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 Introduction

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 site 1; ° 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 Province 2 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.

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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”:

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° The area designated lawfully for landfill with the assistance of USAID over 10 years ago 3; 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 m 3 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.

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2 Project Summary

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 Directive 4 – 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.

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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 m 3 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;

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° 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

Base Price Base Price Contingency Total Ref Type Title TJS USD USD 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, 4,180,000 696,667 34,833 731,500 Pickup 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.

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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.

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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 E nvironmental 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 ES A 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 C ity 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 m 3/year. ° Conclusion of the Department of Agriculture of the Kulob region agreeing on the choice of land for the landfill.

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° Conclusion of the Kulob Vodokanal Kulob t hat 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 2,700 th 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;

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° 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 lan dfill 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 :

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° 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 res trictions 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 wh ich 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 constructi on 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 c ommunity health. Community health is under potential threat in all the stages

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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 potenti ally 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 organizati onal 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 awarenes s 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 opera tional 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.

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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 o perational 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 forc e 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; ° Ada ptation 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 con struction 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” )

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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 a nd require compensations.

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To minimise the aforementioned impacts, the following mitigation measures have been proposed : ° 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 m ovement. 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 prov ided. 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 constructio n 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 L andfill and construction of the New Landfill. Asso ciated 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 constructio n practices and appropriate mitigation measures.

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

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Operation

Potential impacts associated wi th 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 L andfill will be collected in landfills pits, its co mposition 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 grou ndwater and surface water. Purchase of analytical equipment will allow for better control of wastewater composition.

To minimise the aforementioned impacts, the following mitigation measures have been proposed: ° Measures to prevent the infiltration of storm water into the landfill body and c ontrolled 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 p roposed 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 w aste 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.

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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 run ning 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

Earthwork s 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.

Mitigation measures include: ° 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 o f 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.

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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.

Mitigation measures include: ° 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 incr easing 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.

Mitigation measures include: ° 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

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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 excava tion 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 activitie s 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 t he 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.

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4 Information Disclosure

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.

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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

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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.

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5 Summary

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 ).

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Glossary

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

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HSE Health and Safety Executive

Investment Programme Project’s priority investment programme proposed by the Consulta nt under the Assignment

ISO International Standards Organization

Kulob (or City) City of Kulob

Kulob GUP KMK (or Kulob-based branch office of KMK established by the Order no. 132/7 of Company) 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 th e 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

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