 describes the Contractor's obligation to develop and provide client plan (Site Based Management Plan - SBMP) at a time agreed with the client. Here it is specified that SBMP should cover other control elements of the environment, including: (i) a plan for noise abatement; (ii) a plan to combat dust; (iii) a plan for controlling emissions of harmful substances into the atmosphere; and others.

Paragraphs 16.3-16.5 determine compliance requirements by the Contractor with the respect to air, noise and flora and fauna. The following subparagraph describes the controls on the construction site with respect to soil and erosion.

EU involvement in bid evaluation No Yes Ecologist was not involved during bidding

Contractor’s SEMP(s) reviewed and approved by PIU prior to contractor commencing work

Yes Yes

Environmental management plan on the construction site (SEMP) was developed by the Constructor based on EIA, which was included in the tender documents of the Contractor. Consultant Engineer in the development of SEMP advised with contractors. The initial version SEMP was not approved by PMU during the audit. The contractor would have to review SEMP along with the PMU and consultant engineers till 08/11/2013. After the audit, corrected version of SEMP was given to the consultant, but as it turned out, this document also did not meet all the requirements of the PMU and consultant engineers. At present the final version of SEMP is under development (it had to be provided



till the end of 2013) till its approval by the PMU.

C. Construction Environmental Management Compliance (to be completed as

relevant)

Item Status (Y/N)

Follow up required


Monitoring data as per EMP monitoring plan requirements.

Yes Yes Environmental protection is conducted with PMU specialist

Unanticipated environmental impacts identified and assessed and options to address them evaluated.

Yes Yes Impact assessment on Emergency cases is under development because of SEMP is unapproved

Significant EHS incidents reported Yes Yes Cases of serious violations of environmental requirements were not found

EMP reviewed and updated No Yes

At present the final version of SEMP is under development (it had to be provided till the end of 2013) till its approval by the PMU.

Site inspection records ( Mitigation Compliance & Inspection Monitoring Forms)

Yes Yes

In the initial version SEMP which was not approved by the PMU and Consultant Engineer, there are forms of the report on the implementation of the requirements for Health Safety, Technical Safety and Environmental Protection, however need improvement

Site inspection non-compliance notifications and corrective action requests.

Yes Yes

PMU Environmental Specialist, International Specialist on Environmental protection, Consultant engineers and stations ecologists will continuously monitoring of the construction site inspections for assuring compliance with the SEMP.

Complaints log Yes Yes

At the entrance point of the station building there is the announcement that there is a book of complaints, suggestions and to express gratitude to use for the staff of "Talimarjan TPP" and residents of Nuristan

Environmental safeguard compliance included in project progress reports

Yes Yes Consultant Engineer reports on progress include a section on the implementation of environmental protection measures

Training/Capacity building activities undertaken as per EMP requirements. (Training records)

Yes Yes

Contractor conducted training on health and safety for employees, but the records were not provided. However, the Contractor needs to provide training to workers on places on EMP after approval of PMU and Consultant Engineer

Overall current status of project EMP/SEMP implementation (All mitigation measures identified in approved SEMP(s) to be itemized and evaluated as per implementation status)

Yes Yes

The initial version SEMP was not approved by PMU during the audit. The contractor would have to review SEMP along with the PMU and consultant engineers till 08/11/2013. After the audit, corrected version of SEMP was given to the consultant, but as it turned out, this document also did not meet all the requirements of the PMU and consultant engineers. At present the final version of SEMP is under development (it had to be provided till the end of 2013) till its approval by the



Item Status (Y/N)

Follow up required


PMU.

Six monthly Environmental Monitoring Reports submitted to ADB and posted on ADB website

Yes No

PMU prepared six annual reports on environmental monitoring for the ADB in 2009 and in the period from April 2012 to July 2013, that were published on ADB website.

Monitoring reports disclosed to local communities and relevant government agencies

Yes Yes

Report for the first half of 2013 was handed to Kashkadarya Nature Protection Committee. However, reports were not made available in district khakimiyats and nearby makhallas

Final post construction Audit Report completed

Yes Yes Project is under development activities



APPENDIX 7. Multitranche Investment Programs of Regional Road Development Project. Phase II and III.

Checklist of Environmental Audit of “RRDP. Phase II, Tranche-1


Project Data

Project Title: Regional Road Development Project. Phase II. Tranche -1 Project progress (%): 95% Categories of Environmental Safeguards

A B C

X





Completely complies

C. Loan Guarantee/Grant Obligations # Obligation Compliance Status


RRF ensures implementation of environmental requirements included in the IEE

Yes

D. Environmental Safeguards Plan (Prior to Start of Construction Works)

Name Status93

(Y/N)


(Y/N)



Yes Yes Control over environmental issues observance in PMU has been assigned to the Environmental Specialist


No Yes The PMU established the partial system the environment condition monitoring


No Yes The basic monitoring elements are provided in the IEE with the data on pollution of ambient air in Urgench and Bukhara cities. The basic monitoring has not been carried on any other indicators


Yes No The PMU internal order was issued on the hiring of ecologist with description of the ОxpОrt’s tОrms oП rОПОrОncО


Yes Yes EMP was included in the bidding documents - section 6.5, part 2

Environmental Department involvement in the bids

No Yes There is no ecologist available in the bidding board composition; environmental

93

Documentary evidence of each item to be maintainОН in EU’s ОnvironmОntal rОcorНinР sвstОm anН maНО available for audit.



assessment aspects of the bidders are assessed by engineer on construction and machinery


Yes Yes PMU with assistance from Engineering Consultant submitted comments on the SEMP. However, the final, revised and approved version of SEMP does not exist.

A. Compliance with Environment Protection Requirements in the Course of Construction (to be filled, if necessary)

Name Status94

(Y/N)


(Y/N)



2

No Yes The continuous monitoring of the SEMP implementation was not carried out. According to IEE requirements, the qualitative monitoring was supposed to be carried out on the monthly basis, but actually, was accomplished once. The quantitative monitoring of taken water was not accomplished at all


No Yes No assessment of unpredictable effects was carried out. It is necessary to carry it out


Yes Yes Engineering Consultant in the reports was notifying Contractor on the cases of significant violations. However, there is no information available on the situation remediation by Contractor


Yes Yes EMP was submitted by Contractor prior to start of constructions works; Engineering Consultant reviewed them and provided comments


Yes Yes Contractor is using the form of report supposed to be filled in on the monthly basis

Notifications on noncompliance with environmental requirements based on the inspection results and requirements on its elimination

Yes Yes PMU ecologist and Engineering Consultant are carrying out environmental inspections of construction base in line with the work schedule. The results of EnРinООrinР Consultant’s observations are submitted in form of quarterly report



Yes Yes The progress reports prepared include the section on implementation of environmental safeguards


Yes Yes Contractor delivered the training on the health protection and safety engineering for the workers. PMU delivered 2 trainings for the employees of Khorezm provincial nature protection committee, Contractors and Engineering Consultant at the construction site

Overall current status of EMP/SEMP implementation (All measures on environmental impact mitigation specified in approved SEMP have to be

Yes Yes EMP was observed during construction works at the sites and queries. However, the EMP requirements are not met on the construction bases, and concrete plants in terms of collection and disposal of solid

94




Name Status94

(Y/N)


(Y/N)


described point by point and evaluated in line with implementation status)

and liquid domestic waste and FL


Yes No Two semiannual reports for 2011 and 2013 were submitted to ADB and published on official site


3

Yes Yes Engineer’s report was submitted to the Makhallya Committee of Sarymoi settlement; the discussions and activities wОrО implОmОntОН (citiгОns’ accОss to tСО drinking water)


No Yes In September 2013, Engineering Consultant prepared the final environmental report. However, construction works were ongoing until December 2013. Therefore, the final report preparation is required in terms of implementation of all EMP requirements.



Checklist of Environmental Audit of “RRDP. Phase III”, Tranche-1


Project Data

Project Title: Regional Road Development Project. Phase III. Tranche -1 Project progress (%): 12% Categories of Environmental Safeguards

A B C

X





Completely complies

A. Loan Guarantee/Grant Obligations # Obligation Compliance Status


RRF ensures implementation of environmental requirements included in the IEE

Yes

B. Environmental Safeguards Plan (Prior to Start of Construction Works) Name Status

(Y/N) The Further Control is Required

(Y/N)



Yes Yes Control over environmental issues observance in PMU has been assigned to the Environmental Specialist


No Yes The PMU established the partial system the environment condition monitoring


Yes Yes The basic monitoring was not carried out since such requirement had not been included in the bidding documentation. Environmental examination for Tranche 2. Check EE , table 3: Ambient Air Quality 2011, P13: Table 4: Estimate of existing noise

2010-’11;P14


Yes No The PMU internal order was issued on the hiring of ecologist with description of the ОxpОrt’s tОrms oП rОПОrОncО


Yes Yes EMP was included in the bidding documents - section 6.5, part 2


No Yes There is no ecologist available in the bidding board composition; environmental aspects of the bidders are assessed by engineer on construction and machinery


Yes Yes The bidding and contract documents do not include requirements on the SEMP development by Contractor.



C. Compliance with Environment Protection Requirements in the Course of

Construction (to be filled, if necessary)

Name Status95

(Y/N)


(Y/N)



2

No Yes The continuous monitoring of the SEMP implementation was not carried out. The requirements on the qualitative monitoring were not included in IEE


No Yes No assessment of unpredictable effects was carried out. It is necessary to carry it out


No Yes Engineering Consultant prepared reports containing the cases of significant violations in EP field. However, these reports were not submitted to PMU


No Yes The requirements on the SEMP development by Contractor were not included either in IEE or the project documents. The Contractor had presented environmental issues in the frame of the Work Program, however they were not reviewed either by Engineering Consultant or by PMU


No Yes Contractor is using the form of report. The Consultant recommended development of the format for the reporting simplification

Notifications on noncompliance with environmental requirements based on the inspection results and requirements on its elimination

No Yes PMU ecologist and Engineering Consultant are carrying out environmental inspections of construction base in line with the work schedule. The results of EnРinООrinР Consultant’s obsОrvations are included in the quarterly report, which has not been submitted to consultants by PMU



Yes Yes Environmental reports are included in the Contractor’s tОcСnical rОports


No Yes Contractor has not delivered trainings on the environmental protection


No/Yes Yes EMP was observed during construction works at the sites. However, However, the EMP requirements are not met by one of Sub-contractors on the construction bases in terms of collection and disposal of solid and liquid domestic waste and FL


No Yes As of this audit date, no semiannual reports have been submitted

Reports on environmental No Yes Semiannual reports were not submitted to

95




Name Status95

(Y/N)


(Y/N)


monitoring were presented to the local community and respective governmental authorities

3

the local community and nature protection committees


No Yes The final audits were not carried out since the project works had not been completed.



Certificate Issued by the SES of Khorezm Province on Non-exceedance of the Norms

on the Noise Level and Indicators of the Air quality at the Construction Sites



Contractor’s Checklist of Environmental Audit of “RRDP. Phase II” Project, Tranche-1

Stage Indicator under

Monitoring Location

Fact Finding and Taking Actions

Delivery of materials

Availability of official approval or effective work licenses

Supplier of materials (concrete, foreign matters, gravel, etc.)

Delivered materials have required licenses and certificates, including ones for concrete, rubble, etc.

Material transportation in line with the schedule and routes plus TMP

The trucks cargo is covered / waterened

Air pollution with the dust and smoke associated with material transportation

Construction site Material transportation is arranged in line with the schedule and routes. The continuous control of the air pollution with dust due to transportation of the bulk materials is carried out. The covering material for concrete is available

Working hours of construction site

Noise levels; equipment Construction site Minor, does not exceed permissible levels and disturb the population comfort


Vibration Construction site Visual observation, does not exceed permissible levels and disturb the population comfort


Dust and air pollution (solid particles, suspended particles and particles of the heavy metals in the air)

At the construction site or nearby

Continuous irrigation with water has been arranged as well as of the widened part to avoid the dust and air pollution. Bypass road is maintained on continuous basis

Entire construction period

Wild nature: protection of fauna, fish fauna preventing the water pollution. To minimize disturbance of aquatic birds. To prevent poaching

At the construction site or nearby

There is no risk of the water pollution at the construction site or nearby. There are no cases of the poaching and fauna disturbance at the construction site or nearby identified.


Safety of transport traffic/vehicles/access of pedestrians. Visibility/proper signs

Construction site The safe movement of transport has been arranged, including installation of required road signs, cones and flashlights along entire territory of construction site. The continuous irrigation of the widened road part has been arranged


Storing, handling and utilization of material and waste. Quality of water and ground (suspended solid particles, oils, etc.)

Storing places for materials and waste; leakage from construction site; areas of the waste storing; washout areas

The warehouses and containers are available for the storing of materials. The filling station is continuously operating. The mobile filling station is available at the construction site for the fueling


Waste management All construction sites; camps, sites, areas of the dosing facilities

All types of the waste are immediately disposed



Stage Indicator under

Monitoring Location

Fact Finding and Taking Actions


Maintenance of equipment and filling station. Quality of water and ground (suspended solid particles, oils, fuel, etc.)

Equipment for the fueling and maintenance of machinery; leakage from the site; areas of the object storing; (if necessary) washout areas

The working order of vehicles and equipment is under the permanent control. The maintenance and repair of vehicles are carried out to avoid the air pollution with the hazardous substances generated by exhaust gas. The permanent control of the oil products leakage has been arranged


Protective equipment.

Arrangement of the transport bypass

Construction site The transport movement along bypass road has been arranged; required signs and cone barriers have been installed


Air pollution near the dosing facilities/breaking plants

Two measuring points near the dosing concrete facilities

The operation of the breaking plant is under control; the irrigation near the breaking plant is carried out to avoid the air pollution with dust; the workers are provided with required safety means


Water quality at the construction site

Construction site on 488 km of CL

The water testing was arranged in the sanitary epidemiologic station. The various types of filters are continuously used for the drinking water


Noise pollution and vibration

Two measuring points; one is located close to Sarymai settlement on the section 488 km, the other one – near the police station on the section 455 km

Minor; visual observation and control, does not exceed permissible level. Permanent check of Continuous check of the damping system of the vehicles to avoid the disturbance of the workers and local citizens.



APPENDIX 8. Second Small and Microfinance Development Project

Checklist of Environmental Audit on Hamkorbank


Project Data

Project Title: Second Small and Microfinance Development Project (Hamkorbank)

Project progress (%): 100 Categories of Environmental Safeguards

A B C

X



Mostly complies–minor correction


X Completely complies


Schedule 3 Paragraph 11

The Borrower shall cause the PCBs to ensure that Qualified Subprojects shall be for activities that: (a) are excluded in the list of prohibited investment activities set out in the table to this Schedule96

and (b) have a minimal or no adverse environmental or social risks. Activities that fall under categories A or B of ADB’s Safeguard Policy Statement (2009) and /or require environmental assessment clearance be the Borrower shall not be financed under the Project

Yes


Name Status (Y/N)

The Further Control is

Required(Y/N)



Yes No

Control over environmental compliance in Bank was assigned on Environmental Manager and Senior Environmental Coordinator


Yes Yes ESMS system was adopted in 2009 and amendment version was re-adopted in 2012


N/A N/A

The requirements of the “Environmental Management Plan (EMP)” were incorporated in the brief working documentation (confirmation by the Environmental Department of Verification of the

N/A N/A

96 Schedule 3 of Loan Agreement (May 1, 2010)



Brief Working Documentation in terms of its compliance with EMP requirements) EMP requirements are included in the bidding documents

N/A N/A


N/A N/A


N/A N/A

C. Compliance with Environment Protection Requirements in the Course of Construction (to be filled, if necessary) – In according with no construction activities on this project, Part C of given checklist was deleted.



Checklist of Environmental Audit on Ipak Yuli Bank


Project Data

Project Title: Second Small and Microfinance Development Project (Ipak Yuli Bank)

Project progress (%): 100 Categories of Environmental Safeguards

A B C

X



Mostly complies – minor correction


X Completely complies


Schedule 3 Paragraph11

The Borrower shall cause the PCBs to ensure that Qualified Subprojects shall be for activities that: (a) are excluded in the list of prohibited investment activities set out in the table to this Schedule97 and (b) have a minimal or no adverse environmental or social risks. Activities that fall under categories A or B of ADB’s Safeguard Policy Statement (2009) and /or require environmental assessment clearance be the Borrower shall not be financed under the Project

Yes


Name Status (Y/N)

The Further

Control is Required

(Y/N)



Yes No

Control over environmental compliance in Bank was assigned on Environmental and Social Risk Management officer


Yes Yes ESMS system was adopted in 2012 and amendment version was re-adopted in 2013


N/A N/A

The requirements of the “Environmental Management Plan (EMP)” wОrО incorporatОН in tСО brief working documentation (confirmation by the Environmental Department of Verification of the

N/A N/A

97 Schedule 3 of Loan Agreement (May 1, 2010)



Brief Working Documentation in terms of its compliance with EMP requirements) EMP requirements are included in the bidding documents

N/A N/A


N/A N/A


N/A N/A

C. Compliance with Environment Protection Requirements in the Course of Construction (to be filled, if necessary) - In according with no construction activities on this project, Part C of given checklist was deleted.



APPENDIX 9. Housing and Integrated Rural Development Project

Data to be collected in collaboration with District Hokimiyat

Form 1. Province: Surkhon

Name of the Residential Massive

Total Size of the Residential Massive (Ha)

Year when land is available in Government Reserve Land for Housing Purpose

Other previous owner/land lease holder of the land, and the size of land belong to this previous owner

98

Distance from Forest area (km)

Distance from River Canal (km)

Distance from other protected area both for ecological function and cultural heritage (km)

«Tolimaron», Guliston town in the district of the Angor

11,8 11.12.2010 . building a military unit 8 7 8

"Rabot", Bibishirin town in the district of the Boysun

4,7 16.12.2010 . “Inoyatov Asadbek” Farm 50 1 50

"Hazarbog",Jamatak town in the district of the Denov

4,0 31.12.2010 . «OriП Faвг MillОr» Farm 12 14 30

"Anbarsoy", Obodon town in the district of the Denov

2,0 31.12.2010 . building of the old barn belonging Buriev Komil

4 3 25

"Ю ч ", town in the district of the Denov

1,4 31.12.2010 . building of the old barn belonging Khasanov Eraj

18 1,5 20

"Yurchi", Kattakarshi town in the district of Denov

1,38 31.12.2010 . «KСakimjon» Farm 16 1,5 20

"Okkurgan",Kuraentok town in the district of the Jarkurgan

6,0 31.12.2010 . unused land 18 8 13

98

This data could be found in the Act/Certificate of the Regional Selection Committee on the selected site. This Act/Certificate was issued after the me eting of the selection committee. The member of Selection Committee is also include the owner/land lease holder if the selected location involves land that not all under the reserve land.



DATA ON (POTENTIAL) BORROWERS AND HOUSING BLOCKS

99

District Name: Karakalpakstan

No. Residential Blocks that meet Safeguard Selection

Criteria Potential Borrowers

Other information about the Borrowers (This part can be combined with information related with other selection

criteria

1 «Amir Timur», Takirkala town in the district of the Amudarya

1 233,0

2 "Urta kala", Vakum town in the district of the Amudarya

3 "Shimom", Kukuz town in the district of the Beruniy 4 "Navoi", Bobur town in the district of the Beruniy 5 "Kizil-uy", Kizil-uy town in the district of the Kegeyliy

6 «KunРirot», Guliston town in the district of the Kungrad

7 «Samanbaв», Uгunkul town in the district of the Nukus

8 "Pahtachi", Bahor town in the district of the Turtkul

9 "Kuhna Turtkul", Yangi ovul town in the district of the Turtkul

10 ”UlluboР”, UlluboР town in the district of the Turtkul

11 «Samankul», OвbОk town in the district of the Hodjeliy

99

This form will be filled up by ESMS field Staff after checking the location that meet safeguard selection criteria. This Form could be expanded to record other information about the borrower relate to other selection criteria



Recording field monitoring on construction workflow

Location of Residential Block visited

Provide information on Name location of residential Massive, District, Province Surkhon region Deneu Hazarbog village assembly of citizens Jamatak

Date of field Monitoring/Visit 31.05.2013 PROGRESS ON CONSTRUCTION WORKS 1. Completion of Civil works Describe: (1) when was the construction work start and when is expected to be completed ; (2) civil work achievement percentage or (foundation completed/under construction, wall under construction/completed, roof work completed/being completed, finishing touch inside the house and painting etc.)

Beginning-27.03.2013.Finishing-31.12.2013. Grounding completed in 40 houses. Foundations completed in 40-houses. Completed building walls 14 houses. Roof slab completed in 5 homes

2. Compliance with Environmental law and Regulations ObsОrvО tСО contractors’ works, anН cСОck witС tСО Staff of the District Natural Protection Committee (noted also the name of the District staff and get signature if necessary) whether the contractor violating any environmental law/regulation 3. Compliance with Norms on Health and Safety, as well as labor Norms ObsОrvО tСО contractors’ works, anН cСОck witС tСО technical supervisor engineer (TSE), whether the contractor violating above these norms (noted also the name of the TSE staff and get signature if necessary)

The contractor does not violate the Law on Environmental Protection

The contractor does not violate the law on health and safety, and labor laws.

1. Complaints by Affected Peoples Check with local hokimiyat, and technical Supervisor engineer whether any complaint related with the construction works (e.g. road or sewer was blocked

Complaints are not available



during construction, noise so loud, construction workers are not behave etc) or any issue related with location of the rural housing (e.g. used to be the grassing land, or other function) Name of Technical Expert of QQB

A.Abdumuratov Field observation from EFS staff

Signature



Hand over acceptance document for each house (by state commission)





Hand over acceptance document for each house (by house owners)