Second Decentralized Public Service and Financial Management Sector Development Program, Subprogram 1

Initial Environmental Examination (Draft)

December 2019

CAM: Second Decentralized Public Service and Financial Management Sector Development Program, Subprogram 1

Prepared by National School for Local Administration for the Royal Government of Cambodia and the Asian Development Bank.

CURRENCY EQUIVALENTS (as of 9 December 2019)

Currency unit = KHR (Cambodian Riel) KHR1.00 = $0.00025 $1.00 = KHR4,070.00

ABBREVIATIONS ADB – Asian Development Bank CARM – ADB Cambodia Resident Mission CITES – Convention on International Trade in Endangered Species of Wild Fauna and Flora dBA – decibel A-weighted DPSFM – Decentralized Public Service and Financial Management DPWT – Department of Public Works and Transport EA – Executing agency EDC – Electricite du Cambodia EHS – Environment, health and safety EIA – Environmental impact assessment EMP – Environmental management plan EPC – Environmental protection commitment ESIA – Environmental and social impact assessment GDA – General Department of Administration GRC – Grievance redress committee GRM – Grievance Redress Mechanism IA – Implementing agency IEE – Initial environmental examination IESIA – Initial environmental and social impact assessment JICA – Japan International Cooperation Agency LMAP – Land Management and Administration Project MOE – Ministry of Environment MOI – Ministry of Interior NASLA – National School for Local Administration PAM – Project administration manual PMC – Project management consultant PMU – Project management unit PPE – Personnel protective equipment PPWSA – Phnom Penh Water Supply Authority SDP – Sector development program SNA – Sub-national administration SPS – ADB’s Safeguard Policy Statement (2009) UNCCD – United National Convention to Combat Desertification UNESCO – United Nations Educational, Scientific and Cultural Organization UNFCC – United Nations Framework Convention on Climate Change

WEIGHTS AND MEASURES ha – hectare km – kilometer km2 – square kilometer kwh – kilowatt hour m – meter m3 – cubic meter masl – meters above mean sea level mg/l – mg/liter mm – millimeter sqm – square meter

NOTE In this report, “$” refers to US dollars.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section of this website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

TABLE OF CONTENTS

LIST OF PHOTOS ...... 180 I. INTRODUCTION ...... 1 A. PROJECT CONCEPT AND RATIONALE ...... 1 B. METHODOLOGY FOR ENVIRONMENTAL ASSESSMENT ...... 1 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 2 A. ADB’S ENVIRONMENT SAFEGUARDS POLICIES ...... 2 B. LEGAL AND INSTITUTIONAL FRAMEWORK ON ENVIRONMENTAL MANAGEMENT IN CAMBODIA ... 2 C. ENVIRONMENTAL STANDARDS ...... 3 D. INTERNATIONAL CONVENTIONS ...... 4 III. DESCRIPTION OF THE PROJECT ...... 4 A. LOCATION ...... 5 B. FEATURES OF NASLA FACILITY ...... 5 C. CONSTRUCTION ACTIVITIES ...... 10 IV. DESCRIPTION OF THE ENVIRONMENT ...... 10 A. TOPOGRAPHY ...... 11 B. GEOLOGY ...... 12 C. CLIMATE ...... 13 D. AIR QUALITY AND NOISE ...... 13 E. BIOLOGICAL RESOURCES ...... 13 F. HYDROLOGY AND FLOODING ...... 14 G. WATER QUALITY ...... 17 H. LAND USE ...... 18 I. SOCIO-ECONOMIC SETTING ...... 19 J. HISTORICAL AND CULTURAL RESOURCES ...... 21 V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ...... 21 A. ANTICIPATED BENEFITS FROM THE PROJECT ...... 21 B. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES DURING DESIGN PHASE ...... 21 C. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES DURING CONSTRUCTION ...... 24 D. ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES DURING OPERATION ...... 27 VI. ANALYSIS OF ALTERNATIVES ...... 29 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...... 30 A. CONSULTATION MEETING ...... 30 B. STAKEHOLDER INTERVIEWS ...... 33 C. FUTURE PLANS FOR INFORMATION DISCLOSURE AND PUBLIC CONSULTATION ...... 34 VIII. GRIEVANCE REDRESS MECHANISM ...... 34 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 35 A. INSTITUTIONAL ARRANGEMENTS ...... 36 B. MONITORING AND REPORTING ...... 37 C. COST ESTIMATES...... 38 X. CONCLUSION AND RECOMMENDATIONS ...... 38

XI. REFERENCES ...... 40 APPENDICES...... 42 Appendix A: Environmental Management Plan 43 Appendix B: Documentation of Stakeholder Consultation 56

LIST OF FIGURES

Figure 1: Project location ...... 5 Figure 2: Perspective drawing of the proposed NASLA building ...... 8 Figure 3: Perspective drawing of the proposed dormitory building ...... 9 Figure 4: Vicinity map ...... 11 Figure 5: Soil Profile ...... 12 Figure 6: Fish species found in Kop Srov Lake ...... 14 Figure 7: Sections of Ta Mouk Lake (Kop Srov Lake) ...... 15 Figure 8: Flood control structures in Phnom Penh ...... 16 Figure 9: Flood-prone Areas ...... 17 Figure 10: Conceptual design showing growth of vines (climbers) to serve as concrete block screens ...... 23

LIST OF TABLES

Table 1: NASLA Facilities and Estimated Floor Area...... 6 Table 2: Water Quality Monitoring at Kop Srov Lake ...... 17 Table 3: Issues raised during the public consultation ...... 31 Table 4: Estimated cost of EMP implementation ...... 38 Table 5: Environmental Management Plan ...... 46

LIST OF PHOTOS

Photo 1: Project site and vicinity ...... 18 Photo 2: Proposed site in Boueng Tompun (ING City) ...... 29 Photo 3: Other ongoing infrastructure development at Boueng Tompun ...... 29 Photo 4: Preak Thnot River which drains into the Bassac River ...... 30

I. INTRODUCTION

A. Project Concept and Rationale

1. The Asian Development Bank (ADB) is supporting the Government of Cambodia on its public finance management and decentralization reform agenda. The proposed sector development program (SDP) builds on ADB’s ongoing engagement under the first Decentralized Public Service and Financial Management (DPSFM) program. The secondary DPSFM (DPSFM II) will support three reform areas: (i) strengthening vertical and horizontal coordination for improved planning and budgeting; (ii) improving revenue and expenditure management to meet local needs; and (iii) enhancing public administration, skills, and competencies of subnational officials. The project component of the SDP will establish a National School for Local Administration (NASLA) to support government efforts for sustainable, structured skills development for sub-national administration (SNA) staff and to meet their mandate for expanded service delivery. The NASLA under Ministry of Interior (MoI) is the Executing Agency while the NASLA Project Management Unit (PMU) is the Implementing Agency of the project loan. Within MoI, the Training Department under the General Department of Administration (GDA) is appointed as the transitional governing body until NASLA is fully operational.

B. Methodology for Environmental Assessment

2. This initial environmental examination (IEE) and environmental management plan (EMP) covers the project component of the SDP, construction and operation of the NASLA facility. The objectives of the IEE is to:

(i) Assess the existing environmental and socio-economic conditions of the project area including the identification of environmentally sensitive areas; (ii) Identify likely impacts of the proposed NASLA project on the physical, biological and socio-economic environment; (iii) Propose appropriate mitigation and monitoring measures that could be incorporated in the environmental management plan to avoid or minimize the identified potential impacts of the project.

3. The information in this IEE report is based on field visits, stakeholder consultations, key informant interviews, and secondary sources of information. Site visit and meetings with MoI were undertaken from 26 June to 05 July 2019 to check the proposed features of the NASLA facility and to assess the current site conditions, surrounding areas, check the presence of settlers and other sensitive receptors, validate the location of waterways, drainage and flood control structures, types of vegetation, and other environmental issues that need to be addressed in the IEE.

4. Stakeholder consultation was organized by MOI on 05 August 2019 at Sangkat Kouk Roka to present the proposed project to the community and other concerned stakeholders and to seek their views, concerns, and suggestions regarding the implementation of the project. The participants included local authorities from the village, commune, and Sangkat, people living in the vicinity of the project site, representatives from the Division of Solid Waste and Environment of Phnom Penh Municipality, Department of Public Works and Transport (DPWT), Office of Urban Planning, and Department of Environment of Phnom Penh city. A total of 44 participants attended the public consultation. The details of the public consultation are presented in Chapter VII and Appendix B.

5. As part of the due diligence, a meeting was held with the Department of Environmental Impact Assessment of the Ministry of Environment (MOE) to discuss the environmental requirements for the NASLA project and any issues related to climate change, flooding and biodiversity of the Kop Srov Lake. The environmental approvals related to the ongoing and quarrying and landfilling activities at the lake were also clarified with MOE. Separate meeting was also held with the DPWT to discuss the drainage and flood control plans in the communities surrounding the Kop Srov Lake. Impacts on climate change to the project were assessed. Screening of biodiversity of the surrounding areas was conducted using IBAT tool.

6. Secondary data were gathered from statistical records and internet sources on the physical, biological, and socio-economic conditions within the area.

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. ADB’s Environment Safeguards Policies

7. The project is classified under ADB Safeguard Policy Statement (2009) as Category B for the environment. According to ADB SPS (2009), Category B projects have some adverse environmental impacts that are site-specific, largely reversible, and for which mitigation measures can be designed more readily than for category A projects. An IEE with EMP is required for projects classified as environment Category B.

8. The ADB SPS (2009) outlines the requirements for assessment and mitigation of impacts, preparation of environmental assessment reports, disclosure of information and stakeholder consultations, establishment of grievance redress mechanism (GRM), and monitoring and reporting. There are specific environmental safeguard requirements on biodiversity conservation and sustainable management of natural resources, pollution prevention, worker and community health and safety, and conservation of physical cultural resources.

9. The requirement on public disclosure of projects is also in line with the ADB’s Operations Manual and guidelines on Access to Information (2018). As a Category B project, the draft IEE report of the project should be made available to interested stakeholders before project approval and posted on the ADB’s website upon Board approval of a project.

B. Legal and Institutional Framework on Environmental Management in Cambodia

10. The 1993 Constitution of the Royal Government of Cambodia (RGC) requires the State to protect the environment and balance of abundant natural resources and to establish a precise plan of management of land, water, air, wind, geology, ecological system, mines, energy, petrol and gas, rock and sand, gems, forests and forestry products, wildlife, fish and aquatic resources (Article 59). It was within this constitutional context that the MOE was established.

11. There are specific laws and regulations for protected areas, forests, and land management to ensure sustainable development. The key elements of the legal and policy framework on environment that are applicable to the project include the following:

• Law on Environmental Protection and Natural Resources Management, enacted by National Assembly, 1996, and promulgated by Preah Reach Kram/NS/RKM- 1296/36; • Law on Natural Protected Areas enacted by National Assembly, 2008 promulgated by Preah Reach Kram/NS/RKM/0208/007;

• Law on Fisheries Management and Administration (1989); • Law on Forest enacted by National Assembly, 2002 promulgated by Preah Reach Kram/NS/RKM/0802/016; • Law on Land enacted by National Assembly, 2001 promulgated by Preah Reach Kram/NS/RKM/0801/14; • Law on Water Resource Management produced by Ministry of Water Resources and Meteorology (MOWRAM); • Circular No 01 SRNn issued on 3 February 2012, Royal Government of Cambodia on Cambodia Coastal Zone Development; • Law on Protection of Cultural and National Heritage (1993); • Royal Decree on Protected Natural Areas (November 1993); • Law on Land Management, Urban Planning Construction (1994); • Labor Law (1997); and • Law on Disaster Management (2015).

12. Environmental Impact Assessment. The primary legislation for environmental assessment in Cambodia is the Law on Environmental Protection and Natural Resource Management (Preah Reach Kram/NS-PKM-1296/36 enacted December 1996). This law is the enabling legislation which allows the MOE to pass sub-decrees and regulations to protect the environment.

13. Article 6 of the Law on Environmental Protection and Natural Resource Management states that an environmental impact assessment (EIA) shall be prepared for every project and activity, private or public, and shall be reviewed and evaluated by the MOE or its provincial departments for approval. General provisions for the EIA, the institutional responsibilities, and EIA procedures and conditions for approvals are covered in the Sub-Decree on EIA Processes No. 72 ANRK.BK (1999) and the Declaration on General Guidelines on preparing the Initial Environmental and Social Impact Assessment (IESIA) and full ESIA No. 376 BrK (2009). An Annex of the sub-decree specifies the types of project that require an IESIA and if appropriate, ESIA. The required scope and format of the IESIA resembles that of the IEE required under ADB requirements.

14. Article 1 of the sub-decree states that public participation is to be encouraged in the implementation of the IESIA process so that the conceptual inputs and suggestions of the public are considered prior to implementation.

15. Based on the meeting with MOE, the construction of the proposed NASLA facility falls below the threshold of projects requiring an ESIA/IESIA since the building area is less than 8,000 sqm and the building height is less than 12m. For types of projects that are not included in the annex, a Project Description and an Environmental Protection Contract (EPC) is to be submitted to MOE for screening.

C. Environmental Standards

16. Key directives in support of the Law on Environmental Protection and Natural Resources and related to environmental quality standards, pollution control and waste management include:

• Sub-Decree on Air and Noise Pollution (No. 42 ANKr.BK, 2000); • Sub-Decree on Water Pollution Control (No. 27 ANKr.BK 1999); • Sub-Decree on Solid Waste Management (No. 36 ANKr.BK 1999);

• Sub-Decree on Solid Waste Management at Populated Areas (No. 113 ANKr.BK, 2015); • Sub-Decree on Plastic Management (No. 168 ANKr.BK, 2017); • Sub-Decree on the Management of Drainage System and Wastewater Treatment System (No. 235 ANKr. BK, 2017); • Zoning Guidelines for the Protected Areas in Cambodia (2017); and • Sub-Decree on Drainage System and Wastewater Treatment Plant (No. 235 ANKr.BK, 2017).

D. International Conventions

17. The Royal Government of Cambodia is signatory to the following relevant environmental treaties and conventions:

• UNESCO World Heritage Convention, 1991; • UN Framework Convention on Climate Change (UNFCC), ratified in 1995; • Kyoto Protocol, ratified in 2002; • Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and Their Disposal, 2001; • Vienna Convention for the Protection of the Ozone Layer and its Montreal Protocol on Substances that Deplete the Ozone Layer, 2001; • Stockholm Convention on Persistent Organic Pollutants, 2001; • Convention on Biological Diversity, 1995; • Cartagena Protocol on Biosafety, 2003; • UN Convention to Combat Desertification (UNCCD), ratified in 1997; • Ramsar Convention on Wetlands, 1999; and • CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), 1997.

III. DESCRIPTION OF THE PROJECT

18. The establishment of the NASLA was approved by the Prime Minister based on Sub- Decree No. 192 ANK.BK dated 14 September 2016. The NASLA has two main tasks: (i) developing capacity of civil servants, councilors and students through short and medium-term courses and (ii) research on local governance and local democratic development.

19. There are about 11,000 civil servants working at the sub-national level. This number is expected to increase to 13,000 after the first round of functional transfer of some basic service delivery sectors such as education, health, water, and rural infrastructure. The SNA staff ranges from commune clerks to provincial governors. The NASLA aims to target these groups of SNA staff, including national level staff of the MOI dealing with SNAs.

20. The vision of NASLA is to create and sustain competent SNA management professionals committed to service delivery through high quality education and training. There are four types of courses to be delivered under the NASLA curriculum: (i) induction courses for newly recruited SNA staff in different classes; (ii) career courses for grade advancement; (iii) in-service training as regular refresher courses with exchange of experiences with peers; and (iv) special courses that could cater to any topic considered important and relevant any point in time.

A. Location

28. The site selected by MOI for the NASLA facility is located in Sangkat Kouk Roka, Preak Thnoev District, Phnom Penh, covering a land area of about 8.0 hectares. The site has been allocated for MOI since the 1990s. The site used to be occupied by the police department of MOI.

Figure 1: Project location

B. Features of NASLA Facility

21. The NASLA facility will be constructed in support to the delivery of the course programs for SNAs. The facility will consist of (i) a two-level academic building and (ii) a two-level dormitory building. The facility will use an approximate area of 2.6 hectares at the front (eastern side) of the 8-hectare property, thus, providing large area for green and landscaping features and parking.

22. Other auxiliary non-teaching areas include the general administration offices, teaching staff offices, research offices, hospitality and auxiliary management office, reception and waiting room, a medical room, central staff room and lounge, prayer room, staff and student washrooms, canteen, and maintenance/operations and equipment room, and storage areas.

23. Academic Building. The academic building will have four small seminar-type classrooms for group discussion, six large classrooms, three rooms for breakaway/group work, computer laboratory, library, and a 500-person capacity amphitheater with a thick-heavy sliding curtain capable of providing division for the amphitheater where capacity could be reduced to a 200-250 person. There is also a gathering area in the commons patio area with some features to support rain and sun protection while maintaining good ventilation. The ground floor will also feature the main technical room, maintenance room, childcare facility, storage room, and a prayer room. At the first floor of the academic building are classrooms, workshop rooms, study rooms, and academic offices. The classrooms will be equipped with standard supporting equipment such

6 as projector, screen, and white board for curriculum training. A main entrance hall is designed with an information counter. A surrounding walkway with double tree lines is designed.

24. Dormitory Building. The dormitory building will have two levels. The ground floor is dedicated to the men while the first floor to the women to ensure that the design is gender- sensitive and takes in consideration women’s access, safety, and well-being. The dormitory will have a dining room and library on the ground floor. Each floor of the dormitory will be setup with common spaces for small kitchen facility, laundry space, and a drying area, i.e. behind the building at the ground floor for men and on an add-on balcony all along the north side of the building at the first floor for women.

25. Overall, the gross building area of the teaching areas, non-teaching areas and dormitory is about 7,976 sqm. Table 1 presents the components and description of the building requirements and floor area.

Table 1: NASLA Facilities and Estimated Floor Area Facility Capacity Quantity Unit Area Total Area (Persons) (sqm) (sqm) A. Teaching Areas 1. Classroom (small) seminar style/group 25 4 75 300 discussion 2. Classroom (large) 35 8 105 630 3. Rooms for breakaway/ group work 25 1 75 75 4. Rooms for breakaway/group work 25 2 360 174 5. Hall (multi-purpose) lectures/meetings 500 1 400 700 (amphitheater) 6. Computer laboratory 30 2 105 210 7. Library 30 1 105 105 Total Teaching Areas 2,194 B. Non-Teaching Areas 8. Office (Principal) 1 1 12 12 9. Office (Vice Principal) 1 2 10 20 10. Academic Office 25 1 250 250 11. Research Office 10 1 100 100 12. Administration and Finance Office 25 1 250 243 13. Hospitality and auxiliary management 5 1 50 46 office 14. Reception and waiting room 1 1 15 40 15. Meeting room (Board, Staff/Teacher) 20 2 68 140 16. Canteen 115 1 220 220 17. Storage 1 90 90 18. Medical room 1 40 42 19. Maintenance/operations and equipment 1 45 43 room 20. Staff and student washrooms 1 150 150 Total Non-Teaching Areas 1,407 21. Circulation/walls 1,936 Sub-Total Academic Building 5,537 C. Dormitory 22. 58 rooms for 112 persons (with two 112 58 2,439 beds, 4 single rooms, all with attached bathrooms) Total Gross Building Area (sqm) 7,976

Source: NASLA Project Site Relocation. Final report. TA-8929 CAM-Architect (49266-002). October 31, 2019

26. Other environmental sustainability design features of the school and compound include:

a) Wheelchair accessible ramps and walkways for physically impaired; b) Natural ventilation and daylighting support; c) Planting of more trees to protect the building’s façade from heat and increase natural cooling ventilation; d) Exercise/promenade walkway planted both sides with trees around the school to promote exercise and well-being, support natural cooling and act as barrier against noise/pollution and other related inconveniences; e) Childcare area on the north side of academic building; f) First-aid facility g) Low maintenance facilities with energy-efficient lighting system; h) Adequate lighting around the building and outdoor along walkways and gathering areas, with solar power and battery at lamp poles; i) Back-up power supply (generators) near the main technical room; j) Lightning protection for both academic building and dormitory building; k) Sex-segregated toilets; l) Drinking fountains; m) Septic tanks for wastewater treatment; n) Solid waste collection bins; o) Potable water supply system; p) Fire safety monitoring, smoke and alarm detectors, and fire fighting system; and q) Security system at academic building, at dormitory area, and corridors/common areas.

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Source: NASLA Project Site Relocation. Final report. TA-8929 CAM-Architect (49266-002). October 31, 2019

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Source: NASLA Project Site Relocation. Final report. TA-8929 CAM-Architect (49266-002). October 31, 2019 TO MAIN NASLA Master Plan HIGHWAY

C. Construction Activities

27. The project construction shall comply with all existing laws and regulations of Cambodia. Building permit shall be secured from the city prior to starting any activities at the site.

28. There is already an existing fence surrounding the 8 hectare site and only a small portion of the site will be used for the NASLA, hence, all construction works, materials storage, and workers camp will be confined within the property. Initial works include site clearing and demolition of the existing old MoI building. This will be followed landfilling of the site by about +1.0 meter to reach approximately the level of the national highway. Suitable material will be spread in uniform and compacted to ensure inelastic and firm ground foundation. Drainage canals will also be established during site preparation.

29. After the site preparation, staking out will be performed to establish the line or grade of the foundations, structures and manholes. The staging area of the project to be located inside the property will be limited to temporary field offices for contractors. There will also be designated areas for rebar fabrication, raw materials, waste materials, and construction spoils. The temporary offices will be equipped with water, light, first-aid kit, and toilet facilities for the use of workers. The staging area will be maintained in sanitary condition at all times.

During excavation of the building foundation, materials suitable for backfill will be used to landfill the open areas of the site. The foundation works will be immediately followed by the structural works and concreting/masonry works. Upon completion of concreting works on the ground level, plumbing, sanitary, electrical and mechanical works will be undertaken. When the building’s structure is completed, installation of doors, windows, glazing, painting and other finishes will be done.

IV. DESCRIPTION OF THE ENVIRONMENT

30. The proposed NASLA facility is in Trapaeng Veng village, Sangkat Kouk Roka in Prek Pnov District in Phnom Penh. The site is approximately centered at geographic coordinates 11o36’58”N and 104o48’20”E. It is adjacent to existing village roads on the eastern, western, and southern boundaries and by vacant lands on the northern section. A few houses can be found across the village roads. The site is about 40 minutes away from the Phnom Penh city center and is accessible from the city center through the Hanoi Road and the Tompong Kop Srov Street.

Figure 4: Vicinity map

A. Topography

31. The site and surrounding areas lie on a flat terrain. Elevation ranges from 14–15 meters above mean sea level (masl). In general, the topography at the surrounding areas is characterized as part of the low-lying central plains that make up about three-quarters of the country. The Ta Mouk lake, or more popularly known as the Kop Srov lake, is about 400 m away from the site.

32. Phnom Penh is located in the floodplain of the Mekong River. The capital is surrounded by natural levees and ring dikes and its suburbs form low wetlands. There are big lakes like the Cheung Aek Lake at the south of the ring dike, Boeng Kok Lake, Poung Peay Lake, Tumpun Lake, and Trabek Lake surrounding the downtown area but some of these lakes have been reclaimed due to urbanization that has been happening in recent years.

B. Geology

33. Cambodia lies in a region with low seismic hazard. According to the United States Geological Survey, the entire country is located on a large stable tectonic region of the Sunda Plate. The central lowland is covered with young alluvium while the northern mountainous area is covered with lower-middle Jurassic formation. The coastal region is covered with Jurassic- Cretaceous sandstone.1 Phnom Penh is formed by Quaternary sedimentary rock or unconsolidated sedimentary rock and relatively new and soft ground.

34. Cambodia can be divided into three regions on the basis of age and general origins of soils: (i) Cardamon and Central Annamite mountains; (ii) regions covered by ancient alluvial or colluvial plains; and (iii) regions that receive annual alluvial sediments, such as the Tonle Sap floodplain. The project site is located in the region that receive annual alluvial sediments. The area is characterized with sandy surface soils with high permeability and high-water conductivity.

35. Based on a study conducted by JICA, the ground is mainly made up of sand up to about 44 m depth at the boring at Mekong Bridge in Kampong Cham where the lowlands spread about in the northeast of Phnom Penh. In the west of Phnom Penh plain, base rock around 30m as well as clay and sand deposits were found which includes coarse sand and gravel.

Figure 5: Soil Profile

Base map: General soil map of Cambodia.

1 Source: https://www.jica.go.jp/english/our_work/social_environmental/archive/pro_asia/pdf/cam07_02_02.pdf.

C. Climate

36. Cambodia has a tropical climate characterized by an annual monsoon cycle and two distinct seasons, i.e., rainy season from May to early October and a dry season from November to April. The months with the lowest temperature are December and January while the months with the highest temperatures are April and May. According to the observed data from 1985 to 2013 at Pochentong Station, the average monthly maximum and minimum temperatures in Phnom Penh are 35.3 oC and 21.8 oC. The annual average humidity is 77%. The annual average rainfall from 2004 to 2013 is 1,487.2 mm/year with large variation observed in 2006 (1,170.9 mm/year) and 2008 (1,938.7 mm/year).2

37. The country is highly vulnerable to impacts of climate change particularly related to hydro- meteorological hazards such as floods, drought, heavy storms/typhoons, and epidemics. The regions in the riverine central plains, coastal ecosystems, the Dangrek mountain range in the north and the Cardamon mountains in the southwest are the areas exposed to one or more of these hazards.

38. The project site is in the vicinity of the Ta Mouk lake (Kop Srov Lake) which is a natural lake that has been divided into two sections: (i) natural lake located in the northwestern section which supports agriculture and fishing communities; and (ii) the drainage section with a dike on the southeastern section which functions as the drainage and flood control system for the area. The project site is located about 3.37 km west of the dike (Figure 7). The southeastern section of the lake aims to prevent flooding in Phnom Penh from overflows of the Tonle Sap River and Mekong River. The lake and the drainage and flood control system is being managed by DPWT of Phnom Penh city.

39. Based on interviews with residents, there has been no flooding at the proposed project site and immediate vicinity. The Department of Public Works and Transport affirmed that there is a main drainage system along the national road and that the flood control system and pump stations provided around the lake provides protection against flooding.

D. Air Quality and Noise

40. There are no major sources of air pollution in the area except for dust from occasional movement of vehicles along the adjacent earth roads and the burning of garbage by some houses. Air quality at the project site and vicinity can be considered as generally good because of air dispersion from the wide-open area and the site’s proximity to the lake.

41. Similar to air quality, there are no major sources of noise in the area.

E. Biological Resources

42. Kop Srov Lake is identified as an important bird and biodiversity area based on IBAT because of the presence of significant populations of the Pelecanus philippensis or commonly known as the spot-billed Pelican. The said species is classified as “near threatened” under the red list category of IUCN. It inhabits a variety of deep and shallow wetlands and feeds in fish in

2 Source: http://open_jicareport.jica.go.jp/pdf/12270294_01.pdf.

14 open water. Core areas where these species can be found in Cambodia are in Tonle Sap specifically at Prek Toal and Moat Khla/Boeng Chhma. 3

43. During the consultation meeting, the participants identified fish catch from the lake. Most common fishes that thrive and breeds in the lake are the snakehead fish, moonlight gourami, Southeast Asian Yellowtail (Trey Changva), Goldfin tinfoil barb (Trey Chhpin), Asian Redtail catfish (Trey Chhlang), and Peacock eel (Trey Chhlogn).

Figure 6: Fish species found in Kop Srov Lake

Asian Redtail Catfish Peacock Eel Goldfin Tinfoil barb

F. Hydrology and Flooding

44. The project site is in the vicinity of the Ta Mouk lake (Kop Srov Lake) which is a natural lake that has been divided into two sections: (i) natural lake located in the northwestern section which supports agriculture and fishing communities; and (ii) the drainage section with a dike on the southeastern section which functions as the drainage and flood control system for the area. The project site is located about 3.37 km west of the dike (Figure 7). The southeastern section of the lake aims to prevent flooding in Phnom Penh from overflows of the Tonle Sap River and Mekong River. The lake and the drainage and flood control system is being managed by DPWT of Phnom Penh city.

3 Source: BirdLife International (2019) Species factsheet: Pelecanus philippensis. Downloaded from http:// birdlife.org on 08/18/2019

Figure 7: Sections of Ta Mouk Lake (Kop Srov Lake)

45. The Mekong River, Tonle Sap River and the Bassac River are the major water bodies that traverse Phnom Penh. Flooding in Phnom Penh is controlled by several flood control structures that were built such as the Kop Srov dike at the northern part, the Tumpun Dike at the southern part, and natural levees along the Mekong and Tonle Sap rivers (Figure 8). The Kop Srov dike serves to protect the city from flooding as well as serve as ring road to bypass the city center area. Similarly, the Tumpun dike serves as dike and a ring road.

46. It is reported that damage of inland flooding has been decreasing in many parts of Phnom Penh due to the upgrading of the drainage pipe network and drainage channel, rehabilitation of pumping stations, and construction of new pumping stations.4 However, inundation still occurs around the flat plain surrounding the Mekong River and the Tonle Sap River.5

47. Based on interviews with stakeholders and from results of the public consultation, there is no flooding history at the project site itself and at the immediate vicinity even if the area is just about 400 meters away from the Kop Srov lake. There is ongoing laying of drainage pipes along the adjacent road that drain towards the Kop Srov Lake.

4 Source: Final Report. The Study on Drainage and Sewerage Improvement Project in Phnom Penh Metropolitan Area, JICA. 2016. 5 Ibid 4.

Figure 8: Flood control structures in Phnom Penh

Source: Final Report. The Study on Drainage and Sewerage Improvement Project in Phnom Penh Metropolitan Area, JICA. 2016

Figure 9: Flood-prone Areas

Source: GMS: Flood and Drought Risk Management Project, ADB

G. Water Quality

Water quality is being monitored by the MOE once a month in nine water quality monitoring stations in Phnom Penh. There are two monitoring stations located at the mouth of Kop Srov lake and Prek Pnov. Table 2 presents the water quality data from MOE from the period January 2012 to December 2013.

Table 2: Water Quality Monitoring at Kop Srov Lake Monitoring pH TSS BOD COD T-N T-P Cr+6 station (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) Kop Srov Minimum 6.24 40.0 0.7 2.6 0.26 0.01 ND (Upstream) Maximum 8.59 300.0 54.8 126.4 8.56 1.88 0.010 (~6km from Average 7.49 129.1 16.4 35.4 2.08 0.56 0.007 site) Prek Pnov Minimum 6.41 42.0 1.0 3.4 0.09 0.03 ND (~1.5km from Maximum 8.18 442.0 58.4 126.7 11.93 1.74 0.010 site) Average 7.36 119.5 17.4 31.8 4.91 0.53 0.006 Standard 5.0-9.0 <120 <80 <100 - - <0.05 BOD = biochemical oxygen demand, COD = chemical oxygen demand, Cr+6 = hexavalent chromium, T-N = total nitrogen, T-P = total phosphorus; TSS = total suspended solids.

The water quality monitoring data indicate that total suspended solids (TSS) levels exceed the standard of 120 mg/l. Maximum levels of COD also exceeded the standard of 100mg/l. In terms of Cr+6, the values are very low and did not exceed the standard of 0.05 mg/l. When compared to the results of the water quality monitoring in other water bodies in Phnom Penh, the water quality results indicate that the water quality at Kop Srov lake which is in the northern areas of Phnom

Penh is less polluted as compared to the results in the water quality monitoring stations in the southern part of the city.

H. Land Use

The project site is characterized as a wide expanse of open grassland with fence. An old dilapidated building of the police department under MOI is still present at the site. According to MOI, the lot has been allocated for MOI use since the 1990s.

Photo 1: Project site and vicinity

Inside the fenced property Fence and gate at the property Old police building inside the site

View of the Kop Srov Lake Ongoing drainage pipe laying at Village access road adjacent to the southeastern side of the site the site

48. The immediate vicinity is characterized with land primarily used as orchard for mangoes and other crops. Some houses can be found from across the surrounding village roads.

I. Socio-Economic Setting

Population

49. Phnom Penh is the capital city of Cambodia and is the political, socio-economic and cultural center of the country. The city is located about 11o30” north latitude and about 105o east longitude. In 2010, 20 communes from Kandal Province were integrated into the city, thereby, increasing the number of districts and expanding the city area from 376.17 km2 to 678.47 km.2 Today, Phnom Penh comprises of 12 districts (“Khan”), 96 villages (“Sangkats”) and 909 village blocks (“Phum”).

50. Cambodia has a population of 16,250,000 and an annual population growth rate of 1.5% in 2018.6 Population density rose from 69.8 persons per sq.km in 2000 to 92.1 persons per sq.km in 2018.7

51. The majority of urbanization is taking place in Phnom Penh, followed by Battambang and Siem Reap. As the country’s capital city, Phnom Penh’s rapid urbanization and development has forced the city to spatially expand to encompass surrounding suburban areas. In 2012, the population in Phnom Penh was recorded as 1,852,2008. The district with the highest population is in Meanchey District (282,700), followed by Po Sen Chey District (234,900), Sen Sok (198,600), Chamkarmon (184,200) and Toul Kok (186,100).9 Population density is highest in 7 Makara District with 418.7 persons per hectare and at Toul Kok District with 208.8 persons per hectare. These districts are located within the central Phnom Penh area.10 The population in Phnom Penh is projected to increase to 2,867,100 people by 2035.11

52. The project site falls within the district of Prek Pnov which has a land area of 115.4 km2 and a recorded population of 59,700 persons. Prek Pnov is the least populated district of all the 12 districts in Phnom Penh. Population density at Prek Pnov District is 4.1 persons per hectare.

Civil Service 53. The subnational administration (SNA) or local governments in Cambodia include the Phnom City Council, 24 provincial councils, 162 districts, 27 municipalities,14 urban districts (“Khans”), 1410 communes and 236 sangkats. SNA is composed of directly or indirectly elected representatives (council or assembly) and an administration that functions under the guidance of the council. By virtue of the Rectangular Strategy 4 and the National Program for Subnational Democratic Development (NPSDD) 2018-2020, the government has focused efforts on improving the quality of decentralization reforms. These reforms include improvement of autonomy and quality of human resource management and establishing the legislative basis for NASLA through subdecree No. 192 ANK.BK which was issued on 14 September 2016. The policy reforms in restructuring of SNAs will devolve implementation of basic service delivery such as education, health, water, and rural expansion. Currently, there is an estimated 11,000 civil servants working at the SNA level, from provincial governors to commune clerks.12

6 Source: World Development Indicators Database, https://databank.worldbank.org/views/reports/ 7 Ibid. Footnote 6. 8 Urban Development in Phnom Penh, World Bank Group. 2015 9 Ibid. Footnote 8. 10 Ibid. Footnote 8. 11 Ibid. Footnote 8. 12 Final Report. TA-8929 CAM: Second Decentralized Public Service and Financial Management Sector Development Program- Local Government Institute Firm Recruitment. ADB. June 2018

Economy

54. The economy relies largely on agriculture production (rice, rubber, fish, corn, wood, vegetables, and cashew nuts), tourism, industries engaged in textile and shoes and bags production, and construction. There are also about 1,600 small and medium-sized enterprises in Phnom Penh that are involved in sewing/garments manufacturing, food processing, and ironworks.

55. In terms of employment, approximately 63% of the total population in the working age group (age 18 to 60) in Phnom Penh had a primary occupation in 2015. Majority (87%) are in the service sector while 10% are engaged in agriculture and the remaining 2.6% are in handicraft.

Power Supply

56. Electricity is available at the project site from Electricite du Cambodia (EDC). Distribution lines can be found from the main road and running through the adjacent village roads.

Water Supply

57. Majority of the local people are connected to the water supply distribution system being operated by the Phnom Penh Water Supply Authority (PPWSA). There are some who use water from the lake for bathing of animals like cows and for drinking.

58. The PPWSA reported 100% connection of households and establishments in central Phnom Penh. In Prek Pnov district, there is about 76.8% of households connected to the PPWSA system. The site itself will connect to the PPWSA system.

Solid Waste Management

59. Solid waste collection in the area is provided by the city through a private company, CINTRI. Solid waste is disposed to the Dangkor landfill which opened in 2009. The local people disclosed that CINTRI prioritizes collection of waste daily from the main roads and less frequently from narrow village roads. There were instances when CINTRI’s waste collection occurred everyone to two weeks in these difficult to access areas. Households in areas which are underserved by the waste collection services resort to burning or burying of waste or disposal on open roads or in waterways.

Sanitation and Wastewater Management

60. There is no existing sewerage system in the project area. Majority of households have toilet facilities with septic tanks that discharges to drainage canals.

Health

61. The main causes of mortality and morbidity in Cambodia is infectious diseases, with acute respiratory infections as the leading cause of both morbidity: 555 cases per 100,000 population; mortality: 8 cases per 100,000 population based on statistics of the Ministry of Health (2010). Diarrhea is the second leading cause of morbidity, with a rate of 350 cases per 100,000

21 population.13 Non-communicable diseases is a challenge in the future as cases of road accidents, diabetes and hypertension become common in rural and urban areas.

J. Historical and Cultural Resources

62. The nearest culturally significant site is the Ang Toul Kropoer temple which is about 150 meters east of the project site. The site has a direct access from the national highway which is different from the project site’s access road.

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

63. The environmental impacts of the project are identified based on the project design and the activities that are anticipated to occur during project construction and operation. The findings from the field visits, results of stakeholder consultations and information gathered from meetings with MoI, DPWT, and MOE and secondary data from various sources and reports form the basis for the identification of impacts.

A. Anticipated Benefits from the Project

64. The proposed NASLA facility is expected to bring direct benefits to SNA level staff of the government who will be enrolled in courses that will be offered at the NASLA. The SNA staff will be able to upgrade their knowledge and skills through these training programs. The design of the school facility would provide them with a good learning environment that is conducive to study as well as safe and comfortable dormitory for participants, especially for women.

B. Environmental Impacts and Mitigation Measures During Design Phase

65. The project will occupy the public land for NASLA, hence, there is no impact on involuntary resettlement. All activities will be confined within the site. The impacts during the pre-construction phase are related to the site condition, building design and location of the NASLA facility. Impacts may be due to biodiversity and proximity to the Kop Srov Lake, availability and requirements for water supply, sanitation, drainage and flooding, lighting, ventilation, gender and disability.

Biodiversity Conservation

66. The development of the NASLA facility is not expected to result in loss of habitat and biodiversity because the building and related activities will be confined within a small area in the identified property and will not encroach on areas of the Kop Srov Lake. To prevent any negative effects on the lake, fisheries and species of spot-billed Pelican, the project will be designed with adequate drainage to prevent runoff and proper waste management systems for wastewater, solid waste, and hazardous waste.

Drainage and Flooding

67. The development of the site will result to the concreting of a portion of the property. Based on the initial concept design, the building footprint will be about 2 hectares which represents about 20% of the entire 8.0-hectare property. Therefore, there will still be a large area that will remain unconcreted and which could absorb stormwater, thereby, reducing the volume of runoff that will drain through the street canal. Nonetheless, the design of the facility will include the provision of

13 Human Resources for Health Country Profiles Cambodia. World Health Organization Western Pacific Region. 2014.

22 adequate drainage canals at the compound to ensure that there is no area that will have stagnant water.

68. A rainwater harvesting detention tank is proposed to collect stormwater. The rainwater detention tank aims to capture stormwater and delay release into the street drainage canal after a rain event. Collected stormwater can be used for landscape watering. It can also be released only after rain has subsided to help reduce stormwater flow into the public drainage canals that eventually lead to the lake. The rainwater detention tank will be provided with manholes to allow for periodic cleaning and maintenance.

Health and Sanitation

69. The NASLA school will have a dormitory for sex-segregated sleeping accommodation and toilets. It is important that water, sanitation, and hygiene-enabling facilities are adequately provided. Risks of transmission of communicable diseases may occur because of communal eating, sleeping, sanitation and hygiene arrangements in the facility.

70. Sufficient water should be available at all times for drinking, personal hygiene, food preparation, cleaning and laundry. At full occupancy, it is estimated that the facility will require about 36 to 50 m3/day.14 A water storage tank with 1–2 days storage capacity is proposed to ensure that there is adequate supply of water for the occupants of the facility. In addition, a medical clinic is included in the design of NASLA to provide immediate medical needs to students and staff.

71. Domestic wastewater will be generated from toilets, canteen, and at the laundry area. Wastewater generation rate is estimated as 40 m3/day based on the projected water demand. Sewer lines will be designed to receive the wastewater discharges from the buildings for treatment into the septic tanks. Each kitchen sink will be provided with a grease trap to enable removal of grease from the sullage. Collected grease will be disposed as biodegradable waste at the solid waste collection area through the city’s hauler. Effluent from the sewage treatment facility will drain into the into the main public drainage line towards the national road (about 200 m away) for further treatment at wastewater treatment plant that is proposed by the DPWT at Kop Srov. MOI will continue to coordinate with DPWT regarding the arrangements for tapping into main drainage line and the municipal wastewater treatment plant.

72. A solid waste segregation/collection facility that has separate areas for biodegradable wastes and non-biodegradable and recyclable wastes and materials will be designed inside the compound. The solid waste facility should be readily accessible to the recognized garbage hauler of Phnom Penh city.

Energy Consumption, Lighting and Ventilation

73. Based on power demand factor of 150 kwh per square meter15, the proposed NASLA facility’s energy consumption is about 950,250 kwh. Solar rooftop panels are proposed to supplement the electricity supply that is available from the grid. In addition, solar panels for lighting will be used at open grounds to ensure lighting even at night in common and corridor areas.

14 Estimate is based on 200 l/c/d water consumption at occupancy of 180 persons. 15 Page 102. NASLA Concept Paper June 2018.

74. Without compromising comfort, air conditioning will be limited to program areas such as training rooms while the common areas, lounges, and corridors will be cooled by fans, cross breezes, and vegetation. Landscaping elements such as vines (climbers), small and large trees, fruit trees, freestanding pergolas, and trellised walkways will be incorporated in the design. The goal of the landscaping is to provide shady areas and also to cast shade on building walls to reduce increase in temperature in the building. Planters will be installed in the common areas where the vegetation will benefit from overhead daylight. The concept design brings in extensive garden elements to highlight the indoor/outdoor ambiance of the common areas and improve air circulation in the facility and to provide an amenity resource.

Figure 10: Conceptual design showing growth of vines (climbers) to serve as concrete block screens

Gender and Disability

75. Training centers in Cambodia face challenges because of structures that are not responsive to the needs of women and the physically impaired. There are generally no separate toilets or accommodation for female students which discourages families from allowing the female member of their families to study and stay at the school. In the absence of secure facilities, female students are not confident enough to stay at the training centers. There is also a cultural constraint that exists for women not being comfortable to stay away from home for a longer period.16

76. Training centers also fail to include structures for physically impaired, thereby, limiting the capacity of disabled persons to join the training program.

77. In order to address these issues, the design of the NASLA campus will be designed as a place where participants can feel relaxed and safe in a good learning environment. NASLA will include secure sex-segregated toilets and dormitory rooms as well as access ramps for wheelchairs to avoid discrimination and give assurance for women students to feel safe and comfortable to study and stay at the NASLA. The values of gender equity, women empowerment, respect and commitment will be promoted by the project through design of gender-sensitive facilities.

16 NASLA Concept Paper, June 2018.

C. Environmental Impacts and Mitigation Measures During Construction

78. The environmental impacts during construction of the NASLA facilities are considered as site-specific, minor and reversible. The civil works for the construction of the NASLA school and dormitory will be confined within the 8.0 ha project site. Major impacts during construction can be confined within the fenced property and can be properly managed by ensuring that the contractor implements good construction practices and an environmental management plan. Impacts on access road will also be generated due to movement of haulers of construction materials to the site.

79. Issues that need to be taken into account during construction are related to worker and community health and safety, air quality and dust, noise, runoff of sediments, solid waste, improper disposal of any hazardous waste such as used oil, and traffic management. The demolition of the existing old police building, and the disposal of demolition wastes, an dpotential presence of UXO also need to be addressed in the environmental management plan. Contractor specifications to address environmental issues are outlined in the EMP matrix.

Runoff of Sediments

80. The excavation and earthworks will result to the exposure of soil surface to the forces of weathering. During periods of rainfall, sediments may become eroded and cause soil runoff from the property into the drainage canal and surrounding area. In order to prevent the discharge of soil runoff, the contractor will be required to install sedimentation ponds and silt traps within the construction area. As much as possible, earthmoving activities should be scheduled during the dry months where low precipitation occurs. The mounds of stripped soils should be temporarily covered with impervious materials and temporary drainage will be provided to minimize erosion and runoff outside of the site.

81. Another source of soil runoff is the mud tracking by vehicles entering and exiting the construction site during rainy days, particularly at the period when earthworks are in progress. Mud tracking could result to runoff of mud and also create unaesthetic condition at the adjacent access road as well as onsite. To avoid this situation, wash bay at the entrance gate of the construction site is proposed to allow washing of the wheels of vehicles and prevent mud tracking. In addition, site cleaners will be assigned to regularly clean the construction area and adjacent street.

Biodiversity Conservation

82. Workers will be prohibited from any form of bird hunting, sand mining, and throwing of waste materials in the lake. Any worker that has been found to violate this requirement will be meted a fine and/or terminated immediately. These prohibitions and the consequences will be explained during worker orientation briefing.

Worker Health and Safety

83. Because of the large available area within the project site, the contractor may be able to construct the workers’ camp inside the fenced property that includes field office for contractors and subcontractors and sleeping quarters for workers. The construction site will include areas for raw materials, waste materials and construction spoils.

84. The contractor will be required to appoint an Environment, Health and Safety (EHS) Officer to monitor the implementation of health and safety practices by workers. The contractor will also be required to provide and maintain clean and sanitary conditions at the site by providing clean and adequate water at the construction site. The contractor shall also provide toilets with septic tanks for male and female workers with septic tank, and waste segregation/collection area away from the workers accommodation area. Toilets and sanitary fittings will be provided at a ratio of 1, toilet, 1 handwash basin, 1 urinal, and 1 bathroom with bench per 15 male workers in accordance guidance note of the International Finance Corporation (IFC).

85. To ensure safety of workers while inside the construction site, the following shall be provided by the contractor to minimize or eliminate work-related accidents:

a) Personnel protective equipment (PPEs) for workers; b) Safety briefing/orientation for workers; c) Safety signages to be posted in strategic locations within the construction site to remind workers on safety regulations at all times; d) Guard lights for works occurring at night; e) Temporary barricades and warning signs around excavations; f) First aid station with medicines and emergency kits; and g) Scaffoldings and safety nets for protection against falling debris.

Community Health and Safety

86. The impacts on community health and safety will occur primarily during movement of trucks and equipment to and from the construction site. Construction activities will be scheduled from 7:00AM to 5:00PM while deliveries will preferably be at night to avoid traffic-related issues leading to the site. To avoid accidental spill of materials during deliveries, the haulers will be required to cover materials.

87. The contractor will be required to prioritize qualified workers from the village when hiring construction workers for the project. Should there be a need to hire migrant workers, the village authorities will be properly informed about the presence of these workers. Workers will be reminded about the restrictions on alcohol drinking, gambling, drugs, and other illegal activities and on loitering in surrounding areas and causing peace and order problems in the community.

88. Security personnel will be appointed during construction to provide security and safety to both workers and communities. Consultation with residents and neighboring communities will be done to establish cooperation with neighbors and to ensure that any issues and complaints are addressed immediately.

Air Quality and Dust

89. During the construction stage, the primary impact of the project on air quality is the increase in suspended particulate concentration near the construction areas. Civil works will entail digging and excavation of soil that may cause dust to be generated. Winds may carry soil particles but the relatively small area to be disturbed during construction would mostly confine dust emission within the construction site. Dust emission may be more prominent from movement of construction vehicles and equipment along the earth roads adjacent to the project site. Speed limits will be imposed on construction vehicles when passing through these roads. In addition, the contractor will be required to conduct water sprinkling on these roads particularly during dry and windy conditions.

Noise

90. The expected sources of noise during construction is from the operation of major equipment such as backhoe, pay loaders, generators, and heavy trucks. There may also be a need to operate pile driving equipment during foundation works, depending on the results of the soil investigation and structural design of the buildings. Noise levels ranging from 65 to 80 dBA may be experienced within the construction site itself, but which will attenuate with distance. Since the nearest residential house is located about 110 – 120 meters away from the construction site, the impact of noise to residential houses in the surrounding areas will not be significant. Noise is further reduced because of the fence and vegetation in the area. The contractor will be required to closely coordinate with the village authorities and the nearest residential house to inform them of the construction activities and schedule.

Wastewater

91. Domestic wastewater from the sanitation requirements of workers, if left untreated, may drain into canals and lead to further pollution of the Kop Srov Lake which is located about 400 m away from the site. The toilets of the construction camp should have properly designed septic tanks and be regularly emptied by a licensed operator to prevent the discharge of polluted wastewater into the drainage canal.

Solid Waste

92. The construction activities and the establishment of construction camp inside the project site are expected to result to the generation of solid wastes consisting of used formworks and planks, excavated materials, organic debris, stumps, steel bars, cement bags, plastic, wood, and concrete that needs to be properly handled, collected and disposed in a permitted landfill by Phnom Penh city. The contractor will be required to dispose the organic debris as garbage while excavated materials can be used as fill materials within the site. Compost pits can be excavated at the vacant area within the property for biodegradable wastes. Compost material can be used as soil conditioner for landscaping. Other materials such as formworks and scaffoldings can be reused.

93. Workers will be informed about the solid waste segregation and collection system at the construction site. Segregation bins with labels for biodegradable and non-biodegradable wastes will be provided at the construction camp and at the work site. Separate recyclable waste area for formworks, wood, metal, and other reusable materials will be provided at the construction site. Workers will be reminded to avoid mixing of wastes and prohibit them from indiscriminate throwing wastes outside of the property and will be prohibited from burning waste.

94. Demolition of the existing police building will generate concrete wastes which could be used to fill low-lying areas within the site. Demolition wastes is not expected to be transported off-site because there are areas within the property which could make use of the demolition materials as landfill material.

Potential Spill and Leakage of Oil

95. Construction vehicle and equipment fueling, maintenance, and cleaning may cause potential spill and leakage of fuel, petroleum products, lubricants, and other pollutants. To reduce such risks, the contractor will be required to implement the following measures:

a) All construction vehicles will be refueled off-site since there are available gasoline stations in the area; b) Vehicle and equipment wash areas will be located away from drainage canals. The wash areas will be paved with concrete to contain the runoff of oily water; and c) Storage of fuel will be away from drainage canal and retention areas will be provided in order to contain accidental spills of oil and petroleum.

D. Environmental Impacts and Mitigation Measures During Operation

96. During operation of the NASLA facility, the major environmental impacts that need to be considered are related to the maintenance of the facilities. Housekeeping and ground maintenance will be regular tasks of the assigned NASLA building administration/maintenance unit. Regular activities include, among others: (i) cleaning/sweeping/mopping of rooms, lobby and entrances, corridors, lounge, and common areas, (ii) emptying of trash cans, (ii) cleaning of bowls, urinals, and toilets, and (iii) grounds maintenance that includes picking up of litter, cleaning of benches, maintenance of landscaping, cleaning of debris from drains to avoid breeding ground for mosquitoes and rodents, and cleaning of the solid waste segregation/collection area.

97. Environmental impacts during operational phase include the generation of solid wastes, domestic wastewater, and hazardous wastes like broken lamps, cleaning fluids and chemicals.

Wastewater

98. The operation of the NASLA facility including the dormitory and canteen will generate domestic wastewater. The maximum projected wastewater flow rate based on 80% return factor of water consumption is about 40 m3/day. Separate sewer lines will be installed at the NASLA facility to receive the wastewater discharges from the buildings for treatment into the municipal sewage treatment facility. Fats, oils and grease will be generated at the kitchen and grease traps will be provided in each kitchen sink to enable removal of grease from the wastewater before it drains into the sewer lines. Grease from the grease traps shall be regularly removed and disposed in the biodegradable waste bin for disposal off-site.

Solid Waste

99. Solid wastes to be generated by the project mainly consist of food wastes (vegetable and fruit trimmings, leftovers, etc.), recyclable wastes (papers, plastics, bottles, etc.) and non- recyclable wastes (dirt, bits of papers, etc.). At full occupancy, solid waste to be generated by the project is approximately 90 kg per day.17 Signages on proper waste disposal will be posted in strategic areas in the facility. Occupants will be encouraged to implement the three R’s of solid waste management which are: Reduce, Reuse, and Recycle.

100. The project will be provided with waste segregation bins and a garbage collection area. Daily collection of segregated solid waste will be undertaken by the building administration/maintenance personnel. Segregated solid wastes will be collected and taken offsite through a service contact for disposal at the designated landfill.

17 Based on solid waste generation rate of 0.5 kg per capita per day.

Hazardous Waste

101. During project operation, hazardous waste such as broken lamps containing mercury, cadmium, and other hazardous elements, batteries, cleaning fluids, and chemicals will have separate collection bins. The building administration/maintenance will be instructed to segregate these wastes for appropriate disposal in accordance with the requirements of the MOE.

Impacts of Climate Change

102. Changes in climate may have impacts on the maintenance and operation of the project. These impacts include:

a) Premature weathering of building materials such as concrete which is sensitive to carbon dioxide; b) Changes in weather and extremes will directly affect the lifespan of assets and the durability of building materials; c) Users of the facility may experience extreme heat, ventilation issues, and vector borne illnesses; and d) Floods, excessive humidity and poor ventilation can lead to growth of molds.

103. Adaptation to climate change impacts are primarily infrastructural such as:

a) Use of energy efficient options such as LED lighting systems and solar panels for outdoor lighting; b) Installation of cladding c) Use of natural ventilation; d) Development of greenspace around the buildings; e) Provision of adequately sized drainage system and avoid ponding in areas of the property; f) Implementation of other measures to address thermal comfort; and g) Provision of a rainwater harvesting tank to capture runoff from paved areas during storm events. Collected stormwater runoff shall be released only after rain has subsided to help reduce flooding and overflow of Kop Srov Lake.

Fires and other Emergencies

104. During operation, emergencies such as fires and other natural hazards should be addressed to ensure safety of occupants of the NASLA facility. The building should be provided with:

a) Adequate exits with signs; b) Plan for an assembly and evacuation area for emergencies; c) Emergency alarms; and d) Water sprinklers and fire extinguishers.

105. Other institutional development measures include the development of an emergency response plan for floods, blackouts and extreme hot spells, and capacity building of staff on the implementation of the plan.

VI. ANALYSIS OF ALTERNATIVES

106. Initially, the MOI considered a site at Boeung Tompun Lake for the development of the proposed NASLA facility. The MOI has obtained three adjacent plots at the Boeung Tompun Lake project consisting of two 2 ha plots and one 1 ha plot that will be used for a police hospital, a personal identification data center of the police and the NASLA. One of the two-hectare sites was proposed for the NASLA. According to MOI, the property is not yet titled and that land titling will be done through the Land Management and Administration Project (LMAP) of the Ministry of Land Management.

107. Based on the field visit to the site at Boeung Tompun Lake, there are no settlers or immediate neighbors to the proposed site. The site has been backfilled by the Boeung Tompun Lake development project for the development of ING City. Regrowth of vegetation/grasses was already observed onsite. However, the site may need to be landfilled further to level the site to the Hun Sen Boulevard because the NASLA site and immediate vicinity appears to be in the soil compaction and stabilization stage only and are relatively lower in elevation than the Hun Sen Boulevard. The site drains into a creek that leads to the Prek Thnot River which then drains into the Bassac River. Drainage culverts along the Hun Sen Boulevard can be found but none yet at the site. Landfilling of the road leading to the NASLA site from Hun Sen Boulevard is still ongoing.

Photo 2: Proposed site in Boueng Tompun (ING City)

Photo 3: Other ongoing infrastructure development at Boueng Tompun

Photo 4: Preak Thnot River which drains into the Bassac River

108. Two pumping stations which serves the site and surrounding areas in Phnom Penh were visited. There were no wastewater treatment systems found at the development area but a portion of the entire development was left as wastewater receiving lake.

109. The price of land in the area continues to rise and MOI needs to get a title for the property. To reach the proposed site, buses, cars, and tuk tuks coming from Phnom Penh travel through four-lane Hun Sen Boulevard. For much of the way, this road cuts through wetlands and a recently dredged lake that used to serve as wastewater reservoir for Phnom Penh. Just east of the proposed site is a high voltage line. Currently, there is no direct road or any way to reach the site by vehicle. A direct connection will be necessary between Hun Sen Boulevard and the NASLA site which is 800 meters to the east. In addition, the entire footprint of the NASLA site and surrounding lands should first be built up.

110. Another issue at this site is on the wetlands which are being filled to provide vast new plots of land which may be causing damage to environmentally sensitive areas. The wetlands may be acting as flood plain and it is quite possible that land filling and diverting moving lake water will result to channelizing of water, making the area prone to more damaging floodwaters. There is also standing water that remains near the site which may provide breeding grounds for mosquitoes, resulting in vector-borne diseases in the area. There may also be some delay in landfilling of the NASLA causeway and site itself by the developer, thus, may cause uncertainties in the planning of the project implementation. The proposed site is currently without connections to utilities such as water supply, electricity or wastewater sewerage.

111. Owing to these complex issues with the Boeung Tompun Lake site, the MoI identified a property previously occupied by the police department in Sangkat Kouk Roka as an alternative site for NASLA. This location is the subject of this IEE.

VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultation Meeting

112. A joint environment and social public consultation meeting was conducted on August 5, 2019 at Trapaeng Village, Sangkat Kouk Roka to present the proposed project to stakeholders. The public consultation aims to: a) Provide information to the local community and stakeholders about the proposed implementation of the NASLA facility;

b) Have an open discussion of any environmental and social issues about the project that should be taken into consideration in the planning of the project; c) Discuss anticipated impacts and mitigation measures during design, construction and operation of the NASLA facility; and d) Provide an opportunity for local community to discuss any questions, views and suggestions on the proposed project.

113. MOI coordinated with the local authorities of Sangkat Kouk Roka regarding the meeting. People living in the vicinity of the project and representatives of the village, commune, and Sangkat, Ang Toul Kropoer pagoda, MOE, relevant offices of Phnom Penh Capital Council such as Waste Management Division, Planning and Investment Division, Urban Division, Consultative Committee on Women and Children Affairs, and Local Conflict Resolution Office were invited by MOI. A total of 44 participants attended the public consultation.

114. The meeting was chaired by the Deputy Governor of Khan Prek Pnov while the MoI led by Mr. Ear Chariya, Officer from the Department of Training of MoI presented the proposed NASLA project, the status of project planning, and land ownership. The project presentation was followed by a presentation of the social and environmental safeguards policies and objectives of ADB, anticipated impacts and proposed mitigation measures.

115. Stakeholders were asked about their views regarding flooding in the area for consideration in project design; availability of drainage; impacts of the project on the lake, fisheries, and irrigation; and generation of wastewater and solid wastes. In addition, community health and safety issues during construction and the grievance redress mechanism (GRM) were also discussed.

116. The participants were given the chance to raise questions, concerns, views and suggestions during the open forum.

117. The following presents the issues raised by the participants and the responses to these issues.

Table 3: Issues raised during the public consultation Position/category of Issues Raised by Stakeholders Project response person (e.g. local resident, monk, local gov. officer) Mr. Nuon Samnavuth o The project needs to pay • Currently, there is no existing Chief of Division of attention to wastewater wastewater drainage system in the Solid Waste and management and to cooperate project area. The project recommends Environment of Phnom with Sangkat. There are that wastewater will not be discharged directly to the Ta Mouk Lake since it Penh Municipality representatives in this consultation from all relevant will cause water pollution and lead to departments of Phnom Penh. loss of benefits of local residents who o Architectural designs should be depend on fishery lotus plantation, presented to participants during and other lake related incomes. the consultation. Therefore, the project will consider (i) o Waste collection: There is no in-situ small wastewater treatment regular solid waste collection at plant, if it is affordable in this project, the project site by CINTRI. MoI to treat sewage from the school needs to coordinate with before discharge, (ii) design of

Position/category of Issues Raised by Stakeholders Project response person (e.g. local resident, monk, local gov. officer) CINTRI for solid waste separate systems for drainage and management sewage to allow direct storm water o Storm water can be discharged discharge to the lake, and (iii) directly into the lake. discharge or connect wastewater from the project to sewerage system (if available) where it will finally go to Kob Srov lake through existing Phnom Penh municipal wastewater treatment site. • The architectural drawings will be finalized and will be presented to all relevant authorities before the construction starts. • Waste collection in area and in Phnom Penh, in general, is contracted through a private company (CINTRI). However, irregular solid waste collection service is provided in the area because of low population. Waste segregation will be introduced to reduce the waste volume. Solid waste storage area will be recommended within the Project in a well-managed location that is accessible by CINTRI. Mr. Chim Chea o There is current / ongoing plans • It is great to hear about the planning Representative from for the construction of of the wastewater treatment plant in Department of Public wastewater treatment plant in Kob Srov. Works and Transport Kob Srov by the Municipality of • The project will study the possibility of Phnom Penh. connection or discharge of o There is main drainage system wastewater from the NASLA to the along the national road which public municipal wastewater treatment can be tapped for the system. wastewater discharge from the project. o JICA is doing the study on the rehabilitation of drainage and sewerage system of Phnom Penh metropolitan area. Mr. San Sin o Neither drainage nor sewerage • Deputy Governor explained that public Chief of Sangkat Kouk system is available in most part service is improving, and Phnom Roka of Kouk Roka district. Penh Water Supply Authority is o Currently, about 20% still do not expanding their coverage service. have access to clean water supply and they rely on private water suppliers or lake for their daily water consumption.

Position/category of Issues Raised by Stakeholders Project response person (e.g. local resident, monk, local gov. officer) Mr. Chea Seng o The existing lake is now • These are good recommendations on Representative from separated into two parts: natural separate drainage and sewerage DOE lake and wastewater site. systems and solid waste storage o It is proposed to have separate location at site for the project to drainage and sewerage system consider. for NASLA. o DOE proposes to the project to build its own wastewater treatment plant since the land is huge. o There should be traffic management on the access road to the site during construction. o There should be waste separation and storage at site before these are collected by CINTRI. Mr. Po Mom o The project is requested to build • The consultation aims to hear the Representative of local drainage and sewerage system views and concerns from local residents so that people can connect from residents as well as all relevant the household to this public parties in order to include in the system. project design and to avoid adverse o People still can use the lake as impacts to environment and livelihood water supply source, if it is not of people in the project area. polluted and since there is no clean water supply in the area yet. o Some people rely on the lake for their livelihood such as lotus plantation, fishing and restaurant etc. o Apparently, no physical impact or involuntary resettlement impacts will be caused by the project. DOE = Department of Environment, JICA = Japan International Cooperation Agency, NASLA = National School of Local Administration.

B. Stakeholder Interviews

118. Interviews/meetings with MOE and DPWT (Phnom Penh) were held to gather information about the project location and any environmental issues related to the implementation of the proposed NASLA facility.

119. The MoI arranged a meeting on July 8, 2019 with MOE’s Department of Environmental Impact Assessment led by Mr. Danh Serey, Director of EIA Department. During the meeting the environmental requirements for NASLA and the issues related to the project site such as on

34 protection status of the lake, flooding, wastewater treatment, and solid waste collection were discussed. MOE informed that the project is not included in the list of project that requires an IESIA or ESIA because the building is below the threshold of 12 m height or 8,000 m2 area under the Sub-decree No. 72 ANRK.BK on the environmental impact assessment process. A letter request can be submitted by MoI together with the project description so that MOE can further evaluate the project proposal and confirm whether an IESIA or just a simple environment protection commitment (EPC) will suffice. The MOE will conduct a site visit to confirm the environmental requirements. The MOE also disclosed that the Kop Srov lake is not a protected area but is an area specifically managed by Phnom Penh city to address flooding and irrigation.

120. The meeting with DPWT was held on July 9, 2019. Mr. Mao Vunthuan, Chief of the Department of Meteorology of DPWT said that there is no flooding history at the NASLA site in Sangakt Kouk Roka. The lake is primarily used for irrigation as well as for drainage and flood protection. The lake has a dike which separates the area for irrigation and the section that receives wastewater from the city. There are two pumping stations at the lake to control flooding in the city.

C. Future Plans for Information Disclosure and Public Consultation

121. Once the project design is finalized, the IEE and EMP will be updated and plans will be presented again to stakeholders. A translation of the EMP and details of the GRM will be made available to project affected persons. The IEE will be readily available to stakeholders through the MOI Training Department, acting as transitional governing body until NASLA is fully operational. The Khmer summary of the project and the IEE will be uploaded at the MOI website. The English versions of the IEE and EMP will be disclosed on ADB website while the EMP will be translated in Khmer language.

122. MOI’s Training Department through the PMU will consult with stakeholders during project construction and operation. Any issues and complaints that may be raised by stakeholders during project implementation will be reviewed and follow-up consultations with affected persons will be undertaken to check whether corrective actions have been implemented to address the concern.

VIII. GRIEVANCE REDRESS MECHANISM

123. People adversely affected by the project will get opportunity to raise their grievances about the actual or perceived impacts in order to find a satisfactory solution. These grievances can surface at different stages of the project. To ensure that affected persons are able to raise their grievances and be given adequate hearing, and satisfactory solutions mutually beneficial to the affected person(s) and the project, a Grievance Redress Mechanism (GRM) is designed to address stakeholder/community complaints in a timely manner. The GRM is structured to define procedures, timeframe and roles of MOI and other institutions in resolving stakeholder complaints.

124. Types of Grievances. Any affected person or household can submit a grievance on the project if they believe a practice is having a detrimental impact on the community, environment, or on their quality of life. Grievances could include health and safety issues, nuisances, failure to comply with standards or legal obligations, and improper conduct or unethical behavior of the contractor, workers, or MOI personnel. The GRM will be made public through the follow-up public consultation and will be maintained during project implementation.

125. Grievance Redress Committee. The Project Management Unit (PMU) will organize a Grievance Redress Committee (GRC) prior to start of project implementation. The GRC will be

35 composed of the village chief, representative from NASLA, and contractor. The GRC is expected to resolve issues related to construction such as dust, noise, wastes, and other related nuisances to affected persons or households; record grievances; convene meetings with the affected person/household and facilitate the resolution of issues within the specific period and the shortest time possible; and report to the affected person/household the status of the grievance resolution and the decisions made or action taken. Information on the key contacts for the GRC will be posted at the construction site through a public notice board in Khmer language.

126. The GRM process is described as follows:

• Step 1: An affected person can raise a complaint or grievance related to the construction or implementation of the project through the village chief or directly to the construction contractor at the project site or to the NASLA PMU. Any complaint received will be treated confidentially and professionally.

The contractor and PMU together with the village chief will meet with the affected person to discuss the nature of the complaint and the immediate remedial actions to address the complaint. Corrective actions on the complaint should be implemented within one week.

• Step 2: When the affected person is not satisfied with the action or decision of the contractor, the affected person can submit the complaint to Phnom Penh city through the Local Conflict Resolution Office. The office will investigate and assess the validity of the complaint, seek measures to redress valid grievances, and prevent such incidents from occurring again. The office has 15 days to bring the complaint into a resolution. If the affected person considers the issue to be satisfactorily resolved, the Local Conflict Resolution Office of Phnom Penh City will inform the GRC through the village chief and the NASLA PMU. If the grievance remains unresolved, the affected person may advance the grievance to the judicial process.

• Step 3: Unresolved complaints may be filed at the court. The court will make a written decision and submit copies to MOI.

• Step 4: The affected person may also approach the ADB Cambodia Resident Mission (CARM) to directly discuss their concerns about the project.

• Step 5: If resolving the issue is not successful through the above steps, the affected person can also directly contact the ADB Office of the Special Project Facilitator under the ADB Accountability Mechanism which provides a forum for people adversely affected by ADB-assisted projects to raise issues and seek solutions to their complaints and report alleged non-compliance to ADB’s operational policies and procedures.

IX. ENVIRONMENTAL MANAGEMENT PLAN

127. An Environmental Management Plan (EMP) attached in Appendix A has been prepared for the project. The EMP presents the mitigation measures, environmental monitoring plan, institutional arrangements, reporting and cost estimates to address adverse environmental

36 impacts of the project. The EMP is designed to provide environmental mitigation measures for impacts that may occur in all phases of project implementation based on the findings in this IEE.

128. Detailed engineering designs of the NASLA facility are yet to be finalized and may require subsequent revisions to this EMP. The MOI will provide the detailed designs to ADB for review to determine if the EMP requires revision. The draft and final IEE with the EMP will be disclosed on the ADB website (www.adb.org) and included in the project administration manual (PAM). The final EMP will be an annex of the bidding, tender and contract documents to inform the contractors of their obligations to implement the EMP and allow them to allocate costs in the bids for the implementation of mitigation measures.

A. Institutional Arrangements

129. The environmental management of the project will be the responsibility of the following:

a) NASLA under the MoI as Executing Agency; b) Training Department under General Department of Administration (GDA) of MoI as transitional governing body until NASLA is fully operational; c) NASLA Project Management Unit (PMU) as implementing agency; d) Project Management Consultant (PMC); and e) Asian Development Bank (ADB)

130. The NASLA as the Executing Agency (EA) has overall responsibility for supervision and monitoring of project implementation and compliance with loan agreement and the EMP. During the transition phase, the Training Department of GDA of MoI will supervise the implementation of the NASLA until a fully operational NASLA is organized and established. The NASLA shall ensure that the design, construction, operation, and maintenance of the NASLA facility are carried out in accordance with ADB SPS (2009), the IEE and EMP, and the applicable laws and regulations of the Government of Cambodia.

131. The NASLA PMU will be the Implementing Agency (IA) of the project. The PMU will oversee the day-to-day management of the project. An environmental safeguards focal person/staff will be appointed by the IA to oversee implementation of the EMP.

132. The environment safeguards focal person/staff of the PMU will have the following responsibilities:

a) Work with the PMC in evaluating the design and ensure that environmental features such as adequate drainage and water supply, sewage treatment facility, solid waste segregation/collection area, rainwater harvesting, adequate ventilation and lighting, landscaping, sex-segregated dormitories and toilets, among others, are integrated in the detailed engineering design of the NASLA facility; b) Evaluate if an updated IEE and EMP is necessary based on the detailed design of the project, review the updated IEE/EMP prepared by the PMC and submit to ADB for approval; c) Ensure that the final design of the NASLA facility is disclosed to the affected stakeholders prior to implementation; d) Ensure that the EMP is translated in Khmer language and is included in the bid and contract documents for contractor; e) Work with the PMC in coordinating with line ministries, Phnom Penh city, and the village authorities and in organizing public consultation and information disclosure;

f) Coordinate with the PMC and contractor and ensure that permits and clearances are secured by the project prior to implementation; g) Conduct monitoring and inspection of the project and check compliance with the EMP; and h) Review the environmental monitoring reports prepared by the PMC and submit these to ADB on a semi-annual basis.

133. During the operation of the facility, NASLA and the designated focal person on environment safeguards will continue to supervise the operation of the facility. The day-to-day maintenance of the facility will be handled by the NASLA Administration composed of the NASLA Academic Office and the building maintenance administrator and staff.

134. The EA/IA will engage the services of PMC to assist in the implementation of the project, including the EMP. A national environment safeguards consultant under the PMC will be engaged for a period of six (6) months to provide support to the PMU over the duration of the construction which will take about 12 months. The following are tasks of the PMC and the national environment safeguards consultant:

a) Review the detailed engineering design, confirm that environmental features are integrated in the final design of the facility and prepare an updated IEE/EMP to reflect updates, as necessary; b) Assist the PMU in obtaining permits and clearances and in preparing the Environmental Protection Contract (EPC) to be submitted to MOE prior to any civil works; c) Conduct training and capacity building for MOI, PMU, environment safeguards focal person(s) and contractor on ADB SPS (2009), Cambodia’s environmental quality standards, and the EMP; d) Incorporate the IEE/EMP clauses in tender documents, bids and contractors. e) Assist the PMU on information disclosure, consultation and participation activities, including implementation of the GRM; f) Provide technical support to the PMU on environmental mitigation measures and compliance monitoring of the EMP; and g) Review monthly progress reports on EMP implementation by the contractor and prepare the semi-annual environmental monitoring reports until project completion.

135. The contractor will be responsible for implementing the environmental mitigation measures during construction under the supervision of the PMU and the PMC. The contractor will be required to allocate funds for EMP implementation and to appoint an Environment, Health and Safety (EHS) Officer who will monitor and guarantee that the work site and surrounding environment is safe and any nuisances brought about by the project implementation are properly addressed.

B. Monitoring and Reporting

136. The PMU through the appointed environmental safeguard focal person and with assistance of the national environmental safeguards consultant of the PMC will be responsible for monitoring and reporting on compliance with the EMP. The PMU and PMC will conduct site visits, compliance checks, and prepare semi-annual environmental monitoring reports. The semi- annual environmental monitoring reports will be submitted to ADB until the project completion report is prepared, one year after physical completion of the project.

C. Cost Estimates.

137. The contractor will allocate budget for the implementation of the EMP and capacity building activities for the PMU. The estimated costs for these activities are shown in Table 4.

Table 4: Estimated cost of EMP implementation Activity Estimated Cost Source of Fund (US$) Environmental features of NASLA facility in 629,10018 MOI detailed engineering design • Drainage and stormwater management system • Water supply • On-site sewage treatment • Solar energy installation • Solid waste segregation/collection facility • Rainwater harvesting • Ventilation and lighting • Landscaping and fencing • Sex-segregated toilets • Fire exits, water sprinklers/fire extinguishers Public consultation and information disclosure 6,000 PMC of detailed engineering design Training and capacity building for NASLA and 6,000 PMC PMU on ADB SPS (2009), Cambodia’s environmental quality standards and requirements, and EMP EMP implementation during construction (e.g. 20,000 Contractor dust suppression by watering, soil erosion control, site maintenance and cleanup, health and safety measures, waste management, etc.) Total 661,100

X. CONCLUSION AND RECOMMENDATIONS 138. This IEE was prepared to assess the environmental issues associated with the location and design of the proposed NASLA facility. The assessment confirms that the project is classified as Category B for environment. Environmental impacts associated with the implementation of the project will generally occur during the construction and will be localized within the project footprint and along access route. The impacts are short-term, site-specific, reversible and manageable.

139. The civil works for the construction of the NASLA school and dormitory will be confined within the 8.0 ha project site. Impacts can be managed through good construction practices and implementation of the environmental management plan. Issues that need to be taken into account

18 Based on preliminary cost estimates of NASLA Concept Paper. June 2018 and additional 20% for cost of rainwater harvesting detention tank, .fire exits/water sprinklers/fire extinguishers, solid waste segregation, etc. The cost of environmental features will be updated during detailed design.

39 during construction are related to worker and community health and safety, air quality and dust, noise, runoff of sediments, solid waste, improper disposal of any hazardous waste such as used oil, and traffic management. Due to the proximity of the site to Kop Srov Lake, the contractor will be prohibited from any form of bird hunting, sand mining, and throwing of wastes and/or discharge of wastewater into Kop Srov lake. Contractor specifications to address environmental issues are outlined in the EMP.

140. The design of the NASLA facility will include energy and water conservation measures and waste management to avoid adverse impacts to the environment. Some of the proposed environmental sustainability design features include separate sewer line that drains into an onsite sewage treatment facility, solid waste segregation/collection area, drainage and stormwater management system that includes a rainwater harvesting detention tank, energy conservation measures such as LED lighting system, adequate ventilation and lighting, solar panels at common and corridor areas to ensure lighting at night, wheelchair accessible ramps and walkways for physically impaired, sex-segregated toilets and dormitory rooms, adequate water supply, fire exits, water sprinklers/fire extinguishers, and landscaping and fencing.

141. The NASLA is expected to bring direct benefits to SNA staff of the government. The design of the school and dormitory will provide a good learning environment that is safe and comfortable for participants.

142. This IEE and EMP will be disclosed on the ADB website and included in the PAM. Updating of the IEE and EMP will be decided by ADB depending on whether there will be significant variation in the detailed engineering design of the NASLA. The final EMP will be included in the bidding, tender and contract documents to inform the contractors of their obligations to implement the EMP.

XI. REFERENCES

BirdLife International (2019) Species factsheet: Pelecanus philippensis. Downloaded from http:// birdlife.org on 08/18/2019

Boeung Tompun Lake: Future Unknown? F and F #25 February 2015, www.teangtnaut.org Cambodia - Sustaining Strong Growth for the Benefit of All (A Systematic Country Diagnostic)

Report No. 115189-KH. World Bank Group. 2017. https://hubs.worldbank.org/docs/imagebank.pages/docprofile.aspx?nodeid_27520556

Cambodia – Soil Resources, a presentation to the Asian Soil Partnership Consultation Workshop on Sustainable Management and Protection of Soil Resources. 13–15 May 2015 Bangkok., Thailand.

Cambodia Climate Change Strategic Plan 2011–2023. National Climate Change Committee. 2013.

Cambodia’s National Biodiversity Status Report Update 2015. Royal Government of Cambodia.

National Council for Sustainable Development/Ministry of Environment. Phnom Penh, Cambodia. February 2016. www.MOE.gov.kh

Cambodia’s Road Map for Sustainable Development. The National Environment Strategy and Action Plan. ADB. GMS Environment Operations Center. 2018

Climate and Health Country Profile – 2015. Cambodia. World Health Organization.

Climate Change and Health in Cambodia. A Vulnerability and Adaptation Assessment presented on 20–23 July 2010. San Jose, Costa Rica

Concept Paper, National School for Local Administration (NASLA). Final report. TA-8929 CAM: Second Decentralized Public Service and Financial Management Sector Development Program. June 2018

Final Report. The Study on Drainage and Sewerage Improvement Project in Phnom Penh Metropolitan Area, JICA. 2016.

Greater Mekong Subregion Atlas of the Environment. ADB

Country Report of Cambodia. Disaster Management.

Map 12. Administrative Areas in Phnom Penh Municipality by District and Commune

Sub-Decree on Environmental Impact Assessment Process. Royal Government Council of Ministers No. 72 ANKr.BK. Phnom Penh, August 11, 1999

Sub-Decree on Water Pollution Control. Royal Government Council of Ministers No. 27 ANKr.BK Phnom Penh April 06, 1999

The Human Cost of Weather-Related Disasters 1995-2015. Centre for Research on the Epidemiology of Disasters. The United Nations Office for Disaster Risk Reduction. www.unisdr.org

Urban Development in Phnom Penh. The World Bank Cambodia Country Office.

APPENDICES

Appendix A: Environmental Management Plan

Appendix B: Documentation of Stakeholder Consultation

Appendix C: Template of Environment Safeguard Monitoring Report

Appendix A: Environmental Management Plan

This Environmental Management Plan (EMP) presents the potential impacts that were identified in the IEE and the mitigation measures and environmental monitoring requirements to be implemented during the design/pre-construction, construction, and operation of the NASLA facility. The EMP also defines the institutional arrangements, reporting and cost estimates to address adverse environmental impacts of the project.

Detailed engineering designs of the NASLA facility are yet to be finalized and may require subsequent revisions to this EMP. The MOI will provide the detailed designs to ADB for review to determine if this EMP requires revision. The draft and final IEE with the EMP will be disclosed on the ADB website (www.adb.org) and included in the project administration manual (PAM). The final EMP will be an annex of the bidding, tender and contract documents to inform the contractors of their obligations to implement the EMP and allow them to allocate costs in the bids for the implementation of mitigation measures.

A. Institutional Arrangements

Executing Agency. The NASLA is the Executing Agency (EA) that has overall responsibility for supervision and monitoring of project implementation and compliance with loan agreement and the EMP. The MoI shall ensure that the design, construction, operation, and maintenance of the NASLA facility are carried out in accordance with ADB SPS (2009), the IEE and EMP, and the applicable laws and regulations of the Government of Cambodia.

Implementing Agency. The NASLA Project Management Unit (PMU) is the Implementing Agency (IA) of the project. Within the MoI, the Training Department under the General Department of Administration (GDA) is appointed as the transitional governing body until NASLA is fully operational. NASLA Project Steering Committee (PSC) will be established to provide overall direction and guidance for NASLA, review and approve curriculums developed and designed, and facilitate inter-agency or inter-ministerial coordination. The NASLA Project Management Unit (PMU) which comprises of a project manager, deputy manager, focal persons for finance, procurement, gender and safeguards, will be responsible for project management and supervision of implementation of all project activities. The environmental safeguards focal person/staff will be appointed by the IA to oversee implementation of the EMP. In terms of safeguards management, the NASLA PMU will have the following responsibilities:

i) Supervise and oversee compliance with the loan agreement and environment safeguards requirements. j) Ensure that environmental features such as adequate drainage and water supply, sewage treatment facility, solid waste segregation/collection area, rainwater harvesting, adequate ventilation and lighting, landscaping, sex-segregated toilets, among others, are integrated in the detailed engineering design of the NASLA facility. k) Ensure that the final design of the NASLA facility is disclosed to the affected stakeholders prior to implementation. l) Ensure that the EMP is included in the bid and contract documents for contractor. m) Coordinate with line ministries, Phnom Penh city, and the village authorities and ensure compliance with permit requirements. n) Ensure that safeguards training is carried out in line with the EMP and project administration manual (PAM). o) Monitor the project and submit environmental monitoring reports to ADB on a semi-annual basis.

p) Ensure that any issues raised through GRM are resolved, recorded, and reported in the semi-annual monitoring reports.

The operation of the facility will be supervised and maintained by NASLA. In the interim, NASLA comprises of the management and staff of the Training Department and NASLA is expected to increase to full operational capacity with 79 staff by end of 2020.

Project Management Consultant. The EA/IA will engage the services of Project Management Consultant (PMC) to assist in the day-to-day operations and project implementation activities, including the EMP. A national environment safeguards consultant under the PMC will be engaged for a period of six (6) months to provide support to the PMU over the duration of the construction. The following are tasks of the PMC and the national environment safeguards consultant:

a) Review the detailed engineering design, confirm that environmental features are integrated in the final design of the facility and prepare an updated IEE/EMP when necessary. b) Assist the PMU in obtaining permits and clearances and in preparing the Environmental Protection Commitment (EPC) to be submitted to MOE prior to any civil works. c) Conduct training and capacity building for MoI, PMU, environment safeguards focal person(s) and contractor on ADB SPS (2009), Cambodia’s environmental quality standards, and the EMP. d) Incorporate the IEE/EMP clauses in tender documents, bids and contracts. e) Assist the PMU on information disclosure, consultation and participation activities, including implementation of the GRM. f) Provide technical support to the PMU on environmental mitigation measures and compliance monitoring of the EMP. g) Review monthly progress reports on EMP implementation by the contractor and prepare the semi-annual environmental monitoring reports until project completion.

Contractor. The contractor will be responsible for implementing the environmental mitigation measures during construction under the supervision of the PMU and the PMC. The PMU will be required to allocate funds for EMP implementation.

The contractor will appoint an Environment, Health and Safety (EHS) Officer who will monitor and guarantee that the work site and surrounding environment is safe and any nuisances brought about by the project implementation are properly addressed. The contractor through the EHS officer will also regularly coordinate with the village authorities and any affected person or household on updates on project activities and resolution of any issues that may arise during implementation.

The EHS officer will prepare monthly progress report on the implementation of the EMP. The monthly progress reports will be submitted to the PMU who will then prepare the semi-annual environmental monitoring report to be submitted to ADB with assistance from the national environmental safeguards consultant of the PMC.

B. Monitoring and Reporting

The PMU through the appointed environmental safeguard focal person and with assistance of the national environmental safeguards consultant of the PMC will be responsible for monitoring and reporting of the EMP. The PMU and PMC will conduct site visits, compliance checks, and prepare semi-annual environmental monitoring reports. The contractor’s attention will be immediately

45 called on any adverse findings during site visits and compliance checks so that corrective action can be immediately undertaken. The effectiveness of the corrective action(s) will be followed up during subsequent monitoring.

The semi-annual environmental monitoring reports to be prepared by the PMC will be reviewed and then submitted by the PMU to ADB until the project completion report is prepared, one year after physical completion of the project.

C. Cost Estimates

The contractor will allocate budget for the implementation of the EMP and capacity building activities for the PMU. The estimated costs for these activities are shown in the following Table.

Estimated cost of EMP implementation

Activity Estimated Cost Source of Fund (US$) Environmental features of NASLA facility in 629,10019 MoI detailed engineering design • Drainage and stormwater management system • Water supply • On-site sewage treatment • Solar energy installation • Solid waste segregation/collection facility • Rainwater harvesting • Ventilation and lighting • Landscaping and fencing • Sex-segregated toilets • Fire exits, water sprinklers/fire extinguishers Public consultation and information disclosure 6,000 PMC of detailed engineering design Training and capacity building for PMU on ADB 6,000 PMC SPS (2009), Cambodia’s environmental quality standards and requirements, and EMP EMP implementation during construction (e.g. 20,000 Contractor dust suppression by watering, soil erosion control, site maintenance and cleanup, health and safety measures, waste management, etc.) Total 661,100

19 Based on preliminary cost estimates of NASLA Concept Paper. June 2018 and additional 20% for cost of rainwater harvesting detention tank, .fire exits/water sprinklers/fire extinguishers, solid waste segregation, etc. The cost of environmental features will be updated during detailed design.

Table 5: Environmental Management Plan

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by A. Pre- Construction Phase Developing the Lack of capacity of • Designate a focal person on PMU/Training MoI MoI institutional MoI on environment safeguards at the Department capacity of MoI environment PMU. on environment safeguards; • Conduct orientation training for PMC PMU PMC safeguards biodiversity the EA/IE staff and the appointed conservation environment safeguards focal person on ADB SPS, MOE requirements and Cambodia’s environmental quality standards, and the EMP • Ensure that the EMP and PMC PMU MoI environmental clauses are in the bid and contract documents including the prohibitions on any form of bird hunting, sand mining, and wastes discharged into Kop Srov lake. Design and Drainage and • Provide adequate drainage canals PMC PMU MoI planning of the flooding at the compound. NASLA facility • Design a rainwater harvesting detention tank to collect stormwater and reduce volume of stormwater into the street drainage. The collected stormwater may be used for landscape irrigation later on or released after a rain event to

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by reduce volume of water into public drainage lines that lead to the lake. Design and Health and • Design septic tanks for toilets PMC PMU MoI planning of the Sanitation connected to the sewage NASLA facility treatment facility. • Ensure that there is adequate available water supply by providing a water storage tank for the facility. • Medical clinic will be designed at NASLA. Design and Wastewater • Design a sewage treatment facility PMC PMU MoI planning of the and ensure that the effluent NASLA facility complies with the discharge standards of the government. • Locate the sewage treatment facility at least 5m away from a water source/outlet. • Provide grease trap at each kitchen sink to enable removal of grease from the sullage. Collected grease will be disposed as biodegradable waste at the solid waste collection area. Design and Solid waste • Design a solid waste PMC PMU MoI planning of the generation segregation/collection facility that NASLA facility includes separate areas for biodegradable and non- biodegradable wastes. The solid waste facility should be readily

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by accessible for collection by the service provider. Design and Energy • Implement solar power supply PMC PMU MoI planning of the consumption and system to supplement the NASLA facility lighting electricity supply from the grid. • Provide adequate lighting and ventilation in all areas of the building and at the grounds. • Use of energy efficient lighting system such as LED • Install solar panels for lighting in common areas at night. • Provide security lighting at corridor areas. Design and Ventilation • Ensure good ventilation for the PMC PMU MoI planning of the training areas and dormitory NASLA facility • Design cross breezes, vegetation, and fans • Install landscaping elements such as vines (climbers), small and large trees, fruit trees, freestanding pergolas, and trellised walkways to provide shade on building walls. • Install planters in common areas. Gender and Access for • All parts of the school and PMC PMU MoI Disability disabled persons compound will have wheelchair access for the physically impaired. Gender equality • Provide sex-segregated toilets PMC PMU MoI and separate dormitory rooms for women

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by Information Public consultation • Organize a public meeting to PMC PMU PMC disclosure and information disclose the final design of the disclosure of final NASLA facility to stakeholders, detailed including the environmental engineering design features and mitigation measures during implementation. Compliance with • Prepare the EMP and submit EPC PMC PMU MoI permits and with MOE prior to award of civil clearances works contract. B. Construction Phase Developing the Lack of awareness • Require the contractor to appoint Contractor PMC, PMU Contractor capacity of the of contractor on an EHS officer. contractor on EMP and • Require the contractor to prepare environment Grievance Redress the CEMP to include specific safeguards Mechanism mitigation measures for sourcing of materials from commercial suppliers, proper waste disposal, health and safety at construction site, and management of construction camps. • Conduct an orientation briefing for contractor and workers on the implementation of the EMP, prohibitions and penalties on any form of bird hunting and throwing of wastes into the lake, requirements for monitoring and reporting, and the GRM. Site preparation Soil erosion and • Install silt traps, sediment Contractor PMC, PMU Contractor and earthworks runoff of sediments deviation channels, barriers or trenches around stockpiles of

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by excavated soil and materials to confine sediment within the project site. • Schedule excavation works during the dry season. • Cover stripped soils and aggregates with impervious materials. Mud tracking of • Conduct regular cleaning of the Contractor PMC, PMU Contractor vehicles entering construction area and adjacent and exiting the street. construction site • Install wash bay at the entrance gate of the construction site to wash mud from the wheels (with water and sediments confined at the wash bay). Conduct regular cleaning of the wash bay to remove sediments for landfilling within the property. Construction of Worker health and • Require the contractor to maintain Contractor PMC, PMU Contractor the NASLA safety clean and sanitary condition of the facilities construction camp and work areas. • Provide clean and adequate water at the site • Provide separate male-female toilets connected to a septic tank. • Provide a waste segregation/collection area. • Provide PPEs for workers

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by • Conduct worker briefing/orientation on health and safety and EMP • Install safety signages in strategic locations within the construction site • Install guard lights for works occurring at night • Install temporary barricades and warning signs around excavations • Provide a readily accessible first aid station with medicines and emergency kits for workers. • Provide scaffoldings and safety nets for protection against falling debris. Construction of Community health • Schedule construction activities Contractor PMC, PMU Contractor the NASLA and safety; threat from 7:00AM to 5:00PM to avoid facilities to peace and order nuisance to residential houses in due to presence of the vicinity. migrant workers • Schedule deliveries at night to avoid traffic-related issues. • Haulers will be required to cover materials with durable canvass to avoid accidental spill of materials during deliveries. • Prohibit workers from loitering in the surrounding areas. • Prioritize qualified locals during hiring of construction workers

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by • Inform village authorities on the presence of migrant workers (if any). • Prohibit workers from engaging in alcohol drinking, gambling, drugs, and other illegal activities. • Prohibit workers from loitering in the surrounding areas and causing peace and order problems. Construction of Air quality and dust • Impose speed limit of 20kph on Contractor PMC, PMU Contractor the NASLA construction vehicles when facilities; delivery passing through the earth roads of materials near the site. • Require the contractor to conduct water sprinkling on these roads during dry and windy conditions. Construction of Noise • Coordinate with the village Contractor PMC, PMU Contractor the NASLA authorities and the nearest facilities residential house on the construction activities and schedule Construction of Domestic • Require the contractor to install Contractor PMC, PMU Contractor the NASLA wastewater septic tanks at the construction facilities; camp to prevent the discharge of operation of polluted sewage into the canal. construction camp at the site Construction of Solid waste • Implement waste segregation of Contractor PMC, PMU Contractor the NASLA reusable construction materials, facilities; biodegradable, and non- operation of the biodegradable wastes.

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by construction • Concrete wastes from the camp at the site demolition of the existing police building will be placed at low-lying areas inside the property. • Orient workers on the solid waste segregation system and prohibit them from indiscriminate throwing wastes outside of the property. Construction of Potential spill and • Construction vehicles will be Contractor PMC, PMU Contractor the NASLA leakage of oil refueled off-site to avoid oil spills. facilities; • Vehicle and equipment wash operation of the areas will be paved with concrete construction and located away from drainage camp at the site canals. • Fuel storage tank will be provided with retention areas to contain accidental spills. C. Operation Phase Operation of the Wastewater • Operation and maintenance of the NASLA MOI NASLA building and sewage treatment facility Administration dormitory • Effluent from the sewage treatment facility will be connected to the public drainage line on the main road for further treatment of wastewater in the proposed Kop Srov wastewater treatment plant to be managed by DPWT. Operation of the Solid Waste • Waste segregation and recycling NASLA MOI NASLA building and will be implemented to reduce the Administration dormitory volume of wastes to be disposed

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by through the city’s solid waste management system • Provide waste segregation bins. • Issue guidelines on waste segregation Operation of the Hazardous waste • Segregate the busted lamps from NASLA MOI NASLA building and the ordinary garbage. Administration dormitory • Dispose the busted lamps through recognized waste treater in accordance with the requirements of MOE. Impacts of Premature • Use of cladding, vines (climbers) NASLA MOI NASLA climate change weathering of • Use of energy efficient lighting Administration on building building materials options such as LED maintenance due to exposure to • Use of natural ventilation and carbon dioxide; greenspace floods, excessive • Maintenance of drainage system humidity and poor • Maintenance of the rainwater ventilation that can harvesting detention tank lead to growth of • Avoid ponding in areas of the molds; ventilation property. issues due to extreme heat; vector borne illnesses due to poor maintenance Operation of the Fires and other • Provide adequate exits with signs NASLA MOI NASLA building and emergencies • Develop an emergency response Administration dormitory (floods, extreme plan that includes an assembly hot spells, seismic and evacuation area, emergency activity, blackouts, alarms etc.

Activity Environmental Mitigation Measures Responsibility Source of Issues Funds Implemented Supervised by by • Maintain water sprinklers and fire extinguishers • Conduct capacity building of staff on the implementation of the emergency response plan.

56 Appendix B: Documentation of Stakeholder Consultation

Date 05 August 2019 Meeting Venue Sangkat Kouk Roka Project Location Trapeang Veng village, Kouk Roka commune, Prek Phnov district, Phnom Penh Participants Male: 36 Female: 8 Total: 44 Purpose of Discuss with potential affected people and other concerned Consultation stakeholders at early stage of project preparation to (1) identify possible involuntary impact, (2) anticipate environmental impacts, and (3) seek views, concerns, suggestions in order to incorporate into decision making such as project design, mitigation measures, the sharing of development benefits and opportunities, and implementation issues. Chair of the Meeting Deputy Governor of Khan Prek Phnov Mr. Chea Khema

1. Public consultation for the NASLA Project was organised in Sangkat Kouk Roka with participants from local authorities (representative from village, commune, sangkat), people living in the vicinity of the project site on 05 August 2019.

2. The public consultation was led by Mr. Ear Chariya, Officer from the Department of Training of the Ministry of Interior. Mr. Chariya provided the information of the proposed project, National School for Local Administration (NASLA), which is funded by the Asian Development Bank (ADB) on an 8-ha available land of the Ministry of Interior (MOI) in Sangkat Kouk Roka. MOI is now in the process of preparing the transfer of land ownership to the Project. He also mentioned the requirements and the purpose of the feasibility study during project preparation to (i) fulfil ADB safeguard requirements in the early identification of the expected environmental and social impacts and needed mitigation measures, and (ii) to verify if there is any potential project affected people. He wished that all participants can provide views, express concerns if any, and suggestions for better project design.

3. ADB social safeguard consultant, Mr. Sophy Ea explained the importance of social safeguards and the objective of avoiding involuntary resettlement wherever possible. For this project, the site has been chosen to have minimum impact on residents and businesses in the project area. From the site visit, no physical impact was observed such as impact on private land or structures since the project will take place within an enclosed area of 8ha of land owned by the MOI. There is potential local job opportunities during project implementation and local residents will have high chance and priority in working at the construction site.

4. Anticipated impacts and mitigation measures of the project: The environmental issues were presented by Mr. Sethy Sour, ADB Environment consultant. Mr. Sethy explained the anticipated project impacts on the environment and the proposed measures to mitigate negative impacts during construction. He asked the participants about flood events at the site and vicinity including highest reported flood levels for consideration in project design; availability of drainage; impact of project on lake, fisheries, and irrigation; and generation of wastewater and solid wastes. In addition, community health and safety issues during construction were also discussed in the consultation.

5. Before giving the floor to the participants, the ADB safeguards consultant, Mr. Sophy, also explained to all participants that they have the right to complain of the project impacts or express views or concerns; and the project will take into account and address depending on issues to be raised. Therefore, Grievance Redress Mechanism (GRM) will be put in place before the commencement of construction at the proposed location.

6. Questions, concerns, views and proposals from participants and response given to each of the concerns are presented in following table.

Position/category of Question/ concern/ view/ Answer/response given person (e.g. local proposal/suggestion resident, monk, local gov. officer) Mr. Nuon Samnavuth o The project needs to pay • Currently, there is no existing wastewater drainage system in the Chief of Division of Solid attention to wastewater project area. The project recommends Waste and Environment management and to cooperate that wastewater will not be discharged of Phnom Penh with Sangkat. There are directly to the Ta Mouk Lake since it will Municipality representatives in this consultation from all relevant cause water pollution and lead to loss of departments of Phnom Penh. benefits of local residents who depend o Architectural designs should be on fishery as income source, lotus presented to participants during plantation, and other lake related the consultation. incomes. Therefore, the project will o Waste collection: There is no consider (i) in-situ small wastewater regular solid waste collection at treatment plant, if it is affordable in this the project site by CINTRI. MoI project, to treat sewage from the school needs to coordinate with CINTRI before discharge, (ii) design of separate for solid waste management. systems for drainage and sewage to o Storm water can be discharged allow direct storm water discharge to the directly into the lake. lake, and (iii) discharge or connect wastewater from the project to sewerage system (if available) where it will finally go to Kob Srov lake through existing Phnom Penh municipal wastewater treatment site. • The architectural drawings will be finalized and will be presented to all relevant authorities before the construction starts. • Waste collection in area and in Phnom Penh, in general, is contracted through a private company (CINTRI). However, irregular solid waste collection service is provided in the area because of low population. Waste segregation will be recommended within the project in a well-managed location that is accessible by CINTRI. Mr. Chim Chea o There is current / ongoing plans • It is great to hear about the planning of the wastewater treatment plant in Kob Representative from for the construction of wastewater Srov. Department of Public treatment plant in Kob Srov by Works and Transport the Municipality of Phnom Penh. • The project will study the possibility of o There is main drainage system connection or discharge of wastewater along the national road which can from the NASLA site to the public be tapped for the wastewater municipal wastewater treatment system. discharge from the project. o JICA is doing the study on the rehabilitation of drainage and sewerage system of Phnom Penh metropolitan area. Mr. San Sin o Neither drainage nor sewerage • Deputy Governor explained that public service is improving, and Phnom Penh Chief of Sangkat Kouk system is available in most part of Water Supply Authority is expanding Roka Kouk Roka district. o Currently, about 20% still do not their coverage service. have access to clean water supply and they rely on private water suppliers or lake for their daily water consumption.

Mr. Chea Seng o The existing lake is now • These are good recommendations on separate drainage and sewerage Representative from separated into two parts: natural systems and solid waste storage Department of lake and wastewater site. location at site for the project to Environment o It is proposed to have separate drainage and sewerage system consider. for NASLA. o DoE proposes to the project to build its own wastewater treatment plant since the land is huge. o There should be traffic management on the access road to the site during construction. o There should be waste separation and storage at site before these are collected by CINTRI. Mr. Po Mom o The project is requested to build • The consultation aims to hear the views and concerns from local residents as Representative of local drainage and sewerage system well as all relevant parties in order to residents so that people can connect from the household to this public include in the project design and to system. avoid adverse impacts to environment o People still can use the lake as and livelihood of people in the project water supply source, if it is not area. polluted and since there is no clean water supply in the area yet. o Some people rely on the lake for their livelihood such as lotus plantation, fishing and restaurant etc. o Apparently, no physical impact or involuntary resettlement impacts will be caused by the project.

7. Conclusions from NASLA Representative and the consultants:

• The Project information was provided to all participants in the public consultation; • The suggestions and recommendations from the consultation such as separate drainage and sewerage system and in-situ solid waste storage management including waste reduction by separation and re-use will be noted and reported to design engineer for the consideration in the project detail engineering design; • Environmental management plan is required to prepare for the protection of environment and impact mitigation measures; • No physical impact was observed such as impact on private land or structures since the project will take place within an enclosed area of 8ha of land of MOI and the land ownership transfer to the Project is now in the processing stage20; • From site visit, the project will not cause any impact on livelihood or will disrupt any business operation during and after construction of the NASLA; • The participants are informed on their right to complain or express views and concerns to the project to address. The participants were informed that Grievance Redress Mechanism (GRM) will be put in place before the commencement of construction at the proposed location.

20 A letter from General Department of Administration, MOI, to H.E. Deputy Prime Minister Sar Kheng dated on 16 July 2019 requesting land title deed for the Project on a plot of 8ha at Kouk Roka district.

Photos of the Public Consultation and Project Site

Public Consultation Meeting at Sangkat Kouk Roka

Location of the Proposed Construction Site

Notes on Environment Safeguards (during public consultation)

On 05 August 2019, a consultation meeting was conducted at Sangkat Kok Rokar office, Khan Prek Phnov, Phnom Penh. The total participants are 44 of which 8 are women. The participants are representatives from Ministry of Interior, Phnom Penh’s Departments (including Department of Environment, Department of Public Work and Transport, and Environmental and Waste Management Division), Khan Prek Phnov (District), Sangkat Kouk Roka, villager chief, and villagers residing nearby the proposed project site. The meeting was opened by Deputy Governor of Khan Prek Phnov, followed by the presentation on social and environmental safeguards. The results of the discussion are summarized below:

1. The project site is located in Tra Peang Veng village, Sangkat Kok Rokar, Khan Prek Phnov, Phnom Penh. The proposed site covers on 8 ha of land and is approximately 400 m from Ta Mouk lake or most commonly called Kop Srov lake, with an area of 3200 ha. The lake is under control by Phnom Penh City. 2. Flooding: There is no flooding in the proposed project site. 3. Uses of the Ta Mouk lake: 3.1. Water supply/irrigation for rice or other crop: There are no rice land or crops in the project area is planted in the project areas that requires water from the lake, but only lotus is grown in the Ta mok Lake. 3.2. Fishing: Based on consultation meeting, the participants estimated that 40 % of the villagers in the project area are fishers. The fish catch includes: snakehead fish, moonlight gourami, Southeast Asian Yellowtail (Trey Changva), Goldfin tinfoil barb (Trey Chhpin), Asian Redtail catfish (Trey Chhlang), Peacock eel (Trey Chhlogn), so on (in Annex 1). 3.3. Domestic water supply: Participants raised that 40 % of the local people use water from the lake for bathing of cows, while other 60 % has connection to the government’s water pipe system; the water supply pipe system will be increased to 80 % for the Sangkat Kok Rokar (commune) next few months thus the domestic water use (for washing and cleaning of animals and yard) from the lake will decrease to be 20 % only. 4. Existing solid waste management: The waste collection in area is provided by a private company, CINTRI, who is contracted with government as service provider for the Household Solid Waste Collection, Transportation and Disposal in Phnom Penh City. Based on the consultation, the waste collection service is not so good. CINTRI needs to collect the waste daily but sometimes only every 1 or 2 weeks for some areas, particularly in small, difficult or narrow roads. Mostly the company collects waste on main big roads. A fee for waste collection is different that it is based on normal living household or business household. It starts from 1 USD per household for normal living household, but it is more cost for business households. 5. Wastewater drainage/system: There is no existing wastewater drainage system yet in the project area. 6. Electricity: The electricity is available in the area. 7. Awareness of the project: Participants don’t know about the project. They just know the proposed project during the consultation meeting on 05 August 2019. 8. Suggestion and Recommendation: The participants suggested the project to consider on key issues in following: - Wastewater from the NASLA school should not discharge directly to the Ta Mouk Lake because local people get benefit from the lake through fishing, lotus growing, and domestic water consumption, thus they recommended in following: (i) providing a small treatment plant to treat sewerage from the school before discharge; (ii) provide separate drainage systems (for storm water drainage system and sewerage system) thus the storm water can be discharged directly into the lake; (iii) discharging the sewerage to Kob Srov exiting wastewater canal near Kob Srov Dam, which is approximately 1 km from the project site. - Rain water: The rain water should be stored for flower or aesthetic tree or road cleaning in the NASLA school thus it can reduce rain water into a drainage and saving water from the water pipe system. - Solid waste management: School should provide a proper site for waste/garbage storage, waste separation, and disposal of the waste where allowed by government. - During construction, many trucks will be required thus safety should be highly considered. - Participants suggested to show a detail design plan thus they are easy to provide comment.

9. At end of the meeting, Deputy Governor of the Khan Prek Phnov said that this meeting is only preliminary assessment to evaluate on social and environmental assessment and he stressed on consideration on the safeguard issues and thanked the participants and ADB, then declared closing the meeting at 11.30 am, on the same day.

Fish Species in the Project Location

Asian Redtail Catfish Peacock Eel Goldfin Tinfoil barb

List of Participants NASLA PUBLIC CONSULTATION Location: Sangkat Kouk Roka Date: 05 August 2019

NASLA PUBLIC CONSULTATION: LIST OF PARTICIPANTS Gender No. Name Occupation/position Male Female 1 Chea Khema Deputy Governor of Prek Phnov M 2 Sour Sethy Environment Consultant, ADB M 3 Ear Charya Officer of Department of Training, MOI M Nuon Chief of Division of Solid Waste and 4 M Samnavuth Environment of Phnom Penh Municipality 5 San Sin Sangkat Chief, Kouk Roka M 6 Eam Bunthat 1st Deputy Chief of Sangkat Kouk Roka M 7 Men Hay 2nd Deputy Chief of Sangkat Kouk Roka M 8 Oung Ngoun Member of Sangkat Council M 9 Nov Sao Member of Sangkat Council M 10 Sral Sarin Member of Sangkat Council F F 11 Nath Channa Trapeang Veng villager F F 12 Po Mom Trapeang Veng villager M 13 Bo Savorn Trapeang Veng villager M 14 Prang Yong Trapeang Veng villager M 15 Kan Chev Trapeang Veng villager M 16 Soeung Sim Village Chief, Trapeang Veng M 17 Sok Chham Village Chief, O Andoung M 18 Sos Sam Village Chief, Svay Chek M 19 Phal Phoeun Trapeang Veng Village committee member M 20 Peang Vitou Trapeang Veng Village committee member M 21 Lim Savan Trapeang Veng Village committee member M 22 Thol Sothea Trapeang Veng Village committee member F F 23 Mak Sovathana Kouk Roka Clerk M 24 Oung Ngoun Sangkat council member M 25 Bin San Trapeang Veng Village committee member F F 26 Mao MOEun Vice village chief of Trapeang Veng F F 27 Vong Saran Trapeang Veng villager F F 28 Vong Sokna Trapeang Veng villager F F 29 Phal Pannha Trapeang Veng villager M 30 Choeun Phalla Trapeang Veng villager F F 31 Sim Leav Trapeang Veng villager M 32 Each Ath Trapeang Veng villager M 33 Sok Sophanna Vice office chief in charge, MOI M 34 You Manith Officer from MOI M 35 Meas Dara Officer from MOI M 36 Chim Chea Rep. from DPWT M Roath 37 Phnom Penh Municipality M Chansavath 38 Chean Nara Prek Phnov administrative chief M 39 Phal Sopheak Office of Urban Planning, Municipality M 40 Chea Seng Officer, DoE M

Gender No. Name Occupation/position Male Female 41 Oung Ngoun Member of Sangkat council M 42 Nov Sao Member of Sangkat council M 43 Sophy Ea Social safeguards consultant, ADB M 44 Greesh Sharma Procurement Specialist, ADB M

Safeguards Monitoring Report

# Monthly/Quarterly/Semiannual/Annual Report xxx {month} 20xx

COUNTRY: xxx {Project name}, xxx {sub-project name, if report covers only one sub-project}

Prepared by the Project Management Office of the Ministry of Interior (MOI) and the Asian Development Bank.

NOTE (i) In this report, "$" refers to US dollars.

This safeguards monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

I. EXECUTIVE SUMMARY

• Summary of EMP Implementation • Description of monitoring activities carried out (e.g. field visits, environment effect monitoring, survey questionnaire, public consultation meetings, focus group discussions, etc) • Key issues, any corrective actions already taken, and any grievances • Key activities planned in the next reporting period • Recommendations

Use the paragraph numbering format provided below throughout the report}

1. xxx

2. xxx

II. PROJECT OVERVIEW, GENERAL SAFEGUARD MATTERS

1. Project Overview

{Read and delete: Briefly describe project objectives, scope and components – can be taken from PAM or other relevant document}

2. xxx

3. xxx

2. Project Progress

{Read and delete: Using most recent project progress report, describe status of project implementation, including full list of contracts, status of contract awarding and implementation, name of contractor, Engineer, Project Supervision Consultant.}

5. xxx

6. xxx

Table 1: Project Overview, Snapshot of Project Progress Project Number and

Title: Environment

Safeguards Category Indigenous Peoples Involuntary

Resettlement Reporting period:

Last report date:

{This section should include, among others, the following:} Key sub-project Contract awarding activities since last Progress of Work (% physical completion) report: Status of Safeguard Approvals / Permits / Consents Report prepared by:

3. Safeguard Plans Implementation Arrangements

{Read and delete: Describe institutional arrangements and responsibilities for EMP and RP implementation, internal and external monitoring, and reporting, defining roles of PMU, Engineer, Implementation Consultant, Contractors. (Table format as needed)}

7. xxx

8. xxx

4. Updated EMPs, Incorporation of Safeguards Requirements into Project Contractual Arrangements

{Read and delete: Define manner by which EMP requirements are incorporated into bidding documents, contracts. Indicate when updated EMP was submitted for approval to ADB (Table format appropriate).}

9. xxx

10. xxx

III. ENVIRONMENTAL PERFORMANCE MONITORING

1. Status of EMP implementation (Mitigation Measures)

{Read and delete: Summarize main mitigation/protection measures implemented in the reporting period (narrative section). Structure in accordance to phases (detailed design, construction preparation, construction, and operation).}

1. xxx

12. xxx

{Read and delete: Include EMP table or updated EMP table if applicable. Assess compliance of environmental management activities with the original or updated EMP. For that purpose, include additional columns entitled “Compliance Status”, "Comment or Reasons for Non-Compliance", and "Issues for Further Action". Example is provided below.}

Table 2: Compliance with EMP Requirements (Environmental Performance) Compliance Status Comment or Reasons for Issues for Further EMP Requirements (Yes, No, Partial) Non-Compliance Action Use environmental impact Use EMP list as basis for as main heading and EMP rating/evaluating as listing (see example compliance (see example below) below)

Field inspections and Rise of employment interviews with opportunities: communities - DONE Job openings of the project Note each complaint case should give priority to local in the field – 3 communities. COMPLAINTS RECEIVED Recruitment of local Set up grievance redress laborers should be committee and report as stipulated in the contract part of monitoring action for construction plan – NOT DONE

Table 3: Issues for Further Action Responsibility and Issue Required Action Resolution Timing Old Issues from Previous Reports List of EMP measures or activities not completed

(last column of previous table)

New Issues from This Report

2. Health and Safety

{Read and delate: Provide narrative of occupational and community health and safety issues that occurred during the reporting period. Any accident involving injury or death of workers or community members must be reported. Include investigation report as attachment to the report. Provide details in the Table below}.

13. xxx

14. xxx

Table 4: Health and Safety Issues Responsibility and Issue Required Action Resolution Timing Old Issues from Previous Reports

New Issues from This Report

3. Environment Effect Monitoring

15. Monitoring plan. xxx {Read and delete: Present the environment effect monitoring plan as defined in the EMP or the updated monitoring plan. Describe monitoring responsibilities}

16. Monitoring activities in the reporting period. Xxx {Read and delete: Describe the environment effect monitoring activities in the reporting period, including number of monitoring campaigns, number of samples, etc. Confirm compliance with the monitoring plan, or justify any deviation from the plan}

Table 4: Environment Effect Monitoring Results in the Reporting Period {Read and delete: Present monitoring result in a Table (see example below, adjust as needed). Any non-compliance should be highlighted for attention and follow-up.} Date Relevant government Location Parameter Monitoring value standard, standard value

17. Assessment. Xxx {Read and delete: Compare monitoring results with baseline conditions (if baseline data is available) and relevant government standards in qualitative terms. Additional explanatory comments should be provided as necessary. Possible reasons for non-compliance should be identified.}

IV. COMPLIANCE WITH SAFEGUARDS RELATED PROJECT COVENANTS

{Read and delete: List all environment and resettlement related loan covenants, and assess project’s compliance with the covenants (Table format is appropriate, with concluding statement on compliance, partial compliance or non-compliance, and corrective actions as needed)

Remarks/Issues Schedule Para No. Covenant (Status of Compliance) Schedule 5 xxx Complied with / Partially complied with / Not complied with. {Identify reason for partial or non- compliance}

IV. PUBLIC CONSULTATION, INFORMATION DISCLOSURE, CAPABILITY BUILDING

{Read and delete: Describe public consultation activities during the reporting period. Confirm compliance with consultation plan defined in the IEE/EMP, or justify deviation from these plans. Present planned consultation activities in next reporting period. Use Tables as appropriate.}

• Field Visits (sites visited, dates, persons met) • Public Consultations and meetings (Date; time; location; agenda; number of participants disaggregated by sex and ethnic group, not including project staff; Issues raised by participants and how these were addressed by the project team) • Training (Nature of training, number of participants disaggregated by gender and ethnicity, date, location, etc.) • Press/Media Releases • Material development/production (e.g., brochure, leaflet, posters) • Information disclosure

V. GRIEVANCE REDRESS MECHANISM

{Read and delete: Describe mechanisms established to address and redress public complaints and grievances related to social and environment safeguards. Summarize grievances received, if any, and measures implemented to redress them.}

• Number of new grievances, if any, since last monitoring period: ____ • Number of grievances resolved: _____ • Number of outstanding grievances: _____

Details Required Action, (Date, person, Type of Grievance Responsibility and Resolution address, contact Timing details, etc.) Old Issues from Previous Reports

New Issues from This Report

VI. CONCLUSION

{Read and delete: Highlight important results from the implementation of EMP and RP monitoring; recommendations to improve EMP management, implementation, and monitoring; key activities planned in next reporting period}.

22. xxx

23. xxx

VII. ATTACHMENTS

• Consents / permits • Monitoring data (water quality, air quality, etc.) • Inspection checklists • Photographs • Others