contents · ii contents the way forward .....x
TRANSCRIPT
ii
Contents The Way Forward ................................................................................................................................................................... x
Executive Summary ........................................................................................................................................................... xiii
List of Abbreviations ...................................................................................................................................................... xviii
Chapter 1: Conclusions and Recommendations ............................................................................................... 1
1.1 Overview of the Activities ..................................................................................................................................... 1
1.2 Audit Observations and Conclusions ............................................................................................................... 3
1.3 Audit observations on Compliance to ESMF ................................................................................................ 5
1.4 Recommendations .................................................................................................................................................. 11
Chapter 2: End of Term Environmental Audit for KLGSDP ...................................................................... 15
2.1 Background ................................................................................................................................................................ 15
2.2 Environmental and Social Management Framework (ESMF) ........................................................... 15
2.3 E&S Clearance Toolkit of the ESMF and the stages of application in project
implementation ....................................................................................................................................................................... 16
2.4 Institutional Framework for EMSF implementation ............................................................................. 16
2.5 Revisions in ESMF after the Mid Term Audit............................................................................................. 19
2.6 Objectives of Environmental Audit ................................................................................................................ 20
2.7 Scope of Work ........................................................................................................................................................... 20
Chapter 3: Methodology ............................................................................................................................................. 22
3.1 Study Approach ........................................................................................................................................................ 22
3.2 Audit Design .............................................................................................................................................................. 22
3.3 Sampling Design ...................................................................................................................................................... 22
3.4 Local Body Sampling Units (LB-SUs) ............................................................................................................. 23
3.5 Detailed Survey Methodology ........................................................................................................................... 23
3.6 Training of field staff for Environmental Audit ........................................................................................ 26
3.7 Data Analysis Plan .................................................................................................................................................. 26
3.8 Quality Control and Management ................................................................................................................... 26
Chapter 4: Field Training ........................................................................................................................................... 27
4.1 Training for Field Auditors ................................................................................................................................. 27
4.2 Sample Coverage by Field Survey ................................................................................................................... 28
4.3 Stakeholder Consultations .................................................................................................................................. 28
Chapter 5: Audit Observations ................................................................................................................................ 29
5.1 Findings on ESMF Documentation and Implementation ..................................................................... 29
5.1.1. EMSF in the project planning stage ...................................................................................................... 30
5.1.2. Adoption of Mitigation Measures as per EMSF ............................................................................... 31
5.1.3. Feasibility of the Mitigation Measures in ESMF according to the IOs ................................. 31
5.1.4. Feedback on any training programmes attended by IOs related to ESMF ........................ 32
5.1.5. Feedback of the IOs on the adequacy of the training programs ............................................. 32
5.1.6. LESA for L2 (medium Impact) Activities .......................................................................................... 33
5.2 Field Level Observations ..................................................................................................................................... 33
5.2.1. Buildings- New Construction and Expansion, Repair and Furnishings .............................. 33
5.2.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance ......................... 34
5.2.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/
Maintenance ........................................................................................................................................................................ 36
5.2.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid
Wastes, Electronic Waste and Biomedical Waste.............................................................................................. 37
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5.2.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play
grounds, Swimming Pools............................................................................................................................................. 38
5.2.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance ............. 39
5.2.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair
40
5.2.8. Storm Water Drains- Construction, repair and maintenance .................................................. 41
5.2.9. Agriculture/ Horticulture / Social Forestry - Management and extension ...................... 41
5.2.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities ......... 42
5.2.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning ....................................... 42
5.2.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance ..... 43
5.2.13. Tiny and Small Industries – Establishment and Expansion ..................................................... 44
5.2.14. Animal Husbandry dairy farming-construction and expansion facilities .......................... 45
5.3 Comparison of Projects evaluated during the MT Audit and ET Audit ......................................... 45
5.4 Application of Index of Environmental and Social Integrity (IESI) ................................................ 48
5.4.1. Buildings- New Construction and Expansion, Repair and Furnishings .............................. 48
5.4.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance ......................... 49
5.4.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/
Maintenance ........................................................................................................................................................................ 50
5.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid
Wastes, Electronic Waste and Biomedical Waste.............................................................................................. 51
5.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play
grounds, Swimming Pools............................................................................................................................................. 51
5.4.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance ............. 52
5.4.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair
52
5.4.8. Storm Water Drains- Construction, repair and maintenance .................................................. 53
5.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension ...................... 54
5.4.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities ......... 54
5.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning ....................................... 54
5.4.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance ..... 55
5.4.13. Tiny and Small Industries – Establishment and Expansion ..................................................... 55
Chapter 6: Good and Bad practices ....................................................................................................................... 57
6.1 GP/MN Office Building ......................................................................................................................................... 57
6.1.1 Good Practices ................................................................................................................................................. 57
6.1.2 Bad Practice ..................................................................................................................................................... 57
6.2 Anganwadi Centres ................................................................................................................................................ 58
6.2.1 Good practices ................................................................................................................................................. 58
6.2.2 Bad practices.................................................................................................................................................... 60
6.3 Family Welfare Centres ........................................................................................................................................ 60
6.3.1 Good Practice ................................................................................................................................................... 60
6.4 Foot Bridges ............................................................................................................................................................... 61
6.4.1 Bad Practice ..................................................................................................................................................... 61
6.5 Bus Waiting Sheds .................................................................................................................................................. 61
6.5.1 Good Practice ................................................................................................................................................... 61
6.5.2 Bad Practice ..................................................................................................................................................... 62
6.6 Waste management Projects ............................................................................................................................. 62
6.6.1 Good Practices ................................................................................................................................................ 62
6.6.2 Bad Practices ................................................................................................................................................... 64
iv
6.7 Drinking Water Supply projects ...................................................................................................................... 66
6.7.1. Bad Practices ................................................................................................................................................... 66
6.8 Storm water Drains ................................................................................................................................................ 67
6.8.1 Bad Practices ................................................................................................................................................... 67
6.9 Public Markets .......................................................................................................................................................... 68
6.9.1. Good Practices ................................................................................................................................................. 68
6.9.2. Bad Practice ..................................................................................................................................................... 68
6.10 Open Well construction/ Renovation............................................................................................................ 68
6.10.1. Good Practices ................................................................................................................................................. 69
6.10.2. Bad Practice ..................................................................................................................................................... 69
6.11 Road concreting ....................................................................................................................................................... 70
6.11.1. Bad Practice ..................................................................................................................................................... 70
6.12 Pond Maintenance .................................................................................................................................................. 70
6.12.1. Good Practices ................................................................................................................................................. 70
6.12.2. Bad Practices ................................................................................................................................................... 71
Chapter 7: Projects under onetime financial assistance to Backward LSGIs ................................... 72
7.1 One time financial assistance ............................................................................................................................ 72
Chapter 8: Capacity Building Programme ......................................................................................................... 77
8.1 Capacity Building Initiatives .............................................................................................................................. 77
8.1.1. State Level Trainings ................................................................................................................................... 77
8.1.2. District level Orientation Training on ESMF & Procurement Procedures for the
Support Staff of LSGs: ...................................................................................................................................................... 78
8.1.3. Capacity of environmental auditors, LSGI functionaries and Implementing Officers . 79
8.1.4. Orientation Training for the newly elected LSG functionaries & Refresher Training for
the Implementation Officials: ...................................................................................................................................... 79
8.1.5. Orientation training to the newly recruited District Coordinators of KLGSDP under
backward support grant ................................................................................................................................................ 79
8.2 Comments on the strength and weakness found in the existing capacity building
initiatives.................................................................................................................................................................................... 80
v
List of Tables
Table 1.1: Brief overview of subprojects covered during the Environmental Audit (EA) ......................... 1
Table 1.2: District wise distribution of major SPs surveyed during the ET Audit ......................................... 2
Table 1.3: Audit findings vis-a-vis the Audit Objectives ............................................................................................. 3
Table 2.1: Institutional Structure for ESMF Implementation for GPs................................................................ 16
Table 2.2: Institutional Structure for ESMF Implementation for MNs .............................................................. 18
Table 4.1: Details of training for the Field Auditors ................................................................................................... 27
Table 4.2: Subprojects covered during the field training of the Auditors ....................................................... 27
Table 7.1: Projects funded under the onetime financial assistance to Backward LSGIs covered in the
ET Audit ........................................................................................................................................................................................... 73
Table 7.2: Backward Assistance Subprojects requiring Statutory Clearances .............................................. 76
Table 8.1: State Level Capacity Building Programmes ............................................................................................. 77
Table 8.2: District Level Capacity Building Initiatives .............................................................................................. 79
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List of Plates
Plate 5.1: Renovation of Panchayat Office, Pananchry, Thrissur ................................................................. 33
Plate 5.2: Anganwadi at Irikkur GP in Kannur District ..................................................................................... 33
Plate 5.3: Keezhallur Ayithara Road tarring at Dharmadam GP in Kannur District ........................... 34
Plate 5.4: Culvert construction in Narbona Church road at Punnpra South, Alapuzha District ... 34
Plate 5.5: Improvement of Thachakalipadi road in Kallooppara GP in Pathanamthitta District . 35
Plate 5.6: Kochuveli Foot Bridge at Muhamma GP in Alapuzha District .................................................. 35
Plate 5.7: Bus waiting shed at Karunapuram GP in Idukki District ............................................................ 36
Plate 5.8: Bus waiting shed at Kummil GP in Kollam District ........................................................................ 36
Plate 5.9: Parking yard at Vazhathope GP in Idukki District .......................................................................... 36
Plate 5.10: Parking Yard at MN office at Malappuram MN in Malappuram District ........................... 36
Plate 5.11: Biogas Plant at Kallooppara GP in Pathanamthitta District .................................................... 37
Plate 5.12: E-Toilet at Chavara GP in Kollam District ........................................................................................ 37
Plate 5.13: Shed for waste dumping yard at Wadakkanchery MN in Thrissur District .................... 37
Plate 5.14: Vermicompost Shed at Kaduthuruthy GP in Kottayam District ............................................ 37
Plate 5.15: Public Market at Kulathupzha GP in Kollam District ................................................................. 38
Plate 5.16: Chennalode Mini Stadium at Thariyode GP in Wayanad District ......................................... 38
Plate 5.17: Gas crematorium at Thodupuzha MN in Idukki District .......................................................... 38
Plate 5.18: Smoke room for Crematorium at Chenglai GP in Kannur District ...................................... 39
Plate 5.19: Swimming pool construction at Kaduthuruthy GP in Kottayam District ......................... 39
Plate 5.20: Park for Children, Thiruvalla MN in Pathanamthitta District ................................................ 39
Plate 5.21: Thevarakkadavu Check dam renovation at Kannambra GP in Palakkad District ........ 39
Plate 5.22: Venchakulam Lift Irrigation Project Chenkal GP in Trivandrum District ........................ 39
Plate 5.23: Pampa valley community Irrigation project at Ward 12 at Kavalam GP in Alapuzha
District ............................................................................................................................................................. 40
Plate 5.24: Completion of Pulikuzhi drinking water scheme at Kallikadu GP in Trivandrum District
............................................................................................................................................................................. 40
Plate 5.25: Plumbing and Pump set to Thopilavi Drinking water scheme at Chenglai GP in Kannur
District ............................................................................................................................................................. 40
Plate 5.26: Pipeline extension to GP Office, Veterinary Hospital at Nedumudi GP in Alapuzha
District ............................................................................................................................................................. 40
Plate 5.27: Construction of drain with cover slab at Ward 2 in Chellanam GP in Ernakulam District
............................................................................................................................................................................. 41
Plate 5.28: Kattusheri Drainage Construction at Alathur GP in Palakkad District .............................. 41
Plate 5.29: Protection wall to Mudakkuzha padam at Mudakuzha GP in Ernakulam District ....... 42
Plate 5.30: Fish Market at Muvattupuzha MN in Ernakulam District ........................................................ 42
Plate 5.31: Side protection wall for Kuttikulangara Pond at Kayamkulam MN in Alapuzha District
............................................................................................................................................................................. 43
Plate 5.32: Construction of Borewell at Madavur GP in Trivandrum District ....................................... 43
Plate 5.33: Purchase of Generator for GP office at Velukkara GP , Thrissur District .......................... 44
Plate 5.34: Purchase of Touch Screen for GP office at Veeyapuram GP in Alapuzha District ........ 44
Plate 5.35: Maniyarankudi Khadi industrial centre at Vazhathopu GP in Idukki District ............... 44
Plate 5.36: Construction of building to Kolkkalam Vanitha Thozhil Pariseelana Kendram at
Ponmala GP in Malappuram District ................................................................................................. 44
Plate 5.37: Building for Vanitha Vyayasaya Estate at Kannambra GP in Palakkad District ............ 45
Plate 5.38: Cattle feed godown at Karode GP in Trivandrum District ....................................................... 45
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Plate 6.1: GP office at Mannanchery GP in Alapuzha District ........................................................................ 57
Plate 6.2: PHC building at Chettikulangara GP in Alapuzha District .......................................................... 57
Plate 6.3: Vazhathoppe Anganwadi at Vazhathope GP, Idukki District .................................................... 58
Plate 6.4: Kuttooli Anganwadi at Keezhuparamba GP in Malappuram District ................................... 59
Plate 6.5: Kavana Anganwadi at Avoli GP in Ernakulam District ................................................................. 59
Plate 6.6: Madathinkadavu Anganwadi at Mariyapuram GP in Idukki District .................................... 59
Plate 6.7: Manjappara Anganwadi at Nedumkandom GP in Idukki District ........................................... 60
Plate 6.8: Mugu Anganwadi at Puthige GP in Kasaragode District.............................................................. 60
Plate 6.9: Family Welfare Centre at Kallikadu GP in Trivandrum District .............................................. 60
Plate 6.10: Hosabettu Koppala Foot Bridge at Manjeshwaram MN in Kasaragod District ............. 61
Plate 6.11: Kallur Koppala Foot Bridge in Vorkady GP in Kasaragod District ....................................... 61
Plate 6.12: Bus Waiting Shed at Chakkittapara GP in Kozhikode District ............................................... 61
Plate 6.13: Bus waiting shed at Ayavana GP in Ernakulam District ........................................................... 62
Plate 6.14: Bus waiting shed at Kalloorkad GP in Ernakulam District ..................................................... 62
Plate 6.15: Dumping Yard at Division 19 in Karunagappally MN of Kollam District ......................... 63
Plate 6.16: Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta District ............ 64
Plate 6.17: Biogas Plant at Taluk Hospital at Thodupuzha MN in Idukki District ............................... 65
Plate 6.18: E-Toilet at Mavelikkara MN in Alapuzha District ........................................................................ 66
Plate 6.19: Kavilppadi Irrigation Project in Mariyapuram GP in Idukki District ................................. 66
Plate 6.20: Mulamthandu Water Supply Scheme in Santhanpara GP in Idukki District ................... 66
Plate 6.21:Keezhur Pipeline extension in Chemnad GP in Kasargod district ........................................ 67
Plate 6.22: Construction of drainage at 4 cent Colony road Kadapuram GP in Thrissur District 67
Plate 6.23:Construction of Drain at Kulanmavu Ambalabhagom Road at Arakkulam GP in Idukki
District ................................................................................................................................................................ 67
Plate 6.24:Renovation of town market at Kulathupuzha GP in Kollam District ................................... 68
Plate 6.25: New market construction at Nedumkandom GP in Idukki District .................................... 68
Plate 6.26: Renovation and recharge of open well was undertaken at the MN office at Chittoor MN
in Palakkad District ...................................................................................................................................... 69
Plate 6.27:Open well maintenance at Baison Valley GP in Idukki District ............................................. 69
Plate 6.28: Open well near Vallapuzha Railway Station at Vallapuzha GP in Palakkad District ... 70
Plate 6.29: Concreting of Pathichiripadi road at Mankulam GP in Idukki district. ............................. 70
Plate 6.30: Ayyappankulam Renovation at Kollenkode GP in Palakkad District ................................. 70
Plate 6.31: Renovation of Odangattkulam at Edayur GP in Malappuram District ............................... 71
Plate 6.32: Maintenance of Panchayat pond at ward 3 at Kavalam GP in Alapuzha District ......... 71
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List of Figures Figure 5.1: Distribution of IOS responded to the questionnaire for IOs in the ET Audit .................. 29
Figure 5.2: Experience of the IOs in implementing KLGSDP subprojects ................................................. 30
Figure 5.3: Whether ESMF document is referred in the subproject planning stage: response from
IOs ......................................................................................................................................................................... 30
Figure 5.4: Adoption of Mitigation Measures as per EMSF .............................................................................. 31
Figure 5.5: IOs feedback regarding the feasibility of mitigation measures mentioned in ESMF
document ........................................................................................................................................................... 31
Figure 5.6: IOs feedback on whether they have attended any training programs with respect to
ESMF ................................................................................................................................................................. 32
Figure 5.7: Feedback of IOs on the adequacy of training programs ............................................................ 32
Figure 5.8: Percentage of building repair/furnishing projects under green/yellow/red categories as
per IESI Scores and factors causing low scores for Red category projects .................... 49
Figure 5.9: Percentage of building construction projects under green/yellow/red categories as per
IESI Scores and factors causing low scores Red category projects .................................... 49
Figure 5.10: Percentage of road repair and maintenance projects under green/yellow/red
categories as per IESI Scores and factors causing low scores Red category projects50
Figure 5.11: Percentage of road construction projects under green/yellow/red categories as per
IESI Scores and factors causing low scores Red category projects .................................... 50
Figure 5.12: Percentage of operation/repair and maintenance of waiting sheds and parking yards
projects under green/yellow/red categories as per IESI Scores ........................................ 50
Figure 5.13: Percentage of sanitation and waste management projects under green/yellow/red
categories as per IESI Scores and factors causing low scores Red category projects51
Figure 5.14: Percentage of repair and maintenance of public markets, crematorium, playgrounds
and swimming pool projects under green/yellow/red categories as per IESI Scores and
factors causing low scores Red category projects ...................................................................... 51
Figure 5.15: Percentage of construction of public markets, crematorium, playgrounds and
swimming pool projects under green/yellow/red categories as per IESI Scores and
factors causing low scores Red category projects ...................................................................... 51
Figure 5.16: Percentage of construction and maintenance of minor and micro irrigation projects
and check dams under green/yellow/red categories as per IESI Scores........................ 52
Figure 5.17: Percentage of maintenance and repair of drinking water supply projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 52
Figure 5.18: Percentage of construction and expansion of drinking water supply projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 53
Figure 5.19: Percentage of repair and maintenance of storm water drain projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 53
Figure 5.20: Percentage of construction of storm water drain projects under green/yellow/red
categories as per IESI Scores and factors causing low scores Red category projects53
Figure 5.21: Percentage of agriculture/horticulture and social forestry projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 54
ix
Figure 5.22: Percentage of repair and maintenance of facilities for meat and fish production and
marketing projects under green/yellow/red categories as per IESI Scores and factors
causing low scores Red category projects ...................................................................................... 54
Figure 5.23: Percentage of repair and maintenance of ponds/tanks/well/canals projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 55
Figure 5.24: Percentage of electrical and electronic items purchase, installation, operation and
maintenance projects under green/yellow/red categories as per IESI Scores and
factors causing low scores Red category projects ...................................................................... 55
Figure 5.25: Percentage of tiny and small industries-establishment and expansion under
green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects ........................................................................................................................................ 56
x
The Way Forward
Kerala Local Government Service Delivery Project (KLGDSP)
A. Introduction
Government of Kerala, in partnership with the World Bank conceived the Kerala Local
Government Service Delivery Project (KLGSDP) with a vision to boost, institutionalize and
raise the level of service deliveries of Local Self Government Institutions (LSGIs) using modern
tools of planning, development, project implementation and transparency in administration.
The project commenced in the year 2011 and is getting completed by December, 2017.
Direct beneficiaries of the project are the 978 Grama Panchayats (GPs) and 60 Municipalities
(MNs) in the State of Kerala (after delimitation in 2016, the number of GPs is 941 and MNs are
87). KLGSDP consisted of mainly four components viz., (a) an annual, performance-based
untied grant to all GPs and Municipalities in Kerala to be spent on creation and / or
maintenance of capital assets used in service delivery; (b) capacity building inputs to
strengthen and supplement the existing systems and human resource of GPs and MNs to
enhance their institutional performance; (c) support for strengthening the system of
performance monitoring of GPs and Municipalities; and(d) support for a Project Management
Unit (PMU) that would handle overall coordination, implementation, monitoring and
evaluation of the project.
B. Environment and Social Management Framework (ESMF)
The subprojects for service delivery funded by KLGSDP falls under environmental category ‘B’
as per World Bank’s safeguard policies laid down in OP 4.01 on Environmental Assessment
(EA) and hence it required KLGSDP to screen projects upstream in the project cycle for
potential impacts and mitigate the adverse impacts. The Environmental and Social
Management Framework (ESMF) had been developed by KLGSDP in this context and made
mandatory from the beginning of its subproject implementation to address the potential
environmental and social issues. KLGSDP strictly followed the existing decentralized planning
process for the implementation of ESMF.
C. End of Term Environment Audit
The End of Term Environmental Audit (ET Audit) aimed at understanding many a fact which
was instrumental in achieving satisfactory or unsatisfactory level of ESMF implementation in
the subprojects of KLGSDP. The audit further looked into areas of concern which reduced
further effectiveness of ESMF benefits in the subproject implementation.
D. Remarkable findings of the ET Audit
KLGSDP was the first project under Local Self Government Department to implement an
operational ESMF mandatorily and systematically. This was a piloting method for
mainstreaming the ESMF integration in whole LSG system.
Integration of ESMF compliance Proformas in the IKM software as Annexure-6 helped the
local bodies (LBs) a lot in ensuring verification and compliance process enumerated in the
ESMF.
xi
Able guidance provided by KLGSDP mentors and extensive awareness training
programmes at state and district level helped effectively in conveying to support staff of
LSGs the importance of ESMF integration with overall planning and implementation of
KLGSDP projects
Although general understanding of ESMF compliance requirement through Annexure-6 in
the IKM software is good, yet understanding of project specific requirements vis-a-vis
environmental mitigation measures lacked clarity in many of the Block Engineers and
Implementing Officers(Assistant/Municipal Engineers, Municipal/Panchayat Secretaries,
Agricultural Officers etc)
Despite notable capacity building training and monitoring efforts by PMU, training and
monitoring was still found insufficient in sensitizing the entire stakeholder vis-a-vis
importance of ESMF document.
The responsibility for all ESMF related processes at the GP and MN level, such as screening
and verification, lies with the IOs( usually Assistant Engineers) and approval lies with
Block Engineers(usually Assistant Executive Engineers). Same officers are also supposed
to ensure compliance and hence an issue of conflict of interest arises many times, which
goes against the spirit of fair implementation of ESMF provisions.
Mid-Term Environmental Audit (MT Audit) conducted in the year 2014 and its
dissemination of findings to the LBs enhanced quality of ESMF implementation at large.
E. The way forward
For each project, the way forward would entail short- and medium-run interventions with
complementary and mutually reinforcing objectives. In the short run, the GPs and MNs which
are already familiar with the ESMF procedures can start demonstrating better results using
existing ESMF provisions by introducing it to other subprojects implemented using other
funds. In the medium run, the focus can shift to subprojects at a bigger scale such as the
projects taken up by the Block and District Panchayats. Engaging a broad spectrum of
stakeholders such as the elected local body members and the direct beneficiaries of the
projects can facilitate the envisioned guidelines in ESMF to be achieved in its true sense. In
light of the specific challenges faced in the implementation of ESMF, the path toward more
effective and innovative implementation of ESMF calls for action on several fronts. While there
is no single solution, better results can be achieved through action on the following five items
Further simplification and trimming of ESMF formats which could help in better
compliance of ESMF provisions
A State Level Environmental Cell, under the Department of Environment and Climate
Change, Government of Kerala, is advised, where the Environmental and Social (E&S)
mandatory clearance procedures could be facilitated and monitored on behalf of LSGIs.
This will also bring in more knowledge base on ESMF issues and help in holistic
implementation of ESMF procedures
Frequent refresher and orientation training is important for implementing officers and
other engineering staff of LSGIs.
Effective Monitoring is an important aspect of long term success of environmental
safeguard. Current ESMF has a robust monitoring process in place and it is suggested that
existing monitoring procedures should be complied diligently without any dilution.
Elected LB members should also be sensitized to promote their involvement in ESMF
screening and compliance process. Elected members should also try to involve local
community through awareness generation so as to promote ownership towards the assets
created and their maintenance, through citizen-centric information, education and
communication (IEC) campaign
xii
In conclusion, the way forward is to remedy the institutional failures that prevent the ESMF
implementation in its essential spirit to ensure sustainability in the service delivery and
infrastructure projects undertaken by all the LSGIs of Kerala. Moving forward, the World Bank
as well as the Government of Kerala should stand ready to support this laudable agenda of
sustainable and inclusive development propagated by ESMF.
xiii
Executive Summary
A. Background
The State of Kerala has been leading the way in decentralized local governance in our country
in many facets of decentralization and has moved at good pace in transferring functions,
responsibilities, authority and finances to Local Governments. In order to further strengthen
and institutionalize local service delivery and for building useful public infrastructure with
responsive public services, the Government of Kerala, in partnership with the World Bank
conceived the Kerala Local Government Service Delivery Project (KLGSDP).
The project commenced in the year 2011 and is getting completed by December, 2017. Direct
beneficiaries of the project are the Grama Panchayats (GPs) and Municipalities (MNs) in the
State of Kerala as per the Project Implementation Manual (PIM).
KLGSDP consisted of mainly four components viz., (a) an annual, performance-based untied
grant to all GPs and Municipalities in Kerala to be spent on creation and / or maintenance of
capital assets used in service delivery; (b) capacity building inputs to strengthen and
supplement the existing systems and human resource of Municipalities and GPs to enhance
their institutional performance; (c) support for strengthening the system of performance
monitoring of GPs and Municipalities; and(d) support for a Project Management Unit (PMU)
that would handle overall coordination, implementation, monitoring and evaluation of the
project.
B. Environmental and Social Management Framework (ESMF) for KLGSDP subproject implementation
KLGSDP has been classified under category B as per World Bank norms. This mandates the
preparation of an ESMF as a necessary procedural requirement for project appraisal and
adherence/ compliance to the ESMF during project implementation, a vital performance
criterion. Accordingly, ESMF was developed as a relevant tool placed in the hands of local
governments as it will empower them to manage E&S issues arising out of their own decisions
and plans.
The ESMF had been developed and made mandatory from the beginning of the KLGSDP
implementation to address the potential environmental and social issues arising as a result of
the infrastructure development and service delivery that were to be initiated with the help of
the increased untied grant flows to the GPs and MNs. Based on the findings of the Mid Term
Environmental Audit carried out during the in 2014, it has been observed that, for the due
diligent compliance of ESMF, certain revisions/modifications were required in the ESMF
document. A series of Consultation Workshops were carried out by KLGSDP participating
Subject Experts in the field, World Bank Representatives, Elected Representatives
Implementing Officers of local bodies with regard to modification of the ESMF. The outcomes
of the consultation workshops and the Mid Term audit results were consolidated and
integrated appropriately in the ESMF document.
xiv
C. Objectives of End of Term Environmental Audit (ET Audit)
KLGSDP proposed to conduct an “End of Term” Environment Audit with following three major
objectives under consideration:
To determine the extent of compliance to the ESMF achieved over the project period
and identify non-compliances, if any, with respect to applicable national / state / local
regulations. Audit also envisaged finding effectiveness and deficiencies in
implementing the original ESMF and extent of improvement achieved, following
modifications in ESMF suggested by the mid-term environmental audit.
To study and comment on the adequacy of the systems and procedures contained in
the latest version of the ESMF (post mid-term environmental audit) for suitably
managing all possible environmental impacts in context of all sub-projects undertaken
by the local bodies and suggest scope for further improvement, if any.
To determine the extent to which direct/indirect adverse impacts from the subprojects
to various constituents of the environment such as human lives, property and natural
resources, have been avoided, prevented or mitigated
D. Approach and Methodology for ET Audit
The Environmental Audit followed a mix-design based approach, whereby a mix of qualitative
as well as quantitative data set was used. Broadly, the audit included following procedures as
major steps for achieving objectives of the environmental audit:
Scoping and Boundary Setting
It was estimated by PMU of KLGSDP that, the sample-size for this final EA could be 2,500 sub-
projects covering all categories of sub-projects implemented under the KLGSDP, including
community infrastructure / fixed assets created/maintained and other activities undertaken
using Performance Grant and One time assistance to backward Local Bodies. Study Boundary
of the audit included direct as well as indirect beneficiaries of the project and both individual
as well as cumulative impacts and their mitigation.
Desk Review
Subsequent to review of relevant documents from PMU, a list of indicators and guiding
questions was developed focusing on the specific objective of Environmental Audit, which led
to the design of various audit specific study instruments.
Designing Study Instruments (Quantitative & Qualitative)
The audit team designed data / information collection questionnaire for both qualitative as
well as quantitative data/information collection. The audit questionnaires were focused on
determining the environmental aspect of whole project activities, especially around ESMF
provisions. The questionnaire targeted a representative sample of the direct beneficiaries as
well as other key stakeholders.
Selection of Local Body Sampling Unit (LB-SU) through Selection Matrix (LBSM)
Environmental audit was conducted within overall sample size of 2500 sub project, which
included 15% of the completed projects from the 3rd Grant Cycle (FY 2014-15), 15% from the
4th Grant Cycle (FY 2015-16), 15% from 185 Government approved backward assistance
projects, 15% from midterm audited projects and remaining 15% from 5th Grant Cycle (FY
xv
2016-17). In terms of GPs and MNs, audit covered a sample of 34% of the 941 GPs i.e. 321 GPs
and 34 % of the 87 MNs i.e. 30 MNs, covering all the 14 districts of Kerala. The sample
selection should be such that it is representative of all geographical, agro-climatic,
demographic, socio-economic and cultural variations prevailing across the state.
Field Visits:
Audit schedules were prepared which included field visits, desk reviews, actual verification of
the sub-projects at site with respect to the environmental and social parameters with photo
documentation. PMU was kept in loop during this process and their support was obtained from
time to time for facilitating the field activity. Collected field data/information was deeply and
thoroughly analyzed to arrive at audit findings and environmental audit report consisting of
audit observations. Conclusions and recommendations were finally drawn based on audit
findings.
Stakeholder Consultations:
The relevant stakeholders were consulted at various levels to gather information regarding
sub projects. At the state level, policy level and project specific discussions were held with the
KLGSDP officials and at the district, GP and MN level, sub project related discussions were held
with a number of other stakeholders viz District Coordinators of KLGSDP, Implementing
Officers, Elected Representatives and the Public. A consultation workshop was conducted with
the PMU and all the District Co-ordinators at Thrissur. Final audit report was prepared based
on field observation and input from the state and district level stakeholder consultations. The
outcome of this audit report was presented through a state-level audit finding dissemination
workshop, held at Trivandrum, to discuss the preliminary findings and draft EA report of the
environmental audit and receive feedback on the same from a wide variety of stakeholders to
fine tune the final EA Report.
E. Findings of the ET Audit
Audit appreciably found that KLGSDP was successful in integrating the required Proformas for
environmental & social clearance and compliance verification in their regular plan software,
which helped in largely satisfactory compliance of ESMF provisions on the whole. While
screening level ESMF compliance was found to be followed satisfactorily, further compliance at
the level of mitigation measures was found only moderately satisfactory. The compliance
verification by the IOs with facilitation from Block Engineers was found to be moderately
satisfactory. Statutory compliance requirement were not given adequate attention in the
process of ESMF implementation and audit too could not verify such noncompliance since
relevant documentation was not practiced at the LB level. Mid-Term Environmental Audit (MT
Audit) enhanced quality of ESMF implementation at large by the simplification of formats in
the E&S screening tool of ESMF.
Detailed outcome of the audit process is discussed in the report in the context of overall
conclusive comments on the ESMF implementation and monitoring process, as well as activity-
specific observations.
F. Conclusions and Recommendations of the ET Audit
KLGSDP was the first project under LSGD to implement an operational ESMF mandatorily and
systematically and this was a piloting method for mainstreaming the ESMF integration in
whole LSG system. The following are the major recommendations
xvi
A State Level Environmental Cell, under the Department of Environment and Climate Change is recommended, where the E& S mandatory clearance procedures could be facilitated and monitored on behalf of LSGIs.
There should be a dedicated environmental cum social specialist at block level who could be given charge of managing the ESMF verification compliance in association with block engineers.
The ESMF formats for mitigation measures for Level 1 and Level 2 activities shall be further simplified and shall be incorporated in the planning software itself. Photodocumentation of the project implementation phases shall also be promoted through the online platform.
The robust monitoring processes described in the ESMF should be complied diligently without any dilution.
ESMF provisions and stipulated mitigation measures for various types of subprojects must be made part of the tender and contract awarding procedures for the contractors to make the Projects ESMF compliant.
Frequent refresher and orientation training is important for the Implementing Officers (IOs) (Municipal/Panchayat Engineer, Municipal/Panchayat Secretary).
Learning experiences and directional recommendations have been enumerated broadly on the
key areas of improvement via-a-vis implementation for the KLGSDP project as a whole in this
ET Audit report. Activity-specific suggestions have been made for further strengthening of
ESMF implementation process to the entire LSG system as envisaged in the ESMF.
G. One time additional financial assistance to Backward Local Bodies
The ET audit evaluated 28 subprojects of Level 2 category supported under the ‘one time
additional financial assistance to selected backward local bodies’. Audit revealed that these
projects achieved satisfactory level in ESMF implementation and ESMF procedures were
holistically followed in these projects. Annexure-6 and LESA were diligently used in all DPRs.
Since DPRs of these projects were prepared by NGOs as external support to local bodies, it was
relatively easier for PMU to sensitize them via-a-vis ESMF requirement & regulatory
compliance requirements and include the same in DPRs. Fairly good regulatory compliance in
additional backward local body support projects was therefore a highlight of ESMF
implementation. Monitoring of these projects have been strengthened by appointing dedicated
Overseers, who could also be given awareness training on ESMF requirements and expected to
keep an eye on compliance to ESMF.
H. Capacity Building Initiatives of PMU with focus on ESMF
The capacity building initiatives were largely built around the efforts taken by PMU, especially
the Environmental and Social Safeguard Specialist took sincere effort in conveying the
importance of ESMF through the capacity building training programmes. Role of District
Coordinators in reinforcing the ESMF concept during the screening process as part of the
monitoring is also worth mention as they explored and utilised all available platforms like DPC
Meetings, DDP Conferences, Engineers monthly meetings etc. as avenues for disseminating the
ESMF concept as per the directions they received from PMU from time to time. This was visible
in the APA documents that majority of the LBs cleared the minimum mandatory conditions
(MMC) and performance benchmarks in ESMF compliance documentation.
The audit identified that organising refresher training on regular basis is so very important for
sustained implementation of ESMF provisions. In departments where transfers and new
xvii
appointments are frequent, refresher training and orientation training for new recruits is very
important. This was found a weak area in the current capacity building efforts.
I. Structure of the Environmental Audit Report
The environmental audit report has been structured in a manner so that it is easy to
comprehend the report in line with objectives of the audit, and also provides conclusive
statements facts for dissemination and recommendations for policy level decisions based on
detailed analysis of data collected form varied levels. The Report contains following chapters:
Chapter 1: Conclusions and Recommendations
Chapter 2: End of Term Environmental Audit for KLGSDP
Chapter 3: Methodology
Chapter 4: Field Survey
Chapter 5: Audit Observations
Chapter 6: Good and Bad Practices
Chapter 7: Subprojects under one time backward assistance to Local Bodies
Chapter 8: Capacity Building initiatives of PMU with focus on ESMF
xviii
List of Abbreviations
1st Grant Cycle : Financial Year 2011-12 2nd Grant Cycle : Financial Year 2012-13 3rd Grant Cycle : Financial Year 2013-14 4th Grant Cycle : Financial Year 2014-15 and Financial Year 2015-16 5th Grant Cycle : Financial Year 2016-17 CA : Chief Auditor CPCB : Central Pollution Control Board DC : District Co-ordinator ESMF : Environment and Social Management Framework ET Audit : End of Term Environmental Audit FA : Field Auditor GP : Grama Panchayat IO : Implementing Officer KLGSDP : Kerala Local Government Service Delivery Project LB-SU : Local Body Sampling Unit LESA : Limited Environmental and Social Appraisal Level 1 : Low Impact Activities Level 2 : Medium Impact Activities MN : Municipality MT Audit : Mid Term Environmental Audit PMU : Project Management Unit SP : Subproject ToR : Terms of Reference ULTRA-TECH : ULTRA-TECH Environmental Consultancy and Laboratory ZA : Zonal Auditor
1
Chapter 1: Conclusions and Recommendations
This chapter presents the overall observations and recommendations drawn from the environmental
audit of Local Bodies under the KLGSDP, in all the fourteen districts in Kerala. The Chapter starts by
presenting an overview of the activities covered during the environmental audit, in terms of the
number of cases of each type of activity, as well as a district-wise distribution of the same.
1.1 Overview of the Activities
The environment audit of Gram Panchayats (GPs) and Municipalities (MNs) under KLGSDP
project was undertaken in all fourteen project districts, on a sample basis. Overview of the
activities/subprojects whose environmental audits were undertaken during the course of the
field survey are summarized in Table 1.1. A total of 2500 cases of different subprojects were
surveyed, spread over 351 local bodies across the fourteen project districts. Majority of the
subprojects were classified under fourteen categories (following the categorization given in
Proforma B, ie, the Control List Screening Tool of EMSF), i.e. road/bridges/culverts, buildings,
waiting sheds, public markets/ crematoriums, micro and minor irrigation, drinking water
supply, storm water drains, agriculture, meat and fish production and marketing,
ponds/tanks/ wells/ canals, purchase of electrical and electronic items, sanitation and waste
management, animal husbandry& dairy farming and tiny and small industries.
Table 1.1: Brief overview of subprojects covered during the Environmental Audit (EA)
SN Subproject Category
No. of
cases
1. Buildings: Construction, repair, maintenance and furnishings 713
2. Roads/Bridges/Culverts: Construction, repair and maintenance 1126
3. Waiting sheds, Parking Yards, Bathing Ghats-Construction, operation and maintenance 39
4. Sanitation & Waste Management : Collection and Management of Solid & Liquid Waste, Electronic Waste, and Biomedical Waste 15
5.
Public Markets, Crematoriums, Burial Grounds, Public Toilets, Slaughter Houses, Waste Management Installations, Stadiums, Play grounds, Swimming Pools- Construction and Expansion or Operation, Maintenance and Repair 82
6.
Micro and Minor Irrigation - Construction and Expansion, Maintenance, Check Dams – Construction and Maintenance, Minor Irrigation - Maintenance 15
7. Drinking Water Supply Construction and Expansion, Operation, Maintenance and Repair 114
8. Storm Water Drains – Construction, Repair and Maintenance 97
9. Agriculture / Horticulture / Social Forestry - Management and extension 10
10. Meat & Fish Production and Marketing - Construction and Expansion of facilities and Repair and Maintenance of facilities 6
11. Ponds/Tanks/Wells/ Canals – Construction, Cleaning and De-silting 61
12. Electrical & Electronic items - Purchase, Installation, Operation and Maintenance 212
13. Animal Husbandry & Dairy Farming - Construction & Expansion of facilities 2
14. Tiny and Small Industries – Establishment and Expansion 8
TOTAL 2500
2
The purpose of End of Term Environmental Audit (ET Audit) was to find out whether the necessary measures are identified during the ESMF documentation stage to mitigate any adverse environmental impacts arising out of subproject related activities undertaken by the LBs and proper documentation of the same has been carried out or not. In order to fulfil this objective, a list of subprojects undertaken by respective LBs for holistic development of the area, were sampled in consultation with the KLGSDP PMU. Table 1.2 presents a district-wise distribution of the various categories of subprojects surveyed during the ET Audit.
Table 1.2: District wise distribution of major SPs surveyed during the ET Audit
S
No
District
Bu
ild
ing
s
Ro
ad
s
Wa
itin
g s
hed
s
Ma
rke
ts,
crem
ato
riu
ms,
swim
min
g p
oo
ls
Mic
ro
an
d
Min
or
Irri
ga
tio
n
Dri
nk
ing
Wa
ter
Dra
in
Ag
ricu
ltu
re
Mea
t a
nd
F
ish
Ma
rke
t
Po
nd
s/W
ells
Pu
rch
ase
Sa
nit
ati
on
An
ima
l
Hu
sba
nd
ry
Tin
y a
nd
S
ma
ll
Sca
le I
nd
ust
ries
1. Trivandrum 64 60 3 15 1 12 7 1 0 8 23 0 1 0
2. Kollam 59 87 2 7 0 6 11 2 0 2 10 2 0 0
3. Pathanamthita 45 101 5 8 0 5 5 0 0 2 12 3 0 1
4. Alappuzha 52 136 0 2 1 1 8 1 0 5 22 2 0 0
5. Kottayam 66 69 2 8 1 2 4 1 0 4 20 0 0 0
6. Idukki 39 43 3 3 2 6 5 0 0 4 11 1 0 1
7. Ernakulam 69 90 4 5 2 1 20 3 1 2 24 0 0 0
8. Thrissur 50 66 0 4 3 8 5 0 0 3 14 3 0 1
9. Palakkad 37 79 5 5 1 33 7 0 0 11 14 0 0 2
10. Malappuram 69 91 2 7 0 13 7 2 0 10 16 3 0 1
11. Kozhikode 39 119 6 5 1 18 2 0 3 2 18 0 1 0
12. Wayanad 44 42 4 4 3 1 4 0 1 6 11 1 0 1
13. Kannur 43 89 0 7 0 1 3 0 0 0 4 0 0 1
14. Kasaragode 37 54 3 2 0 7 9 0 1 2 13 0 0 0
Total 713 1,126 39 82 15 114 97 10 6 61 212 15 2 8
Grand Total 2500
3
1.2 Audit Observations and Conclusions
As per the mandate provided in ToR, audit aimed at understanding many a fact which were
instrumental in achieving satisfactory or unsatisfactory level of ESMF implementation in the
project. The audit further looked into areas of concern which reduced further effectiveness of
ESMF benefits in the subproject implementation. Since KLGSDP strictly followed the existing
decentralized planning process for its implementation, the ET Audit findings (positive &
negative) are also summarized to reconcile with the relevant plan procedures.
The audit findings and inferences vis-a-vis audit objectives mandated in the ToR are
summarized in table 1.3 below.
Table 1.3: Audit findings vis-a-vis the Audit Objectives
Audit Objective Audit Findings
1. Determine the extent of compliance to the ESMF (both in documentation and in field level implementation) achieved over the project period and identify non-compliances, if any, with respect to applicable national / state / local regulations
KLGSDP was successful in integrating the required Proformas
for environmental & social compliance verification (annexure-6
ie, the Proforma C and D of ESMF) in their regular plan
software(IKM software). This has resulted in local bodies
following the ESMF documentation procedure successfully.
Integration of ESMF compliance porformas in the IKM software
as Annexure-6 helped the LBs a lot in ensuring verification and
compliance process enumerated in the ESMF. It is observed that
the documentation of same is also reasonably good in LBs since
proper documentation of compliance verification form was
mandatory in Annual Performance Assessment (APA) as well.
Extent of compliance to the ESMF over the project period could
be interpreted in two ways. With regard to screening and
verification process by KLGSDP through relevant proforma
application at the time of project formulation and approval by
District Planning Committees, ESMF compliance was found to
be highly satisfactory; however, when it came to further
applying the provision of ESMF such as incorporation of
mitigation measures or diligently filling up the Limited
Environmental and Social Appraisal (LESA) form, ESMF
compliance was found to be moderately satisfactory.
It was difficult to identify through audit process, non-
compliances, if any, with respect to applicable national / state /
local regulations since most of the project related
Environmental & Social Compliance proformas (Annexure-6 in
IKM Software) did not explore regulatory compliance column in
detail. This is due to lack of enough knowledge on the part of
Implementing Officers (Municipal/Assistant Engineers,
Municipal/Panchayat Secretaries, Agricultural Officers etc) or
lack of interest in further exploring the applicability of
regulatory compliances necessary for the projects.
4
2. Determine how effectively the systems and procedures defined in the latest version of the ESMF have been applied by the project implementation team and identify deficiencies therein, if any.
Able guidance provided by KLGSDP mentors and extensive
awareness training programmes at state and district level
helped effectively in conveying to support staff of LSGs the
importance of ESMF integration with overall planning and
implementation of KLGSDP projects.
The level of understanding of the Implementing Officers (IOs)
of projects responsible for implementing ESMF provisions
were not consistent as majority of them were transferred
frequently or given additional charges of other LBs also
causing loss of ESMF knowledge base for the time till the new
Implementing Officers were given refresher training on ESMF
implementation.
In order to fill the knowledge gap, refresher training
programmes need to be more frequent.
Although general understanding of ESMF compliance requirement through Annexure-6 in the IKM software is good, yet understanding of project specific requirements via-a-vis environmental mitigation measures lacked clarity in many of the Block Engineers and IOs.
There is immense scope to further improve their understanding on this aspect, through capacity building activities at different levels.
3. Determine the extent of improvement achieved, if any, after modifications suggested by the mid-term environmental audit had been incorporated
Modified ESMF suggested by the Mid-Term Environmental Audit (MT Audit) enhanced quality of ESMF implementation at large mainly for the reason that several confusing and overlapping implementation aspects of ESMF were done away with.
For example, in earlier version of ESMF all types of road
projects were taken into Level 2 (medium impact) category in
the Control List (Proforma B of ESMF), but in reality most of
such projects were related to only surface toping or
maintenance and fell in Level 1 (low impact) category and as
such LESA applicable for Level 2 were not applicable to these
projects. Revised ESMF did away with this confusion and
pushed all these projects in Level 1 while new road
construction projects were only kept in Level 2 list. Similarly,
there were several maintenance activities taken up on adhoc
basis in different areas, were in new ESMF these subprojects
were better categorized so as to bring them under Level 1
projects and manage in systematic way via-a-vis
environmental management. New proforma guiding mitigation
plans for the Level 2 projects and projects involving land
acquisition were also introduced in new ESMF for better
screening and mitigation of impacts.
New proforma, guiding mitigation plans for the Level 2 projects and projects involving land acquisition were also introduced in new ESMF for better screening and mitigation of impacts.
5
Following MT Audit recommendations, overall ESMF compliance increased reasonably well and many non compliant projects moved into the category of compliant projects with proper intervention of KLGSDP through dissemination workshops at district level and also through the constant follow ups of District Coordinators (DCs) and PMU of KLGSDP.
However, the Audit also observed that owing to weak maintenance at post implementation stage, some of the projects which were performing well during midterm audit failed to achieve even “satisfactory” conditions of the current audit rating. This showed lack of maintenance activities following implementation of a subproject.
4. Determine the extent to which possible direct or indirect adverse impacts to various constituents of the environment such as human lives, property and nature, as a consequence of project related activities, have been avoided, prevented or mitigated
Significant number of projects in L1 category(37%) were found to have performed as “good”. However, same is low in L2 category where percentage of good projects is only 9.
o Good projects are those which scored over 75% marks in audit process.
Good projects have been successful in avoiding any adverse impact on environment by means of holistic application of all ESMF provisions right from sub project planning to implementation and monitoring stages of the project.
Majority of the projects have performed satisfactorily in terms
of avoiding direct or indirect adverse impact on the
environment by applying ESMF provisions:
60% of the project in L1 and 80% of the projects in L2 category
have performed satisfactorily
o Satisfactory projects are those which scored marks
between 61% to 74%
Very small (3% in L1 and 11% in L2 category) number of projects were found to have performed poorly in applying ESMF provisions, thereby causing some very low level adverse impact on environment and natural resource
5. Comment on the adequacy of the systems and procedures contained in the latest version of the ESMF (post mid-term environmental audit) and point out scope for further improvement, if any.
Some lack of clarity was found on the approach and process of filling the ESMF formats, especially the section on mitigation measures for Level 1 and Level 2 sub projects and LESA for Level 2 sub projects. There is good scope for bringing more simplicity and clarity in these formats.
The responsibility for all ESMF related processes at the GP and MN level, such as screening and verification, lies with the IOs( usually Assistant Engineers) and approval lies with Block Engineers(usually Assistant Executive Engineers). Same officers are also supposed to ensure compliance and hence an issue of conflict of interest arises many times, which goes against the spirit of fair implementation of ESMF provisions.
There is a need as well as good scope for further improving the ESMF compliance at the GP and Municipality level. However, this may also likely give rise to extra workload for already stretched Implementing Officer.
The important position of IO is on a dual-charge basis at many GPs and MNs, This affects attention of IOs to environmental mitigation measures required for subproject activity, which invariably causes unsatisfactory level of implementation and monitoring of sub projects.
1.3 Audit observations on Compliance to ESMF
Audit appreciably found that KLGSDP was successful in integrating the required Proformas for
environmental & social compliance verification in their regular plan software and imparting
6
information on same through a series of Capacity Building trainings and sensitizing the LBs
through all available platforms through their District Units which helped in largely
“Satisfactory” compliance of ESMF provisions on the whole. Screening of the projects for the
ESMF compliance by PMU and District Units through their regular monitoring and reporting
system is also commendable. However, despite notable capacity building training and
monitoring efforts by PMU, training and monitoring was still found insufficient in sensitizing
all the stakeholder vis-a-vis importance of ESMF document. A questionnaire was developed by
the audit team for the implementing officers (IOs) in the local bodies as the IOs are the
technical personnel in LSGIs dealing with the environment safeguard issues, procedures and
practices. IOs can be Municipal/Assistant Engineers for infrastructure projects excluding the
construction of agriculture related projects or Municipal/Panchayat Secretaries for purchase
projects.
The rationale for arriving at the auditor’s conclusion that ESMF compliance was “satisfactory”
in KLGSDP is explained below:
i) Whether Implementing Officers (IOs) referred to the ESMF document during project
planning stage, notably the screening level compliance documentation
ii) Whether mitigation measures for L1 and L2 category projects were applied by IOs as per
Proforma E and F given on ESMF document
iii) Whether IOs views on feasibility of applying Mitigation measures successfully
iv) Feedback on training programs attended by IOS
Of the 341 IOs included in the scope for EA, 62% responded that respective IOs referred to the
ESMF document for screening as well as for applying mitigation measures according to type of
activity. Above 60% of the IOs were also of the view that application of mitigation measures in
their projects was very much feasible. Above 60% marks achieved in above three categories
clearly suggests that ESMF compliance was “ Satisifactory” in KLGSDP sub projects.
Training frequency, however, was not found fully satisfactory in the opinion of auditor, vis-a
vis capacity building component mentioned in the ESMF Document, since only 35% IOs were
either aware of training programs on ESMF or actually participated in the same. Even though
the reasons for this moderate percentage was attributed to different factors such as frequent
transfers, new recruitments and high work load of IOs, this was found to be an area of
intervention by Government to ensure a sustained capacity building mechanism for further
improvement in this area.
The sections 5.1.1 to 5.1.5 in Chapter 5 of Audit findings provides more explanations and
pictorial representation for these rationale and findings of the auditors.
Statutory compliance requirement were not given adequate attention in the process of ESMF
implementation and audit too could not verify such noncompliance since relevant
documentation was not practiced. Auditors also found that, Mid-Term Environmental Audit
(MT Audit) and its dissemination of findings to the LBs enhanced quality of ESMF
implementation at large.
There are activity-specific observations and sub project wise observations noted by auditors,
and are summarized in the following sections.
7
Activity Specific General Observations
Around 40,000 subprojects have been undertaken with KLGSDP during the project period.
KLGSDP has led to asset creation and better service delivery in all the LBs audited.
The building projects such as modernization or construction of cabins and front offices for
GP/MN offices have rendered the LB offices more receptive and public friendly.
The Proforma E and Proforma G of the ESMF envisages the planning and adoption of solid and
liquid waste management system in all the building projects. Onsite solid waste disposal
system was being followed in some of the Anganwadi projects audited, through the yard
composting of the food waste generated. The absence of compound walls in some of the
Anganwadis audited which were having close proximity to roads, ponds etc have raised safety
and security concerns of the children there.
The use of recycled material in building construction as envisaged by ESMF (mitigation
guidelines) was not being undertaken in the LSGs as the current Public Works Department
(PWD) manual does not have provisions for the same.
Waste was observed to be poorly managed during the construction activity in some of the
ongoing projects. The construction waste such as leftover cement, wood logs, stone, steel rods,
rubble, etc. were not properly disposed of and were still lying around the project site during
audit. Often, there was no provision for waste bins in some of the completed buildings.
Construction of some bridges has provided connectivity to high range people who were
secluded due to the absence of all weather roads.
Conducting road safety audits, provision of sign boards or pedestrian facilities for the entire
stretch of road constructed etc as envisaged in the ESMF are not being practiced in any of the
road projects audited, as mostly these projects are of the nature of upgradation of the existing
roads or retarring of the roads.
Construction of roads without drains, in the water logged areas and construction of drains
without considering the natural slope of the terrain were observed as poor practices in a few
cases.
Sanitation and waste management being pressing issues in Kerala, the initiative by the LSGs
under KLGSDP for solving these issues prove promising. However, a few completed projects
under this category were not functional due to lack of the adequate equipment and machinery
for waste treatment and have rather become a public nuisances under non-compliant
categories of projects as per ESMF provisions (Any activity involving littering and burning of
Municipal Solid Waste in cities, towns and in urban areas is a prohibited activity as per ESMF)
Drinking water projects were found to be highly beneficial in most of the cases by providing
access to piped water supply, except for a few where, the water quality of the water source
itself was not maintained. A project involving new drinking water supply without testing of
water quality to ensure that it is safe for human consumption is a prohibited activity according
to ESMF as well.
Digging of a bore-well for water abstraction without permission of the State Ground Water
Authority in notified areas or in areas classified as Critical / Over Exploited Zones, which is a
prohibited activity as per the EMSF provisions was observed in 3 cases of ET Audit.
8
It was observed that in some cases, sewage is directed towards the storm water drains. There
is also a lack of trappings for silt and waste in stormwater drains, which can lead to stagnation,
mosquito breeding, growth of weeds and over-flow of waste water along the roads.
Sub project specific observations: The sub project-specific observations are summarized in the following paragraphs.
1.4.1. Buildings- Construction, Repair and Expansion
Awarded scores based on the audit observations to the projects coming under this category
clearly indicate that there is a noticeable percentage of projects coming under Green category
having audit scores more than 75 percent. Almost all of them ensured effective service delivery,
but in a few cases, there were buildings with construction completed, but were not in use, due to
the lack of electric or water connection. A total of 713 cases of buildings were surveyed, whereby
the major observations are:
In case of natural resource usage, locally available materials were used in majority of the
projects.
Rain water harvesting integrated in building design was observed only in a very rare number
of cases. Rainwater harvesting should be promoted and implemented to a larger extent, as
Kerala is gifted with abundant monsoon, yet go through dry spells every year.
The recyclable wastes such as paper and plastics from office buildings are usually send to
recyclers, but there were provisions for onsite treatment of biodegradable waste in a very
limited number of instances.
Development and maintenance of greenery in the building premises as envisioned in the ESMF
is practiced in a few buildings
Most of the buildings had system for sewage treatment through septic tank followed by soak
pit.
Provision for health, hygiene & safety was average in completed and as well as in ongoing
projects. Only a very few projects had access to first aid, fire-fighting measures, etc.
1.4.2. Roads/Bridges/Culverts: Construction, Repair and Maintenance
A total of 1126 cases of projects were surveyed and most of the projects revealed a satisfactory way of execution according to the provisions of ESMF. Road and bridges which provide all weather connectivity to high range people/tribals, who are otherwise secluded stands out as classic examples of service delivery. Other observations are summarized below.
Quality of roads was found above average and highly beneficial to the local residents. There is
a scope of improvement in areas like road safety, by provision of sign boards. In majority of the
projects, roadside drains were not constructed due to lack of space.
Though the quality of the project implementation is good, most of the roads are constructed
/maintained for small stretches. There were projects involving the retarring or concreting of
only a 100 m stretch of road, while the rest of the portion in the road remains unmaintained
due to lack proper planning of the funds.
Metalling is not enough for severe monsoon in the region like Kerala, concreting or tarring of
road may be considered in future. If tarring is considered, use of plastic waste along with
bitumen (plastic roads) shall be considered which will help in tackling the plastic waste
management issue as well.
Lack of maintenance has resulted in blockage in some culverts.
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1.4.3. Waiting Sheds, Parking Yards, Bathing Ghats - Construction, Operation and
Maintenance
A total of 39 projects under this category were surveyed – both new constructions and
maintenance. Apparently audit reflects a good deal of satisfaction among locals via-a-vis built
quality of these infrastructure and in terms of service delivery.
1.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid
Wastes, Electronic Waste and Biomedical Waste
The total number of projects audited under this category was 15. The audit observations for this
category of projects is summarized below
Provision of better sanitation facilities for the government schools is creates an enabling
environment which secures children’s dignity, safety, health and attendance in classes.
Maintenance was also properly done for the toilets constructed under KLGSDP funds in
schools, whereas the maintenance of toilets in public places remains unsatisfactory. The toilets
constructed were provided with septic tanks.
E-Toilets, which are self cleaning with very limited water consumption and in built STP,
remain public abandoned projects mainly due to the lack of awareness about their usage
Solid waste management projects lacked the adequate machinery and equipment for
treatment of waste such as shredders, gas collection or flaring systems etc. Mechanisms for
segregation of biodegradable and non-biodegradable waste was absent in all such facilities
audited. Provision of technical support and adequate funds can drastically improve these
projects and can make them model projects in solving the never ending solid waste
management issues Kerala is facing these days.
Subprojects involving the collection and management of electronic waste and biomedical
waste were not observed during the audit. This may be because, the e-waste or biomedical
waste collection in Kerala are done by big players such as the Clean Kerala Company Limited
or IMAGE respectively which are authorized by Central Pollution Control Board (CPCB) for the
management of these types of waste. Management of these wastes by decentralized systems is
still in a nascent stage only.
1.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Waste
Management Installations, Stadiums, Play grounds, Swimming Pools: Construction/
Repair and Maintenance
A total 82 cases of such projects were audited, whereby the major observations are:
The public markets constructed proved to be a boon to the local people in selling their
produce, but in one instance, the market was not functional due to lack of access road.
The LBs have provided waste collection system at some of the markets audited.
First aid and firefighting equipment shall be compulsorily made available in all such projects
Slaughter house projects, burial grounds etc were not undertaken under KLGSDP.
1.4.6. Minor and micro Irrigation and Check Dams - Construction and Maintenance
There were 15 projects audited under this category and it was observed that the projects were
meticulously implemented.
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Canals constructed for irrigation have proved to be real blessing for the small scale farmers in
many regions by providing regular water supply even during summer, whereas the water
source was observed to be inadequate in one of the audited cases.
Periodic desiltation as envisioned in the ESMF was not being done in any of the cases audited,
however, this was not observed to be hampering the performance of the irrigation projects
1.4.7. Drinking water supply- Construction, expansion, operation, maintenance and repair
Drinking water projects were found to be highly beneficial in most of the cases by providing
access to piped water supply, except for a few where, the water quality of the water source itself
was not maintained. A project involving new drinking water supply without testing of water
quality to ensure that it is safe for human consumption is a prohibited activity according to ESMF
as well. Water treatment methods were not adopted for the water sources such as borewells or
ponds. A total of 114 cases were surveyed, findings are listed below:
Water supply scheme projects were implemented successfully and now water is easily
accessible to nearby locals. While doing so, enough attention was not given to water treatment
and water quality testing.
Some of the projects audited were observed to be non-functional due to lack of adequate
quantity of water in the water source.
Water testing is not undertaken in many cases for overall water quality and microbial
contamination.
1.4.8. Storm water Drains- Construction, repair and maintenance
A total of 97 cases of drains were surveyed with following observations:
The drains were mostly constructed with cover slabs, but in some cases there were open
drains constructed in which littering were observed.
Although quality of the construction was found good, there was lack of trappings for silt and
waste in storm drains. Periodic cleaning to remove any sedimented silt/sand/debris shall be
done. Otherwise, the accumulated silt over time will reduce the drain capacity considerably.
But desilting work must be monitored and done from end to end.
In some of the roadside drain projects audited, the slope of the terrain was not given due
consideration in the design of the drain and hence water was not draining to the drains and
rather remaining stagnant on the road itself.
1.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension
These projects mostly included the training centres for agriculture. In two of the cases audited, a marketing centre for agriculture was being used as a fire station.
1.4.10. Meat & Fish Production and Marketing - Repair and Maintenance of facilities
A total of 6 cases of such projects were surveyed. Following are the notable observations:
In the fish markets, there was no treatment facility for disposal of liquid & solid wastes
generated. There was littering in the some fish markets.
Provision for health, hygiene & safety was poor, since site is not regularly cleaned and proper
hygiene is not maintained.
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1.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning
These projects were constructed for small drinking water/irrigation projects. A total of 61
such projects were surveyed in this audit and major observations are outlined here under.
In a few instances. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District,
Ozhukkuneettil Thodu at Kayamkulam MN, Alapuzha District), waste was seen dumped in
nearby water body, ditch etc. causing pollution, mosquito breeding, stagnation etc
Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water
Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified
areas, no individual and/or agency, is expected to undertake any ground water based activity,
which will entail additional ground water draft. In one of these blocks (Chittoor in Palakkad), a
project for renovation and recharge of well was undertaken which can be considered as one of
the best practices.
1.4.12. Electrical & Electronic items - Purchase, Installation, Operation and Maintenance
A total of 212 such projects were audited. These project were found to be beneficial to the LB
officials. The environmental impacts of such projects are very limited during the operation
phase, but after the end of life, such projects are a real threat to the environment as they
become e-waste. E-waste management shall be carefully planned and implemented in the LBs.
1.4.13. Tiny and Small Industries – Establishment and Expansion
Only 8 such projects were surveyed during ET Audit. These projects were mostly meant for
tiny and small scale women centric industries. Most of them are under construction or
construction might have just completed, but the buildings are not yet operational due to lack of
water/electricity connection.
1.4.14. Animal Husbandry and dairy farming-construction and expansion facilities
Two such projects were audited and found satisfactory from ESMF point of view. However, one of the projects was not operational while other one was found lacking in suitable infrastructure.
1.4 Recommendations
It was clear from the audit findings that, the ESMF implementation experience throughout the
project cycle has given a number of learnings and lessons for way forward. KLGSDP was the
first project under Local Self Government Department to implement an operational ESMF
mandatorily and systematically. It is understood that, this was a piloting method for
mainstreaming the ESMF integration in whole LSG system. The lessons learnt will pave the
way for opportunities for further strengthening of the current ESMF. Given below are the key
recommendations:
Design related environmental safeguards built in the sub projects through ESMF need to be
integrated at the sub project planning stage by suitable institutional mechanism, because some
of the design based environmental mitigation measures listed in the ESMF at present become
redundant if not looked at during sub project planning. There is also a need for proper budget
allocation at the time of planning itself for meeting environmental mitigation cost.
In the current system, IOs are looking after most of the ESMF implementation aspects and
block engineers are responsible for verification and supervision of ESMF compliance. This not
only raises conflict of interest issue but also stretches their work load. It is recommended that
there should be a dedicated environmental cum social specialist at block level who could be
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given charge of managing the ESMF verification compliance in association with block
engineers. A State Level Environmental Cell is advised, where the E& S mandatory clearance
procedures could be facilitated and monitored on behalf of LSGIs. This will also bring in more
knowledge base on ESMF issues and help in holistic implementation of ESMF procedures.
IOs are transferred regularly. Newly appointed IO should be able to at least know all the
project sites. This was one of the problems frequently observed by the ET auditors. Frequent
refresher and orientation training is important for IOs.
A capacity building plan was conceptualized and made part of ESMF implementation
framework. Kerala Institute of Local administration(KILA) and State Institute of Rural
Development(SIRD) are the two nodal agencies which have been given mandate for planning
and imparting training under local government projects . However, both the agencies could not
deliver on training needs of the KLGSDP project owing to their inherent internal issues,
especially lack of faculty on the expected training areas. It is recommended that these agencies
should have a provision for hiring faculties from outside, if required and compulsorily
complete the training mandate given to them under LSG projects since training goes a long
way in successful implementation of ESMF provisions.
Effective Monitoring is an important aspect of long term success of environmental safeguard.
Current ESMF has a robust monitoring process in place and it is suggested that existing
monitoring procedures should be complied diligently without any dilution.
Elected LB members should also be sensitized to promote their involvement in ESMF
screening and compliance process. Elected members should also try to involve local
community through awareness generation so as to promote ownership towards the assets
created and their maintenance, through citizen-centric information, education and
communication (IEC) campaign.
ESMF formats have been simplified in the new version of ESMF. There is still scope for further
simplification and trimming of ESMF formats which could help in better compliance of ESMF
provisions.
Mitigation measures, identified at initial stage and implemented subsequently, should be
documented. The compliance must be recorded with photographic evidence. Further,
provision for photographic evidence at various stages of project implementation should be
kept for a systematic recording and follow –up of activities undertaken in environmentally safe
manner at GP and MN level.
Monitoring of ESMF activities should also be integrated with other monitoring activities
through MIS.
Requirement of permissions and NOCs towards the concerned project (e.g. land acquisition,
NA certificate, NOC etc.) should be acquired by IOs in advance. Proper procedure needs to be
followed in such circumstances and records must be maintained.
Project files along with all the documents should also be stored in soft copy, so that, in case of
hardcopy of the file being misplaced, it will be easier to regenerate the file.
In case of execution of sub projects falling under prohibited/restricted activities as per
proforma A of ESMF document, permission from appropriate authority should be compulsorily
obtained and properly documented. There were cases found during audit where Implementing
Officers are unaware of such stipulations. As an example, maximum of 5 HP pump is permitted
for ground water extraction as per the earlier version of ESMF, however, pumps up to 20 HP
were found during audit in certain Local Bodies.
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ESMF provisions and stipulated mitigation measures for various type of subprojects must be
made part of the tender and contract awarding procedures for the contractors to make the
Projects ESMF compliant.
Apart from the policy level recommendations and suggestions mentioned above, some of the
activity-specific recommendations are also summarised below:
Photographs of the project site before, during and after completion of the project should be
kept in the records.
There should be regular inspection of the project, especially before and after the monsoon
season. During auditing, issues like cracks, leakage, etc. were observed in some buildings,
roads, drains etc. In many cases, projects were incomplete, resulting in deterioration of
unfinished project.
There is a need to focus on an integrated solid waste management approach for the LBs.
Although the provision for SWM exists in the project, it has not been taken up yet at most
places.
Environment-friendly activities such as installation of solar lights, plantation drives etc should
be promoted.
More plantation measures need to be taken up by the LBs for prevention of soil erosion.
For projects related to water, quality of water must be checked periodically (for drinking
water, at least once a week and for other uses, once a month) and classify as per Central
Pollution Control Board norms and inform beneficiaries accordingly.
Wherever applicable, silt traps should be provided to trap silt. Such traps will not allow silt to
flow in drains, thereby occupying useful volume. This will reduce de- silting requirements.
Ground water abstraction should be avoided for the project work, wherever possible. The
height of guard walls for the ponds should be higher than the ground level.
There should be provision for non-conventional energy sources (solar and biogas), energy
efficient electric fixtures (LED lights, energy star rated devices etc.), rain water harvesting and
recycling of waste. Wastage of paper, water, electricity, etc. should be minimized in offices. Use
of materials like wood, glass and agricultural soil should be minimized, while asbestos must be
prohibited for regular use.
When roofing sheets are laid for buildings, transparent sheets, which can act as skylights can
be provided.
Buildings must have suitable fire-fighting measures installed, and staff should be trained to use
fire extinguishers and these should be checked regularly towards working condition and
expiry date.
The Anganwadi projects are mostly constructed in small land parcels obtained through land
donation. Hence provision of open space as play area for children is lacking in most of the
projects audited. If possible, a nearby alternate open space as play area shall also be identified
for the children
Regular maintenance is required for tarred roads because of wear or deterioration and hence
fund allocation in the project planning stage should consider this aspect. When retarring is
being done, use of plastic waste along with bitumen (plastic roads) shall be considered, which
will improve the longevity of the roads.
Concrete roads require lesser maintenance compared to tarred roads and hence can be
preferred in water logged areas depending on the budget
The wastewater should not be discharged in the water bodies and be treated properly as per
the existing rules.
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The streetlights (tube lights), after end of life become hazardous waste. This shall be disposed
off through authorized hazardous waste recyclers. Similarly, the waste oil/lube oil from the
diesel generator is a hazardous waste. Care must be taken to store it separately in drums etc
and dispose it through Kerala Pollution Control Board approved vendors.
E-waste management shall be carefully planned. Clean Kerala Company Limited collects e-
waste in bulk. Hence any e-waste generated can be stored separately and shall be handed over
to them.
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Chapter 2: End of Term Environmental Audit for KLGSDP
This chapter gives a brief overview of the Kerala Local Government Service Delivery Project (KLGSDP), and the need for conducting an End of Term Environmental Audit (ET Audit). The objective and scope of the ET Audit are also detailed here.
2.1 Background
Since independence, Kerala has been leading the way in decentralized local governance in the
country. After the new Panchayati Raj Act came into force in 1994, the State has moved at good
pace in transferring functions, responsibilities, authority and finances to Local Governments.
Government of Kerala also realized that strengthening of Local Governments can play an
instrumental role in delivering effective governance, building useful public infrastructure,
responsive public services and effective poverty alleviation efforts. In order to further boost
local service delivery projects, The Government of Kerala, in partnership with The World Bank
conceived the Kerala Local Government Service Delivery Project (KLGSDP).The project strived
to raise the level of service deliveries of Local Self Government Institutions (LSGIs) using
modern tools of planning, development, project implementation and transparency in
administration. Direct beneficiaries of the project are the 978 GPs and 60 Municipalities in the
State of Kerala as per the project implementation manual(PIM)(after delimitation in 2016,the
number of GPs are 941 and MNs are 87).
Several interventions proposed in this project consisted of (a) an annual, performance-based
untied grant to all GPs and Municipalities in Kerala to be spent on creation and / or
maintenance of capital assets used in service delivery; (b) capacity building inputs to
strengthen and supplement the existing systems and human resource of Municipalities and
GPs to enhance their institutional performance; (c) support for strengthening the system of
performance monitoring of GPs and Municipalities; and(d) support for a Project Management
Unit (PMU) that would handle overall coordination, implementation, monitoring and
evaluation of the project.
2.2 Environmental and Social Management Framework (ESMF)
It is mandatory requirement under World Bank appraisal procedures to undertake
environmental and social assessment of projects. Community driven development projects
such as the KLGSDP having several sub projects of various nature and widely spread in the
state required environmental and social assessment within an Environmental and Social
Management Framework (ESMF), which identifies possible impacts on various environmental
and social aspects and suggests ways to prevent and or mitigate them. Accordingly, an ESMF
was prepared for the KLGSDP, which describes specific safeguard measures to be undertaken
at various stages of the project planning and implementation process – formulation, approval,
implementation & post-implementation.
Application of the ESMF has been closely monitored and evaluated during the project period.
The responsibility for application of the ESMF rests with the Environment Specialist in the
PMU set up at the state level. For ensuring compliance of ESMF, capacity building of different
project stakeholders has been undertaken. Adherence to ESMF has been monitored on a
regular basis by the PMU through District Units. The MT Audit was conducted to assess the
extent of compliance to the ESMF achieved midway through the project implementation phase.
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The MT Audit suggested specific revisions and modifications in the existing screening
procedures that could significantly improve its effectiveness. Suggested revisions have since
been incorporated and the revised document finalized. The revised ESMF document has been
published in the LSGD website and KLGSDP website for ready reference of LSG functionaries as
well as the public and other stakeholders.
2.3 E&S Clearance Toolkit of the ESMF and the stages of application in project implementation
The ESMF presents certain screening tools and guidelines which were developed for use of
concerned LB functionaries / officials for according Environmental and Social Clearance to
proposed activities and subsequently verifying compliances. This is referred to as the E&S
Clearance toolkit of the ESMF. This includes the following
1. The Regulatory List Screening Tool (Proforma A)
2. The Control List Screening Tool (Proforma B)
3. E&S Clearance and Compliance Format for GPs (Proforma C)
4. E&S Clearance and Compliance Format for Municipalities (Proforma D)
5. E&S Mitigation Guidelines for Level-1 activities (Proforma E)
6. Format for Conduction of LESA for Level-2 activities (Proforma F)
7. E&S Mitigation Guidelines for Level-2 activities (Proforma G)
8. Social Screening Compliance Format for Subprojects involving Land Acquisition
(Proforma H)
The ‘Regulatory List’ has been prepared for use in the first stage of screening and is intended
for weeding out activities that are prohibited by prevailing applicable regulations or allowed in
only very special circumstances. The second stage of screening known as the ‘Control List’ is
meant for proposals which have cleared the first stage. The Control List consists of two
separate components: that of activities classified as Level 1 and that of activities classified as
Level 2. Level 1 activities are expected to have relatively low magnitude E&S impacts while
Level 2 activities could lead to slightly higher, i.e., medium level E&S impacts. The mitigation
measures for Level 1 activities are given in Proforma E and the mitigation measures for Level 2
activities are given in Proforma G.
2.4 Institutional Framework for EMSF implementation
The actual implementation of the ESMF is to be affected through the existing organizational
structure in the LSG system. The few marginal changes that have been made have more to do
with providing facilitation and mentoring support as well capacity building. Overall
coordination and monitoring support will be provided through the Project Management Unit
(PMU). The Environment and Social Management Specialist of PMU has the mandate is to
ensure correct and effective implementation of the ESMF.
Table 2.1: Institutional Structure for ESMF Implementation for GPs
Institution Current roles in development planning
Responsibilities with respect to EMF
KLGSDP State PMU having 1 Environmental and Social Expert (On institutionalization at later stage, for ESMF to be made applicable to all LB activities,
Project Implementation Overall Management Monitoring Reporting and
Provide technical support to development of capacity
building modules Coordinate Capacity building
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this would appropriately be replaced with designated Environmental Engineer/Environmental Specialist placed at Block/District level
documentation activities on ESMF Institutionalize ESMF
process Ensure correct
implementation of ESMF Review & update ESMF
procedures, if required Compile annual report on
ESMF implementation and compliance with highlights of environmental gains
Ward/Grama Sabha Conceive & raise the local needs & issues
Review earlier development pursuits.
Prioritizes subproject proposals
Raise E&S issues with respect to proposed project, if any
Working Group Prepares project proposals
based on inputs from Ward/Grama Sabha
Prepares DPR
Raise E&S issues with respect to proposed project, if any
Undertakes screening and mitigation plan preparation
GP Committee Conducts Development
Seminar and prepares final subproject plan
Cross-verifies ESMF
implementation
GP Engineer /Implementation Officer
Oversees all technical work and works execution
Provides technical guidance to GP
Prepares DPRs
Prepares DPR Screens project and prepares
mitigation plan Forwards DPR to GP
Committee for onward processing
Oversees and supervises work in progress including
ESMF compliance and manages contractors
Verifies ESMF compliance Block Level Officer in the next higher tier of Implementing Officer
Ensures compliance to mandatory guidelines
Ensures compliance to technical guidelines and ESMF
Verifies costing & phasing of projects
Suggests innovation & integration possibilities
Sub-group Gives technical sanction to projects
Ensures ESMF compliance Examines the accuracy of
impact assessment & adequacy of mitigation measures
Addresses inter-sectoral environmental conflicts, if any
Recommend E&S clearance to the project
Extend support as resource persons for capacity building on ESMF
District Planning Committee (DPC)
Project approval Plan integration
Issue E&S clearance along with Project approval
Conduct annual review Suggest modifications, if any,
in EMP
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Table 2.2: Institutional Structure for ESMF Implementation for MNs
Institution Current roles in development planning
Responsibilities with respect to EMF
KLGSDP State PMU having 1 Environmental and Social Expert (On institutionalization at later stage, for ESMF to be made applicable to all LB activities, this would appropriately be replaced with designated Environmental Engineer/Environmental Specialist placed at Block/District level
Project Implementation Overall Management Monitoring Reporting and
documentation
Provide technical support to development of capacity
building modules Coordinate Capacity building
activities on ESMF Institutionalize ESMF
process Ensure correct
implementation of ESMF Review & update ESMF
procedures, if required Compile annual report on
ESMF implementation and compliance with highlights of environmental gains
Ward Sabha Conceive & raise the local needs & issues
Review earlier development pursuits.
Prioritizes subproject proposals
Raise E&S issues with respect to proposed project, if any
Ward Committee Prepares project proposals
based on inputs from Ward Raise E&S issues with
respect to proposed project, if any
Standing Committee Conducts Development
Seminar and prepares final subproject plan
Cross-verifies ESMF
implementation
Municipal Council Conducts Development
Seminar and prepares final subproject plan
Cross-verifies ESMF
implementation
Municipal Engineer /Implementation Officer
Ensures compliance to mandatory guidelines
Ensures compliance to technical guidelines and ESMF
Verifies costing & phasing of projects
Suggests innovation & integration possibilities
Sub-group gives technical sanction to projects
Ensures ESMF compliance Examines the accuracy of
impact assessment & adequacy of mitigation measures
Addresses inter-sectoral environmental conflicts, if any
Recommend E&S clearance to the project
Extend support as resource persons for capacity building on ESMF
Assistant Executive Engineer/ Executive Engineer / Chief Engineer
Oversees all technical work and works execution
Provides technical guidance to the SC/MC/DPC
Prepares DPRs
Prepares DPR including mitigation plan if applicable
Forwards DPR to Standing Committee for onward processing
Oversees and supervises work in progress including ESMF compliance and manages contractors
Verifies ESMF compliance District Planning Committee (DPC)
Project approval Plan integration
Issue E&S clearance along with Project approval
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Conduct annual review with respect to environmental gains, in general, District level ESMF Compliance Report, in particular
Suggest modifications, if any, in EMP
2.5 Revisions in ESMF after the Mid Term Audit
The E&S Clearance toolkit of ESMF developed at the commencement of KLGSDP
implementation, especially the Control List (Proforma B of ESMF) was thoroughly revised
following the recommendations from the Mid Term Environmental Audit. Revisions were done
in the regulatory list (Proforma A) and the control list (Proforma B) and 2 new formats,
Proforma G and Proforma H were added. There was a revision in the institutional framework
also. The duties of Block Engineer and Technical Advisory Group were merged and given to the
block Engineer.
The major revisions done in the regulatory list (Proforma A) of the ESMF are as follows:
As per the earlier version: “Any subproject involving construction within 200 meter to
historical monuments and within 100 meter to railways, highways, etc was a prohibited
activity”. In the modified version, this was changed to “Any subproject involving
construction adjacent to historical monuments, railways, highways etc. infringing the
distance prescribed by the Town Planning Department of Government of Kerala” is a
prohibited activity
As per the earlier version: “Activities involving abstraction of water from a water course by
a mechanical device of more than five horse power” is a prohibited activity. In the modified
version, this has become, “Abstraction and pumping should be restricted to the safe yield
of the source of water as per the certification of the Ground Water” is a prohibited activity
As per the earlier version: “Any construction activity involving locating of the leach pit,
soak pit, earth closet or septic tank within a distance of 7.5 m radius from existing well or
1.2 m from the plot boundary is a prohibited activity, whereas in the new version: “Any
construction activity involving locating of the leach pit, soak pit, earth closet or septic tank
as per the existing guidelines of Kerala Municipal Building Rule (KMBR) & Kerala
Panchayat Building Rule (KPBR)” is a prohibited activity.
The major revisions in the Control List are outlined below
All the building construction projects, irrespective of whether new construction or
repair/maintenance was considered as Level 1 in the earlier version of ESMF. Considering
even the new constructions as Level 1, led to lower levels of implementation of mitigation
measures. In the modified version of ESMF, all the new constructions were categorized as
Level 2, requiring LESA (Limited Environmental and Social Appraisal, as per Proforma F of
ESMF) and all the repair maintenance of building projects are categorized as Level 1.
All the road construction projects, irrespective of whether new construction or
repair/maintenance was considered as Level 2 in the earlier version of ESMF. Considering
even the repair/maintenance as Level 2, led to the requirement of doing LESA for
appraisal. This resulted in lengthier documentation process for even small maintenance
works. This was revised in the modified version of ESMF. Only new roads were considered
as Level 2 in the new version.
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Similar revisions in re-categorization for better clarity were applied to the projects related
to (1) ponds/tanks/wells/canals, (2)irrigation channels (3) storm water drains and
(4)drinking water supply projects
Health Institutions: management of sanitation and hygiene: this category was removed and
biomedical waste was included under the sanitation and waste management projects in
the new version of ESMF.
A new category, Public Markets, Crematoriums, Burial Grounds, Public Toilets, Slaughter
Houses, Waste Management Installations, Stadiums, Play grounds, Swimming Pools –
Operation added.
A new format for the mitigation measures for Level 2 activities (Proforma G) was incorporated.
A new format for Social Screening Compliance for Subprojects involving Land Acquisition
(Proforma H) was incorporated in the modified version of ESMF.
2.6 Objectives of Environmental Audit
The Project is expected to end by June, 2017. At this juncture, End of Term Environment Audit
(ET Audit) has been conducted to assess and determine the extent of success achieved in
applying the ESMF, thereby suitably preventing / mitigating any likely adverse impacts on the
environment infrastructure created / other expenses made using the performance grant
during the project implementation period.
ET audit has been conducted with following specific objectives:
Determination of the extent of compliance to the ESMF achieved over the project period and
identify non-compliances, if any, with respect to applicable national / state / local regulations
Determination of how effectively the systems and procedures defined in the latest version of
the ESMF have been applied by the project implementation team and identify deficiencies
therein, if any. Also determine the extent of improvement achieved, if any, after modifications
suggested by the mid-term environmental audit had been incorporated
Determination of the extent to which possible direct or indirect adverse impacts to various
constituents of the environment such as human lives, property and nature, as a consequence of
project related activities, have been avoided, prevented or mitigated
Comment on the adequacy of the systems and procedures contained in the latest version of the
ESMF (post MT Audit) for suitably managing all possible environmental impacts in context of
all sub-projects undertaken by the local bodies in the project and point out scope for further
improvement, if any.
2.7 Scope of Work
The scope of the ET Audit included all sub-projects implemented under the KLGSDP, including
the projects coming under the onetime assistance to backward LBs. Compliance requirement
laid out in all relevant legal documents pertaining to this project were required to be assessed.
Scope of the audit assignment involved discussions at length with all officials / staff involved in
project implementation including officials from the PMU, Project staff at the district level,
relevant government officials at state and district levels and respective line department staff.
Findings, observations and recommendations of the MT Audit were to be revisited during ET
audit.
Some of the major aspects that the audit exercise dwelt upon are summarized below:
21
Assessment of strengths and weakness of internal controls which shall include but not limited
to awareness, knowledge and competence of personnel (including elected members)in LSGs on
environment safeguard issues, procedures and practices, maintenance of appropriate
documentation/records pertaining to testing, other technical analysis, conclusions based on
site conditions, reports on inspection and maintenance programs practiced, definition
Strengths / weaknesses of capacity building activities on environment;
Usefulness of including environmental performance in the Annual Performance Assessment
(APA) criteria
Effectiveness and correctness of screening procedure (including LESA, if applicable) deployed
Correctness or aptness of the mitigation measures recommended. Deficiencies, if any, in
screening or mitigation planning.
Correctness of implementation of compliance verification procedures
Documentation of (including photographic evidence) of good and bad practices
Issues on health and safety aspects.
Knowledge, capacity and skill levels of concerned LSG functionaries, officials and technical
personnel with respect to ESMF
Effectiveness of the monitoring, reporting and feedback system between the Local Self
Government Institutions and the PMU with respect to ESMF
Recommendations on strengthening the implementation of environmental and social
safeguards
Recommendations on improving effectiveness of ESMF and its implementation for future LSGD
activities.
The approach for the study was to undertake a situation analysis of the environmental practice
on a sample basis. Based on the audit of present situation, audit team examined the existing
practices for ensuring environmental safeguards and has recommended measures to be
included in the present framework and operational guidelines for ESMF. The next chapters
describe the approach and methodology for the environmental audit study in detail.
22
Chapter 3: Methodology
This chapter presents the approach followed for the ET Audit. The detailed methodology along with
the data analysis plan and measures for quality control and management are depicted in this chapter
3.1 Study Approach
The ET Audit of the KLGSDP was based on the Logical Framework Approach consisting of
survey tools, sample design, survey design and field survey with over all purpose of satisfying
audit objective in robust manner. The boundary of ET audit or inclusions was defined in line
with the scope of work as discussed in the previous chapter.
3.2 Audit Design
A dual, Quantitative and Qualitative based audit design was adopted for the ET Audit. The
specific objectives of the audit clearly sought out the need for collection and collation of
data/information at different levels to gauge effectiveness as well as efficiency of various
processes of implementation of Environmental and Social Management Framework (ESMF)
developed for the KLGSDP.
3.3 Sampling Design
The sample design and distribution adopted along with the sampling methodology was
discussed and agreed upon, in consultation with the KLGSDP officials. Audit team referred the
project MIS data of KLGSDP, considering detailed criteria to identify the representative sample
of districts, sub divisions, GPs and MNs for this assignment.
Environmental audit was conducted within overall sample size of 2500 sub project, which
included 15% of the completed projects from the years 2014-15, 15% from the year 2015-16,
15% from backward support projects, 15% from midterm audited projects and remaining
15% from 2016-17 projects. In terms of GPs and MNs, audit covered a sample of 34% of the
941 GPs i.e. 321 GPs and 34 % of the 87 MNs i.e. 30 MNs, covering all the 14 districts of Kerala.
Each district was given fair representation in the audit by means of an index calculated for
each district depending on (a) the number of GPs in the district (b) number of MNs in the
district (c) population density of the district (d) ranking of the district in the 1st Grant Cycle
and 2nd Grant Cycle, based on the MT Audit. The LB-SUs in each district were selected
randomly based on above mentioned index, at the same time; purposive sampling too was
adopted to select some LBSUs in each district to satisfy two other significant criteria. The first
criterion was to ensure that the best performed as well as the worst performed LB-SUs in all
the districts during MT audit are represented in the ET audit as well. In this regard, three LB-
SUs with the highest and lowest ranking each were selected for ET Audit. The second criterion
was to ensure a fair representation of the economically weaker and marginalized communities
such as the fishermen communities or economically weaker purely agronomic areas or very
low income areas, minority and marginalized communities such as Scheduled castes and
Scheduled tribes and regions with language minorities.
23
3.4 Local Body Sampling Units (LB-SUs)
The Local Body Sampling Units (LB-SUs) refer to the specific place or location which can be
used for the sampling process. The LB-SUs are selected from the sampling frame. Hence the
LB-SUs are selected from the 941 GPs and 87 MNs.
Selection of LB-SUs
For the identification of number of LB-SUs, stratified sampling is adopted. In stratified
sampling, members of the sample are selected proportionally from each stratum. All the strata
should be mutually exclusive also. In this EA, the 14 districts of Kerala represent 14 different
strata. This method of sampling improves the representativeness of the sample by reducing
sampling error. Comparison between findings of the ET audit and the MT audit is an essential
objective of the ET audit. Accordingly, for the selection of LB-SUs the results of MT audit were
utilized.
The LB-SUs (GP/MN) from each district is selected proportional to the aspects mentioned
below.
Number of GPs in the district
Number of MNs in the district
Population density of the district (Obtained from 2011 Census data)
Ranking of the district in MT audit for the 1st Grant Cycle of KLGSDP
Ranking of the district in MT audit for the 2nd Grant Cycle of KLGSDP
All the above criteria are given equal weightage. The details regarding the GPs/MNs for the
districts were obtained from the website of Government of Kerala, Local Self Government
Department. The population density is obtained from the Census 2011 data. The ranking for
the MT audit was obtained from the MT audit report.
The Index of each district for the above five criteria are determined, based on following
formula:
SCategory =
Number of entities in the given district belonging to the given category
Maximum number of entities in the given category in a district of Kerala
State
For .e g., Index for Trivandrum is obtained as follows.
Number of GPs in Trivandrum = 73 GP s
Maximum number of GPs in Kerala State is in Malappuram district, 94 GPs
Therefore, Index for Trivandrum for first criteria = 73/94 = 0.78
Indices are calculated for all above five criteria, where each criterion has been given same
weightage.
Further criteria for selection of LB-SU and selection of activities, etc have been elaborated in
detail in Voume-II document as part of this report
3.5 Detailed Survey Methodology
The ET Audit of GPs and MNs followed following steps for undertaking field surveys:
Step 1: Scoping and Boundary setting:
In terms of Audit scope, the study covered all sub-projects implemented under the KLGSDP,
including community infrastructure / fixed assets created and other activities undertaken
using Performance Grant and Onetime assistance to backward Local Bodies. Study Boundary of
the audit included direct as well as indirect beneficiaries of the project and both individual as
24
well as cumulative impacts and their mitigation. Compliance requirements laid out in all
relevant legal documents pertaining to this project were thoroughly analysed such as the
Contract Agreement with the World Bank, the PAD, the PIM, the ESMF and other applicable
National, State and Local regulations. The Framework for the Environmental Audit was
presented to the client and finalised in consultation with the client.
Step 2: Meeting officials and Desk Review:
In order to understand their perspective of implementing environment management in
projects, all officials / staff involved in project implementation including officials from the
PMU, Project staff at the district level, relevant Government officials at state and district levels
and respective line department staff were visited by audit tem from time to time during audit
process.
Further, In order to familiarize themselves with project objectives, procedures and
implementation framework, the audit team carried out a detailed and thorough review of
relevant KLGSDP documents and other relevant documents pertaining to assessment of ESMF
implementation such as PAD, ISDS, ESMF, MTR report, Mid-term Environmental Audit report,
screening documentation, progress reports and ACRs. Further, the team also identified
additional secondary data sources and literature useful in the context of the proposed study
and reviewed the same. The team conducted an exhaustive review if the monitoring data as
well as filled environmental and social review formats related to KLGSDP sub projects..
Following the review of relevant secondary documents, a list of indicators and guiding
questions was developed focusing on the specific objective of Environmental Audit, which led
to the design of various study instruments. A distinct set of indicators and guiding questions
were developed for each of the environmental concerns identified for review, followed by
development of distinct sets of study instruments for each of the identified process. These
study instruments are discussed in Volume-II document of this report
Also, while conducting desk reviews, the study team sought to identify key / critical areas,
capacity needs, institutional aspects and building blocks for the environmental concerns and
implementation, as per the environmental safeguards. The study team also sought to identify
any areas for adaptation or modification, thereby enabling the project management to learn
how to better shape and implement the environment aspect related to various activities.
Step 3: Designing Study instruments (Qualitative and Quantitative)
The study team designed data/information collection questionnaire for both qualitative as
well as quantitative data collection. The survey questions were largely open ended, focused on
determining the environment aspect of whole project activities, especially around ESMF
provisions. Survey tools targeted a representative sample of the direct beneficiaries as well as
other key stakeholders. All tools were used in English language.
Based on past experience in the area of environmental audits, quantitative data collection was
set up to form the main-stay of this study, and was ably supported by qualitative data (as
required to substantiate tracking events and targets). A participatory approach was adopted
for qualitative data collection. The qualitative data was collected through Focus group
discussions (FGDs), Shared learning dialogues (SLDs), In-depth interviews and In-depth
discussions with various stakeholders. Volume –II appended with this report explains more on
this aspect.
25
Step 4: Field Visits
The audit team undertook field visits to all the selected districts under the project, as per the
sampling design proposed and finalized in consultation with the KLGSDP for specific site-
based assessments. The field visits focused on collection of specific data to facilitate the
determination of environment status, extent and impact of the various project activities under
review as well as undertaking discussions with the relevant stakeholders.
Field Visit Guide
A field visit guide was developed to maintain consistency in all the field visits and to collect
data in a structured manner. Based on the desk review and stakeholder consultation, activity-
wise survey instruments (based on ESMF) were prepared to facilitate the experts to focus on
the key information and collect data in an effective and efficient manner.
Based on the finalized methodology and instruments, audit team visited each of the LBs
selected through robust sampling for ensuring quality. The activities included the following
tasks as per the RFP:
Comparison between findings of this audit and the earlier one
Assessment of strengths and weakness of internal controls which shall include but not limited
to awareness, knowledge and competence of personnel (including elected members)in LSGs on
environment safeguard issues, procedures and practices, maintenance of appropriate
documentation/records pertaining to testing, other technical analysis, conclusions based on
site conditions, reports on inspection and maintenance programs practiced, definition
Strengths / weaknesses of capacity building activities on environment;
Usefulness of including environmental performance in the Annual Performance Assessment
criteria
Effectiveness and correctness of screening procedure (including LESA, if applicable) deployed
Correctness or aptness of the mitigation measures recommended. Deficiencies, if any, in
screening or mitigation planning.
Correctness of implementation of compliance verification procedures
Documentation of (including photographic evidence) of good and bad practices
Issues on health and safety aspects.
Knowledge, capacity and skill levels of concerned LSG functionaries, officials and technical
personnel with respect to ESMF
Effectiveness of the monitoring, reporting and feedback system between the Local Self
Government Institutions and the PMU with respect to ESMF Recommendations on
strengthening the implementation of environmental and social safeguards
Recommendations on improving effectiveness of ESMF and its implementation for future LSGD
activities.
Step 5: Success Stories Framework
Success stories were documented to showcase and highlight a very positive experience of a
particular environment focused execution that is worth narrating. By nature, these case
studies are very short.
Step 6: Workshop for sharing draft findings and Report Finalization
The outcome of this audit report was presented through a state-level audit finding
dissemination workshop, held at Trivandrum on June 28th 2017, to discuss the draft findings of
the ET Audit and receive feedback on the same from a wide variety of stakeholders. The Audit
26
team has gathered and incorporated all the relevant comments and feedback into the final
report.
3.6 Training of field staff for Environmental Audit
Selection of Audit Personnel
The ULTRA-TECH team selected and engaged experienced personnel as field auditors for the
ET Audit. The field auditors were able to undertake data collection and interviews. Also,
selected personnel had experience of interacting with elected representatives and employees
at the GP and MN level. They were skilled at building rapport and experienced at gathering and
interpretation of quantitative and qualitative data. Training programme for the field auditors
was organized. Training was planned and organized prior to commencement of the audit at the
field level.
Training of field staff
The field auditors underwent a training program (both qualitative and quantitative study
instruments) of two days (April 11 and April 12th/17th , 2017), which included one day
classroom training and one day field training in four batches on April 12 and 17. The training
also included practice fieldwork and write-ups. In addition, the teams were made clear about
the schedule for the field work, who will be responsible for which parts of the field work, and
other such aspects.
3.7 Data Analysis Plan
After the survey instruments were finalised, a data entry format was prepared in MS Excel. The
data collected from the field was entered using this format, on which analysis was undertaken.
Data analysis was conducted and presented activity-wise, followed by an overarching analysis
of the entire project and feedback on the modifications or additions required in KLGSDP
implementation from the environmental perspective.
3.8 Quality Control and Management
Quality control protocols were followed as per standard practices for both qualitative and quantitative survey in the audit. During the mid of field auditing, a review meeting was organized by KLGSDP with the field auditors to review the progress of the audit and also to take recourse measures for the field level issues experienced during the audit.
27
Chapter 4: Field Training
This chapter describes briefly the process followed for the field survey. The same has been explained in
detail in Volume-II document of this report in form of Annexure-2.
4.1 Training for Field Auditors A two-day training programme for the Environmental Audit field team was conducted, as per
the following schedule, which included one day class room training and one day field
training. The field trainings were conducted zone wise, details of which are tabulated in
Table 4.1.
Table 4.1: Details of training for the Field Auditors
Day 1 April 11, 2017 Class-room training at Thrissur District
Day 2
April 12, 2017 Field level training at Kottuvally GP in Ernakulam District for the Field Auditors from Ernakulam, Idukki and Kottayam Districts
April 18, 2017 Field level training at Wadakkanchery MN in Thrissur District for the Field Auditors from Malappuram, Palakkad and Thrissur
April 18, 2017 Field level training at Dharmadom GP in Kannur District for the Field Auditors from Kannur, Kasaragod, Wayanad and Kozhikode Districts
April 18, 2017 Field level training at Chavara GP in Kollam District for the Field Auditors from Alapuzha, Pathanamthitta, Kollam and Trivandrum Districts
The field trainings of sub project specific questionnaires were conducted in four local bodies
coming under four different zones. Details of the same is summarised in Table 4.2.
Table 4.2: Subprojects covered during the field training of the Auditors
S No District GP Sub Projects Covered
1 Ernakulam Kottuvally
Road metalling and tarring Building Maintenance and Repair
2
Kannur
Dharmadom
Drainage construction Drainage maintenance and repair Construction of footpath Road tarring Building Maintenance and Repair
3 Thrissur Wadakkanchery
Maintenance of solid waste treatment plant Drinking water project Computerization
4 Kollam Chavara
Drainage construction Building Construction E Toilet Foot path concrete
28
4.2 Sample Coverage by Field Survey The field survey for this study was undertaken at GP and MN level, with a review of a variety
of activities implemented under the KLGSDP project. Sector specific questionnaires were
used for the field data collection. Details of the survey are provided in the following
paragraphs. The questionnaires developed for each of the sub projects are appended as
Annexure 2 in Volume- II.
The actual field survey for the ET Audit was undertaken from 12th April 2017 to 1st June
2017.
As per the sample distribution provided in the previous chapter, the field survey was carried
out in all 14 districts of KLGSDP implementation. In each of the districts, minimum 15 LBs
were sampled (proportionate to the total no. of local bodies in the district, its population
density, its ranking in the 1st Grant Cycle and 2nd Grant Cycle in the MT audit), in which 6
LBs (3 highest ranking and 3 lowest ranking LBs as per the MT audit) sampled were from the
list of LBs covered under the MT Audit in 2013-14. Further, in each LB, at least five sub
projects were sampled.
In each of the sample LBs, discussions were held with the elected members of LB, employed
members of LB, the District Co-ordinators of KLGSDP and the immediate beneficiaries of the
sub projects, ie the local community, etc., along with site visits to all the sampled activities.
Further details with photographic presentation are explained in Annexure-2 of Volume-II
document as part of this ET audit report.
4.3 Stakeholder Consultations
As part of the environmental audit of KLGSDP supported Sub Projects implementation, a
wide variety of stakeholder consultations were key to forming an opinion on the audit
process and field level audit findings. Several stakeholders were consulted at various levels
to gather information regarding sub projects. At the state level, policy level discussions were
held with the KLGSDP officials and at the district, GP and MN level, sub project related
discussions were held with a number of other stakeholders viz district coordinators of
KLGSDP, implementing officers, elected representatives and the public. Final audit report
was prepared based on field observation and input from the state and district level
stakeholder consultations. The outcome of this audit report was presented through a state-
level audit finding dissemination workshop, held at Trivandrum, to discuss the draft findings
of the environmental audit study and receive feedback on the same from a wide variety of
stakeholders.
29
Chapter 5: Audit Observations [
This chapter covers the audit observations including the awareness of the Implementing Officers on the various aspects in ESMF along with the field level observations for the 14 different categories of subprojects implemented under KLGSDP spread across the 14 districts of Kerala. The observations are detailed subproject wise.
5.1 Findings on ESMF Documentation and Implementation
The prime objectives of the ET Environmental Audit are associated with the implementation
aspects including the adequacy of knowledge levels of the implementing officers with respect
to ESMF and how are they getting equipped (capacity building) for better implementation of
the ESMF guidelines. These objectives of the EA are depicted below:
Assessment of strengths and weakness of internal controls which shall include but not limited
to awareness, knowledge and competence of personnel (including elected members)in LSGs on
environment safeguard issues, procedures and practices, maintenance of appropriate
documentation/records pertaining to testing, other technical analysis, conclusions based on
site conditions, reports on inspection and maintenance programs practiced.
Assessment of the strengths / weaknesses of capacity building activities on environment.
Evaluation of the correctness or aptness of the mitigation measures recommended and to
identify, the deficiencies, if any, in screening or mitigation planning.
Evaluation of the knowledge, capacity and skill levels of concerned LSG functionaries, officials
and technical personnel with respect to ESMF.
Towards achieving these four prime objectives, a questionnaire was developed for the
implementing officers (IOs) in the local bodies as the IOs are the technical personnel in LSGIs
dealing with the environment safeguard issues, procedures and practices. Maintenance of
appropriate documentation is the responsibility of the IOs. The capacity building activities are
aimed at the IOs mostly. The IOs are the ones responsible for the implementation of the
projects as well as the planning and implementation of mitigation measures for easing the
environmental impacts of the projects. The questionnaire developed for the IOs assessed the
various aspects involved in project implementation starting from the project planning and
formulation to the adoption of mitigation measures and their adequacy. This questionnaire
also assessed the adequacy of the training programs that the IOs had undergone and how
equipped are they to implement the ESMF guidelines.
Distribution of the IOs participated/responded in the ET Environmental Audit
A total of 341 IOs responded to the assessment questionnaire for IOs which included 65
Panchayat/Municipal Secretaries and 276 AEs. The distribution of the IOs is depicted in Figure
5.1.
Figure 5.1: Distribution of IOS responded to the questionnaire for IOs in the ET Audit
81%
19%
Muncipal Engineer/Assistant Engineer
Panchayat/Municipal Secretary
30
Experience of IOs in implementing KLGSDP subprojects
The knowledge, capacity and skill levels of concerned IOs with respect to ESMF and their
familiarity with the environment safeguard issues, procedures and practices, maintenance of
appropriate documentation/records with respect to ESMF is directly linked to the number of
KLGSDP subprojects they have implemented in their tenure as well as the number of years of
experience they have in the project implementation field. These aspects were covered in the
assessment tool for IOs. The result of the assessment is depicted in Figure 5.2.
Figure 5.2: Experience of the IOs in implementing KLGSDP subprojects
8% of the 341 IOs responded have implemented more than 30 KLGSDP subprojects, while
10% have implemented less than 5 KLGSDP subprojects. There was no response from a
whopping 46% of the IOs regarding the number of KLGSDP subprojects they have
implemented.
5.1.1. EMSF in the project planning stage
The Environmental and Social (E & S) clearance procedures detailed in ESMF document are
simple, non-expert based and user friendly, but these are new and relatively unfamiliar to
various stakeholders who are expected to make use of these procedures while discharging
their respective roles and responsibilities. The E&S clearance and compliance verification
procedure as envisaged by ESMF enables LSGIs to integrate appropriate mitigation measures
into the activity implementation plan itself and subsequently verify whether these were
adequately complied with during work execution. For understanding and analyzing the use of
ESMF guidelines by the Implementing Officers during the project planning phase, 341
Implementing Officers (IOs) who participated in the EA were asked whether they referred to
ESMF document before commencing any Sub Project (SPs) related activities. The response
from the IOs in this regard is depicted in Figure 5.3.
Figure 5.3: Whether ESMF document is referred in the subproject planning stage: response
from IOs
8% 11%
14%
11% 10%
46%
>30
20 - 30
10 - 20
5 - 10
< 5
No response
62% 14%
24% Refer ESMF document
Don't refer ESMF document
No response
31
5.1.2. Adoption of Mitigation Measures as per EMSF
Mitigation measures for L1 (Low Impact) activities are given in the Proforma E of the ESMF
document and the mitigation measures for the L2 (Medium Impact) activities are given in the
Proforma G of the ESMF document. The response to the IOs regarding adoption of mitigation
measures as per ESMF is given in Figure 5.4.
Figure 5.4: Adoption of Mitigation Measures as per EMSF
62% of the 341 IOs responded stated that they adopt the mitigation measures for the
environmental impacts of the subprojects, as per the ESMF document, while 4% responded
that they don’t adopt the mitigation measures as per the ESMF citing reasons such as lack of
expertise, time and budget constraints.
However, it was noticed during the audit that the environmental impact identified in the
Proforma C/D for the subprojects was only air pollution from fugitive dust emissions and the
mitigation measure identified for this impact was water sprinkling or fencing. Other
environmental impacts and mitigation measures detailed in the Proforma E/G are not being
adopted in the LBs.
5.1.3. Feasibility of the Mitigation Measures in ESMF according to the IOs
The IOs’ feedback on the feasibility of the mitigation measures mentioned in the ESMF
document is depicted in Figure 5.5.
Figure 5.5: IOs feedback regarding the feasibility of mitigation measures mentioned in
ESMF document
60% of the 341 IOs responded that the mitigation measures adopted in the ESMF are feasible
while 7% say these are not feasible citing reasons such as there can’t be universally applicable
mitigation measures, as most of the mitigation measures are site and project specific.
As cited earlier, even though the IOs have opined that the mitigation measures mentioned in
the ESMF document are feasible, it was noted that the only environmental impact identified for
62%
4%
34% Adopted mitigation measures as perESMF
Didn’t adopt mitigation measures as per ESMF
No response
60% 7%
33% Mitigation measures in ESMF are feasible
Mitigation measures in ESMF are not feasible
No response
32
all the subprojects was air pollution from fugitive dust emissions and the mitigation measures
adopted for this included water sprinkling or fencing around the project site.
5.1.4. Feedback on any training programmes attended by IOs related to ESMF
Several capacity building training programmes were conducted by KLGSDP for the various
stakeholders such as the IOs and other implementing staff such as the plan clerks, the KLGSDP
district co-ordinators, the various other LB officials such as the Panchayat Presidents etc. Since
ESMF is unique to only KLGSDP subproject implementation and this is a first of its kind in
subproject implementation, knowledge dissemination to ensure ESMF implementation is possible
only through training programmes. The response of the 341 IOs on whether they have attended
any training program or not is depicted in
Figure 5.6.
Figure 5.6: IOs feedback on whether they have attended any training programs with respect
to ESMF
The capacity building of the IOs is possible mainly through trainings. While 53% of the IOs
have not attended any training programs with respect to ESMF, only 35% have attended
training programs. This show that the effectiveness of the capacity building programs in terms
of coverage was less, as the capacity building programs could not even cover 60% of the IOs in
the LBs audited.
5.1.5. Feedback of the IOs on the adequacy of the training programs
The prime objective of the training programs shall be to provide enough knowledge
dissemination so that IOs shall be capable to identify the environmental impacts due to
subproject related activities and identify mitigation measures for these impacts and implement
the mitigation measures. The response of the 341 IOs in this regard is depicted in Figure 5.7.
Figure 5.7: Feedback of IOs on the adequacy of training programs
35%
53%
12%
Attended training for ESMF
Have not attended any trainings for ESMF
No response
35%
22%
43%
The training programs have equipped me to identifythe environmental impacts and implement themitigation measuresThe trainings are not adequate
No response
33
35% of the 341 IOs felt that the capacity building programs are adequate and have equipped
them to identify the environmental impacts of subprojects and implement the mitigation
measures for them, while 22% opined that the training programs are not adequate. There was
no response from a whopping 43% of the IOs.
5.1.6. LESA for L2 (medium Impact) Activities
In case of L2 (medium impact) activities, the ESMF recommend that Limited Environmental
and Social Appraisal (LESA) should be carried out. However, it was observed during the audit
that, though LESA form was attached in the file, the identification of impacts and
corresponding mitigation measures were not identified properly. The Block Engineer (BE) and
the Implementing Officers need to ensure that these mitigation measures are included and
integrated with the overall activity proposal and the associated cost figures were suitably
updated to reflect the additional cost, if any, to implement the mitigation measures.
Surprisingly, this aspect was missing in many Local Self Government Institutions audited.
5.2 Field Level Observations
Detailed observations from the field audits are presented in following sections.
5.2.1. Buildings- New Construction and Expansion, Repair and Furnishings
This category includes the construction/maintenance/repair or furnishing of GP/MN offices,
community halls, PHCs, Homeo/Ayurveda dispensary, Family Welfare Centres, Anganwadis,
Pakalveedu, Libraries, School buildings, auditoriums etc. Plate 5.1 and Plate 5.2 represent 2
typical examples of this category of subprojects.
Plate 5.1: Renovation of Panchayat
Office, Pananchry, Thrissur
Plate 5.2: Anganwadi at Irikkur GP in
Kannur District
Awarded scores based on the audit observations to the projects coming under this category
clearly indicate that there is a noticeable percentage of projects coming under Green category
having audit scores more than 75 percent. Almost all of them ensured effective service
delivery, but in a few cases, there were buildings with construction completed, but were not in
use, due to the lack of electric or water connection. A total of 713 cases of buildings were
surveyed, whereby the major observations are:
The building projects such as modernization or construction of cabins and front offices for
GP/MN offices have rendered the LB offices more receptive and public friendly.
The Anganwadi projects constructed at the remote sites are a boon to the economically and
socially weaker locals belonging there by providing basic healthcare facilities to their children
including immunizations and nutritious food along with providing them easier access to
preschool activities. ESMF envisages the planning and adoption of solid and liquid waste
34
management system. Onsite solid waste disposal system was being followed in some of them
through the yard composting of the food waste generated.
The absence of compound walls in some of the Anganwadis audited which were having close
proximity to roads, ponds etc have raised safety and security concerns of the children there.
In case of natural resource usage, locally available materials were used in majority of the
projects.
The use of recycled material in building construction as envisaged by ESMF (mitigation
guidelines) was not being undertaken in the LSGs as the current Public Works Department
(PWD) manual does not have provisions for the same.
Waste was observed to be poorly managed during the construction activity in some of the
ongoing projects. The construction waste such as leftover cement, wood logs, stone, steel rods,
rubble, etc. were not properly disposed of and were still lying around the project site during
audit. Often, there was no provision for waste bins in some of the completed buildings.
Rain water harvesting integrated in building design was observed only in a very rare number
of cases. An appreciable example for rainwater harvesting is Mannanchery GP office building in
Alapuzha district. Rainwater harvesting should be promoted and implemented to a larger
extent, as Kerala is gifted with abundant monsoon, yet go through dry spells every year.
The recyclable wastes such as paper and plastics from office buildings are usually send to
recyclers, but there were provisions for onsite treatment of biodegradable waste in a very
limited number of instances.
Development and maintenance of greenery in the building premises as envisioned in the ESMF
is practiced in a few buildings only.
Most of the buildings had system for sewage treatment through septic tank followed by soak
pit.
Provision for health, hygiene & safety was average in completed and as well as in ongoing
projects. Only a very few projects had access to first aid, fire-fighting measures, etc.
5.2.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance
Road construction and repair is one of the fundamental activities under the KLGSDP project. A
total of 1126 roads were included in the ET Audit. This category of subproject includes
gravelling, soling, tarring, concreting of roads, or construction of footpaths, bridges and
culverts These projects provide a thrust for multifaceted growth in transport infrastructure of
Kerala. Plate 5.3 to Plate 5.6 represent typical examples of such projects.
Plate 5.3: Keezhallur Ayithara Road
tarring at Dharmadam GP in Kannur
District
Plate 5.4: Culvert construction in Narbona
Church road at Punnpra South, Alapuzha
District
35
Plate 5.5: Improvement of
Thachakalipadi road in Kallooppara
GP in Pathanamthitta District
Plate 5.6: Kochuveli Foot Bridge at
Muhamma GP in Alapuzha District
Though there were roads constructed under KLGSDP with very high social benefits such as
providing connectivity to tribals or replacing the existing wooden bridge with new concrete
bridge etc, one of the roads was observed to be constructed by obstructing natural drainage
channel (Kurikkachira - Kattuchira road at Cherthala MN in Alapuzha District)
The audit observations for this category of subprojects are detailed below:
Most of the projects under this type belong to ‘Yellow’ category, which indicates satisfactory
way of execution, as yellow category indicates audit scores more than 60 percent. Quality of
roads was found above average and highly beneficial to the local residents as most of the
roads constructed/maintained provided connectivity to the main roads.
Though the quality of the project implementation is good, most of the roads are constructed
/maintained for small stretches. There were projects involving the retarring or concreting
of only a 100 m stretch of road, while the rest of the portion in the road remains
unmaintained due to lack proper planning of the funds.
Since most of the road projects involved the upgradation of existing roads no land
acquisition was required for construction of any road in any of the LBs visited as part of the
ET Audit.
Many roads tarred in the water logged areas 3-4 years ago, are now in poor condition, with
potholes and gutters.
Most of the roads are constructed without drain mainly due to lack of space or adequate
funds. Construction of roadside drains shall be included in the project budgeting in the case
of roads proposed/constructed in water logged areas.
In some of the roads with roadside drains, it was observed that the drains were not
constructed without considering the slope of the road. Hence storm water remained
stagnant on the road itself rather than entering the drain.
There is a scope of improvement in areas like road safety, by provision of sign boards.
Some roads in the hilly areas were provided with safety rails along the bends on slopes.
Similarly, most of the foot bridges constructed are also provided with safety handrails.
Conducting road safety audits, provision of sign boards or pedestrian facilities for the entire
stretch of road constructed etc as envisaged in the ESMF are not being done in any of the
road projects audited, as mostly, these included the upgradation of the existing roads or
retarring.
The demands for construction of PCC road, from the communities, are highest under the
KLGSDP activities since these roads are more durable.
36
Most of the footpaths are constructed with covered drains.
Lack of maintenance has resulted in blockage in some of the culverts.
A display board containing the activity name, project name and the cost of the activity has
been kept in most of the projects audited.
Regular maintenance is required for tarred roads because of wear or deterioration. Road
maintenance also shall be given due consideration in project planning stage itself to ensure
that the road is maintained in good condition.
5.2.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance
This category of projects includes Construction, Operation and Maintenance of Waiting Sheds
Parking Yards, Bathing Ghats etc. A total of 39 projects under this category were surveyed –
both new constructions and maintenance. Apparently audit reflects a good deal of
satisfaction among locals via-a-vis built quality of these infrastructure and in terms of
service delivery. Most of the parking yards have been constructed in the GP/MN offices,
which have proved beneficial to both the LSGI officials as well as the people visiting such
offices. Plate 5.7 to Plate 5.10 are a few examples of this category of subprojects.
Plate 5.7: Bus waiting shed at
Karunapuram GP in Idukki
District
Plate 5.8: Bus waiting shed at Kummil
GP in Kollam District
Plate 5.9: Parking yard at
Vazhathope GP in Idukki District
Plate 5.10: Parking Yard at MN office at
Malappuram MN in Malappuram District
Some of the audit observations for this category of subprojects are as follows:
The provision of waste bins as depicted in the ESMF was not observed in any of the audited
projects. Consequently, the timely and regular collection and appropriate disposal of waste
as envisioned in the ESMF was not practiced anywhere.
Faulty design features such as poor visibility, no seating arrangement etc, has resulted in
public abandoning some of the bus waiting sheds.
37
5.2.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste
Sanitation and waste management being pressing issues in Kerala, the initiative by the LSGs
under KLGSDP for solving these issues prove promising. The total number of projects
audited under this category was 15. The projects included the construction of solid waste
management facilities such as biogas plants, vermi-composting units, dumping yards, e-
toilets, public toilet/comfort stations, plastic shredding units etc. Typical examples of
subprojects coming under this category are given in Plate 5.11 to Plate 5.14.
One incinerator unit for was also audited, but was found non-operational (Ponnani Govt
Taluk Hospital in Ponnani MN, Malappuram District). A ring was constructed for solid
waste disposal at Kulathoor GP in Trivandrum District, which has resulted in unmindful
dumping of waste all around the ring.
Plate 5.11: Biogas Plant at Kallooppara
GP in Pathanamthitta District
Plate 5.12: E-Toilet at Chavara GP in
Kollam District
Plate 5.13: Shed for waste dumping
yard at Wadakkanchery MN in
Thrissur District
Plate 5.14: Vermicompost Shed at
Kaduthuruthy GP in Kottayam District
The audit observations for this category of projects are summarized below:
Provision of better sanitation facilities for the government schools creates an enabling
environment which secures children’s dignity, safety, health and attendance in classes.
Maintenance was also properly done for the toilets constructed under KLGSDP funds in
schools, whereas the maintenance of public toilets/comfort stations remains unsatisfactory.
Sewage disposal of the toilets were through septic tanks followed by soak pit.
E-Toilets, which are self cleaning with very limited water consumption and in built STP,
remain public abandoned projects mainly due to the lack of awareness about their usage
38
The sites for solid waste management projects were not having compound walls, which has
resulted in easy access for stray animals.
Solid waste management projects lacked the adequate machinery and equipment for
treatment of waste such as shredders, gas collection or flaring systems etc. Mechanisms for
segregation of biodegradable and non-biodegradable waste was absent in all such facilities
audited. Provision of technical support and adequate funds can drastically improve these
projects and can make them model projects in solving the never ending solid waste
management issues Kerala is facing these days.
The non-functional projects due to the lack of the adequate equipment and machinery for
waste treatment and have become public nuisances and non-compliant projects as per ESMF
provisions (Any activity involving littering and burning of Municipal Solid Waste in cities,
towns and in urban areas is a prohibited activity as per ESMF).
Subprojects involving the collection and management of electronic waste and biomedical
waste were not observed during the audit. This may be because, the e-waste or biomedical
waste collection in Kerala are done by big players such as the Clean Kerala Company Limited
or IMAGE respectively which are authorized by Central Pollution Control Board (CPCB) for the
management of these types of waste. Management of these wastes by decentralized systems is
still in a nascent stage only.
5.2.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools
A total 82 cases of such projects were audited including public markets, crematoriums,
stadiums (indoor as well as outdoor), playgrounds and swimming pools. Typical examples of
these projects are shown in Plate 5.15 to Plate 5.20. Slaughter house projects, burial grounds
etc were not undertaken under KLGSDP.
Plate 5.15: Public Market at
Kulathupzha GP in Kollam District
Plate 5.16: Chennalode Mini Stadium at
Thariyode GP in Wayanad District
Plate 5.17: Gas crematorium at
Thodupuzha MN in Idukki District
39
Plate 5.18: Smoke room for
Crematorium at Chenglai GP in
Kannur District
Plate 5.19: Swimming pool
construction at Kaduthuruthy GP in
Kottayam District
Plate 5.20: Park for Children,
Thiruvalla MN in Pathanamthitta
District
The major audit observations are:
The public markets constructed proved to be a boon to the local people in selling their
produce.
In some of the public markets, the LB has provided solid waste collection system.
The LBs have provided waste collection system at some of the markets audited.
The gas crematorium projects are environmental friendly. It saves a lot of land space and
prevents toxins from directly leaching into soil or underground water sources. Compared to
a conventional crematorium, a gas-fired crematorium consumes lesser amount of fuel and
the burning process is also quicker. Care shall be taken to ensure that air pollution control
equipment such as scrubbers or cyclone separators are maintained properly. The ash disposal
shall also be taken care of.
In one of the crematorium projects audited (Elamkulam GP in Malappuram District), the GP
has taken special interest in developing a green belt around the crematorium, as envisaged in
the Proforma E and G of ESMF.
First aid and firefighting equipment shall be compulsorily made available in all such projects
5.2.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance
There were 15 projects audited under this category and it was observed that the projects were
meticulously implemented. Typical examples are given in Plate 5.21and Plate 5.22.
Plate 5.21: Thevarakkadavu Check
dam renovation at Kannambra GP
in Palakkad District
Plate 5.22: Venchakulam Lift Irrigation
Project Chenkal GP in Trivandrum
District
The major audit observations are as follows:
40
Canals constructed for irrigation have proved to be real blessing for the small scale farmers in
many regions by providing regular water supply even during summer, whereas the water
source was observed to be inadequate in one of the audited cases (Venchakulam lift irrigation,
water reservoir renovation, in Chenkal GP in Trivandrum District).
Periodic desiltation as envisioned in the Proforma E and G of ESMF was not being done in any
of the cases audited, however, this was not observed to be hampering the performance of the
irrigation projects
5.2.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair
Drinking water projects were found to be highly beneficial in most of the cases by providing
access to piped water supply, except for a few where, the water quality of the water source
itself was not maintained. A project involving new drinking water supply without testing of
water quality to ensure that it is safe for human consumption is a prohibited activity according
to Proforma A of ESMF as well. Water treatment methods were not adopted for the water
sources such as borewells or ponds. Typical examples of this category of subprojects are
shown in Plate 5.23 to Plate 5.26.
Plate 5.23: Pampa valley community
Irrigation project at Ward 12 at
Kavalam GP in Alapuzha District
Plate 5.24: Completion of Pulikuzhi
drinking water scheme at Kallikadu GP in
Trivandrum District
Plate 5.25: Plumbing and Pump set to
Thopilavi Drinking water scheme at
Chenglai GP in Kannur District
Plate 5.26: Pipeline extension to GP Office,
Veterinary Hospital at Nedumudi GP in
Alapuzha District
A total of 114 cases were surveyed, findings are listed below:
Water supply scheme projects were implemented successfully and now water is easily
accessible to nearby locals. While doing so, enough attention was not given to water treatment
and water quality testing.
Some of the projects audited were observed to be non-functional due to lack of adequate
quantity of water in the water source.
41
Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water
Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified
areas, no individual and/or agency, is expected to undertake any ground water based activity,
which will entail additional ground water draft. In one of these blocks, a project for renovation
and recharge of well was undertaken which can be considered as one of the best practices.
One of the projects audited(Pampa Valley Community Irrigation at Kavalam GP in Alapuzha
District, Plate 5.23) is a good example for community managed drinking water supply scheme.
The project has water intake from river Pampa, the water is brought through underground
pipelines to the water treatment unit. The water treatment unit has an RO plant. The treated
water is distributed to the nearby residents at the rate of 50 paise/litre. The disadvantages of
this scheme are, water quality testing is not being conducted regularly and the water storage
tanks are also not cleaned regularly.
5.2.8. Storm Water Drains- Construction, repair and maintenance
A total of 97 cases of drains were surveyed under this category and typical example of a drain
constructed with cover slab is given in Plate 5.27and a recently constructed open drain is
shown in Plate 5.28 .
Plate 5.27: Construction of drain with
cover slab at Ward 2 in Chellanam GP
in Ernakulam District
Plate 5.28: Kattusheri Drainage
Construction at Alathur GP in Palakkad
District
The drains were mostly constructed with cover slabs, but in some cases there were open
drains constructed in which littering were observed.
Although quality of the construction was found good, there was lack of trappings for silt and
waste in storm drains. Periodic cleaning to remove any sedimented silt/sand/debris shall be
done. Otherwise, the accumulated silt over time will reduce the drain capacity considerably.
But desilting work must be monitored and done from end to end.
In some of the roadside drain projects audited, the slope of the terrain was not given due
consideration in the design of the drain and hence water was not draining to the drains and
rather remaining stagnant on the road itself.
5.2.9. Agriculture/ Horticulture / Social Forestry - Management and extension
These projects mostly include the asset creations for agriculture such as the protection for
paddy fields (Plate 5.29)or training centres for agriculture. In one of the cases audited, a
marketing centre for agriculture was being used as a fire station (Nilambur MN in Malappuram
District). In another project involving a training centre for Agriculture, the building was used
currently for fire station (Kallikadu GP in Trivandrum District)
42
Plate 5.29: Protection wall to Mudakkuzha padam at Mudakuzha GP in Ernakulam
District
5.2.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities
A total of 6 cases of such projects were surveyed.
Plate 5.30: Fish Market at Muvattupuzha MN in Ernakulam District
Following are the notable observations:
In the fish markets, there was no treatment facility for disposal of liquid & solid wastes
generated. There was littering in the some fish markets.
In one of the markets audited, which was a new market construction, the new market was not
operational due to the lack of a proper access road (Fish market at Muvattupuzha MN, in
Ernakulam District, Plate 5.30)Provision for health, hygiene & safety was poor, since site is not
regularly cleaned and proper hygiene is not maintained.
One of the projects audited, the biogas plant for a fish market (at Nilambur MN in Malappuram
District) though had adopted robust technology (BARC model biogas plant), but was not
operational due to public protest. Those who are working in the fish market registered a
complaint of unbearable smell when the plant was operational and the plant was shut down.
The smell might be due to the overloading of the biogas plant. In addition, there were no
provisions for using/flaring the biogas produced as well.
5.2.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning
These projects such as ponds/tanks/ wells/canals were constructed/repaired/maintained for
small drinking water/irrigation projects. Plate 5.31 and Plate 5.32 show 2 examples of such
subprojects.
43
Plate 5.31: Side protection wall for
Kuttikulangara Pond at
Kayamkulam MN in Alapuzha
District
Plate 5.32: Construction of Borewell at
Madavur GP in Trivandrum District
A total of 61 such projects were surveyed in this audit and major observations are outlined here
under.
In the case of pond protection, deepening of the ponds were not done, only side walls for
protection were constructed. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District,
pond at Thumpamon GP in Pathanamthitta District)
In a few instances. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District,
Ozhukkuneettil Thodu at Kayamkulam MN, Alapuzha District), waste was seen dumped in
nearby water body, ditch etc. causing pollution, mosquito breeding, stagnation etc
Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water
Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified
areas, no individual and/or agency, is expected to undertake any ground water based activity,
which will entail additional ground water draft. In one of these blocks (Chittoor
Thathamangalam MN in Palakkad District), a project for renovation and recharge of well was
undertaken which can be considered as one of the best practices.
5.2.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance
A total of 212 such projects were audited which included the purchase of computers, printers,
scanner, air conditioners, DG sets etc for LB offices. These projects were found to be highly
beneficial to the LB officials. The purchase of streetlights and electric line extensions were also
included in this category. The environmental impacts of such projects are very limited during
the operation phase, but after the end of life, such projects are a real threat to the environment
as they become e-waste. E-waste management shall be carefully planned and implemented in
the LBs. Clean Kerala Company Limited collects e-waste in bulk. Hence any e-waste generated
can be stored separately and shall be handed over to them. Plate 5.33 and Plate 5.34 show 2
typical examples of this category of subprojects.
44
Plate 5.33: Purchase of Generator
for GP office at Velukkara GP ,
Thrissur District
Plate 5.34: Purchase of Touch Screen for GP
office at Veeyapuram GP in Alapuzha
District
The following aspects shall be taken care of in such projects
The streetlights (tube lights), after end of life become hazardous waste. This shall be disposed
off through authorized hazardous waste recyclers.
The AC filters shall be periodically maintained to ensure that the indoor air quality is
maintained.
The waste oil/lube oil from the diesel generator is a hazardous waste. Care must be taken to
store it separately in drums etc and dispose it through Kerala Pollution Control Board
approved vendors.
5.2.13. Tiny and Small Industries – Establishment and Expansion
Only 8 such projects were surveyed during ET Audit. These projects were mostly meant for
tiny and small scale industries, majority of them are women centric. Most of them are under
construction or construction might have just completed, but the buildings are not yet
operational due to lack of water/electricity connection. Plate 5.35 to Plate 5.37 show typical
examples of such projects
Plate 5.35: Maniyarankudi Khadi
industrial centre at Vazhathopu GP
in Idukki District
Plate 5.36: Construction of building to
Kolkkalam Vanitha Thozhil Pariseelana
Kendram at Ponmala GP in Malappuram
District
45
Plate 5.37: Building for Vanitha Vyayasaya Estate at Kannambra GP in Palakkad
District
5.2.14. Animal Husbandry dairy farming-construction and expansion facilities Two such projects were audited and found satisfactory from ESMF documentation
(Proforma C) point of view. However, one of the projects was not operational while other
one was found lacking in suitable infrastructure. One typical example for this category of
subprojects is given in Plate 5.38.
Plate 5.38: Cattle feed godown at Karode GP in Trivandrum District
5.3 Comparison of Projects evaluated during the MT Audit and ET Audit
A brief comparison of some of the projects evaluated during the MT Audit and the ET Audit is
given in this section.
During ET Audit
During MT Audit
Comparative Status of Waiting Shed at Kallooppara GP in Pathanamthitta during MT and ET Audits Waiting shed maintenance at Kallooppara GP in Pathanamthitta District (Project No SO 0093/13, KLGSDP
46
fund Rs 25,000/-).
No change in the condition of the Waiting Shed
During ET Audit
During MT Audit
Comparative Status of Ayyappankulam Renovation at Kollenkode GP in Palakkad during MT and ET Audits
Ayyappankulam Renovation at Kollenkode GP in Palakkad District (Project No. 115, KLGSDP fund Rs 65,000)
The pond has been renovated and maintained and fencing has been provided to avoid
trespassing or disposal of waste
During ET Audit
During MT Audit
Comparative Status of Storm water drain at Pandakashala at Karumkulam GP in Trivandrum during MT and ET Audits
During ET Audit
During MT Audit
47
Comparative Status of Construction of ring for waste management at poipallivilakom at Kulathoor GP in Trivandrum during MT and ET Audits
During ET Audit
During MT Audit
Comparative Status of Construction of Open Air Auditorium to Govt Girls’Higher Secondary School Mavelikkara MN, in Alapuzha during MT and ET Audits Construction of Open Air Auditorium to Govt Girls’Higher Secondary School Mavelikkara MN, in Alapuzha
District
During ET Audit
During MT Audit
Comparative Status of Construction of GP office in Chettikulangara GP in Alapuzha during MT and ET Audits
During ET Audit
During MT Audit
Comparative Status of Construction of Anganwadi No.15 at Eraviperoor GP in Pathanamthitta during MT and ET Audits
This was a non-compliance project during the Annual Performance Assessment (APA) in 2011-12 due
48
to the absence of a compound wall. This problem was rectified and compound wall was constructed
during the MT audit. During the ET audit, it was observed that water is still not available at the
Anganwadi, though water connection is present. Water is brought from the neighbouring houses.
During ET Audit
During MT Audit
Comparative Status of E-Toilet at Mavelikkara MN in Alapuzha during MT and ET Audits
5.4 Application of Index of Environmental and Social Integrity (IESI)
The Index of Environmental & Social Integrity (IESI) has been conceived to provide a broad
based tool to evaluate environmental & social conditions in sample project locations. The
mode of deriving IESI from the scores of attributes has been demonstrated in Annexure 2.4.
The questionnaires of all the 21 types of projects audited for Level 1 and Level 2 combined
were comprised of attributes under different metrics, and marks were allocated individually
(Annexure 2.4.1 and 2.4.2). Each attribute carried pre-determined maximum marks, and
subsequent to field auditing, 4 Zonal auditors evaluated critically and awarded deserving
scores leading to Index of Environmental & Social Integrity (IESI). Mean values of IESI under
different categories for all types of projects, implemented in Mid –Term Audit (MT), 2013-14
(Y3), 2014-15 & 2015-16 (Y4) and 2016-17 (Y5) in 14 districts of the State are presented in
Annexure 3.1.The application of this index to the evaluation of the subprojects, and the ranking
obtained for the LBs for the various Grant Cycles are described in detail in Annexure 3, of this
report.
In order to point out the reasons for ‘red’ category projects (alarm), each attribute under
different groups was analysed critically. Accordingly, per cent IESI of each group (ESMF
Documentation; Natural Resources; Waste Management; Health, Hygiene & Safety; Ecology &
Biodiversity; Socio-economic; General etc.), denoted as Percent Causative Factors, was worked
out. This exercise clearly indicates weak groups that need special attention for improvement in
near future. The application of IESI to various categories of subprojects is depicted in the
following sections.
5.4.1. Buildings- New Construction and Expansion, Repair and Furnishings
The percentages of building repair and furnishing projects coming under red, green and yellow
categories are depicted in the pie chart in Figure 5.8. The histogram in Figure 5.8 the shows
the contributing factors for the lesser scores for the red category projects. Attention on these
49
contributing factors indicated as red in the histogram can improve the performance of the
subprojects in the IESI scale.
Figure 5.8: Percentage of building repair/furnishing projects under green/yellow/red
categories as per IESI Scores and factors causing low scores for Red category projects
From the above presented histogram and pie chart, it is clear that, in building
repair/furnishings category, very few (3%) projects are coming under Red category. Health,
hygiene & Safety, Natural resource depletion and waste management are the aspects which
need immediate attention.
The percentages of building construction projects coming under red, green and yellow
categories are depicted in the pie chart in Figure 5.9. The histogram in Figure 5.9 shows the
contributing factors for the lesser scores for the red category projects. Attention on these
contributing factors indicated as red in the histogram can improve the performance of the
subprojects in the IESI scale.
Figure 5.9: Percentage of building construction projects under green/yellow/red
categories as per IESI Scores and factors causing low scores Red category projects
In this category of projects, 12% are Red category projects and 82% are under Yellow
category, showing that there is a possibility that these projects may come under Green
category, if attention is given to Natural Resources, Waste Management, Health, Hygiene &
Safety and Ecology and Biodiversity.
5.4.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance
Red 3%
Yellow 61%
Green 36%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS SE Gen
Red 12%
Yellow 82%
Green 6%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS EB SE Gen
50
Figure 5.10: Percentage of road repair and maintenance projects under green/yellow/red
categories as per IESI Scores and factors causing low scores Red category projects
Figure 5.10 depicts that; very few (2%) projects are coming under Red category. Health,
hygiene & Safety, Natural resource depletion and waste management are the aspects which
need immediate attention to improve overall project quality to good level. Green projects also
are around 40%.
Figure 5.11: Percentage of road construction projects under green/yellow/red categories as
per IESI Scores and factors causing low scores Red category projects
Percentage of Red and Green projects is almost comparable (12% and 11% respectively)
(Figure 5.11) for road construction projects. Immediate attention is required for the sectors
Health, Hygiene and Safety, Ecology – Biodiversity and General Impression of the projects.
5.4.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance
Figure 5.12: Percentage of operation/repair and maintenance of waiting sheds and parking
yards projects under green/yellow/red categories as per IESI Scores
The pie chart (Figure 5.12) shows that there are no Red category projects in this category.
Hence the histogram for causative factors for the red category projects is also absent for this
category of projects. 39% of the projects are coming under Green category.
Red 2%
Yellow 58%
Green 40%
0.00
20.00
40.00
60.00
80.00ESMF
NR
Waste
HHS
SE
Red 12%
Yellow 77%
Green 11%
0.00
20.00
40.00
60.00
80.00
100.00
ESMF NR Waste HHS EB SE Gen
51
5.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste
Figure 5.13: Percentage of sanitation and waste management projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
50% of the projects in this category (Figure 5.13) are in Red category, showing immense scope
for improvement in Natural Resources, waste Management, Health, Hygiene & safety.
5.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools
Figure 5.14: Percentage of repair and maintenance of public markets, crematorium,
playgrounds and swimming pool projects under green/yellow/red categories as per IESI
Scores and factors causing low scores Red category projects
For projects involving the repair/maintenance of public markets, stadiums, play grounds and
swimming pools, 4% of Red Category projects (Figure 5.14) while 29% are Good category
projects. Areas for improvement are Natural Resources and Project Specific arrangements
including Health & Safety and Waste Management
Figure 5.15: Percentage of construction of public markets, crematorium, playgrounds and
swimming pool projects under green/yellow/red categories as per IESI Scores and factors
causing low scores Red category projects
0.00
20.00
40.00
60.00
80.00
100.00
ESMF NR Waste HHS EB SE Gen
Red 4%
Yellow 67%
Green 29%
0.00
20.00
40.00
60.00
80.00
ESMF NR SE Gen PS
ESMF
NR
SE
Gen
PS
Red 15%
Yellow 75%
Green 10%
0.0020.0040.0060.0080.00
100.00
ESMF NR EB SE Gen ProjectSp. (for
D)
52
The projects involving the construction of public markets, play grounds, stadiums and
swimming pools have 15% Red and 10% Green category projects (Figure 5.15). Areas for
improvement are Natural Resources and Project Specific arrangements including Health &
Safety and Waste Management and overall impression.
5.4.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance
Figure 5.16: Percentage of construction and maintenance of minor and micro irrigation
projects and check dams under green/yellow/red categories as per IESI Scores
As depicted in Figure 5.16, this category has no Red category projects. It consists of 58% Green
category projects, which is the only case, where Green Category projects outnumber the Yellow
Category projects. This shows good implementation and proper maintenance.
5.4.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair
Figure 5.17: Percentage of maintenance and repair of drinking water supply projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
From Figure 5.17, it can be inferred that 24% projects are in Red category and 38% in Green
and Yellow category. This is the only case where Green projects are equal in number with
Yellow category. This number can be improved by taking care of Waste management and
Health, Hygiene & Safety issues. This type of projects has good record in Socio economic area
as they have good social benefits and people satisfaction.
Yellow 42%
Green 58%
Red 24%
Yellow 38%
Green 38%
0.00
20.00
40.00
60.00
80.00
100.00
ESMF NR Waste HHS SE Gen
53
Figure 5.18: Percentage of construction and expansion of drinking water supply projects
under green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects
For the construction and expansion of drinking water supply projects, only 6% projects are in
Red category (Figure 5.18), with attention required for Waste, HHS, Ecology – biodiversity and
overall impression.
5.4.8. Storm Water Drains- Construction, repair and maintenance
Figure 5.19: Percentage of repair and maintenance of storm water drain projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
Figure 5.19 demonstrates that in this category, only 9% projects are in Red and 31% in Green
category. The number of Red category projects can be reduced by giving additional attention to
Natural resources, Waste management, HHS and overall impression.
Figure 5.20: Percentage of construction of storm water drain projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
In case of construction of new drains, attributes resulting in poor scores are waste
management, HHS and EB (Figure 5.20). This type has more red Category projects (13%) than
Green category projects (5%).
Red 6%
Yellow 73%
Green 21%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS EB SE Gen
Red 9%
Yellow 60%
Green 31%
0.00
20.00
40.00
60.00
80.00
100.00
ESMF NR Waste HHS SE Gen
Red 13%
Yellow 82%
Green 5%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS EB SE Gen
54
5.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension
Figure 5.21: Percentage of agriculture/horticulture and social forestry projects under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
Figure 5.21 shows that this category has 40% Green and 10 % Red category projects. This
percentage can be further improved by taking additional care for Natural resources, Waste
management and HHS.
5.4.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities
Figure 5.22: Percentage of repair and maintenance of facilities for meat and fish production
and marketing projects under green/yellow/red categories as per IESI Scores and factors
causing low scores Red category projects
This category has 33% Green, 50% Yellow and 17% Green category projects. Waste
management. HHS and socioeconomic are three areas where improvement is desired (Figure
5.22).
5.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning
Red 10%
Yellow 50%
Green 40%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS SE Gen
Red 17%
Yellow 50%
Green 33%
0.00
20.00
40.00
60.00
80.00
100.00
ESMF Waste HHS SE Gen
55
Figure 5.23: Percentage of repair and maintenance of ponds/tanks/well/canals projects
under green/yellow/red categories as per IESI Scores and factors causing low scores Red
category projects
This category has only 6% red projects, it needs special attention for Ecology-biodiversity
along with Waste management and HHS (Figure 5.23).
5.4.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance
Figure 5.24: Percentage of electrical and electronic items purchase, installation, operation
and maintenance projects under green/yellow/red categories as per IESI Scores and factors
causing low scores Red category projects
Even though number of Red category projects in L1M is meager (4%), it is because of
unawareness of E-waste management, Safety and overall impression of project (Figure 5.24).
Other than that, other attributes of L1M are quite good.
5.4.13. Tiny and Small Industries – Establishment and Expansion
Red 6%
Yellow 68%
Green 26%
0.00
10.00
20.00
30.00
40.00
50.00
60.00
70.00
80.00
ESMF NR Waste HHS EB SE Gen
Red 4%
Yellow 69%
Green 27%
0
20
40
60
80
100
120
ESMF Waste HHS SE Gen Cert
56
Figure 5.25: Percentage of tiny and small industries-establishment and expansion under
green/yellow/red categories as per IESI Scores and factors causing low scores Red category
projects
This category has 14% Red and 86% Yellow category projects (Figure 5.25). There are no Green
category projects. Areas to be improved for Red category projects are Natural Resources, Waste
management, HHS and Ecology – biodiversity. Socio-economic attribute has good score.
Red 14%
Yellow 86%
Green 0%
0.00
20.00
40.00
60.00
80.00
ESMF NR Waste HHS EB SE Gen
57
Chapter 6: Good and Bad practices
This chapter depicts the good and bad practices in subproject implementation, observed during the ET Audit
One of the mandates of the ET Audit was to identify good as well as bad practices observed in
KLGSDP project vis-à-vis environmental and social safeguard and document them for further
reference or learning opportunities. ULTRA-TECH audit team took utmost diligence in
understanding such projects and documenting the same under the title Good Practice and Bad
Practice. These practices are explained below under different categories of the projects.
6.1 GP/MN Office Building
6.1.1 Good Practices
One of the notable and replicable good practices is the GP office construction at Mannanchery
GP in Alapuzha District (Plate 6.1). The building had rain water harvesting system, a vegetable
garden, a baby feeding room and the access to the GP office was made disabled friendly with a
ramp.
Highlight: Rain water
harvesting system, vegetable
garden, baby feeding room and
ramp constructed for
providing easy access to the
disabled.
Plate 6.1: GP office at Mannanchery GP in Alapuzha District
6.1.2 Bad Practice Some of the buildings were constructed without proper safety features for the users. One typical example is the truss work and maintenance of PHC building at Chettikulangara GP in
Alapuzha District (Plate 6.2). A staircase in the rear side of PHC building and tile works was
done using KLGSDP funds in this project.
Highlight: The stair is not provided with any safety hand rail.
Plate 6.2: PHC building at Chettikulangara GP in Alapuzha District
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6.2 Anganwadi Centres
Anganwadi Centres were started by the Indian government in 1975 as part of the Integrated
Child Development Services program to combat child hunger and malnutrition. These centres
provide supplementary nutrition, non-formal pre-school education, nutrition and health
education, immunization, health check-up and referral services of which latter three services
are provided in convergence with public health systems. About 80 Anganwadi Centres were
including the ET audit. Four Anganwadi centres are presented here as case study for good
practices and two for bad practice.
6.2.1 Good practices
Vazhathopu Anganwadi at Vazhathope GP in Idukki District (Plate 6.3) can be projected as one
of the well implemented and model Anganwadi Centres. It has a well-furnished room for pre-
school activities, an open space for play area, outdoor play equipment, a separate room for
kitchen, adequate space for veranda, provision for drinking water, child friendly wash basin
and child friendly separate toilets for girls and boys.
Highlight: Well furnished
room, open area, outdoor play
equipment, separate kitchen,
drinking water facility, child
friendly wash basin, child
friendly toilets for boys and
girls
Plate 6.3: Vazhathoppe Anganwadi at Vazhathope GP, Idukki District
Kuttooli Anganwadi in Keezhuparamba GP in Malappuram district (Plate 6.4)is another well
implemented project. It is an air conditioned Anganwadi. Well maintained and spacious front yard
and a neat, clean and spacious kitchen. It is also used as a meeting place for different local groups of
the GP. Air-conditioning is aimed at attracting more children to the Anganwadi. Children are found
to be in extreme distress during the peak summer months of March, April and May prompting the
GP to implement such a project.
59
Highlights: The only air conditioned Anganwadi audited. It is also used as a meeting hall for the
various local meetings during the off hours of the Anganwadi
Plate 6.4: Kuttooli Anganwadi at Keezhuparamba GP in Malappuram District
Madathinkadavu Anganwadi at Mariyapuram GP in Idukki district (Plate 6.5) and Kavana Angawadi at Avoli GP in Ernakulam district (Plate 6.5) are another set of good practices. At these places, the food waste is composted within premises and the children are encouraged to actively participate in gardening. By deepening children's sense of connection with nature, school gardening is inspiring environmental stewardship and evokes in them a greater awareness of sustainable living and help them in achieving insight into the long-term human impact on the natural environment. From the water shortage to the over-use of pesticides, children who engage in gardening have first-hand opportunities to observe the importance of conservation and intelligent allocation of resources.
Highlights: Food waste is yard composted and used for gardening. Children are encouraged for
gardening which imprints in them the first lessons of sustainable living.
Plate 6.5: Kavana Anganwadi at Avoli
GP in Ernakulam District
Plate 6.6: Madathinkadavu Anganwadi
at Mariyapuram GP in Idukki District
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6.2.2 Bad practices
The Anganwadi at Manjappara at Nedumkandom GP in Idukki District and the Mugu
Anganwadi at Puthige GP in Kasaragod District were found with negligence in safety
aspects. Compound walls, which are necessary for children safety was found missing in
these Anganwadis. These Anganwadi centres are located on the main road with poor access
to the building.
Highlight: The Anganwadi is on the side of
main road but compound wall is not provided.
No proper access way provided.
Highlight: Anganwadi on the top of an elevated
land parcel, without any compound wall or access
road.
Plate 6.7: Manjappara Anganwadi at
Nedumkandom GP in Idukki District
Plate 6.8: Mugu Anganwadi at Puthige
GP in Kasaragode District
6.3 Family Welfare Centres
6.3.1 Good Practice
Family Welfare Centre (FWC) is aimed at extending the family planning and welfare
services and three FWCs were included in the ET audit. Nirappukala FWC at Kallikad GP
in Thiruvananthapuram District (Plate 6.9) follows certain good practices which can be
replicated in other FWCs. At Nirappukala FWC awareness classes are conducted for
adolescents, women and old people. Non Communicable Disease checkups and medical
camps are conducted once in 2 months. Child immunization programmes are also
conducted through this FWC, besides there is a small library facility for the women in the
locality.
Highlights: A small library is maintained in the FWC for women in the locality
Plate 6.9: Family Welfare Centre at Kallikadu GP in Trivandrum District
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6.4 Foot Bridges
6.4.1 Bad Practice The Hosabettu Koppala Foot Bridge constructed at Manjeshwaram MN in Kasaragod District
had access steps in a very dilapidated state (Plate 6.10) . Kallur Koppala Foot Bridge, in
Vorkady GP in Kasaragod District had no proper access way(Plate 6.11).
Highlight: Safety Handrails are provided to the foot bridge, but the access steps are in a dilapidated state
Highlight: Safety Handrails are not provided to the foot bridge, and no proper access way to the bridge
Plate 6.10: Hosabettu Koppala Foot
Bridge at Manjeshwaram MN in
Kasaragod District
Plate 6.11: Kallur Koppala Foot Bridge in
Vorkady GP in Kasaragod District
6.5 Bus Waiting Sheds
Bus waiting sheds provide a proper waiting area for pedestrians/commuters waiting to get
a ride from the various bus services. A good bus waiting shed is one that allows visibility
and easy access to the bus, is comfortable, safe and convenient, provides clear information,
has low maintenance requirements and is vandal-resistant. An unused waiting shed is a
waste of money and an unnecessary maintenance problem. Waiting sheds are expected to
provide a place to sit, protection from weather, and a feeling of safety and security. The size
of a bus waiting shed depends on the climate as well as the number of people who are
expected to use it. Given below are good (Plate 6.12 and Plate 6.13) and bad practice
(Plate 6.14) case studies under this category project.
6.5.1 Good Practice
Highlights: Allows visibility and easy access to bus, provides place to sit and provides
protection from the sun and rain.
Plate 6.12: Bus Waiting Shed at Chakkittapara GP in Kozhikode District
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Highlights: Sleek design with minimum requirement of construction material. Hence a
low cost and effective design.
Plate 6.13: Bus waiting shed at Ayavana GP in Ernakulam District
6.5.2 Bad Practice
Highlights: Not used by public and seems abandoned.
Plate 6.14: Bus waiting shed at Kalloorkad GP in Ernakulam District
6.6 Waste management Projects
6.6.1 Good Practices
i Waste Dumping Yard at Division 19 at Karunagappally MN in Kollam District (Plate 6.15)
currently does not have a leak proof roof causing leachate generation and pollution.
Karunagappally MN has realised the significance of the dump yard site reclamation and
proposed to transform this dump yard to a sophisticated waste management facility with a
plastic shredding unit, crematorium etc. KLGSDP fund has been allocated in the year 2016-
17 for renovating the dilapidated roofs of the existing dump yard to make it a leak proof
trussed roof. This is likely to eliminate the risk of leachate generation. The construction of
trussed roof will commence by July 2017.
The dump yard site reclamation is a very promising step towards achieving compliance
with Solid Waste Management Rules ,2016.
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Highlights: KLGSDP fund of Rs 1,75,000/- has been allocated to replace the existing ramshackle
roofing of the dump yard with a leak proof trussed roof. The MN further aims at a reclamation of the
dump yard and convert it to a sophisticated waste processing facility with a plastic shredding unit,
crematorium etc.
Plate 6.15: Dumping Yard at Division 19 in Karunagappally MN of Kollam District
ii For installing a waste Incinerator at Kollenkode GP in Palakkad district, Rs 50,000/ was
allocated from KLGSDP funds. “Incineration” means an engineered process involving
burning or combustion of solid waste to thermally degrade waste materials at high
temperatures. The GP governing body during the procurement stage felt that, incinerators
can be environmentally degrading and the project was cancelled and a refund of Rs
50,000/- was made to KLGSDP.
For running a waste incinerator, volume of waste produced daily should be adequate to
continuously run an incinerator. Moreover, the type of waste generated in Kerala
household is not suited to incineration i.e. it is very wet. The local environmental conditions
(e.g. high humidity) and wet waste would cause corrosion of the incinerator and shorten its
life span. Moreover, the capital cost of incineration and ongoing equipment maintenance
are very high. There is no opportunity for promoting material recovery from incinerator. If
an incinerator planned to be installed in any local body, it should have suitably designed
pollution control devices to achieve the emission limits prescribed by the Solid Waste
Management Rules 2016.
Highlight: An incinerator project earlier planned and formulated was dropped and a total refund
was made to KLGSDP funds as the GP governing body of Kollengode GP in Palakkad District felt that
the incinerator can be environmentally degrading.
64
6.6.2 Bad Practices
i Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta District (Plate 6.16) is
one of the worst waste management projects. Plastic rejections are considered to be the major
contributor towards the irreparable damage caused to the environment due to pollution,
world over. Converting these rejects into recyclable products will enable the LSGIs to sell off
the value added products to generate revenue. Plastic rejects are used in many local bodies for
road tarring. As per the G.O (RT) No. 3119/2016/LSGD dated 17.11.2016, instructions for the
construction of road using non-recyclable plastics has been issued. Besides, in the plan
formulation guidelines for Urban local bodies and 3 tier GPs for the year 2017-18 this has been
emphasised [GO (MS)No.79/2017/LSGD Dt.3.4.2017 and GO(MS)No.72/2017/LSGD
Dt.29.3.2017]. Clean Kerala Company Ltd under LSGD has been entrusted to facilitate this
activity.
In a well designed and implemented plastic shredding unit, clean plastic rejects can be
converted into utility material for recycling. The required infrastructure for a plastic shredding
unit are (a) Plastic scrap shredder - for shredding low grade plastics (b) Blade grinding
machine and (c) Hydraulic baling machine along with the allied equipment.
At Ranni Pazhavangandi GP in Pathanamthitta District, the plastic shredding unit is defunct.
The project was implemented in 2014-15. The project consists of a shed without any
machinery. The plastic waste, cardboard waste etc are collected by the GP appointed staff and
dumped at the shed and outside it. Hazardous waste such as tube lights (fluorescent light
tubes) were also found in the piled up waste dump.
Highlights: Not a secured facility. Consists of a shed without any walls or compound wall. No
machinery to shred the waste. All sorts of recyclable and non-recyclable waste such as plastic
bottles, cardboard boxes and hazardous waste such as tube lights are being dumped at the site
and outside. Chances of leachate generation, as waste are dumped on the earth without any
cover. Easy access to rodents and stray animals.
Plate 6.16: Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta
District
ii Biogas plant at the Taluk hospital in Thodupuzha MN in Idukki District (Plate 6.17)was
implemented in 2012-13 for treating the organic waste from the Taluk hospital. The project is
currently not in use and is in a dilapidated condition. An underground tank has been
constructed with an opening to throw the organic waste into it. The project does not even
qualify to be called a biogas plant as the components required for carrying out biomethanation
are not there for this project.
65
Highlights: Abandoned asset with inadequate infrastructure. No eqipment to pulverise the
waste or to collect the gas produced. Easy access to rodents and stray animals.
Plate 6.17: Biogas Plant at Taluk Hospital at Thodupuzha MN in Idukki District
iii The eToilets can be an integral part of urban as well as rural sanitation infrastructure. The
eToilets are electronic public toilets. E-Toilets can be considered as one of the innovative
sanitation solution for the public spaces around as such as the premises of (1) local body
offices, (2) court buildings (3)bus stands (4) railway stations etc. The e-toilets are usually
provided at public places or in schools etc.
Project Features
The insertion of a coin opens the door of the eToilet for the user, switches on a light—thus
saving energy. The toilets are programmed to flush automatically. These are modular, sleek
and have appealing aesthetics. The features of the e-toilets are (1) they are very compact and
(2)easy to install. The STP (Sewage Treatment Plant) of the e-toilets has 2 kLD capacity which
means more than two hundred people can make use of this facility in a day. Other features of
the e-toilets are, they have automatic doors which open only when the intended user inserts
coin in the designated slit. Another important feature is that, the doors won’t open, if there is
not enough water in the storage tank for flushing. It has automatic flushing mechanism as well.
The model DB 9007K from Keltron was used by Mavelikkara MN in Alapuzha District (Plate
6.18). This project was audited during the MT audit and it was observed that the social
acceptance of the e-Toilets is very less and the public are very reluctant to use this facility.
With all its obvious features for ensuring public utility, the e-toilets, become a nuisance, if not
maintained well. In the ET audit, it was discovered that the project is maintained well. The
AMC has been awarded to Eram Scientific and they offered an SMS based system for redressing
any operational issues. The social benefits from the project remains very poor, as the number
of persons utilizing this facility remain very limited despite the efforts being made to maintain
it properly.
66
Highlights: The projects are not used by public, despite the efforts made in maintaining them.
All the 3 e-Toilets audited remain public abandoned projects, though efforts are being made at
Mavelikkara MN to ensure regular maintenance of the project
Plate 6.18: E-Toilet at Mavelikkara MN in Alapuzha District
6.7 Drinking Water Supply projects
Drinking water supply projects have largely been well executed. However, a few cases of bad
practices too were observed and listed here (Plate 6.19 to Plate 6.21).
6.7.1. Bad Practices
Highlight: The bore well is not given any safeguard or protection.
Plate 6.19: Kavilppadi Irrigation Project in Mariyapuram GP in Idukki District
Highlight: The exposed pipeline along the foot of the hill can result in pipe breakage at any time
Plate 6.20: Mulamthandu Water Supply Scheme in Santhanpara GP in Idukki District
67
Highlights: Not functional. Water quality is not maintained, as the water source
itself is highly unhygienic
Plate 6.21:Keezhur Pipeline extension in Chemnad GP in Kasargod district
6.8 Storm water Drains
6.8.1 Bad Practices
In a typical drainage system, storm water is collected by drains which then convey it and
discharge it through an outfall to a natural water body such as a creek, river, lake or pond. A
storm water drain designed without a discharge system will reverse its very purpose of
protection from flooding and can result in maximising the floods along the region near it. The
storm water drain at Kadappuram GP in Thrissur District (Plate 6.22) was constructed
without providing any outfall or discharge system. Another bad practice is the construction of
open drains without regular cleaning/desilting/maintenance (Plate 6.23)
Highlight: A storm water drain constructed without any outfall or discharge system or any receiving water body/drain/sewer system
Plate 6.22: Construction of drainage at 4 cent Colony road Kadapuram GP in Thrissur
District
Highlight: The drain is not cleaned regularly. Filled with debris and mud, as there is no covering slab and hence unable to allow proper water drainage
Plate 6.23:Construction of Drain at Kulanmavu Ambalabhagom Road at Arakkulam GP in
Idukki District
68
6.9 Public Markets
New market construction at Nedumkandom GP in Idukki district was found to be a bad case of
construction while the same facility in Kulathupuzha GP in Kollam District was found under
good case.
6.9.1. Good Practices
The public market at Kulathupuzha GP in Kollam District (Plate 6.24) is a good market construction project.
Highlights: Facility used by local people for selling the goods they produce. Storm water drains are
present. Solid waste from the market is being collected by the Panchayat for disposal
Plate 6.24:Renovation of town market at Kulathupuzha GP in Kollam District
6.9.2. Bad Practice
The public market at Nedumkandom GP in Idukki District (Plate 6.25) doesn’t have provision for solid waste management. All the market stall are not occupied by vendors
Highlights: Facility is electrified but not utilized much. No provision for solid waste management
exists in this facility.
Plate 6.25: New market construction at Nedumkandom GP in Idukki District
6.10 Open Well construction/ Renovation
Protection to well structure is important for long term use of constructed wells. During audit it
was found that some of the wells are not usable currently owing to contamination of water
since such wells were not provided with compound wall etc. Given below are two good
practices and one bad practice.
69
6.10.1. Good Practices
One of the best and replicable examples of open well renovation was undertaken at Chittoor-
Thathamangalam MN in Palakkad District. Out of the 151 blocks in Kerala, 5 blocks have been
notified by the State Ground Water Authority vide its Extra Ordinary Gazette Notification as
‘Notified Areas’. These areas are ‘over exploited’ in terms of ground water. In the Notified
areas, no individual and/or agency, is expected to undertake any ground water based activity,
which will entail additional ground water draft. In Chittoor Thathamangalam MN, which is
coming under Chittoor block, a project for renovation and recharge of open well was
undertaken at the MN office compound. The rainwater collected from the rooftop of the MN
office was filtered through a filter unit and the filtered water was flowing to the ground to
recharge the well. The MN has gone an extra mile, by beautifully decorating the open well
parapet wall, so as to easily grab the public attention to the project and create awareness
among the public regarding the significance of ground water recharge (Plate 6.26). Another
good practice is shown in Plate 6.27.
Highlights: Rainwater from the rooftop of the MN office is directed to a filter and the filtered
water is fed to the well, resulting in recharge of the well. The parapet wall of the well has been
beautified to grab public attention to create awareness regarding ground water recharge. The
filtering process is depicted through pictures on the filtration unit.
Plate 6.26: Renovation and recharge of open well was undertaken at the MN office at Chittoor
MN in Palakkad District
Highlight: Open well maintenance done by
constructing compound wall and gates,
covering nets are also provided for
covering wells when not in use..
Plate 6.27:Open well maintenance at Baison Valley GP in Idukki District
6.10.2. Bad Practice
Well water was contaminated and cannot be used at Vallapuzha GP in Palakkad District (Plate
6.28)
70
Highlight: The well has contaminated water and not in use because this well is unprotected.
Plate 6.28: Open well near Vallapuzha Railway Station at Vallapuzha GP in Palakkad
District
6.11 Road concreting
6.11.1. Bad Practice
Some of the road concreting/tarring was found abruptly terminated (Plate 6.29) and without
drain provisions causing frequent damage due to rain.
Highlight: Road concreting ending abruptly and constructed without any drainage provision.
Plate 6.29: Concreting of Pathichiripadi road at Mankulam GP in Idukki district.
6.12 Pond Maintenance
6.12.1. Good Practices
Two good practices in pond maintenance (Plate 6.30 and Plate 6.31) and a bad practice (Plate
6.32)in the same category are presented here.
Highlight: During the MT Audit, the pond was
observed to be dumped with waste. But during the
ET Audit, it was observed that the pond has been
renovated and maintained and fencing has been
provided to avoid trespassing or disposal of waste.
Plate 6.30: Ayyappankulam Renovation at Kollenkode GP in Palakkad District
71
Highlight: It is a very large pond and is well maintained. The walls of the pond are well maintained and in some portions new walls constructed. Interlocks paved, cement benches constructed. Some garden trees are also planted. Steel handrails for the stairs to the pond are the pending work (going on). Currently local people wash and take bath in the pond and in future it will be used for drinking water supply after necessary modifications.
Plate 6.31: Renovation of Odangattkulam at Edayur GP in Malappuram District
6.12.2. Bad Practices
Highlight: The pond maintenance is not at all effective. The pond is filled with aquatic weeds such as Azolla. The protection mesh is not serving any purpose.
Plate 6.32: Maintenance of Panchayat pond at ward 3 at Kavalam GP in Alapuzha
District
72
Chapter 7: Projects under onetime financial assistance to Backward LSGIs
This chapter presents the observations on subprojects which were implemented using the onetime
financial assistance to Backward LSGIs and elaborates how sustained effort from PMU
Environmental and Social Specialist through numerous capacity building programmes helped in
convincing the Backward LSGIs that environment friendly projects will give them benefit over and
above just service delivery .
7.1 One time financial assistance
A provision was made in the final phase of KLGSDP to provide grants up to Rs. 2 crores to 60
backward LBs (40 backward GPs, 10 tribal GPs and 10 revenue deficit MNs). Till now, the PMU
has focused expressly on getting DPRs prepared, obtaining Technical Sanctions and getting the
work contracted as early as possible. Consequently, about 182 sub-projects have been
contracted before the deadline of 31 March 2017, out of which, work on 165(90%) has begun.
Since grant is coming to a close, the thrust quickly shifted to ensuring timely execution and
completion of implementation activities in the field with respect to these backward local
governments. The PMU facilitated the appointment of around 58 Overseers at LSGI level
exclusively for the 182 sub-projects contracted under this arrangement. The monitoring,
supervision and administrative measures were enhanced in such projects to positively ensure
completion of all civil / other works.
At the LSGI level the Overseers appointed exclusively for the purposes of monitoring progress
of these activities were integrated with this monitoring mechanism. They were supposed to be
providing real time updates on physical and financial progress of the sub projects on a daily
basis.
The Project Director periodically (preferably on a bi-monthly basis) holds a review meeting
wherein all concerned Executive Engineers / Assistant Engineers are be invited to present the
progress on activities pertaining to this component. Simultaneously the present system of
Deputy Project Director level review also continues. The PMU held refresher trainings at KILA
on 10th April 2017 to introduce the enhanced monitoring mechanism to all the District
Coordinators and Overseers. This training will be repeated multiple times if and whenever
required during the period till project completion.
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During ET audit 28 such projects were included in the scope of audit. List of these projects along with their features are tabulated in Table 7.1.
Table 7.1: Projects funded under the onetime financial assistance to Backward LSGIs covered in the ET Audit
No. District Name of LB Name of Project Auditor Observations
1. Trivandrum
Ottoor
1. Construction of PHC building at Njakkad
Participatory Rural Appraisal (PRA) and Focus Ground Discussion (FGD) conducted with respect to development plan of Ottoor GP. Nursing station, wards, a mini operation theatre and a fitness centre will be constructed as part of this work. The work is ongoing. Just finished the concreting.
2. Construction of Mullarancode LPS building
PRA and FGD were conducted. Total 256 students are studying here. Construction of 2 classrooms and 2 toilets, as part of this project. Now the concreting work has finished. They demolished half portion of toilet. So they are planning to a construct a new toilet block also. Site was a barren land used by students for playing before the project.
3. Construction of class room in Njekkad LPS
PRA and FGD were conducted. 224 students studying here. 2 additional classrooms, one office room and 2 toilets are being constructing now. Before the project the land was barren. Now the concreting work has finished.
Anchuthengu 4. Vekkamkulam Drinking
water project Ongoing work and hence water supply has not yet started. After the completion many houses will get drinking water continuously
2. Kollam Mundrothuruth
5. Construction of Ayurveda Hospital building
The work is under construction. Coconut trees are cut down for construction purpose. Coconut trunks are used in pilling as the ground water level is high.
6. Construction of LPS and Buds school
The works in under construction and has some disputes with the nearby communities. Coconut trunks are used in pilling as the ground water level is high. During the pilling process, the local people are facing many problems. The walls of the neighbourhood households found to have some cracks and breakage and they claim it is due to the piling process. The work disturbs the water supply of nearby families.
3.
Pathanamthitta
Thumpamon
7. Muzhangottuchal Natural village (model Anganawadi, Pakal veedu, Buds school, Women/ Kudumbasree facilitation Centre, Open auditorium, Library& Park)
Since the total fund to be allotted from KLGSDP was modified, the project is modified to a natural pool with pedestrian track. These constructions are completed. Important project as it’s a major step to conserving water sources.
8. Construction of model Anganavadi building with compound wall no.
Construction almost completed. Wiring is to be done.
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69 9. Construction of model
Anganavadi building with compound wall no. 70
Work ongoing. Construction nearing completion
10. Construction of model Anganavadi building with compound wall no. 71
Work ongoing. Construction nearing completion
11. Construction of Road in Malappuram Colony
Work completed. Beneficial to SC Colony.
4. Alappuzha Veeyapuram
12. Construction of Ayurveda Hospital
The work is just started, piling work is going on. It is a wet area, hence strong foundation is needed. Soil tests were carried out
13. Renovation and extension of PHC building
PHC Building extension work, where piling work and foundation work started. 2 trees were cut down, but no replanting/ compensatory planning done.
5. Kottayam
Vechoor
14. Koduthuruth-Mattom-SNDP-Valachakari-Vechoor road and bridges
Road gravelling and metalling work has completed bridge work going on.
15. Kaipuzhamuttu-Valyavelicham-Manjadikari road and bridge
New road construction provides access to main road easier.
6. Idukki Peruvanthanam
16. Peruvanthanam Drinking water supply project including Check dam & Pond construction
Total of 8 tanks and their pipelines are planned in the project. The work is in progress. The base of tank is completed. Installation of pipeline is not yet started
7. Ernakulam Muvattupuzha MN
17. Renovation and Modernisation of Fish market
The construction is good. The debris is properly disposed. But not working yet, because the road to the market is under construction.
8. Thrissur
Kadappuram
18. Construction of Crematorium
Construction of gas crematorium undertaken by COSFORD. Hence local people not engaged for construction.
19. Improvement of basic infrastructure and construction of an Anganwadi in Tsunami Rehabilitation colony
Beneficial to the children in the colony as currently, they have to walk up to 1.5 km to reach the nearest Anganwadi. Work is ongoing. Spacious building.
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9.
Palakkad
Muthalamada 20. Tribal Agro marketing,
service and facilitation centre
It is an ongoing and big project. It will be a great platform for the tribal’s to sell their agricultural products.
Chittoor 21. Construction of
Thathamangalam Community hall
Construction is going on as per the rules. The foundation & pillar work is completed. The local people are engaged in the project work. The raw materials using for this project is local items
Peringottukurrissi
22. Construction of Community hall in Parithipully
The construction work is in process. It is double store building. It will benefit to the people more. It is situated in a junction, so the people can reach this place easily and very accessible.
Kuthannur
23. Construction of Gas Crematorium
The construction work is going on. 8%of this project is used for environmental management. After this implementation external flow of cash will become and income to the GP. It increases the welfare of the society.
24. Construction of Anganwadi building at Karakode
Construction work is on process. They are taking mitigation measures. The beneficiaries of the project are children, women and adolescents. It will help to improve skills.
25. Construction of Anganwadi building at Lakshamveedu (Kothamangalam)
Construction work is on process. They are taking mitigation measures. The beneficiaries of the project are children, women and adolescents. It will help to improve skills and help in health inequalities that’s the benefits gained from growth can be enjoyed by everyone.
10. Malappuram Urangattiri 26. Renovation of
Odakkayam tribal school
Construction of additional classrooms including one smart class room and toilet. Work is going on. Construction materials are carefully dumped. One compound wall may be needed behind the building because of a natural canal which is fed only in rainy season. But not seriously dangerous. Socially very important since the school belongs to a rural and tribal area. The project has enhanced people’s attention towards school.
11. Kozhikode Koothali
27. Construction of model Anganwadi building-Koothali Theru Anganwadi
ICDS Self Delivery Centre, model building and facility. Good construction, no cracks, side wall, water and electricity available.
12. Wayanad
Mullankolli
28. Construction and maintenance of Anganwadi building Seethamoodu.
Good construction but not completed due to the non availability of labourers. Need to plant much trees near the building.
Kottathara
29. Construction of model Anganavadi building with compound wall and recreation hall for old & derived people
Construction ongoing. Since the fund allotted was modified, the recreation hall for old and deprived people not planned in the present construction.
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All 28 projects achieved satisfactory level in ESMF implementation, although it was found that
there still exists a great scope for further improving ESMF implementation in such projects in
future. As mentioned above, monitoring of these projects have been strengthened by
appointing dedicated Overseers, who could also be given awareness training on ESMF
requirements and expected to keep an eye on compliance to ESMF.
A notable achievement in terms of environmental safeguard in these projects took place when
LBs took greater interest in deciding the nature of subprojects. Sustained effort from PMU
environmental and social specialist through numerous capacity building programmes helped
in convincing these bodies that environment friendly projects will give them benefit over and
above just service delivery. ET audit found that satisfaction level of LBs is quite high in
backward local body support projects.
Out of the 28 projects, 6 projects require clearances from Statutory/ Regulatory agencies. The
list of the projects requiring the clearances are given in Table 7.2.
Table 7.2: Backward Assistance Subprojects requiring Statutory Clearances
Sl No
District Local Body Name of Sub- Project Project Cost
Type of statutory/regulatory clearance required
1. Kottayam Vechoor Koduthuruth-Mattom- SNDP-Vechoor road and bridges
13000000 Irrigation Department, State Wetland Authority
2. Idukki Peruvanthanam
Peruvanthanam Drinking water supply project including Check dam & Pond construction
20000000 Forest Department
3. Thrissur Kadappuram
Improvement of Basic Infrastructure facilities at Tsunami Rehabilitation Colony
12000000 Revenue Department, CRZ Clearance
4. Thrissur Kadappuram Construction of a gas crematorium
8000000
Pollution Control Board, DMO & District Collector
5. Palakkad Peringottukurrissi
Construction of community hall in Parithipully
18064173
PWD
6. Palakkad Kuthannur Construction of gas crematorium
6594601
Pollution Control Board, DMO & District Collector
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Chapter 8: Capacity Building Programme
An effort was made as part of ET audit to understand and analyse the capacity building initiatives
taken up by PMU with specified focus on ESMF right since the project inception. Audit team also
looked into various aspects of strength and weakness in current capacity building measures of
KLGSDP, especially focussing around ESMF. Both these aspects have been explained in this chapter.
8.1 Capacity Building Initiatives
A capacity building plan was conceptualized and made part of ESMF implementation
framework itself with the objective of inculcating the concept and essentiality of integrating
environmental & social concerns in Performance based Grant. For the benefit of beneficiaries
and for the effective project implementation, PMU took up the decision to involve itself
proactively in arranging and imparting capacity building training in big way. Result of this
effort can be best understood by the fact that the word “ESMF’ is now known and familiar to
majority of the LB functionaries including Implementing Officers and Elected Representatives
at GP or MN level. During stakeholder consultations, it was observed that, the majority of the
functionaries are aware of the green concept projects after the effort of dissemination
trainings of MT audit findings at district levels. Although it is likely to take more time by the
LBs to make ESMF practical and implementable in its true effect, yet it is appreciable that the
sense of ESMF is currently accepted by the LBs to a great extent. It is understood that this
sensitisation is the result of various types of capacity building programmes adopted and
implemented by PMU in team effort with its District Units.
Various Capacity Buildings initiated by KLGSDP are discussed in detail in following
subsections.
8.1.1. State Level Trainings
State level trainings conducted by PMU are depicted in Table 8.1.
Table 8.1: State Level Capacity Building Programmes
Sl No Training Event Category of Participants
Duration of training
Date of training
No. of participants
1 Orientation training for District Co-ordinators and Execution Support Agencies
KLGSDP District Co-ordinators / Specialists of ESAs / District Planning Officers
2 day 12-13 July 2012
35
2 Orientation Training on ESMF and procurement for Block Engineers
LSGI Block Engineers
1 day 12th
September 2012
70
3 Orientation Training in ESMF and procurement for Municipal Engineers
Municipal Engineers
1 day 13th
September 2012
65
i Project Orientation Training for the KLGSDP District Co-ordinators and Execution Support
Agencies
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For the effective implementation of the Project, 14 District Co-ordinators were recruited
during July 2012. To make them aware about various components and activities of the Project,
a two day Project Orientation Workshop was conducted on 12th and 13th July 2012 at Institute
of Management in Government (IMG) Trivandrum. . The following participants attended the
programme.
14 newly recruited KLGSDP District Co-ordinators
14 District Planning Offices
Specialists from DAC and SIRD
ii Orientation Training on ESMF & Procurement for the LSGI Block Engineers:
As part of project implementation, the Assistant Executive Engineers at Block level are
assigned to provide technical assistance (engineering design, ESMF, procurement, contract
supervision, quality assurance) to individual GPs and Municipalities during preparation of
DPRs. In order to make them aware about the project, a one day Orientation training with
special focus on ESMF and Procurement procedures was organised by PMU on 12th September,
2012. The sessions were handled by PMU Specialists in association with World Bank Senior
Environment Specialist. The training was attended by 70 Block Engineers.
iii Orientation Training on ESMF & Procurement Procedures for the Municipal Engineers:
Similar to LSGI Block Engineers, a one day Orientation training on ESMF & Procurement
procedures was imparted to the Municipal engineers of all Urban Local Bodies by PMU on 13th
September, 2012. Sixty five Municipal Engineers attended in the training programme.
8.1.2. District level Orientation Training on ESMF & Procurement Procedures for the Support
Staff of LSGs:
During the inception of the project, orientation training was imparted only to the Presidents
and Secretaries of Local Self Governments by KILA during 2011. However, the grass root level
officials viz. Plan Clerks (Clerks dealing with KLGSDP Performance Grant Projects) and
Overseers directly involved in various stages of project formulation and field level
implementation, were left out from the first phase of capacity building programmes. As the
knowledge of KLGSDP activities is a pre requisite for the successful implementation of
Performance grant projects under KLGSDP, it has been proposed to impart training to the
support staff (Plan clerks & Overseers) of all 978 GPs and 60 Municipalities. The training were
planned to organise at District level. 14 District level Orientation training programmes were
conducted on a war foot basis spanning over a period of two months (September 10 -
November 15, 2012). Perhaps this was one of the major initiatives taken up by the PMU to
disseminate the idea of ESMF in the Performance Grant bringing all the LB functionaries (LB
Presidents / Chairmen, Secretaries, AEs & Plan Clerks who are the real stakeholders in
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project formulation, approval & implementation) in a common platform to spread the idea of
ESMF in a unified manner, so that during the process the spirit of ESMF integration is kept
intact mandatorily.
Details of these programmes are summarised in Table 8.2.
Table 8.2: District Level Capacity Building Initiatives
Sl No
Training Event Category of participants
Duration of training
Date of training
No. of participants
1 Orientation Training on ESMF and procurement procedures for the support staff of LSGs
Plan Clerk Overseers Asst. Engineers
1 day (14 batches)
September 10-15th November 2012
2637
2 Orientation training on Annual Performance Assessment (APA) for LSGI functionaries
Elected representatives, Secretaries, Assistant Engineers, Plan Clerks, Accountants
1 day (14 batches)
16th August to 8th September 2013
4934
8.1.3. Capacity of environmental auditors, LSGI functionaries and Implementing Officers
In addition to capacity building training programmes, workshops were held during MT Audit
and ET Audit. The Consultation Workshop on Environmental Audit was organised in
association with M/s. ULTRA-TECH. The participants include selected Block Engineers,
Implementing officials namely Secretaries, Municipal Engineers, Assistant Engineers and
Agriculture Officers of selected LSGIs covering all Districts, representatives of EA firm, District
Coordinators of KLGSDP and officials from KLGSDP Project Management Unit.
State and district level dissemination workshop on environmental audit findings were
organised at both MT and ET audit which helped in understanding stakeholders perspective on
audit finding and fine tuning the same.
8.1.4. Orientation Training for the newly elected LSG functionaries & Refresher Training for
the Implementation Officials:
An important initiative of PMU was the conduct of Orientation training to the newly elected
LSG functionaries and Refresher training for project Implementation Officials (Secretaries and
Engineers). Programs were conducted at District level. GP Presidents/Municipal Chairpersons,
LSG Secretaries and LSG Engineers were the participants. 12 such District level programs were
conducted .The sessions covered in the training are i) KLGSP an overview, ii) Procurement
procedures, iii) Environmental and Social Management Framework (ESMF) and iv) Vulnerable
Group Development Framework (VGDF) and Gender action plan. Various sessions were
handled by Specialists from PMU. Altogether 1948 LSG functionaries were trained in 12
programs. Out of this, 611 were elected representatives, 792 Secretaries and 545 Engineers.
8.1.5. Orientation training to the newly recruited District Coordinators of KLGSDP under
backward support grant
As part of implementation of sub projects under backward support grant, 11 new District
Coordinators were recruited by PMU. In order to orient them a two day Orientation training
was organised for the newly recruited District Coordinators during 14th – 15th October, 2016
at Maria Rani Centre, Trivandrum. The objective of the training was to orient the new District
Co-ordinators about the various components of KLGSDP with focus on Performance Grant and
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Backward LG support Grant. Besides, awareness was given on Procurement procedures and
ESMF guidelines – its rationale, protocols and procedures.
8.2 Comments on the strength and weakness found in the existing capacity building initiatives
Current capacity building initiatives were largely built around the efforts taken by PMU. PMU,
especially Environmental and Social Safeguard Specialist took sincere effort in conveying the
importance of ESMF to all, irrespective of position or designation. Role of District Coordinators
in reinforcing the ESMF concept during the screening process that they were doing as part of
the monitoring is also worth mention as they explored and utilised all available platforms like
DPC Meetings, DDP Conferences, Engineers monthly meetings etc. as avenues for
disseminating the ESMF concept as per the directions they received from PMU, time to time.
This was visible in the APA documents that majority of the LBs cleared the minimum
mandatory conditions (MMC) and performance benchmarks in ESMF compliance
documentation. Training became a much sought after programme in KLGSDP’s events. This
was well noted during audit when it was found that the word ESMF is so very well known to all
the stakeholders audit team met with.
Nevertheless, it was also observed by the audit team that support from KILA must be there in
organising refresher training on regular basis which is so very important for sustained
implementation of ESMF provisions. In departments where transfers are frequent, refresher
training and orientation training for new recruits were very important. This was found a weak
area in the current capacity building efforts.
Project authorities must make sure that whatever strengthening requires at KILA for training
and capacity building is provided to it. A notable suggestion in this regard is provision for
hiring of external/permanent faculty, as environmental compliance is most sought after theme
in the current scenario.
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