kulob solid waste sub-project – feasibility study · 2020. 8. 3. · chapter title page 1...

KULOB SOLID WASTE SUB-PROJECT

– FEASIBILITY STUDY

Non-Technical Summary

March 2016

Contents

Chapter Title Page

1 Introduction 1

1.1 Background __________________________________________________________________________ 1 1.2 Project Area and Context _______________________________________________________________ 1 1.3 Purpose of NTS _______________________________________________________________________ 3

2 Project Summary 4

3 Impacts and Mitigation Measures 8

3.1 General _____________________________________________________________________________ 8 3.2 Environmental and Social Management Review and Analysis ___________________________________ 8 3.3 National Environmental Law and Permits ___________________________________________________ 8 3.4 Benefits and opportunities of the Project ___________________________________________________ 9 3.5 Environmental and Social Impacts of the Project ___________________________________________ 10 3.5.1 Classification of Impacts _______________________________________________________________ 10 3.5.2 Socio-Economic Aspects _______________________________________________________________ 11 3.5.3 Community and Occupational Health, Safety and Security ____________________________________ 11 3.5.4 Community Relations and Conflict Management ____________________________________________ 12 3.5.5 Employment ________________________________________________________________________ 13 3.5.6 Occupational Health and Safety _________________________________________________________ 13 3.5.7 Land Acquisition and Economic Displacement ______________________________________________ 14 3.5.8 Ecology and Biodiversity _______________________________________________________________ 15 3.5.9 Water Resources and Water Quality______________________________________________________ 15 3.5.10 Waste Management __________________________________________________________________ 16 3.5.11 Chemicals and Hazardous Materials ______________________________________________________ 17 3.5.12 Soil Contamination ___________________________________________________________________ 17 3.5.13 Air Quality __________________________________________________________________________ 18 3.5.14 Landscape and Visual _________________________________________________________________ 18 3.5.15 Noise and Vibrations __________________________________________________________________ 19 3.5.16 Cultural Heritage _____________________________________________________________________ 19

4 Information Disclosure 20

4.1 How the Project Information Will Be Disclosed? ____________________________________________ 20 4.2 Grievances and Comments _____________________________________________________________ 21

5 Summary 23

Glossary 24

1

1.1 Background

The City of Kulob (“Kulob” or the “City”) has requested assistance from the European Bank

for Reconstruction and Development (the “EBRD” or the “Bank”) with a view to rehabilitate its solid

waste operations (the “Project”). The Project constitutes part of the Bank's solid waste framework

in Tajikistan, which already covers projects in Dushanbe, Khujand, Kurgan-Tyube and Tursun-Zade and

USD 4 million solid waste projects in Khorog and Nurek with respect to which loan agreements

with the Bank have been signed.

The benefits brought by the financing advanced by the Bank would serve to extend and improve the solid

waste operations in the City, in particular by:

� Providing the new equipment (waste collection bins, trucks, etc.) needed to improve the operating

efficiency and technical capacity of the landfill as well as the waste collection/transportation services;

� Funding civil works to re-develop the existing landfill or develop a new site1;

� Preparing a closure and monitoring plan for the existing landfill;

� Introducing institutional and strategic changes in waste management aimed at boosting

commercialisation and achieving full cost recovery;

� Assessing the feasibility of a landfill gas recovery system; if proven feasible and economically viable,

the landfill renovation will include the necessary infrastructure in preparation for a second investment

programme to utilise landfill gas for energy production.

The solid waste operations in the City are currently carried out by the Kulob-based branch office

of the State Unitary Communal Enterprise Khojagii Manziliyu Komunali (the “GUP KMK”), established

by the Order no. 132/7 of the General Director of GUP KMK on 13 January 2005 under the title „Дочернее

госудрственное предприйятие хочагии манзилию комунили города Куляб“, identification

no. 031128982 (the “Kulob GUP KMK”) within the territory of the City. The term “Company” used

in this Report means also any entity which might substitute Kulob GUP KMK in the provision of waste

management services in Kulob in the future.

The company 3G Consulting Engineers, s.r.o. (the “Consultant”) with its partners (sub-consultants) Mott

MacDonald CZ, spol. s. r. o. and CAI Consulting Tajikistan LLC and their sub-consultants was selected

by the Bank to conduct a feasibility study on the Project (the “Study” or the “Assignment”).

1.2 Project Area and Context

Kulob is located 203 km south-east of the Tajik capital of Dushanbe on the Yakhsu River (a right tributary

of Panj) at the foot of the Khazratishokh Range at 580 m above sea level. The City is the second largest

city in the Khatlon Province2 with a core population of approx. 100 thousand inhabitants (this is

the population NOT including the surrounding jamoats). Kulob consists of 59 neighbourhoods (mahallas).

1 This feasibility study should determine if there is an economic/environmental merit in developing a new landfill in a new location. 2 The province is naturally defined by the river Panj (upper Amu-Darya) and the Hazrat-e Shah range in the east, offshoots

of Tajikistan's central mountains in the north, the Teraklitag and Karatag ranges in the west, and again the Panj in the south, to which flows southward the Kizilsu (Sorkab), the main river of the region.

1 Introduction

2

Figure 1-1: Kulob Location

Source: Google Maps

The City is surrounded by four jamoats (rural settlements - municipalities) forming the District of Kulob

(Nohiya-i Kulob). The population of these jamoats is approx. 94,300 inhabitants, namely:

� Dakhana (Дахана) Jamoat with approx. 22 thousand inhabitants;

� Ziraki (Зираки) Jamoat with approx. 28 thousand inhabitants;

� Kulob (Кулоб) Jamoat with approx. 24 thousand inhabitants; and

� Zarbdor (Зарбдор) Jamoat with approx. 20 thousand inhabitants.

Solid waste operations in the City are carried out solely by Kulob GUP KMK and include:

� Municipal solid waste collection and disposal;

� Cleaning of urban areas (street cleaning); and

� Collection of septic tank contents (“septage”).

Municipal solid waste collection is only provided in the central parts of Kulob. About 35%-40%

of the population of the City have reasonably good access to the MSW collection service. No municipal

solid waste collection services are provided in the jamoats or the outskirts of the City.

The service for municipal solid waste management comprises:

� 89 roadside collection points (60% containerised) at which consumers can deposit their waste;

� Daily (overnight, six days in week) collection of waste; and

� Deposit of collected waste at the current landfill area / dump site.

The Company currently collects waste using four vehicles:

• One compacting waste collection vehicles: KAMAZ with side loader; and

• Three tractors each with one trailer – loose waste, no compaction.

All the collected waste is disposed of at the current landfill area, located about 4km Southwest of the City

centre. The landfill area comprises two “parts”:

3

� The area designated lawfully for landfill with the assistance of USAID over 10 years ago3; and

� An adjacent area which stretches from the designated (lawful) area to the road – this “unlawful” area

is about equal in area to the lawful area.

Both parts are owned by GUP KMK. The current landfill area contains about 120 thousand m3 of waste.

1.3 Purpose of NTS

One of the main objectives of this comprehensive Study was to identify the potential environmental and

social impacts of the proposed Project proposal (the “Investment Programme”) and, if necessary,

to recommend respective mitigation measures and strengthen environmental and social opportunities in

the Project Area.

The purpose of this Non-Technical Summary (the “NTS”) for the “Kulob Solid Waste Sub-Project” (Project)

is to provide an overview of key findings and conclusions of the environmental and social appraisal and

the results of the appraisal process, including assessment of investment sub-projects proposed to be

implemented in the City.

The Non-Technical Summary (NTS) is an important tool for informing affected communities on potential

environmental and social risks, impacts and benefits of the Project, and engaging key Project stakeholders.

The NTS is a document included in the Project’s disclosure package and prepared in line

with the Environmental and Social Policy of the Bank, issue May 2014 (the “E&S Policy (2014)”) and

respective Performance Requirements (“PRs”). The Project disclosure package also comprises

the Stakeholder Engagement Plan (the “SEP”).

3 The Current Landfill was built in 2005 as a medium term landfill and the Projected lifetime of the landfill was 10 years.

4

Alternatives for the management of solid waste in Kulob were considered for:

� Waste collection, including the extension of service coverage, the potential for separate collection and

the possible introduction of individual collection containers for each dwelling;

� The management of collection waste including the potential treatment of the waste for the recovery

of materials and energy;

� The optimal location of the disposal site; and

� The most appropriate means for the remediation of the current landfill site.

Bearing in mind the prevailing constraints in the Project Area, in particular the limitations of the investment

envelope, and the low level of household income (resulting in relatively low affordable tariffs),

a short-term investment programme has been developed as summarised here.

The proposed Investment Programme comprises four main elements:

� A. Construction of a new landfill in compliance with the Landfill Directive4 – see Figure 2.1 below

(the “Current Landfill”);

� B. Remediation of current landfill to eradicate public nuisance and minimise environmental

impacts – see Figure 2.1 below (the “Current Landfill”);

� C. Renovation of central depot to improve corporate management and staff welfare; and

� D. Extension and Improvement of the solid waste collection system to achieve 100% containerised

collection in the City and substantial improvements in efficiency and working conditions

through the provision of a new and larger collection fleet.

The proposed investments in the collection system entail:

� Collection points: concrete standing areas for the placement of containers,

– Renovation of existing collection points where needed (36),

– Construction of new collection points (360);

� Vehicles:

– 5 large side loading compacting refuse vehicles,

– 1 small side loading compacting refuse vehicle to service less accessible areas; and

� Containers:

– 720 metal GOST containers with lids.

Small additional investments in support of the street cleaning service are also proposed in this context and

comprise one street cleaning vehicle.

These investments will achieve 100% coverage of Kulob with waste collection (and disposal) services.

The Current Landfill area is (now) located too close to inhabited dwellings to be considered viable.

However, a secluded and hydrologically isolated valley immediately to the East of the Current Landfill area

has been assessed as being the most favourable development option. Detailed topographical, geological,

environmental and technical assessment of the site indicates its suitability for development as the new

sanitary landfill for Kulob (New Landfill).

4 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste as amended by Regulation (EC) No. 1882/2003.

2 Project Summary

5

Figure 2.1: Location of Current Landfill and proposed New Landfill

Source: Consultant (local investigations) and Google maps

The total volume of the projected New Landfill is 830,000 m3 of disposed waste.

Adjacent to the New Landfill, it is proposed to construct a “waste management centre”

(the “Waste Management Centre”). The Waste Management Centre will include:

� Entry – Exit area including weighbridge,

� Staff facilities,

� Parking for collection vehicles,

� Landfill gas flare, and

� Storage for materials and equipment.

The site will be constructed in accordance with the requirements for sanitary landfill being provided

in particular with a composite lining system, gas collection, leachate collection and surface water drainage.

The New Landfill will be provided with suitable equipment including a compactor and wheeled loader.

The New Landfill will be constructed as an engineered landfill in compliance with the Landfill Directive

(1999/31/EC, as amended).Options for remediation of the Current Landfill area were examined including

in-situ remediation and complete removal (as noted above re-development of the Current Landfill area is

not an acceptable option). A compromise option was selected as the most favourable whereby

the scattered waste mass closest to the road and the inhabited dwellings is to be consolidated

into the (adjacent) area of the (licensed) USAID funded landfill area and that this consolidated area be

remediated through:

� Re-profiling of all waste to form a self-draining mound;

� Installation of leachate catch drain;

6

� Installation of gas capture and connection of this to the Waste Management Centre system serving

the New Landfill;

� Cover layer over waste mass: two metres in depth/height with the lower layers being compacted

to provide a sealing layer;

� Re-cultivation layer and landscaping; and

� Peripheral surface water drainage.

The final aspect of the proposed Investment Programme is the improvement of the main operational

centre of the Company (the “Central Depot”).

Investments into the improvements needed at the Central Depot in Kulob are considered in four

categories:

� C.1 Reconstruction of the Yard Area,

� C.2 Reconstruction of the Administrative Building,

� C.3 Construction of New Workshop, and

� C.4 Construction of new Staff Welfare Facilities, and

� C.5 Equipment.

The investments have been compiled into packages and contingencies applied as shown in the following

table:

Table 2.2: Cost summary of Investment Programme – per procurement and investment category

Ref Type Title Base Price

TJS

Base Price

USD

Contingency

USD

Total

USD

1 Works New Landfill Works 10,415,980 1,735,997 173,600 1,909,596

2 Works Old Landfill Remediation Works 2,979,000 496,500 49,650 546,150

3 Works Central Depot Works 535,200 89,200 8,920 98,120

4 Works Collection Points Works 438,228 73,038 7,304 80,342

5 Supply Landfill Plant and Equipment 2,182,000 363,667 18,183 381,850

6 Supply Waste Collection Vehicles, Minibus, Pickup

4,180,000 696,667 34,833 731,500

7 Supply Containers 1,080,000 180,000 9,000 189,000

8 Supply Furniture and Administrative Equipment 30,000 5,000 250 5,250

9 Supply Information Technology Software 150,000 25,000 1,250 26,250

10 Supply Information Technology Hardware 120,000 20,000 1,000 21,000

11 Supply Personal Protective Equipment 60,000 10,000 500 10,500

22,170,408 3,695,068 304,490 3,999,558

Source: Consultant

In considering the implementation process, it must be emphasised that a key pre-requisite is

the establishment of a new institutional structure whereby, a new waste management company is

established under the City, and that the staff and assets of the current Kulob GUP KMK responsible

for waste management and street cleaning are transferred to the new municipal company.

7

Notwithstanding the comparatively straightforward nature of the proposed Project, it entails very

substantial changes for the Company and for consumers who have not previously had access to the waste

collection service. Therefore, it is proposed to procure and implement the Investment Programme

over a two to three-year period whereby waste collection services are expanded at the beginning of 2017,

2018 and 2019.

The establishment of the Project Implementation Unit (“PIU”) and the contracting of corporate

development support are envisaged for the second half of 2016.

8

3 Impacts and Mitigation Measures

3.1 General

This section provides a summary of the Environmental and Social Appraisal (the “ESA”) findings,

the Investment Programme opportunities, potential impacts and mitigation measures to address and

prevent environmental and social issues and risks. Mitigation measures are described in the Environmental

and Social Action Plan (the “ESAP”) which represents a roadmap for addressing anticipated impacts and

enhancing general environmental and social performance of the Company. It forms a solid basis

for managing environmental and social issues at all phases of the Investment Programme.

Furthermore, all information provided in this document, including environmental and social impacts, will be

disclosed and communicated to affected communities via consultation and disclosure activities identified

in the Stakeholder Engagement Plan (the “SEP”). The SEP programme and the description

of the grievance mechanism developed for the purpose of receiving and handling any concerns, questions,

comments and suggestions from the affected communities and other stakeholders throughout the life

of the Project are provided in Chapter 4.

3.2 Environmental and Social Management Review and Analysis

The ESA for the Investment Programme measures was carried out in compliance with the applicable

requirements of the national law, the EBRD E&S Policy (2014), and EU guidelines. The key findings and

conclusions of the appraisal are summarised below.

3.3 National Environmental Law and Permits

The national procedure of Environmental Impact Assessment (the “EIA”) of the Investment Programme

measures has not been carried out at this stage, since under the current requirement of the national

environmental law no measures contained in the Investment Programme are subject to the national EIA

procedure.

The main requirement under the legislation of the Republic of Tajikistan is the availability of necessary

permits, such as permission to emit pollutants, in particular:

� Air emissions;

� Discharging pollutants into bodies of water; and

� Limits on waste disposal.

Thus far, the Company has obtained the following orders and decisions (conclusions) for the Current

Landfill construction and land acquisition:

� Order of the Mayor of Kulob №173 dated 28 May 2004 on the allocation of land for the City landfill,

of which 3 hectares of arable land and 1 ha pastures.

� Conclusion of the Kulob City Electric Networks to consent the selection of 4 hectares of land

for municipal landfill.

� Conclusion of the Environmental Protection Department of Kulob that the landfill does not harm

the environment in Kulob, toxicity class of solid waste - IV, a capacity of 50 thousand m3/year.

� Conclusion of the Department of Agriculture of the Kulob region agreeing on the choice of land

for the landfill.

9

� Conclusion of the Kulob Vodokanal Kulob that the landfill meets the water utility requirements for its

construction.

� Conclusion of the Sanitary and Epidemiological Service of Kulob to follow landfill sanitary and

epidemiological rules 245 and 92-94 of sanitary norms, structures at the dump pits for dead animals.

� Conclusion construction and urban planning department of the Kulob City to consent to the choice

of land for landfill.

� The consent of the Chairman H. H. S. Zarifov and HH Khatlon on allotment of land for the landfill site.

� Acceptance of the Commission under the Kulob Mayor of 4. 4. 2004 on the allocation of land

for the landfill with a document about the choice of site for the construction of the landfill. As a result,

the Commission adopted a decision to satisfy the request to allocate 4 hectares of land to build

the landfill. The construction of landfills is scheduled to the 2,700th meeting of Kulob.

Signatures of members of the Commission - the parties under concern: The Mayor of the City, the

environment, water utility, sanitary epidemic station, etc.

Licenses for the Current Landfill

License №5 dated 3. 4. 2006 issued by the State Committee for Environmental Protection and Forestry

under the Government of Tajikistan, Kulob gave the right to waste management in the period

up to 3. 4. 2011.

License №003/013 dated 4. 6. 2013 issued by the State Committee for Environmental Protection

under the Government of Tajikistan valid for 5 years before 4. 6. 2018. The license gave Kulob GUP KMK

right to collect, use, decontaminate, transport and dispose of hazardous waste at the Current Landfill.

At the same time it noted the need to comply with all sanitary and environmental requirements

under the laws of the Republic of Tajikistan.

State Environmental Expertise on Land Selection for the City Landfill (3 October 2005)

The State Environmental Expertise Committee for Environmental Protection and Forestry

under the Government of the Republic of Tajikistan № 444-24 dated 3. 10. 2005, on the location

of the City landfill in Kulob.

Permissions for discharging pollutants into bodies of water and air emissions were not identified.

3.4 Benefits and opportunities of the Project

Implementation of the Investment Programme will provide environmental benefits and improve social

conditions in the Project Area.

The benefit brought by the financing advanced by the Bank would serve to extend and improve the solid

waste operations in the City, in particular by:

� Providing the new equipment (waste collection bins, trucks, etc.) needed to improve the operating

efficiency and technical capacity of the waste collection/transportation services;

� Funding civil works to develop a New Landfill site, including the operational equipment and facilities

required to operate the landfill;

� Remediating the Current landfill;

10

� Introducing institutional and strategic changes in waste management in order to improve

commercialisation and achieve full cost recovery; and

� Investment in landfill gas collection infrastructure at both the Current and New Landfill in order

to collect landfill gas, which will initially be flared, pending investment in electricity generation

equipment

in 2024, once gas generation from the new site is such as to make the investment in generation

equipment financially beneficial.

The key positive effects arising from the Investment Programme will include:

� Improved quality of life across the Project Area through provision of reliable waste management

services and infrastructure across the whole City (as opposed to the current 35-40% coverage);

� Reduction of community health and safety risks associated with improper waste management

practices; improvement in security provisions for the Company’s assets and operational sites;

� Reduction of environmental impacts in respect to land, air and water contamination;

� Improved natural resources management and introduction of modern low-energy equipment, decrease

in energy consumption;

� Improved working conditions and enhanced Occupational Health and Safety (“OHS”) performance

at the Company’s facilities;

� Employment generation at contractor companies for the period of construction;

� Procurement opportunities generated for national and local businesses during the implementation

of the Investment Programme; and

� Reduction of greenhouse gas emissions.

In addition, the implementation of the Investment Programme will provide additional benefits that will

help the Company to successfully manage associated risks and improve environmental and social

performance in general. Thus, the Company will:

� Implement an integrated management system or its components in compliance with international ISO

14001 (environmental management) and OHSAS 18001 (occupational health and safety management)

standards

� Monitor environmental, social, and OHS performance of the contractors / subcontractors / suppliers

for compliance with international standards

� Strengthen the Human Resources (“HR”) management system including implementation of the HR

policy and grievance mechanism to manage workers’ and community concerns and grievances

� Implement an effective waste management and monitoring system

� Renew and improve the maintenance equipment and vehicle fleet

Generally, implementation of such measures draws attention both to the City and the Company and can

create good history for further investments in MSW projects and thus contribute to development of the City

and neighbouring communities.

3.5 Environmental and Social Impacts of the Project

3.5.1 Classification of Impacts

The review and appraisal of the proposed Investment Programme have identified a number of potential

environment and social impacts. Key potential impacts have been classified under the following groups:

11

� Socio-economic aspects,

� Occupational health and safety,

� Land acquisition and economic displacement,

� Ecology and biodiversity,

� Water resources and water quality,

� Waste management,

� Chemicals and hazardous materials,

� Soil contamination,

� Air quality,

� Landscape and visual,

� Noise and vibrations, and

� Cultural heritage.

3.5.2 Socio-Economic Aspects

The expected socio-economic impacts are primarily associated with such aspects as:

� Community and occupational health, safety and security;

� Community relations and conflict management;

� Employment.

3.5.3 Community and Occupational Health, Safety and Security

Construction

Construction of the infrastructure can directly affect pedestrian and vehicle traffic in vicinity of the New

Landfill, Company Depot and reconstructed or newly built collection points. Closures of roads and other

traffic restrictions and cumulating traffic in some other parts of the City can result in delays, more

complicated access to economic and social infrastructure, increased local ecological burdens as well

as reduced traffic safety. Demolition of old infrastructure which can contain also hazardous materials

like asbestos and construction of new one could have negative health impacts on people living or working

in the vicinity of construction areas. Unauthorised access to construction sites and character of construction

works also increase risks of injuries.

To minimise the aforementioned impacts, the following mitigation measures have been proposed to:

� Prepare a corresponding traffic management plan with minimized traffic impediments;

� Provide timely information and clear instructions including safety signs;

� Build necessary barriers/fences;

� Install pedestrian guardrails and proper lightning wherever it is necessary;

� Arrange transportation activities during day time;

� Clean regularly access ways in the work sites vicinity and maintain the roads; and

� Prevent unauthorised access and provide security guards at the facilities.

Operation

Improper operation of waste collection system (e.g. waste collection points) can directly and indirectly

affect personnel as well as community health. Community health is under potential threat in all the stages

12

of solid waste handling from its collection, through transportation to disposal. MSW is taking place

in a working environment which is dangerous. Handling solid waste is potentially leading to occupational

diseases and accidents without corresponding health and safety regulations, industrial hygiene and fire

safety.

The following measures will help to reduce potential impacts:

� Development and implementation of a set of organizational and technical measures preventing waste

management system failures which could affect community and personnel health; and

� Support of safe working environment through adaptation and proper implementation of occupational

health and safety (OHS) instructions including the relevant job training.

3.5.4 Community Relations and Conflict Management

Construction

Construction and rehabilitation works will cause nuisance, which may result in community grievance. Weak

communication resulting in a low level of awareness on different restrictions and interventions to personal

rights during construction stage and unclear grievance mechanisms could generate misunderstandings

with particular potential to cause conflicts.

The following measures will help to reduce potential impacts:

� Building a functioning community information system;

� Control of disclosure and public consultation activities in compliance with the Stakeholder Engagement

plan (SEP); and

� Implementation of community grievance mechanism;

Operation

No potential conflicts are expected to arise since the Investment Programme is generally focused

at improving the quality of services. Nevertheless, insufficient communication and low awareness on proper

handling of solid waste and related impacts and risks during operational stage and unclear community

grievance mechanism could decrease the effectiveness of the entire MSW system, the quality of provided

services and generate misunderstandings or disappointment with customers. To minimise

the aforementioned impacts, the following mitigation measures have been proposed:

� Accommodation of community information system;

� Preparation of an information plan for the operational stage of the Project comprising also regular

community consultations and regular maintenance of the Information boards;

� Implementation of the information plan including provision of regular community consultations and

ensuring maintenance of the Information boards with timely updated information;

� Accommodation and implementation of the community grievance mechanism for the operational stage

of the Project; and

� Monitoring and evaluation of consumer satisfaction.

13

3.5.5 Employment

Construction

Construction of the MSW infrastructure will have a direct as well as indirect positive impact on local labour

market bringing new local employment opportunities. Misbalance on the local labour market characterized

by a high level of unemployment arouses the threat of conflicts between local jobseekers and non-resident

workers and discrimination, exploiting and unfair treatment of particular parts of labour force available or

employed.

Construction works employment opportunities are primarily assumed for the local labour force.

To minimise the aforementioned impacts, the following mitigation measures have been proposed to:

� Create conditions for preferential employment of the local labour force on construction works including

women in both qualified and unskilled labour positions;

� Develop and implement an unbiased, non-discriminatory human resources policies ensuring working

conditions, remuneration and social standards in compliance with national legislation; and

� Monitor and supervise permanently implementation of the HR policy principles.

Operation

The operational phase should also have a positive impact on local labour market through new employment

opportunities for operational and maintenance works and supplementary services like guarding

the Company Depot and New Landfill. Employment opportunities within the operational phase

of the Project are primarily assumed for the local labour force. High demand for employment in the City

and its vicinity can lead to discrimination, exploiting and unfair treatment of particular parts of labour force

when recruited, hired or employed.

� The following measures will help to reduce potential impacts: Create conditions for preferential

employment of the local labour force for operating and maintenance of the system and providing

supplementary services;

� Adaptation and implementation of a human resources policy of the Company to avoid discrimination,

adaptation and implementation documented staff grievance mechanism, unbiased working conditions

standards and guaranteeing non-discrimination, and equal opportunities and treatment;

3.5.6 Occupational Health and Safety

Construction

Construction of the infrastructure can affect occupational health and safety increasing related risks. OHS

potential adverse impacts and risks are related in particular to demolition and construction activities

generating different kinds of emissions, noise pollution, and risks of injury, and potentially requiring work

with hazardous materials.

Occupational health and safety mitigation measures during construction include:

� Provision of mandatory recruitment/assignment of the Health and Safety Executive (“HSE”)

14

officer/engineer/manager responsible for day-to-day compliance with OHS/HSE requirements,

� Creation of safe on-site working conditions;

� Conducting regular safety briefings and trainings with workers involved in demolition and construction

works;

� Provision of personal protective equipment provision and monitoring of their use; and

� Monitoring and control dangerous materials safety handling and its compliance with the OHS

requirements.

Operation

Potential occupational health and safety risks associated with MSW operations at all facilities

of the Investment Programme are in particular the risk of injury and health hazards related to handling

solid waste as a hazardous material.

To minimise the adverse impacts, the following mitigation measures have been proposed to:

� Develop organizational and technical measures to create safe working environment;

� Develop gender responsive OHS measures which would ensure considering women-specific needs,

as identified through full engagement of women as stakeholders throughout the Project lifecycle;

� Adopt safety instructions;

� Conduct regular trainings in health and safety regulations, industrial hygiene and fire safety; and

� Provide personal protective equipment and supervise its use by all workers involved in operations.

3.5.7 Land Acquisition and Economic Displacement

Construction

Construction of the infrastructure can directly and indirectly affect the rights of land ownership including

soil and vegetation damage or even devaluation of the given estates. Significant impact could also arise

for economic activities in the area or vicinity of construction due to the emissions, pollution and restriction

of access to economic facilities (e.g. shops or offices). As such the construction works are associated

with the risk of property rights restriction and/or potential economic displacement.

To minimise the aforementioned impacts, the following mitigation measures have been proposed:

� Development and implementation of the documented procedure for checking all land rights and

any restrictions relating to construction work, application of sanitary protection zone requirements and

other limitations in the case of any collection points and facilities reallocation; and

� Avoiding or minimalizing any impact of any Investment Programme sub-project on private and

economic activities of nearby land users or entrepreneurs, e.g. through the land re-cultivation or

compensations.

Operation

Operation of the waste collection system (e.g. waste collection points) can affect the rights of land

ownership including soil and vegetation damage or even devaluation of the given estates. It can also have

a significant impact on private and economic activities of nearby land users or entrepreneurs and require

compensations.

15


� Adaptation and implementation of the documented procedure for checking all land rights and any

restrictions relating to operation and maintenance of the collection system.

3.5.8 Ecology and Biodiversity

Construction

Minor biodiversity impact is anticipated during the construction phase mainly by noise coming from civil

works and transportation of materials, and increased emissions from vehicle movement. The avoidance

of construction works at night time will prevent disturbance for the night fauna.

An ecological survey aimed at the protected species identification on and nearby the Company sites and

Investment Programme sub-projects will be provided. Procedure requirements in respect to the preventive

measures for biodiversity conservation and permitting provisions which are to be undertaken

during the construction stage will be developed. These requirements will be included into the construction

tender documentation for the implementation of the Investment Programme.

Operation

The implementation of the Investment Programme will have a small direct impact on wild fauna species

(e.g. nesting of birds in walls of loess quarries). Fencing of the New Landfill and remediated Current

Landfill will be required.

3.5.9 Water Resources and Water Quality

Construction

Earthworks and construction machinery will be required at the rehabilitation phase of the Current Landfill

and construction of the New Landfill. Associated impacts such as fuel and lubricant spills from vehicles and

machinery, waste handling, soil erosion and sedimentation are estimated as moderate due to absent

management procedures and can be mitigated to minor via application of the good construction practices

and appropriate mitigation measures.


� Development of procedures for dealing with ground masses and monitoring during the construction

period;

� Using good approaches to the building process during excavation/construction works;

� Implementation of earthworks under normal weather conditions, i.e. at low wind speed and no rain

conditions to minimize the amount of wind- blown dust and eliminate erosion of soils;

� Timely elimination and prevention of potential spills from machinery on site; and

� Development of an accurate record-keeping process to document the construction, installation phases

of the New Landfill.

16

Operation

Potential impacts associated with waste disposal into the New Landfill are considered to be negative,

as spills of fuel and leachate can get into the soil.

As a result of the Investment Programme, all water infiltrated into the New Landfill will be collected

in landfills pits, its composition will be frequently monitored and based on its composition possibly reused

at the landfill or treated at the waste water treatment plant. Together with favourable geological

conditions (impermeable loess loam) this would reduce the impact on groundwater and surface water.

Purchase of analytical equipment will allow for better control of wastewater composition.


� Measures to prevent the infiltration of storm water into the landfill body and controlled surface water

runoff;

� Development and implementation of procedures for oil spill elimination;

� The landfill staff will be familiar with operation plan and emergency response plan of the landfill; and

� Minimization of open active zone of the landfill and frequent monitoring of the landfill seal.

3.5.10 Waste Management

Construction

Construction waste will be generated during remediation of the Current Landfill, reconstruction

of the Central Depot, construction of the New Landfill and waste collection points. Generated waste will

contain mostly non-hazardous materials. In the Central Depot surfaces contaminated with total petroleum

hydrocarbons, used oils, lubricants and asbestos sheets were identified.

The proposed mitigation measures include:

� Development of procedures for earth masses and waste from the Current Landfill;

� Treatment and monitoring plan during the construction period;

� Using the best approaches to the organization of construction process in accordance with local

regulations and international recommendations. Monitoring the work of the Contractors in respect

of waste management and recycling;

� Development of waste management plan;

� Hazardous waste must be collected separately and disposed of appropriately; and

� Asbestos waste must be disposed of in a timely manner to a special landfill.

Operation

The basic principle of the Investment Programme is to significantly improve waste management practices

of the Company and to significantly decrease its impacts on public health and the environment

Appropriate waste management practices and handling should not present significant negative impact

on the environment.

17

Compared to current waste management practices, the Investment Programme will significantly improve

living conditions and environment in Kulob.

3.5.11 Chemicals and Hazardous Materials

Release of chemicals may occur during welding, machine works, repair, car maintenance and running

of engines both during construction and operation stages.

Mitigation measures include:

� Absorbent material (and fire-fighting equipment) must be available for cases of incidental spill or leaks;

� Procedures for storage and handling of waste, hazardous wastes and raw material (e.g. batteries,

lubricants, chemicals, fuel) must be developed and implemented; and

� Chemicals and hazardous chemicals should be stored in Central Depot on a secured, paved and roofed

area.

3.5.12 Soil Contamination

Construction

Earthworks and construction machinery will be required during construction of the New Landfill,

reconstruction of the Central Depot and construction of collection points.

Compared to the current situation remediation of the Current Landfill will present significant improvement

regarding soil contamination.

Impacts such as fuel and lubricant spills from vehicles and machinery, waste handling, soil erosion and

sedimentation are estimated as moderate due to absent management procedures and can be mitigated

to minor via application of the best construction practices and appropriate mitigation measures.


� Topsoil removal and storage in separate piles;

� Proper maintenance of transport and construction equipment;

� Storage of fuel in leak-proofed tanks, installed on impermeable surface;

� Maintenance, fuelling and cleaning of vehicles and equipment done at workshops/sites with adequate

leakage prevention;

� Absorbent material (and fire-fighting equipment) must be available for cases of incidental spill;

� Procedures for storage and handling of waste, hazardous wastes and raw material (e.g. batteries,

chemicals, fuel);

� Application of appropriate erosion-protection measures such as silt screens.

Operation

Potential impacts may be linked with contamination of soil by accidental spills of petroleum products.

Compared to the current situation there will be significant improvement regarding soil contamination

on Current Landfill, Central Depot and waste collection points.

18

Mitigation measures:

� In case of accidental oil spills, appropriate remediation measures must be taken;

� Regular inspections for leakages must be carried out.

3.5.13 Air Quality

Construction

Emissions from vehicles and machinery may lead to a temporary increase in the concentration of pollutants

in the air, in the zone for construction and adjacent areas. Emissions of asbestos dust may be generated

during the rehabilitation of the Central Depot (roofs).

Dust generated during construction and vehicular traffic, may extend beyond the site and could potentially

have an impact on human, soil and vegetation. The impact can be enhanced under extreme weather

conditions.


� Use of vehicles with a valid technical inspection (emission check);

� Minimization of traffic flow interference from construction activities;

� Proper maintenance and tuning of construction machinery and equipment;

� Minimization of idling time to save fuel and reduce emissions;

� Emission concentration monitoring;

� Implementation of appropriate dust abatement measures, such as: Prevention of dust

through sprinkling during periods of dry weather;

� Limitation of work sites and duration of works; and

� Daily cleaning of access ways in the neighbourhood of work sites to prevent dust.

Operation

The increase in air emissions while increasing car fleet and operation of flare on the New Landfill site. Dust

and odour will be generated predominantly on the New Landfill and waste collection points and other

wastes removal activities and transport for final disposal.


� Evaluation of the emission of pollutants, prohibition to work idling equipment.

� Prevention of dust on the New Landfill through sprinkling during periods of dry weather.

� Cleaning of roads on waste transport routes and waste collection points form dust and loose waste.

3.5.14 Landscape and Visual

Construction

Visual impact is anticipated for inhabitants of the Nurbakh village which is located at the distance

of approximately 350 meters from the New Landfill site beyond the natural barrier made of a hilly terrain.

No impacts are anticipated for the Central Depot and the collection system. No mitigation measures are

19

required.

Operation

The site of the Current and New Landfills is located between two hills north and south, that serve

as natural barriers. However, the site is visible from the nearby human settlements. The natural visual

barrier of the Current Landfill is damaged by excavation works of loess performed by inhabitants of nearby

settlement. Therefore, it is recommended to rehabilitate the natural visual barrier.

3.5.15 Noise and Vibrations

Moderate noise impact will be associated with various construction and rehabilitation activities such

as earthworks and vehicle movements. Noise impact during the operation phase is expected to be

intermittent on waste collection points and waste disposal into the New Landfill and associated activities.

Use of low noise and vibration installations and equipment is recommended.

The ESAP proposes the following mitigation measures:

� Apply silent (or low-noise) equipment;

� Carry out construction / rehabilitation works during day time;

� Provide site briefings in how to keep noise to a minimum; and

� Prohibit idle running of machinery.

3.5.16 Cultural Heritage

In the Project Area there is minimum number of objects of local cultural values. The risks of exposure

of such objects with the impact on the Project can be assessed as low.

If any chance find occurs during the construction earthworks, the contractor has to follow the national

legal requirements including temporary termination of works, informing the responsible authorities and

other associated steps. This requirement is to be included in the construction tender documentation.

20

4.1 How the Project Information Will Be Disclosed?

Public consultation and ongoing stakeholder engagement will be arranged throughout the life

of the Investment Programme. The Stakeholders Engagement Plan (SEP) has been developed to identify

key stakeholders and communicate to the communities the nature of the Project, including information

on its environmental and social impacts. The SEP will be regularly reviewed and updated

during implementation of the Investment Programme. If any new measures are included in the Investment

Programme or previously proposed projects need to be amended, the SEP will be updated and

stakeholders advised accordingly.

The SEP is organised to provide:

� Brief Project Description,

� Applicable requirements (of national and international requirements for consultation and disclosure),

� Stakeholders Identification and Analysis,

� Summary of previous stakeholder engagement,

� Stakeholder engagement and information disclosure programme,

� Stakeholder engagement timescales and responsibilities,

� Project grievance mechanism,

� Workers’ grievance mechanism, and

� Monitoring and reporting (with regard to the SEP).

Project information to be disclosed and disclosure methods used during the Project preparation stage

include: � Information on the purpose, nature and scale of the Investment Programme, its programme and scope

through the SEP and NTS documents in Tajik, Uzbek, and Russian languages via the City Hall’s

information board and in hard copy directly to affected communities and City councillors. For other

stakeholders the hard and electronic copies of the documents will be also made available upon request

in the Project Implementation Unit (“PIU”), City Hall and City libraries throughout the lifetime

of the Investment Programme.

� An opening event in Kulob promoted as the Solid Waste Management Platform will be conducted. Its

location and date to be announced in adverts, City Hall, Project Room, Company offices. Community

members, representatives of City council, district administration, environmental and social protection

authorities, local non-governmental organizations (“NGOs”) and civil society organisations will be

invited to attend. The Company will present information about the Project and its potential impacts,

proposed mitigation measures and benefits there.

� Project notice board to be installed in the entrance hall of the City and presented information regularly

updated.

� Company’s Customer Service Centre to be established in the City Hall building.

� Disclosure of Project information through the media will have a form of press releases or will be done

in other format on request

� Face-to-face meetings with mahallas and NGO representatives will be organized and supplemented

by informational letters and direct contact through email and phone or other media, as appropriate;

� Communications with local communities in the Project Area and collecting comments and suggestions

is proposed on the basis of weekly grievance reporting to the PIU Project Manager.

4 Information Disclosure

21

Project information to be disclosed and disclosure methods used during the Project implementation

preparation stage are to include:

� Pre-announcements of potential disruptions, construction works, changes in MSW collection

scheme/schedule, potential impacts, nuisances and mitigations in a form of printed document locate

by operational services at visible places (Project Room, Company´s office, notice boards of apartment

blocks, leaflets or letters dropped to households, etc.);

� Provision of information on management of construction impacts, monitoring reports and annual

reports summarizing Project performance, activities of the Community Liaison Officer (“CLO”),

grievances and the SEP updates through the Company’s Customer Service Centre; and

� Presentation of any SEP updates at information board in the City Hall and Project Room.

Presentation of information on the Project and proper MSW and its importance in schools in the form

of visits to the company when new equipment and means of transport received, peer to peer education

for primary and secondary school children, organizing contest drawing/essays writing on MSW themes

in local schools, developing leaflets and/or brochures on MSW in a user (children) friendly language, which

may include pictures/parts of the texts received from schoolchildren during the contest, etc. The Company

will appoint a dedicated Community Liaison Officer (CLO) who will be responsible for meaningful

interaction with the affected communities and interested stakeholders during the lifetime

of the Investment Programme. The CLO will be responsible for the functioning and control of the formal

logging system where grievances related to the Investment Programme will be classified and registered.

The CLO will organise meetings with local stakeholders to inform them of the Investment Programme

progress, performance, benefits and impacts.

Any questions, comments, grievances and suggestions related to the Investment Programme can be

communicated directly to the CLO by post, e-mail, fax or telephone or via specified contact details.

4.2 Grievances and Comments

A Project Grievance Mechanism has been developed to address stakeholders’ concerns related

to the Investment Programme.

Information about the Project grievance procedure, whom to contact and how will be made available

at the Company on its website, at the Project Room, on the Project’s noticeboard and Customer Service

Centres at the City Hall and the Central Depot.

Grievances will be logged in a formal logging system for which the CLO will be responsible. People may

register grievances using the form contained in Appendix B to the SEP or by contacting the Community

Liaison Officer (contact information: to be completed at the next stage of the Project) or Emergency and

Operations Control Centre (“EOCC”) of the Company (contact information: to be completed at the next

stage of the Project).

The CLO will classify grievances according to the Grievance classification criteria as low, medium and high

(significance given by the potential risk level) and process them in concordance with the Flowchart

for Processing Grievances presented in the SEP. In cases where investigations are required, Project staff

and outside authorities will assist with the process, as appropriate. The CLO will collaborate

22

with the Company management to identify an appropriate investigation team with the correct skills

to review the issue raised. The investigation will also aim to identify whether the incident leading

to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities,

procedures, equipment and training to address and prevent reoccurrence will comprise part

of the investigation activities.

The CLO will explain in writing to the complainant (or orally, where more appropriate, such as when

literacy is an issue) the review process, the results, and any changes to activities that will be undertaken

to address the grievance and how the issue is being managed to meet appropriate environmental and

social management systems.

All grievances will be considered within 7 days and responses will be provided within 30 days.

The procedure will be gratis and without retribution of the Project to the affected persons and

stakeholders.

23

The Environmental and Social Appraisal for the Project comprises:

� Environmental and Management Review,

� Environmental and Social Analysis,

� Performance Requirements Compliance Table,

� Environmental and Social Action Plan (ESAP),

� Stakeholder Engagement Programme (SEP), and

� This Non-Technical Summary (NTS).

The Study has identified a number of benefits, opportunities and impacts associated with the proposed

Investment Programme.

The positive effects of the Project will be significant and unchallenged. The implementation

of the Investment Programme will improve the existing MSW system and introduce first stage of a new

MSW infrastructure building, reduce the overall negative impact on the environment, improve

the environmental performance of the Company, minimise costs, increase energy efficiency and enhance

monitoring and control.

Social opportunities to be brought in by the Project are associated with the enhanced quality and reliability

of MSW services, better working conditions, new jobs for local communities, increased public awareness

and enhanced interaction with the key Project stakeholders.

Nevertheless, demolition, (re-)construction and subsequent operation of the MSW infrastructure will be

associated with a number of environmental and social impacts. In general, potential environmental and

social impacts are estimated to be minor or moderate and the proposed mitigation measures will help

to reduce or prevent anticipated risks.

In compliance with the EBRD's requirements the Company has prepared the disclosure package to inform

communities and other stakeholders of the proposed Investment Programme. This includes as follows:

� Non-Technical Summary (this document);

� Stakeholder Engagement Plan – a programme of actions to engage stakeholders and communicate

the information of the Project.

The disclosure package is available to the public via the through the SEP and NTS documents in Tajik,

Uzbek, and Russian languages via the City Hall’s information board. The hard copies of the documents will

be distributed directly to the representatives of affected communities and City councillors. For other

stakeholders the hard and electronic copies of the documents will be available upon request in the Project

Implementation Unit (contact information: to be completed at the next stage of the Project) City Hall

(contact information to be completed at the next stage of the Project) and City libraries (contact

information to be completed at the next stage of the Project).

5 Summary

24

Assignment (or Study) Tajikistan: Kulob Solid Waste Sub-project - Feasibility Study,

C31592/CZDT-2015-02-02

Bank (or EBRD) European Bank for Reconstruction and Development, with its

headquarters at One Exchange Square, London EC2A 2JN, United

Kingdom

CLO Community Liaison Officer

Company (or Kulob GUP

KMK)

Kulob-based branch office of KMK established by the Order no. 132/7 of

the General Director of GUP KMK on 13 January 2015, Id. No.

031128982

Consultant 3G Consulting Engineers, s.r.o. with its partners (sub-consultants) Mott

MacDonald CZ, spol. s. r. o. and CAI Consulting Tajikistan LLC and sub-

consultants

Current Landfill existing landfill at the south-eastern edge of the City as as shown in

Figure 2.1 in this Report

District of Kulob the City and four adjacent jamoats of Kulob, Ziraki, Dakhana and

Zarbdor

EBRD (or Bank) European Bank for Reconstruction and Development, with its

headquarters at One Exchange Square, London EC2A 2JN, United

Kingdom

E&S environmental and social

EHS environmental, health and safety

EIA Environmental Impact Assessment

EOCC Emergency and Operations Control Centre

ESA Environmental and Social Appraisal

ESAP Environmental and Social Action Plan

ESMP Environmental and Social Monitoring Plan

ESP (2014) Bank's Environmental and Social Policy, May 2014 edition

EU European Union

GOST refers to a set of technical standards maintained by the Euro-Asian

Council for Standardization, Metrology and Certification (EASC), a

regional standards organization operating under the auspices of

Commonwealth of Independent States

GUP KMK State Unitary Communal Enterprise Khojagii Manziliyu Komunali

HR Human Resources

Glossary

25

HSE Health and Safety Executive

Investment Programme Project’s priority investment programme proposed by the Consultant

under the Assignment

ISO International Standards Organization

Kulob (or City) City of Kulob

Kulob GUP KMK (or

Company)

Kulob-based branch office of KMK established by the Order no. 132/7 of

the General Director of GUP KMK on 13 January 2005, Id. No.

031128982

MSW municipal solid waste

New Landfill new landfill to be constructed under the Project to be located above the

Current Landfill as shown in Figure 2.1 in this Report

NGO Non-Governmental Organization

NTS Non-Technical Summary

OHS Occupational Health and safety

PIU Project Implementation Unit

Project Bank's project to rehabilitate solid waste operations in Kulob and its

surroundings

Project Area territory of the City and the 4 jamoats covering the District of Kulob

PRs Performance Requirements of the Bank (EBRD) under the Environmental

and Social Policy of the Bank (2014)

Report this Report, i.e. Non-Теchnical Summary report as Part 4 of the

Environmental and Social Appraisal under the Assignment

SEP Stakeholder Engagement Plan

Study (or Assignment) Tajikistan: Kulob Solid Waste Sub-project - Feasibility Study,

C31592/CZDT-2015-02-02

TJS Tajikistani Somoni

USD United States Dollar

USAID United States Agency for International Development, www.usaid.gov

Waste Management Centre a new waste management centre to be built under the Project at the

entrance to the New Landfill

kulob solid waste sub-project – feasibility study · 2020. 8. 3. · chapter title page 1...

Documents