INCLUSIVE EARLY CHILDHOOD EDUCATION AND CARE (ECEC) PROJECT

Environmental Management Plan for sub-project in

Draft Document v 6.0

Prepared by: Srdjan Susic, Environmental consultant

Belgrade, 6 March 2019 TABLE OF CONTENTS

TABLE OF CONTENTS ...... 2 LIST OF ABBREVIATIONS ...... 3 1. SUMMARY ...... 4 2. BACKGROUND INFORMATION AND GENERAL DIAGNOSTIC ASSESSMENT ...... 7

COUNTRY BACKGROUND ...... 8 TRIGGERED WORLD BANK SAFEGUARD PROCEDURES ...... 8 PROJECT DESCRIPTION ...... 8 3. APPROACH AND METHODOLOGY ...... 9 4. SUB-PROJECT DESCRIPTION ...... 10

BROADER LOCATION ...... 10 SITE DESCRIPTION ...... 11 PLANNED INTERVENTIONS ...... 11 RELEVANT CONSIDERATIONS...... 18 5. ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES ...... 20 6. CLAUSES FOR ENVIRONMENTALLY SOUND CIVIL WORKS CONTRACTS ...... 20 7. IMPLEMENTATION ARRANGEMENTS ...... 20 8. MONITORING ARRANGEMENTS ...... 21 9. REPORTING ARRANGEMENTS ...... 22 10. ENVIRONMENTAL IMPACT ASSESSMENT REPORT ...... 23 11. ENVIRONMENTAL MITIGATION PLAN ...... 25 12. ENVIRONMENTAL MONITORING PLAN ...... 36 13. REPORT ON PUBLIC CONSULTATIONS...... 41 14. ANNEXES ...... 44

2 LIST OF ABBREVIATIONS

ACM – Asbestos containing material EA – Environmental Assessment ECD – Early Childhood Development ECEC – Early Childhood Education and Care EIA – Environmental Impact Assessment ESMFD - Environmental and Social Management Framework Document EMP – Environmental Management Plan HEPA – High-efficiency particulate arrestance INP - Institute for Nature Protection of IPCM - Institute for Protection of Cultural Monuments of Serbia MEP – Ministry of Environmental Protection MESTD – Ministry of Education, Science and Technological Development of Serbia NGO – Non-Governmental Organization NOx – nitrous oxides OH&S – Operational Health and Safety OP – Operational Procedure PAH – polycyclic aromatic hydrocarbons PIU Project Implementation Unit PM – particulate matter RS – Republic of Serbia WB – World Bank

3 1. SUMMARY According to the Environmental and Social Management Framework Document for the INCLUSIVE EARLY CHILDHOOD EDUCATION AND CARE PROJECT (ECEC) and the World Bank Environmental Safeguard Operational Procedure 4.0.1, the Bank requires Environmental Assessment of sub-projects proposed to be financed with a Bank loan in order to ensure that the projects are environmentally sound and apply sustainable decision-making processes.

This Project is foreseen to expand access to quality ECEC services, in particular for children from socially disadvantaged backgrounds. This Project is expected to encompass four main components: i. Component 1 - Increasing the supply of ECEC services (approximately 35 million USD) ii. Component 2: Ensuring the Quality of Inclusive ECEC Services (approximately 5 million USD) iii. Component 3: Outreach to parents and young children (approximately 10 million USD) iv. Component 4 - Project Management and Monitoring and Evaluation (approximately 4 million USD) This Environmental Management Plan (EMP) is prepared in order to identify adverse environmental impacts of the sub-project located in Sremska Mitrovica, including site-specific impacts that could be overcome with proposed mitigation measures. This EMP ensures compliance relevant national legislation and WB requirements related to environmental impact assessment procedures and physical cultural resources, and is in line with the Environmental and Social Management Framework document that was completed and subject to public consultations in on November 4, 2016. In addition, this EMP is based and provides compliance with, relevant WB OPs that provide general policies, guidelines, codes of practice and procedures to be integrated into the implementation of all sub-projects considered for financing. This Plan consists of 14 chapters dealing with specific issues, as follows.

Chapter 2. Background information and general diagnostic assessment. This Chapter provides an overview of basic country information and the current environmental institutional architecture in the Republic of Serbia. It identifies the Ministry of Environmental Protection (MEP), as the key institution in Republic of Serbia responsible for formulation and implementation of environmental policy matters, while other institutions, such as the Institute for Nature Protection of Serbia (INP), the Institute for Protection of Cultural Monuments of the Republic of Serbia (IPCM) and the administrations of local municipalities address additional aspects of environmental management in the country. Concerning national environmental legal and environmental impact assessment frameworks in the Republic of Serbia, contained in the legislative system of the Republic of Serbia, as regulated by the Law on Environmental Impact Assessments, preparation of an Environmental Impact Assessment is not required for activities foreseen by the proposed sub-project (improving and extending the existing ECD infrastructure and construction of the new ECD infrastructure) in Sremska Mitrovica. In addition, this Chapter also addresses the triggered World Bank safeguard procedures, ECEC project falls into the category B concerning OP/BP 4.01 ENVIRONMENTAL ASSESSMENT, with its potential adverse environmental impacts on human population or environmentally important areas- including wetlands, forests, grasslands, or other natural habitats - are site specific, with only a few/if any, irreversible. This also applies to the proposed sub-project in Sremska Mitrovica. Finally, this Chapter provides detailed information about the ECEC project as a whole.

Chapter 3. Approach and methodology, discusses the developed and agreed methodology for developing site-specific EMPs to include primary data collection and analysis, mapping and analysis of secondary data through a desk study concerning publicly available information, including data on the location of the proposed sub-project. This methodology is entirely consistent with ESMF document developed for the Project.

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Chapter 4. Sub-project description, provides an in-depth description of the planned activities for the sub-project located in Sremska Mitrovica and is planned to be implemented under Component 1 of ECEC project. The sub-project is located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica, in the cadastral land plot no. 1032. The land plot in question has an area of 2509 m2, and is registered in the Cadaster of immovable properties as public property with title registered in the name of City Sremska Mitrovica. This land plot and adjacent land plot no. 1031 are placed under the previous protection categorized as "Conglomeration of a memorial character". The land plot adjacent to the site of the proposed sub-project is registered as property of the Serbian Orthodox Church and contains the church of Saint Archangel Michael, registered and protected as a cultural monument of great importance. Currently, the site of this sub-project contains an existing kindergarten facility built in 1970's, with the capacity that does not meet the needs of this pre-school institution.. This building is located along the construction line parallel to the street, measuring approximately 43.5x14.5m, with a gross surface area of 532 m2. Within the facility there are six classrooms for children, sanitary facilities, a small kitchen and a room for education and other staff. There is one underground fuel tank and one underground septic tank in close proximity to the existing building. Both of these tanks are currently out of use, decommissioned and are not visibly marked. Both tanks are in relatively poor condition and it is not known if they leak. The exact volume of both tanks is not known. The contents of both tanks was not checked. The building has only ground floor and is constructed of pre-fabricated gypsum elements on the inside (divisive walls), asbestos panels on the facade and the roof constructed of asbestos-containing corrugated elements. According to the official Project for Building Permit, the existing building is planned to be demolished at a certain future stage. Based on the information received from the PIU staff at the meeting held in MoESDT on 1 August 2018, in spite of the plans laid down in the Project for Building Permit, this sub-project envisages reconstruction of the existing facility and construction of a new ECD facility in its immediate proximity. According to the presented information, demolition of the existing infrastructure is not planned and the existing building will be reconstructed and connected to the new building. The conceptual solution for the new facility foresees a new kindergarten facility with a ground floor and one additional floor. The new building is located in parallel with the existing one, along the construction line in the northwest part of the plot. In this way, the southeast orientation of the children's rooms are turned to the inner courtyard. With the existing facility, the object is physically connected with a closed corridor that connects the existing building with the dining room and has exits to the yard. In this way, minimal intervention on the existing kindergarten facility was achieved, and a fusionary connection between the old and the new part was achieved. The location of the proposed sub-project currently possesses major infrastructure connections: drinking water, fire hydrants, waste collection and disposal service; electric lighting installation; telephone installations and city’s gas pipeline. Since the construction site is located in the existing and operational urbanized area, the environmental impacts during execution of civil works will be limited to the ones which are common to all construction activities – air, dust and noise pollution, vibrations and local soil and possibly groundwater disturbance. Most of the negative impacts will be felt only temporarily (during the execution of works) and will be limited in scope. In this regard, it is important to ensure maximum protection of facility users during the reconstruction and construction works on site, by implementing adequate measures.

Chapter 6. Environmental management responsibilities, identifies and discusses responsibilities of relevant parties (MOESTD, ECEC PIU, contractors, supervisors and others) to address each potential environmental and other impacts identified by the EMP and relevant mitigation measures.

Chapter 7. Clauses for environmentally sound civil works contracts, states that the most environmental impacts during the re-construction/construction phase will be possibly mitigated by including appropriate clauses into the civil works contracts. This Chapter concludes that construction

5 and other civil works contracts have to include this EMP with its Environmental Mitigation Plan and Environmental Monitoring Plan in a form to be fully binding to the contractors.

Chapter 8. Implementation arrangements, states that MOESTD will be responsible for overseeing the overall project implementation. Project management functions and day to day operations are be the responsibility of MOESTD and the ECEC Project Implementation Unit (PIU). PIU within MOESTD will also coordinate the overall working plan related to this sub-project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks. During the operational phase, when the facilities envisaged in this sub-project are constructed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment).

Chapter 9. Monitoring arrangements, ECEC project will be monitored by MOESTD and the PIU. Information and data collected at each of the implementation agencies will be fed into overall monitoring and evaluation framework. MOESTD will oversee M&E activities regularly through project reports, evaluate results achieved and guide the implementing agencies on corrective management actions. The main responsibility for implementation of EMP-related measures lays with the contractor, who needs to take into account and apply on a daily basis all proposed preventive and mitigation measures. The designated supervisory body needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor, and issue corrective instructions and/or orders, if necessary, in conjunction with the investor and ECEC PIU. The main inspection responsibility is, according to national legislation, given to the municipal staff (environmental Inspectors, communal inspectors, health and safety inspectors, building inspectors) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP), in accordance with the relevant legislation in Serbia. The Contractor is obliged to perform all activities defined within the Environmental Monitoring Plan of this EMP for which the Contractor is contracted. The designated supervisory body is responsible to monitor all construction activities, including environmental protection during project implementation.

Chapter 10. Reporting arrangements, provides detailed information on four separate monitoring lines and general reporting requirements: Tier 1. Contractor to Supervisor-The Contractor will prepare its compliance reports in respect to implementation of this EMP as EMP Quarterly Progress Reports and submit these to the designated supervisory body. These reports will be submitted in both Serbian and English languages, in hard copy and electronic versions. These reports will document the implemented environmental mitigation and protection measures, together with prescribed monitoring activities carried out during that quarter’s reporting period. The Contractor will take care of the quality of the environment according to the mitigation and monitoring plan, which are parts of this EMP. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation. Tier 2. Supervisor to Investor-The designated supervisory body will submit EMP Quarterly Progress Reports and the mid-term Environmental Report to the investor (municipality). Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the designated supervisory body will forward these reports to the investor (municipality) not later than 3 working days after the intial submission of the reports by the contrctor. Tier 3. Investor to ECEC PIU/MoESTD-The investor (municipality) will submit EMP Quarterly Progress Reports and and the mid-term Environmental Report to ECEC PIU/MoESTD. Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the investor will forward these reports to ECEC PIU not later than 3 working days after the intial submission of the reports by the contrctor. Tier 4. ECEC PIU to WB-ECEC PIU shall provide at least semi-annual reports to MOESTD

6 and WB, as layed out in the Project Operations Manual and Project Apppraisal Document, regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed. Monitoring and compliance in accordance with ESMF and this site-specific EMP, during project implementation will be undertaken by ECEC PIU (environmental specialist), and reported in writing to the Bank at least once during the lifetime of this sub-project. For all reporting, in case of any kind of accident or endangerment of environment happens and/or in case of health and safety related incidents, including but not limited to serious injury at work, loss of limb or death due to site related activities, reporting to ECEC PIU and WB will be immediate. This reporting will be done from Tier 1 to Tier 4 immediately and in its totality not exceeding 24 hours following the incident. The Contractor has the final responsibility for reporting and addressing the incidents to the designated supervisory body and the relevant authorities of the Republic of Serbia. ECEC PIU has the final responsibility for reporting and addressing the incidents to WB.

Chapter 11. Environmental Impact Assessment Report, provides a diagnostic overview of main parameters assessed in the physical/natural environment (groundwater, landscape and visual environment, existing or future land use and water and energy resources) and public hazardous elements (air quality, water quality, soil pollution, waste, noise and vibrations, biodiversity). All potential impacts examined are assessed to be negative, their magnitude is confined to the localized area of their appearance and their extent is localized to the sub-project site. Most of the identified impacts occur during the construction phase of this sub-project, their duration is mainly long and they are all reversible. The likelihood of identified impacts is assessed as unlikely, apart from the likelihood of impacts arising from waste generation and management, that is deemed certain. Significance of almost of identified impacts is minor, apart from impacts arising from waste generation and management, that is deemed significant.

Chapters 12. Environmental mitigation plan and 13. Environmental monitoring plan provide a detailed and specific overview of environmental risks associated with this sub-project and adequate mitigation measures, providing information on the responsibility of different stakeholders in implementing this Plan and safeguarding the environment in the sub-project operational area. Main identified risk areas are possible adverse environmental, health and safety impacts due to poor design and planning, inadequate application of EMP due to weak linkages of EMP with other contract documents, possible adverse environmental, health and safety impacts due to absence or non-observance of relevant procedures, Possible adverse environmental and health effects related to OH&S issues, water and soil pollution, waste generation, noise pollution and air pollution.

Chapter 14. Report on public consultations, provides the proofs concerning public disclosure obligations under ECEC ESMF, list of participants of public consultations and minutes from the public consultation meeting.

2. BACKGROUND INFORMATION and GENERAL DIAGNOSTIC ASSESSMENT This Environmental Management Plan (EMP) is prepared in order to identify adverse environmental impacts of the sub-project located in Sremska Mitrovica, including site-specific impacts that could be overcome with proposed mitigation measures. This EMP ensures compliance with relevant national legislation and WB requirements related to environmental impact assessment procedures and physical cultural resources and is in line with the Environmental and Social Management Framework document1 that was completed and subject to public consultations in Belgrade on November 4, 2016.

1 ESMF document can be accessed here: http://www.mpn.gov.rs/wp-content/uploads/2016/11/ESMF-ENG- 2.pdf

7 In addition, this EMP is based and provides compliance with, relevant WB OPs that provide general policies, guidelines, codes of practice and procedures to be integrated into the implementation of all sub-projects considered for financing.

Country Background Ministry of Environmental Protection (MEP), is the key institution in Republic of Serbia responsible for formulation and implementation of environmental policy matters. Other aspects of environmental management are addressed by other institutions, such as the Institute for Nature Protection of Serbia (INP), the Institute for Protection of Cultural Monuments of the Republic of Serbia (IPCM) and the administrations of local municipalities. Concerning national environmental legal and environmental impact assessment frameworks in the Republic of Serbia, contained in the legislative system of the Republic of Serbia, as regulated by the Law on Environmental Impact Assessments, , preparation of an Environmental Impact Assessment is not required for activities foreseen by the proposed sub-project (improving and extending the existing ECD infrastructure and construction of the new ECD infrastructure) in Sremska Mitrovica.

Triggered World Bank safeguard procedures ECEC project falls into the category B concerning OP/BP 4.01 ENVIRONMENTAL ASSESSMENT, as its potential adverse environmental impacts on human population or environmentally important areas- including wetlands, forests, grasslands, or other natural habitats - are site specific, with only a few/if any, irreversible. This applies to the proposed sub-project in Sremska Mitrovica. Further details on classification of the Project, procedure of environmental screening and preparation of the EIA/EMP and other environmental safeguards instruments is available in the Project-specific ESMF2.

Concerning World Bank OP/BP 4.11 PHYSICAL CULTURAL RESOURCES, the Sremska Mitrovica sub- project is classified as category B project, as it "will be located in, or in the vicinity of, a physical cultural resources site recognized by competent authorities of the borrower". This EMP identified the likely major physical cultural resources issues and proposes mitigation measures, as presented in Environmental Mitigation Plan in Section 6.

Project Description The World Bank approved the project "Inclusive Early Childhood Education and Care" on 21 February 2017 with a total project cost of 50 MUSD to support the Government of the Republic of Serbia to improve access to quality Early Childhood Education and Care (ECEC) services, in particular for children from socially disadvantaged backgrounds. This Project is implemented through four main components: Component 1: Expanding the supply of preschools spaces (approximately 34 MUSD). The objective of this component is to improve access to preschool services, particularly for disadvantaged children ages 3 to 5.5 years, by increasing the supply of spaces in high quality preschools. This component will finance approximately 17,000 new physical places in both urban and rural areas through a combination of new construction, extension of existing preschools, and repurposing or upgrading of other public buildings such as primary schools (or other buildings available in the municipality). Renovations and repurposing/upgrading will be prioritized in the first steps of project implementation to ensure fast increases in access, while new constructions will require more time. The refurbished and newly constructed environments will be conducive to child-centered education practices and will employ solutions that increase efficiency and flexibility. For all new and rehabilitated preschool institutions, the

2 ESMF document can be accessed here: http://www.mpn.gov.rs/wp-content/uploads/2016/11/ESMF-ENG- 2.pdf

8 component will also finance furniture, teaching-learning materials, equipment, and playgrounds. I. Municipalities will be identified and prioritized based on a proposed index (Municipality Eligible Index—MEI). The index is based on two dimensions (estimated preschool needs and social and economic characteristics of the municipality). In addition to all the new and upgraded preschools described above, this component would also finance up to five innovative centers to serve as model preschools for training and knowledge sharing purposes. This would be done either through new construction or through renovation of existing preschools that can demonstrate their potential to become such innovative centers. These preschool centers will be linked to teacher training institutions and will be used to share best practices in child-centered pedagogy (including as part of the roll-out of specific training activities under Component 2). They will be equipped as needed for optimal delivery of preschool services and for teacher training purposes. This component will also include training for local architects and engineers to promote efficiency and child-centered pedagogy in construction and renovation designs.

Component 2 (with three sub-components): Strengthening the quality of preschool services (approximately USD 5 million). This component would finance activities aiming to build the foundation of a quality preschool system that is characterized by a holistic approach to supporting children’s physical, emotional, cognitive development and wellbeing.

Component 3 (with three sub-components): Supporting young children and families (approximately USD 9 million). This sub-component would contribute towards creating effective learning environments that successfully nurture children’s wellbeing and holistic development and thereby maximize their gains from preschool attendance, including in the new or upgraded preschools supported as part of Component 1 but also more broadly.

Component 4 (with two Sub-components): Project management, technical assistance, and monitoring and evaluation (approximately USD 2 million).

Activities under the Component 1 of the ECEC Project, including the sub-project in Sremska Mitrovica, are the most likely to create adverse environmental impacts during construction on new sites and/or reconstruction of existing facilities. If negative environmental effects cannot be avoided, mitigation measures, as presented in this EMP, should be applied and monitored during site selection and all subsequent stages of Project planning and implementation. It is less likely that any environmental effects will be effectuated during preparation and implementation of Project components 2 and 3.

3. APPROACH AND METHODOLOGY The Environmental Consultant developed and agreed with the developing site-specific EMPs to include the following: • Primary data collection and analysis o Interviews and meetings with key stakeholders o Meetings with national and local decision makers o Interviews with other stakeholders relevant for the implementation of the project, • Mapping and analysis of secondary data through a desk study concenring other publicly available information such as relevant legislation, regulations and standrads of the Republic of Serbia, including data on the location of the proposed sub-project.

The methodology is entirely consistent with ESMF document developed for the Project, as presented above. A written confirmation or a statement from the World Bank, if the EMP deviates from it (and where, in case it deviates) is needed.

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Primary data made available to the consultant are listed in the exhaustive list below: • Design and technical documentation for Construction Permit, • Construction permit, • Property register database

The primary and secondary data were supplemented by one site visit, field verification and a walk over survey performed on 7 August 2018.

Data collection and review activities undertaken by the Environmental Consultant have followed the developed methodology and for the scope of the assignment was deemed to be sufficient. Based on data available the sub-project and its particulars were assessed by using the EA form as provided in ESMFD and presented in Section 5.

Information on location and type of works of the proposed sub-project were provided by authorized representatives of PIU and MOESTD. Identification and prioritization were of sub-projects were not part of the scope of this EMP and remain sole and exclusive covenants of PIU and MOESTD.

4. SUB-PROJECT DESCRIPTION Broader Location The proposed sub-project is planned to be implemented under Component 1 of ECEC project. It will provide for a significant expansion of pre-school spaces in the preschool facility "Pčelica" located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica.

Sremska Mitrovica is a city and the administrative center of the in the autonomous province of , Republic of Serbia. It is situated on the left bank of the river. As of 2011, the city has a total population of 37,751 inhabitants, while the city administrative area has a population of 79,940 inhabitants. The city of Sremska Mitrovica includes the town of Mačvanska Mitrovica, and several villages. Villages on the northern bank of the river Sava are Bešenovački Prnjavor, Bešenovo, , Čalma, Divoš, , , Kuzmin, Laćarak, Ležimir, Manđelos, , Sremska Rača, Stara , Šašinci, Šišatovac, Šuljam and . Villages on the southern bank of the river Sava, in the region of Mačva, are , Radenković, Ravnje, Salaš Noćajski, I and Zasavica II.

According to the 2011 national census results, the city administrative area has a population of 79,940 inhabitants. Concerning ethnic diversity, most of the settlements in the city have an ethnic Serb majority. Ethnically mixed settlement with relative Serbian majority is . The main concentration of ethnic minorities is in the urban area of the city. Climate of Sremska Mitrovica is humid continental climate (Köppen-Geiger climate classification)3. The area where Sremska Mitrovica is located is dominated by riverine wetlands, arable areas and flooded forests. This area belongs to the Black Sea catchment area and contains one protected site Zasavica, designated as a Ramsar Site (No.1783), Important Plant Area, Important Bird Area (RS008), and Prime Butterfly Area (40). According to the IUCN management categories, it is a Habitat and Species Management Area, category IV4.

3 Geiger, Rudolf (1961). Überarbeitete Neuausgabe von Geiger, R.: Köppen-Geiger / Klima der Erde. (Wandkarte 1:16 Mill.) – Klett-Perthes, Gotha. 4 The fifth national report to the United Nations Convention on Biological Diversity. 2014. https://www.cbd.int/doc/world/rs/rs-nr-05-en.pdf

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Site Description The sub-project is located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica, in the cadastral land plot no. 1032. The land plot in question has an area of 2509 m2, and is registered in the Cadaster of immovable properties as public property with title registered in the name of City Sremska Mitrovica in accordance with the law. The existing facility is constructed in the 1970's. The aerial view of the land plot is presented in Figure 1. This land plot and adjacent land plot no. 1031 are placed under the previous protection categorized as "Conglomeration of a memorial character". The land plot adjacent to the site of the proposed sub-project is registered as property of the Serbian Orthodox Church and contains the church of Saint Archangel Michael, registered and protected as a cultural monument of great importance.

Figure 1. The aerial view of the land plot1032 for this sub-project.

Planned Interventions

Currently, the site of this sub-project contains an existing kindergarten facility, with the capacity that does not meet the needs of this pre-school institution (photograph of the existing facility are presented in Figure 2). The building is located along the construction line parallel to the street, measuring approximately 43.5x14.5m, with a gross surface area of 532 m2. Within the facility there are six classrooms for children, sanitary facilities, a small kitchen and a room for education and other staff. There is one underground fuel tank and one underground septic tank in close proximity to the existing building. Both of these tanks are currently out of use, decommissioned and are not visibly marked, as presented in figures 3 to 5. Both tanks are in relatively poor condition and it is not known if they leak. The exact volume of both tanks is not known. The contents of both tanks was not checked. The building has only ground floor and is constructed of pre-fabricated gypsum elements on the inside (divisive walls), asbestos panels on the facade and the roof constructed of asbestos-containing corrugated elements (photos of these elements are presented Figures 6 to 10).

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Figure 2. The existing kindergarten facility (front view) and the adjacent churchyard (photo S. Susic)

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Figure 3. Approximate position of decommissioned fuel and septic tanks (position of the fuel tank indicated with a red square and of the septic tank with a blue square).

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Figure 4. Decommissioned septic tank in the yard of the facility (photo S. Susic)

Figure 5. Decommissioned heating fuel tank in the yard of the facility (photo S. Susic)

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Figure 6. Asbestos containing roof sheets (photo S. Susic) Figure 7. Heating pipes exposing a cross-section of an internal wall in the existing facility (photo S. Susic)

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Figure 8. Chipped samples of an internal wall in the existing facility Figure 9. Air-conditioning shaft exposing a cross-section of an internal (photo S. Susic) wall in the existing facility (gypsum, carton, paint) (photo S. Susic)

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Figure 10. A ventilation shaft with a cross-section of a facade insulation panel containing asbestos (photo S. Susic)

According to the official Project for Building Permit, drafted by Quiddita d.o.o., Belgrade and dated to December 2015 formally provided to the environmental consultant by the ECEC PIU staff, the existing building is planned to be demolished at a certain future stage. It is presumed that facility users (children) would be re-located in this case to other ECD facilities in Sremska Mitrovica during the works. However, based on the information received from the PIU staff at the meeting held in MoESDT on 1 August 2018, this sub-project envisages reconstruction of the existing facility and construction of a new ECD facility in its immediate proximity. No detailed plans or documentation on reconstruction of the existing facility have been provided by PIU or MOESTD during the preparation of this EMP. According to the presented information, demolition of the existing infrastructure will not be conduceted and the existing building will be reconstructed and connected to the new building (as presented in Figure 11). The conceptual solution for the new facility foresees a new kindergarten facility with a ground floor and one additional floor. The new building is located in parallel with the existing one, along the construction line in the northwest part of the plot. In this way, the southeast orientation of the children's rooms are turned to the inner courtyard. With the existing facility, the object is physically connected with a closed corridor that connects the existing building with the dining room and has exits to the yard. In this way, minimal intervention on the existing kindergarten facility was achieved, and a fusionary connection between the old and the new part was achieved. This EMP considers the renovation of the existing facility and construction fot new facility as the planned intervention for this sub-project.

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Figure 11. Rendered appearance of the new and old facilities on site.

Relevant Considerations The location of the proposed sub-project currently possesses major infrastructure connections: drinking water, fire hydrants, waste collection and disposal service; electric lighting installation; telephone installations and city’s gas pipeline. Since the construction site is located in the existing and operational urbanized area, the environmental impacts during execution of construction works will be limited to the ones which are common to all construction activities – air, dust and noise pollution, vibrations and local soil and possibly groundwater disturbance. Most of the negative impacts will be felt only temporarily (during the execution of works) and will be limited in scope.

As this EMP considers the renovation of the existing facility and construction fot new facility as the planned intervention for this sub-project, it is assumed that the functioning structural elements of the existing facility will be kept and that the existing facility will be fully reconstructed. This processes, is expected to generate different waste streams, that should be dealt with as presented in the subsequent sections of this EMP, but it is expected that certain waste streams will contain ACM that will be removed from the existing facility. These will have to be disposed in line with relevant national regulation and ECEC ESMF. In addition, the decomissioned septic tank and fuel tank found on the site, will have to be checked for their contents. In case either of them is found not be empty and dry, their contents should be checked for presences of hazardous chemicals/materials. In case either tank is found to be empty and dry it can bre moved and/or permanently sealed and left in the ground. In case that either tank contains liquids or other materials contaminated with hazardous chemicals/materials, their contents should be treated according to the Waste Management Plan to be developed for this sub-project and the relevant national legislation. In case that contents of either of the tanks is found not to be contaminated with hazardous chemicals/materials, the contents should be pumped out and removed and tanks permanently sealed and left in the ground or removed from the ground.

However, application of sound engineering practices and proper site and contract control will contribute to minimize or avoid negative impacts altogether. In order to avoid, prevent or mitigate

18 the potential occupational and community health and safety risks, potential environmental impacts on air quality, underground waters, noise disturbance, waste generation and management (particularly waste streams containing asbestos), sound demolition/construction practices implementing several mitigation measures is proposed within the following Environmental Mitigation Plan - EMP (Section 5 of this EMP). In this regard, it is important to ensure maximum protection of facility users during the reconstruction and construction works on site, by implementing adequate measures, such as closing and not using the existing faciity during the renovation and construction works, and/or ensuring that the site of the new facility is fully fenced with solid fence panels, and separate transport and access routes created for the children using the existing facility and new construction site/workers.

The main responsibility for implementation of EMP-related measures lays on the Contractor/Sub- contractor, who needs to take into account and applies on daily basis all proposed preventive and mitigation measures. The Site Supervisor needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor/Sub-contractor, and issue corrective instructions and/or orders, if necessary. The main inspection responsibility is, according to national legislation, given to the municipal staff (Environmental Inspector and Communal Inspector) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP).

PIU within MOESTD will also coordinate the overall working plan related to this sub/project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks. During the operational phase, when the facilities envisaged in this sub-project are reconstructed and constructed/completed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment).

19 5. ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES For each potential impact the EMP identifies proposed mitigation measure(s) and parties responsible for implementing those measures5, i.e.: • Executing agencies responsible for delivering the action. For this specific sub-project, the contractor/investor will ensure that all necessary agreements and permits are obtained from relevant national and local authorities before the construction works have started. • Construction contractors will take the responsibility for physical implementation of mitigation measures provided under the EMP during the construction phases according to the Bank’s policies and relevant Serbian legislation. • The designated supervisory body responsible for supervising the works (performed by the contractor) to ensure that they execute the mitigation measures as planned. Designated supervisory bodies (companies, individual consultants) will be responsible for supervising the timely, proper and reliable implementation of works and measures identified in this EMP, according to the risk mitigation table presented below. • ECEC PIU holds management responsibility to MOESTD and WB concerning the implementation of this EMP. • The Contractor will prepare its compliance reports in respect to EMP as Quarterly Progress Reports and submit these to the designated supervision body, that in turn provides these to the investor and ECEC PIU, as described in Sections 9 of this document. The same applies to the Environmental Monitoring and Supervision Contractors for their part of mitigation and environmental monitoring activities. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation6. • ECEC PIU shall provide semi-annual reports to MOESTD and WB regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed.

6. CLAUSES FOR ENVIRONMENTALLY SOUND CIVIL WORKS CONTRACTS Most environmental impacts during the re-construction/construction phase will be possibly mitigated by including appropriate clauses into the civil works contracts. Construction and other civil works contracts have to include this EMP with its Environmental Mitigation Plan and Environmental Monitoring Plan and at least, the following, in a form to be fully binding to the contractor(s): • Compliance with national environmental laws and standards; • Compliance with World Bank Operational Policies; • Adequate disposal of construction and excavation wastes; • Reasonable restoration of landscape in construction sites after works completion, in line with the relevant design documents (such as the design for the surrounding areas); • Occupational safety and health (consultants and contractors working on this sub-project will be required to adhere to all applicable laws and regulations controlling workplace health and safety).

7. IMPLEMENTATION ARRANGEMENTS

5 The World Bank during supervision missions may request randomly to check if such permits are issued and are valid as well as if the EMP mitigation and monitoring aspects are implemented on the ground during the construction phases according to the Bank’s policies and relevant Serbian legislation. 6 A provisional table of contents for this report is provided in Annex

20 Project management functions, including monitoring of the implementation of this EMP, and day to day operations are be the responsibility of the ECEC Project Implementation Unit (PIU) and MOESTD.

For the purpose of this sub-project, the MOESTD is considered to be the financing body while the municipal administration is considered as the investor. The financing body and the investor will sign a contract outlining mutual obligations, that will contain basic information and guidance on preserving the environment, as presented in this EMP. The financing body and the investor sign the contract for performance of works, after a tendering procedure, with the contractor. The designated supervisory body responsible for supervision of works performed by the contractor, will be selected after a tendering procedure and will sign the relevant contract with the investor. ECEC PIU and MOESTD will also coordinate the overall working plan related to this sub-project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks. During the operational phase, when the facilities envisaged in this sub-project are constructed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment) in accordance with the relevant legislation in the Republic of Serbia.

8. MONITORING ARRANGEMENTS

ECEC project will be monitored by MOESTD and the PIU. Information and data collected at each of the implementation agencies will be fed into overall monitoring and evaluation framework. MOESTD will oversee M&E activities regularly through project reports, evaluate results achieved and guide the implementing agencies on corrective management actions.

The main responsibility for implementation of EMP-related measures lays with the contractor, who needs to take into account and apply on a daily basis all proposed preventive and mitigation measures. The designated supervisory body needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor, and issue corrective instructions and/or orders, if necessary, in conjunction with the investor and ECEC PIU. The main inspection responsibility is, according to national legislation, given to the municipal staff (environmental Inspectors, communal inspectors, health and safety inspectors, building inspectors) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP), in accordance with the relevant legislation in Serbia. The Contractor is obliged to perform all activities defined within the Environmental Monitoring Plan of this EMP for which the Contractor is contracted. The designated supervisory body is responsible to monitor all construction activities, including environmental protection during project implementation. The Monitoring plan for this sub-project should be drafted against the bidding documents and it should include, at least:

• Environmental issue to be monitored and the means of verification • Specific areas, locations and parameters to be monitored; • Applicable standards and criteria; • Duration • Institutional responsibilities for monitoring and supervision • Reporting

The draft Monitoring plan is presented in Chapter 13. of this document.

21 9. REPORTING ARRANGEMENTS The reporting procedure for this sub-project will be done in four tiers, as described below.

Tier 1. Contractor to Supervisor The Contractor will prepare its compliance reports in respect to implementation of this EMP as EMP Quarterly Progress Reports and submit these to the designated supervisory body. These reports will be submitted in both Serbian and English languages, in hard copy and electronic versions. These reports will document the implemented environmental mitigation and protection measures, together with prescribed monitoring activities carried out during that quarter’s reporting period. The Contractor will take care of the quality of the environment according to the mitigation and monitoring plan, which are parts of this EMP. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation.

Tier 2. Supervisor to Investor The designated supervisory body will submit EMP Quarterly Progress Reports and the mid-term Environmental Report to the investor (municipality). Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the designated supervisory body will forward these reports to the investor (municipality) not later than 3 working days after the intial submission of the reports by the contrctor.

Tier 3. Investor to ECEC PIU/MoESTD The investor (municipality) will submit EMP Quarterly Progress Reports and and the mid-term Environmental Report to ECEC PIU/MoESTD. Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the investor will forward these reports to ECEC PIU not later than 3 working days after the intial submission of the reports by the contrctor.

Tier 4. ECEC PIU to WB ECEC PIU shall provide at least semi-annual reports to MOESTD and WB, as layed out in the Project Operations Manual and Project Apppraisal Document, regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed. Monitoring and compliance in accordance with ESMF and this site-specific EMP, during project implementation will be undertaken by ECEC PIU (environmental specialist), and reported in writing to the Bank at least once during the lifetime of this sub-project.

Specific Provisions on Reporting For all reporting tiers presented above, in case of any kind of accident or endangerment of environment happens and/or in case of health and safety related incidents, including but not limited to serious injury at work, loss of limb or death due to site related activities, reporting to ECEC PIU and WB will be immediate. This reporting will be done from Tier 1 to Tier 4 immediately and in its totality not exceeding 24 hours following the incident. The Contractor has the final responsibility for reporting and addressing the incidents to the designated supervisory body and the relevant authorities of the Republic of Serbia. ECEC PIU has the final responsibility for reporting and addressing the incidents to WB.

22 10. Environmental Impact Assessment Report

Evaluation of impact – reconstruction of the existing facility and construction of a new facility Environment

Duration of of Duration Type of Type of impact impact impact Reversible/ir of Likelihood Significance reversible occurs impact Extent/locati Positive Positive or negative Magnitude of impact on where impact occurs when Timing Physical/Natural Environment Groundwater pollution from leakage from negative local on site during long irreversible unlikely major underground fuel tanks extraction of underground fuel tanks Landscape and visual disruption of existing landscape negative local on site operational long potentially unlikely minor environment and visual environment phase irreversible Existing or future land use none Water and energy none resources Public hazardous elements Air quality Generation of emissions from negative local on site reconstructio long reversible unlikely minor mobile sources of CO2, NOx, PAH, n/constructio SO2 and suspended particulates n phase (PM10, PM2.5). Generation of airborne due to dismantling of the equipment, excavation, vehicle movement and handling with materials, particularly around the construction site. Water quality Possible impacts on due to negative local on site reconstructio long reversible unlikely minor contamination from spillage of n/constructio vehicle fuel, motor oils, lubricants n phase and improper dismantling of boilers and fuel reservoirs Soil pollution none Waste Environmental and health effects negative local on site reconstructio long irreversible/ certain significant due to inappropriate waste n/constructio reversible management of various waste n phase streams

23 Noise and vibrations Construction activities and traffic negative local on site reconstructio long reversible unlikely minor related noise and vibrations due to n/constructio machinery and vehicles used for n phase transportation of construction materials, transportation of workers, and transportation of waste Biodiversity (flora and none fauna) Physical Cultural Resources Protected cultural sites Possible disturbance by noise and negative local on site reconstructio short reversible unlikely minor vibrations due to removal of a fuel n phase tank, if applicable, located on the land plot containing a protected cultural building (church of St. Michael)

24 11. ENVIRONMENTAL MITIGATION PLAN

General Provisions

Potential Environmental Impact scale Proposed mitigation measures Responsibility Impact Activity: Design activities Possible adverse environmental, Local/ short • Relevant permits must obtained prior to any construction/re-construction works • Investor health and safety impacts due to term/unlikely to (Information about the location, Location Permit (including an extract from the poor design and planning happen/ major cadastral register of underground installations is issued by the Republic Geodetic significance Bureau, Department of Real Estate Cadaster); Approval of the location and the project documentation for fire protection (issued by the Serbian Ministry of Internal Affairs, Department for Emergency Situations) and Water Management permit, especially if the new facility is located near the riverbed, (issued by Public Enterprise “Srbijavode”), Construction Permit and Utilization permit for projects of constructing new facilities and reconstruction of the existing ones regardless; • In addition to addressing the requirements of the Mitigation Plan, the following additional documents will be produced during the design phase: • Site Organization Plan: to incorporate environmental, health and safety • Contractor protection measures that meet legal requirements (including the measures defined in this EMP), particularly taking into account transportation routes that should minimize adverse effects to nearby communities. • Soil Management Plan detailing measures to be undertaken to minimize effects of wind and water erosion on stockpiles, measures to minimize loss of fertility of topsoil, timeframes, haul routes and disposal site; • Waste and Wastewater Management Plan. All construction waste materials including drums, lumber, sand and gravel, cement bags etc. are to be suitably disposed of. If these cannot be recovered for scrap value these materials should be taken to an approved landfill sites for safe disposal. The Plan should cover all aspects of waste management, including implementation of practice standards such as reduce, re-use and recycle. It should specify final disposal alignments for all waste and demonstrate compliance to national legislation and best practice procedures on waste management. The Plan will, as a minimum, include details of temporary waste storage, waste transfer and pre-treatment prior to final disposal or recycling. Licensed/approved facilities for solid and liquid waste disposal must be used and a duty of care and chain of custody for all waste leaving the site will be followed. This plan needs to be updated by the Contractor (and approved by the Supervisor) within 30 days from the start of the

25 Contract. Inadequate application of EMP Local/ short • This EMP is to become integral part of the bid and contract documents. It is the • PIU due to weak linkages of EMP term/likely to Contractor’s obligation to cost the implementation of the environmental • Contractor with other contract documents happen/ major mitigation measures in his overall cost. The Contractor will be required to • Supervisor significance provide a short statement that confirms that EMP conditions have been costed into the bid price.

Activity: Civil Works – General Provisions Possible adverse environmental, Local/ short The Supervisor will be required to confirm that the following documents have been • Contractor health and safety impacts due to term/likely to prepared by the Contractors: • Supervisor absence or non-observance of happen/ major • Waste Management Plan, as desrbied in detail below. • MoESTD/ECEC project relevant procedures significance • Sewage management plan for provision of sanitary latrines and proper sewage staff (concenring collection and disposal system to prevent pollution of watercourses during the grievance redress plan) execution of civil works. This plan needs to be updated by the Contractor (and approved by the Supervisor) within 30 days from the start of the Contract. • Oil and fuel storage management plan. The Contractor’s Plan should cover all procedures for storage, transportation and usage of oils and fuels, refueling of machinery and procedures for minimizing the risk of ground and water contamination. All oils and fuels will be required to be stored within secondary containment of 110 % capacity and all spillages shall be cleaned up immediately. Re-fueling vehicles will carry Spill Kits to enable spillages to be cleaned up as soon as possible. • Emergency response plan. The Contractor’s Plan should contain procedures for emergency response in the event of accidents or major incidents, in order to safeguard people, property and environmental resources. Details of the spill response equipment to be provided on site are to be specified. • Noise Reduction Plan – all equipment is licensed and approved in accordance with EU standards. This applies to all machinery, vehicles and construction sites where noise and vibration may affect susceptible receptors. The contractor will be responsible for ensuring that noise and vibration does not affect the adjacent communities, in accordance with the Law on Noise Protection. • Rehabilitation Plan: Rehabilitation of construction sites and removal of contractor‘s facilities following successful completion of construction activities. This includes removal of all waste materials, machinery and any contaminated soil, if any. The contractor will develop a plan for handover, removal of all plant, vehicles and machinery to ensure that no unserviceable items are left on the construction site, in accordance with the Law on Waste Management and Law on Environmental Protection. • Grievances Plan: detailing the means by which local people and other project affected persons can raise grievances arising from the rehabilitation process and

26 how these will be addressed (e.g., through dialogues, consultations, etc.),as presented in ESMFD and sections of this EMP dealing with social issues ; • Health and Safety Plan: Contractor will be required to identify potential hazards and proposed relevant mitigation measures, including, provisions for emergency responses. This plan will ensure, at least, the following: • Provision for a safe work environment and provide safety measures and protective equipment to all workers, including hand, head, eye and ear protection and safety footwear. • Provision or first aid facilities on-site and employ a trained first aid person, in accordance with the Law on Safety and Health at Work. • Supplies of potable water, toilets and wash water to the workers. • Keep the site free of drugs and alcohol. • Contractor is responsible to ensure workers are properly trained and certified to use the equipment • Contractor is insured against accidents. • Contractor has qualified and experienced persons (at least one staff with an environmental or technical degree and at least 2 years of relevant professional experience in conducting similar tasks) on the Contractor‘s team who will be responsible for implementation of the environmental compliance requirements as stated in this EMP; • Contractor (and its sub-contractors) will comply with Republic of Serbia national laws and Lender requirements. Waste generation Local/ short • Preparation of Waste Management Plan for expected waste streams during the • Contractor Possible adverse environmental term/certain to decommissioning and construction phases and its approval, within 28 days from • Supervisor and health effects could occur happen/ high the reception of the Letter of Acceptance by the selected contractor. This Plan due to inappropriate waste significance must be reviewed and approved by the site supervisor. management of various waste • streams • Identify hazardous and non-hazardous waste and separate them at the demolition/construction site; • The majority of waste is expected to be classified under the Waste Chapter 17 “Construction and demolition wastes” with the waste code 17 01 – Waste from concrete, bricks, 17 09 04 – Mixed waste from construction site including glass from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it is possible, transport to the final deposition site); • Small quantities of glue, paint, packaging waste from paint, glue and solvents, aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company);

27 • Contract with company for waste collection and transportation should be signed for collection and transportation of waste including old windows and doors; • The materials should be covered during the transportation to avoid waste dispersion; • On-site open incineration of construction waste is prohibited.

Sub-project Specific Provisions

Activity: Reconstruction of the existing facility OH&S issues Local/ short • The construction site needs to be fully fenced using hard fencing panels not • Contractor Possible adverse health impacts term/certain to shorter than 2m, gated and information signs containing basic information on • Supervisor on workers, facility users and happen/ high this sub-project, including accessibility of grievance mechanisms should be general population in the significance placed on the construction and maintained during the civil works; community due to: • The area of the existing facility that is expected to be used by children during the • Location of facility in construction works should be fenced using hard fencing panels not shorter than an urban area 2m in the form of an inner fence, within the perimeter of the outer construction • Possible injury to site; people and facility • Traffic to and from the construction site, must be regulated in such a way to users due to ongoing ensure minimal disturbance to the daily routine of facility users, facility staff, works parents and the local community. Access and other roads on the construction • Non - compliance with site should not cross the roads and/or paths used by facility users, facility staff, local community parents and the local community in their daily routines. If this can not be safety regulations avoided, traffic on such roads should be organized outside of the busiest hours • Non - compliance with locally.; local community • Protection of pedestrians, general population and facility users and access of safety regulations non-authorized personnel to the construction site, will be achieved as above; • For construction workers - legally prescribed health and safety measures should be applied: a) use of appropriate protective clothing and equipment (masks against dust, wooden fragments and fibers, and safety harnesses for work at heights etc; b) Maintain a good level of personal hygiene; c) Health protection- first aid kits and medical service on sites need to be provided during the works; • Old windows and doors should be temporary placed in an area/space that prevents access of unauthorized persons on site within the perimeter of the outer fence; • Follow relevant safety guidelines contained in the Law on Waste Management of Republic of Serbia for the storage, transport, and distribution of hazardous materials to minimize the potential for misuse, spills, and accidental human exposure; • Perform regular maintenance of vehicles to minimize potentially serious accidents caused by equipment malfunction or premature failure;

28 • Organize 24-hour security service on the construction site; • Use labeling and placarding (external signs on transport vehicles); • Cleaning routines of facilities should be increased to address extra dust and dirt created by demolition/construction works. • Ensure that none of the facility users, parents and facility staff are rmoved from the facility during the reconstruction works; • If possible, start and end construction activities during the usual adequate season. • Old windows and doors should be stored temporary in a separate room on the • Contractor site or if this is not possible outside of the facility, covered and labeled “not to • Facility staff open/uncover” until final disposal. Water and soil pollution Local/ short • Possible hazardous waste (motor oils, vehicle fuels, lubricants) should be • Contractor Possible environmental impact term/medium collected separately and authorized company should be sub-contracted to • Supervisor on the underground water could significance/low transport and finally dispose hazardous waste. occur due to ground probability contamination from spillage of materials such as vehicle fuel, motor oils and lubricants Waste generation Local/ short • Identify hazardous and non-hazardous waste and separate them at the • Contractor Possible adverse environmental term/certain to demolition/reconstruction site; • Supervisor and health effects could occur happen/ high • The majority of waste is expected to be classified under the Waste Chapter 17 due to inappropriate waste significance “Construction and demolition/reconstruction wastes” with the waste code 17 01 management of various waste – Waste from concrete, bricks, 17 09 04 – Mixed waste from construction site streams including glass from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it is possible, transport to the final deposition site); • Small quantities of glue, paint, packaging waste from paint, glue and solvents, aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company); • Contract with company for waste collection and transportation should be signed for collection and transportation of waste including old windows and doors; • The materials should be covered during the transportation to avoid waste dispersion; • On-site open incineration of construction waste is prohibited. Removal of the asbestos Local/ short • Post signs indicating” ASBESTOS REMOVAL – NO ADMITTANCE” should be placed • Contractor containing construction term/major impact on construction site; • Supervisor elements on facility site • Restrict access to the removal area to those people directly involved in asbestos • Facility staff Possible adverse health impacts removal, site supervisor and municipal inspectors;

29 to the workers, facility users, • Roof and facade elements of the existing facility should be demolished during students and general public as a non-working days to decrease health risks to facility users; result of emissions of asbestos • Install barrier tapes and warning signs in proximity to facilities; fibers and dust during the • All construction workers must wear personal protective equipment (full body removal of asbestos sheets, covering including the head, water proof foot and hand protection and eye their transport and final disposal protection, dust mask with special HEPA filters); • Maintain a good level of personal hygiene (facility for washing hands and face should be made available and needs to be used by each employee when leaving the work area, all protective clothing and equipment shall work in the work area, footwear is to be kept in the construction area until works are completed; • Health protection-first aid kits and medical service on sites need to be provided during construction works; • No smoking, drinking or eating is allowed inside the construction area; • Surrounding area should be kept clean, without ACM waste disposed there. ACM waste (roof sheets, side wall panels, pipes) need to be collected, packaged and immediately removed from facility site. • If possible start and end demolition/reconstruction activities during summer months or during absence of facility users and staff. ACM Waste management Local/ short • Persons in charge of removal of ACM construction elements, such as roof sheets Possible adverse environmental term/major impact and facade panels should be trained on appropriate techniques for safe impacts and health effects could dismantling of ACM to minimize health risks, as prescribed in the Regulation on occur due to inappropriate preventive measures for safe ad healthy work during exposure to asbestos (OGRS handling of asbestos-containing 108/15), particularly concerning the utilization of protective equipment, waste maintenance of protective equipment, regular health monitoring of workers involved in ACM handling, applying for relevant permits, if applicable, and procedures for handling, transportation and final disposal of ACM by certified contractor(s); • Identification of asbestos containing materials – waste as a hazardous waste should be executed; • ACM waste need to be classified as a hazardous waste under the Waste Chapter 17 “Construction and demolition/reconstruction wastes” with the waste code 17 06 05* – Construction material containing asbestos in accordance with relevant national legislation; • ACM waste should be placed in polyethylene bags or other containers of at least 0.15 mm thickness, that ensure the receptacle/container are hermetically sealed; • Printed asbestos warning labels must appear on the outer surface of the container/bag warning that it is an “asbestos waste”; • Breaking of ACM roof sheets and facade panels into smaller pieces to fit into containers/bags is forbidden. Roof sheets and facade panels should be handled very carefully and removed in one piece, aiming not to be broken because during

30 the break the asbestos fibers and dust appear and pose a health risk. In case of deformation and/or breakage the above provisions apply. Techniques for safe handling and transportation are numerous, e.g. using wrapping materials and ensuring they are hermetically sealed or using larger solid containers with thickness exceeding 0.15 mm, provided they have ensure hermetic seal (Article 7, point 4, of the Regulation on preventive measures for safe ad healthy work during exposure to asbestos (Official Gazette of the Republic of Serbia, 108/15); • Avoid temporary storage of roof sheets and side wall panels within the facility, but it is necessary, precautionary measures should be applied – the ACM waste should be stored in a designated area with posted signage and/or caution tape to eliminate any possible access or damage; • Contract with the company for asbestos-containing waste collection and transportation should be signed for collection and transportation of asbestos- containing waste; • Following the removal of asbestos waste all surfaces in the facility need to be dusted with a damp cloth or vacuumed with a HEPA filter; • Workers who perform clean up should wear protective clothes as those who perform dismantling of roof sheets, side wall panels or pipes; • Contract with relevant landfill or other utility should be signed for final disposal of asbestos containing roof sheets, side wall panels and pipes; • Asbestos-containing waste should be disposed at the special area for disposal of that type of waste (responsibility of relevant landfill or other chosen utility) at the chosen landfill. Improper dismantling of fuel • Heating fuel tank and the septic tank should be checked for their contents and • Contractor and septic tanks the contents identified. • Supervisor • In case that heating fuel tank and/or the septic tank contain hazardous substances, the tanks must be emptied by pumps, as relevant, and removed in a manner to minimize environmental risks, also following provisions on protecting the physical cultural resources. • In case that the heating fuel tank and the septic tank are empty and do not contain any hazardous materials, they also may be be permanently sealed and left in the ground or removed. • Dismantling of tanks must be done by trained persons in order to avoid potential effects of oil spills on soil, which would contaminate the underground water and fully in line with the Law on Waste Management (OGRS 36/09 and 88/10). Noise pollution Local/ short • Construction works should not be permitted during nights, the operations on site • Contractor Demolition/reconstructionand term/medium should be restricted to the period 7.00 AM -7.00 PM. Bearing in mind the above • Supervisor reconstruction activities and significance/certain relevant OH&S measures, alterations of this schedule can be made exclusively on • Local communal and traffic will cause noise and to happen a case by case basis, subject to approval of the investor and ECEC PIU; environmental vibrations due to machinery and • The level of noise should not exceed national limited values for residential areas inspectors

31 vehicles used for transportation in open spaces, i.e. 55 dB during the day and evening and 45 dB during the night; of construction materials, • Excessively noisy vehicles should not be operated until corrective measures are transportation of workers, and taken, taking into account maximum noise levels (55 dB during the day and transportation of waste produce evening and 45 dB during the night). in decommissioning and construction phase Air pollution Local/Short • Usage of protective masks for the workers; • Contractor Demolition/reconstructionand term/low • Vehicles and construction machinery will be required to be properly maintained • Supervisor reconstruction activties will significance/ certain and to comply with relevant emission standards; • Local communal and generate emissions from mobile to happen • Conduct regular maintenance of vehicles and construction machinery in order to environmental sources (vehicles and reduce leakages of engine oils, emissions and dispersion of pollution; inspectors construction machinery) of CO2, • Vehicle loads have to be covered to prevent emission of dust; NOx, PAH, SO2 and suspended • Construction site, transportation routes and materials handling sites should be particulates (PM10, PM2.5). water-sprayed on dry and windy days; Airborne dust will be caused by • Construction materials should be stored adequately to minimize dust dismantling of the equipment, generation; excavation, vehicle movement • Open incineration of debris will not be permitted; and handling with materials, • Restriction of the vehicle speed within the construction location. particularly around the construction site. Physical Cultural Resources Local/Short • Consent from the relevant administrative authority to perform works on the • Contractor Possible disturbance by noise term/low grounds containing a protected cultural monument and consent from the owner • Supervisor and vibrations due to removal of significance/unlikely of the affected land plot containing a protected cultural monument, should be • Local communal a fuel tank located on the land obtained; inspectors plot containing a protected • Equipment used should be fitted with appropriate noise reduction devices; cultural building (church of St. • The level of noise should not exceed national limited values for (depends on the Michael), if applicable area of protection where works take place); • Install barrier tapes and warning signs in proximity to facilities; Activity: Construction of the new facility OH&S issues Local/ short • The construction site needs to be fully fenced using hard fencing panels not • Contractor Possible adverse health impacts term/certain to shorter than 2m, gated and information signs containing basic information on • Supervisor on workers, facility users and happen/ high this sub-project, including accessibility of grievance mechanisms should be general population in the significance placed on the construction and maintained during the civil works; community due to: • The area of the existing facility that is expected to be used by children during the • Location of facility in construction works should be fenced using hard fencing panels not shorter than an urban area 2m in the form of an inner fence, within the perimeter of the outer construction • Possible injury to site; people and facility • Traffic to and from the construction site, must be regulated in such a way to users due to ongoing ensure minimal disturbance to the daily routine of facility users, facility staff, works parents and the local community. Access and other roads on the construction

32 • Non - compliance with site should not cross the roads and/or paths used by facility users, facility staff, local community parents and the local community in their daily routines. If this can not be safety regulations avoided, traffic on such roads should be organized outside of the busiest hours • Non - compliance with locally.; local community • Protection of pedestrians, general population and facility users and access of safety regulations non-authorized personnel to the construction site, will be acheieved as above; • For construction workers - legally prescribed health and safety measures should be applied: a) use of appropriate protective clothing and equipment (masks against dust, wooden fragments and fibers, and safety harnesses for work at heights etc; b) Maintain a good level of personal hygiene; c) Health protection- first aid kits and medical service on sites need to be provided during the works; • Old windows and doors should be temporary placed in an area/space that prevents access of unauthorized persons on site within the perimeter of the outer fence; • Follow relevant safety guidelines contained in the Law on Waste Management of Republic of Serbia for the storage, transport, and distribution of hazardous materials to minimize the potential for misuse, spills, and accidental human exposure; • Perform regular maintenance of vehicles to minimize potentially serious accidents caused by equipment malfunction or premature failure; • Organize 24-hour security service on the construction site; • Use labeling and placarding (external signs on transport vehicles); • Cleaning routines of facilities should be increased to address extra dust and dirt created by demolition/construction works. • If possible, start and end construction activities during the usual adequate season. Water and soil pollution Local/ short • Possible hazardous waste (motor oils, vehicle fuels, lubricants) should be • Contractor Possible environmental impact term/medium collected separately and authorized company should be sub-contracted to • Supervisor on the underground water could significance/low transport and finally dispose hazardous waste. occur due to ground probability contamination from spillage of materials such as vehicle fuel, motor oils and lubricants Waste generation Local/ short • Identify hazardous and non-hazardous waste and separate them at the • Contractor Possible adverse environmental term/certain to demolition/construction site; • Supervisor and health effects could occur happen/ high • The majority of waste is expected to be classified under the Waste Chapter 17 due to inappropriate waste significance “Construction and demolition wastes” with the waste code 17 01 – Waste from management of various waste concrete, bricks, 17 09 04 – Mixed waste from construction site including glass streams from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it

33 is possible, transport to the final deposition site); • Small quantities of glue, paint, packaging waste from paint, glue and solvents, aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company); • Contract with company for waste collection and transportation should be signed for collection and transportation of waste including old windows and doors; • The materials should be covered during the transportation to avoid waste dispersion; • On-site open incineration of construction waste is prohibited. Noise pollution Local/ short • Construction works should not be permitted during nights, the operations on site • Contractor Construction activities and term/medium should be restricted to the period 7.00 AM -7.00 PM. Bearing in mind the above • Supervisor traffic will cause noise and significance/certain relevant OH&S measures, alterations of this schedule can be made exclusively on • Local communal and vibrations due to machinery and to happen a case by case basis, subject to approval of the investor and ECEC PIU; environmental vehicles used for transportation • The level of noise should not exceed national limited values for residential areas inspectors of construction materials, in open spaces, i.e. 55 dB during the day and evening and 45 dB during the night; transportation of workers, and • Excessively noisy vehicles should not be operated until corrective measures are transportation of waste produce taken, taking into account maximum noise levels (55 dB during the day and in decommissioning and evening and 45 dB during the night). construction phase Air pollution Local/Short • Usage of protective masks for the workers; • Contractor Construction activities will term/low • Vehicles and construction machinery will be required to be properly maintained • Supervisor generate emissions from mobile significance/ certain and to comply with relevant emission standards; • Local communal and sources (vehicles and to happen • Conduct regular maintenance of vehicles and construction machinery in order to environmental construction machinery) of CO2, reduce leakages of engine oils, emissions and dispersion of pollution; inspectors NOx, PAH, SO2 and suspended • Vehicle loads have to be covered to prevent emission of dust; particulates (PM10, PM2.5). • Construction site, transportation routes and materials handling sites should be Airborne dust will be caused by water-sprayed on dry and windy days; dismantling of the equipment, • Construction materials should be stored adequately to minimize dust excavation, vehicle movement generation; and handling with materials, • Open incineration of debris will not be permitted; particularly around the • Restriction of the vehicle speed within the construction location. construction site. Operational phase of the Project No environmental risks are Local/ short • Fire prevention Plan should be prepared addressing fire risks and ignition • Facility staff expected. Positive impact (more term/major at the sources, as well as measures needed to limit fast fire and smoke development. space for facility users, new location of facilities • Prevention Maintenance Plan for regular and preventive maintenance should be sport facilities, energy efficiency prepared to ensure proper operation of all infrastructure components of the

34 and energy savings, reduction of facility (sewer system, storm-water system, water supply system, heating GHG emissions) is expected with devices); construction of the new • Procedure for keeping records should be established in order to ensure proper facilities. storage of all technical documentation.

35 12. ENVIRONMENTAL MONITORING PLAN

Which parameter is to be Where is the How is the When is the Why is the parameter to be Responsibility monitored? parameter to parameter to parameter to be monitored? be monitored? be monitored? monitored (frequency of measurement)? Activity: Design activities Status of necessary permits On facility site Review of the Before the start of To ensure full compliance with Investor and plans (Site Organization necessary construction works regulations of the Republic of Serbia and Contractor-Bidder Plan, Soil Management Plan, permits, Plans the lender Design engineers/Architects Waste and wastewater and contracts ECEC PIU staff management plan, Sewage with the To ensure full application of EMP by the management plan, Oil and contractors Contractor and ensure efficient linkages fuel storage management of EMP with other contract documents plan, Emergency response plan, Noise reduction plan, Rehabilitation Plan, Grievances plan, Health and Safety Plan) Inclusion of EMP provisions in contracts Activity: Civil Works – General Provisions Completion and On facility site Review of plans Before the start of To minimize the risk of adverse Contractor - Bidder /Supervisor implementation of relevant and contracts construction works environmental, health and safety impacts procedures with the due to absence or non-observance of contractors relevant procedures Project activity: Demolition of the existing facility and construction of the new facility Community safety In vicinity of Visual checks At beginning of works To ensure minimization of health and Contractor - Bidder /Supervisor/ regulations and protection facility sites and every working day safety risks - mechanical injuries to Municipal staff: Communal and measures applied until closure of works members of local community - Environmental Inspector/ Facility staff especially from broken glass, wooden windows and doors and spikes. Special attention should be given to removal of the asbestos containing roof sheets Fire Protection Plan Before the start Review of the At the beginning of To ensure that all fire protection Municipal staff: Communal and of facility Plan facility operation measures are implemented Environmental Inspector operation

36 The OH&S protection On facility site Visual checks Every working day until To minimize risks related to occupational Contractor - Bidder /Supervisor/ measures applied for closure of works health and safety of workers using, Municipal staff: Communal and workers at facility sites particularly those handling asbestos Environmental Inspector/ Facility staff containing wall panels Avoid and minimize safety In facility and Visual checks At the beginning of To avoid injuries of facility users and Contractor - Bidder /Supervisor/ and health risks for facility immediate demolition works and staff from falling objects (fragments of Municipal staff: Communal and users and staff surroundings continuously every windows, doors, broken glass and Environmental Inspector/ Facility staff working day inhalation of asbestos fibers or dust) Waste Management Plan for On facility site Review the Before demolition To ensure minimization of waste Contractor - Bidder/Supervisor/ all generated waste streams document - activities start generation and appropriate disposal Municipal staff (Communal and Waste Environmental Inspector Management Plan Existence of fragments of In facility Visual checks For broken glass To avoid and minimize injuries and dust Contractor - Bidder /Supervisor/ glass, dust generated during immediately/For dust inhalation Municipal staff: Communal and the demolition generation every day Environmental Inspector/ Facility staff after completion of work Generation of different types for inert waste every on of waste 2 days Level of dust - fine On facility site Visual monitoring On sunny dry days only To avoid and minimize airborne dust Contractor - Bidder and authorized particulate matter (once a week at the peak accumulation and minimize health risks company for dust measurements working hour) for facility users and staff, as well as local residents. Collection, transportation In temporary Review the Before transportation of To improve waste management Authorized contractor for collection and storage of hazardous storage facility transportation list hazardous waste (if any practices at municipality and national and transportation of hazardous waste waste (if any generated) and conditions at generated) level. (if any generated) subcontracted by the storage the Contractor- Bidder/ Environmental facility inspector Noise from construction On facility site Auditory On regular basis during To monitor if noise levels are above or Contractor - Bidder Authorized works monitoring of works, in accordance below the accepted noise levels for that Company for performing noise level noise and noted with national legislation particular area measurements sub-contracted by the of complaints Contractor – Bidder/ Environmental from local Inspector to collect noise level residents measurements

37 Exposure to noise from On facility site Review noise Before beginning of To protect the workers against exposure Contractor - Bidder Supervisor vehicles, machines, level technical works (first day) for all to loud noise taking into account the Environmental Inspector /Inspector for mechanization and other specifications for vehicles and equipment technical specifications of the communal works equipment vehicle used, equipment and time duration of the mechanization work outside and equipment for their usage outside Physical Cultural Resources On facility site Visual checks and During and after the Presence of excessive dust, cracks Contractor - Bidder Supervisor Disturbance by noise and interviews dismantling of the fuel caused by vibrations and disturbance in Local communal inspector vibrations due to removal of tank appearance of the land plot containing a fuel tank located on the the protected cultural building. land plot containing a protected cultural building (church of St. Michael) Project activity: Demolition of construction elements containing asbestos Primary selection of waste On facility sites Review At beginning of works To separate hazardous (packaging for Contractor - Bidder Supervisor/ streams at facility sites documentation - glue, paint, solvents, insulation and Municipal staff: Communal and identification of other material) from non-hazardous Environmental Inspector waste types waste according to national waste To separate inert from biodegradable categorization waste lists Identification of asbestos- On facility sites Review At beginning of works Asbestos containing (ACM) waste is Contractor - Bidder Supervisor/ containing waste, documentation - hazardous waste with adverse Municipal staff: Communal and appropriate packaging and identification of environmental and health impacts Environmental Inspector labeling waste types according to national waste categorization lists

38 Temporary storage of In separate Visual checks On daily basis To minimize injuries and adverse Contractor-bidder removed windows and doors rooms/basement environmental and health impacts Facility staff with appropriately labelled of facilities or in and covered their close Temporary storage of proximity removed asbestos containing roof sheets and piped, appropriately labelled and packed Collection, transportation On facility sites Visual monitoring After the collection and Not to leave waste on facility sites to Contractor - Bidder who needs to sign and final disposal of wooden and in their and reviewing transportation of waste avoid environmental and health impacts the contract with licensed company for windows and doors vicinity transportation from old wooden to the facility users collection, transportation and disposal logs windows and doors by of waste public communal utilities Contract with authorized Before works Review contracts During collection and To ensure that asbestos-containing Contractor - Bidder who needs to sign transporter of asbestos start transportation of waste will be treated according to contract with licensed company for containing waste should be removed roof covers and national legislation, international acceptance and final disposal of signed pipes conventions and best available practices asbestos-containing waste. Chosen Contract with the chosen landfill must hold a license for landfill should be signed as Before final disposal of acceptance and final disposal of well for acceptance and final removed sheets and asbestos waste issued by the relevant disposal of asbestos- pipes Ministry. containing waste

Annual Report on Local self- Review of After completing To improve waste management and Mayor of municipality transportation and disposal government documentation - collection, hazardous waste management at local of waste administration Identification transportation, and national level waste list temporary disposal and final disposal of different types of waste, including asbestos-containing waste

39 Project activity: Operational phase of facility Drinking water quality Before starting Laboratory Before starting facility To ensure distribution of high quality Municipal staff Facility staff operation of equipment for operation drinking water facility users and to Institute for public health piping in facilities, physical- chemical minimize health risks of waterborne tap water should and diseases be sampled and microbiological analyzed by the water quality authorized and analysis accredited laboratories Fire Protection Plan Before starting Review Plan At beginning of facility To ensure that all fire protection Municipal staff: Communal and facility operation operation measures are implemented Environmental Inspector Facility staff Plan for regular and Before starting Review Plan At beginning of facility Municipal staff: Communal and preventive maintenance of facility operation operation Environmental Inspector facilities Facility staff

40 13. REPORT ON PUBLIC CONSULTATIONS

The disclosure of this EMP document started on 25 February 2019, when ECEC PIU and the City of Sremska Mitrovica announced the invitation for Public Consultations for the public, bodies and organizations interested in this EMP document. Public and other interested parties and organizations were invited to participate in process of public consultation on this draft EMP document. Insight into the ESMF document was ensured by the following: • Placing the draft document in on the following Internet address: o http://www.sremskamitrovica.rs/admin_area/kcfinder/upload/files/javnakosult1_.p df • Inviting all interested parties to review the EMP document and attend public consultations by placing an hard copy of the invitation on the notice board of the City of Syrmaks Mitrovica on 25 February 2019. • Ensuring access to a hardcopy of the document at the premises of the municipal administration building of the City of Sremska Mitrovica (address: Svetog Dimitrija Street 13, Sremska Mitrovica).

Disclosure of this EMP document finished by organizing public consultations and presentation of this EMP document that were held in the premises of the City of Sremska Mitrovica on 5 March 2019, from 11:00 AM to 12:00 midday. Up to the said date when the disclosure process was concluded, no complains, suggestions or any other form of communication concerning the draft EMP document had been received in any form and through any of the communication means.

There were 8 attendees present at the public consultation meeting, and these were the following: 1. Zorica Žigić, interested citizen 2. Petar Ranisavić, staff of City of Sremska Mitrovica 3. Vera Jakšić, interested citizen 4. Jovana Karastanković, interested citizen 5. Slavoljub Erdeljan, interested citizen 6. Milan Dimitrijević, staff of City of Sremska Mitrovica 7. Momčilo Gajić, ECEC PIU staff 8. Srdjan Sušić, ECEC PIU environmental specialist

The meeting started according to schedule at 11:00 AM. EMP document was presented in detail to the interested attendees by Srdjan Sušić. During the public consultations, there were several questions, comments and remarks in regards to environmental protection issues, presented below of which all of them were addressed immediately: 1. Question: To whom the designated supervisory body (page 10, section 7) is responsible in this sub-project? It should be made clearer that the designated supervisory body has to operate according to the relevant Serbian regulations. Answer: Monitoring of the implementation of this EMP is discussed in details in Chapters 9 and 10. At the time of completion of this EMP, monitoring and reporting lines were defined as presented in the current document. In the following months, agreement between MOESTD and WB on the final outline of the reporting lines was reached. This outline was explained at the Public Consultations and will be changed in the final version of the EMP document accordingly.

41 Action: Introduce the new agreed reporting outline to the text of this EMP.

2. Question: The currently valid Construction Permit, issued by the City of Sremska Mitrovica to the City administration for infrastructure and administration on 25 November 2016 (number: ROP-SMI-26564-CPI-3/2016) is going to be altered in the coming days/weeks, upon the request for alterations by the City administration for infrastructure and administration. The new Construction Permit is expected to state that the existing kindergarten facility will not be demolished, but rather reconstructed. All other issues are expected to remain unchanged.

Answer: The current EMP is based on the pertinent information collected from the currently valid Construction Permit and information received from ECEC PIU staff. The works and actions to be taken during the implementation of this sub-project are reflected in the current EMP, and fully encompass the expected alterations in the new Construction Permit.

3. Question: What are the planned measures to be taken by the contractor in order to ensure safety of the facility users during reconstruction and construction works? This issue should be covered in more detail in the current EMP. One of the potential solutions would be not to limit the working hours on the construction site only outside of the working hours of the existing facility, but to allow flexibility of the operational schedule, based on the individual daily needs. It was suggested that the facility users should be moved out of the facility during the reconstruction works on the existing building and re-assigned to other similar neighboring facilities. During the construction phase of the new building, the construction site has to be physically separated from the rest of the perimeter of the facility, with hard paneling of at least 2m height. Access roads to the construction sites in both cases (reconstruction of the existing building and construction of the new one) should not disturb the daily routine of the facility and pose additional risks to its users.

Answer: The relevant provisions of the current EMP will be changed to respond to these requests. Action: Amend the current EMP to reflect the presented requests.

4. Question: What does the lighting of the construction site mean? Can it be ensured that this lighting does not produce excessive pollution by light?

Answer: The usual general practice in Serbia that does not cause excessive pollution by light, prescribed in the current EMP, is suggested to be applied.

5. Question: According to the current Serbian legislation, it is not the designer who is responsible for obtaining all necessary permits, but the investor. Can this be changed in the current EMP?

Answer: The relevant provisions of the current EMP will be changed to respond to this request. Action: Amend the current EMP to reflect the presented request.

6. Question: In addition to Question 3, it should be ensured that the operating hours for the construction site remain flexible and not only from 7 AM to 7 PM. This is because a need might arise to work during the night when temperatures are expected to be lower, rendering the operation conditions, e.g. for works with fresh concrete, more favorable.

Answer: The relevant provisions of the current EMP will be changed to respond to this request. Action: Amend the current EMP to reflect the presented requests.

42 7. Question: The provision on necessary training of the facility staff by municipal authorities on relevant administrative procedures should be removed. Answer: The relevant provisions of the current EMP will be changed to respond to this request. Action: Amend the current EMP to reflect the presented requests. 8. Question: The provision for measuring the concentration of dust particles in the air and the level of noise on the construction site should be removed. Works envisaged for this sub- project are of smaller scope and are not expected to cause significant increase of dust particles in the air or excessive levels of noise on the construction site. Answer: The relevant provisions of the current EMP will be changed to respond to this request, with the addition that the measurements concerning dust concentration and levels of noise should be performed only in case when repeated complains in this regard have been formally lodged with the project, based on the project Grievance Mechanism. Action: Amend the current EMP to reflect the presented requests.

The Public Consultations meeting ended at 12:00 midday, local time. Copies of internet announcements, copy of the newspaper advertisement, copy of the list of participants of public consultations and photos from the Public Consultations meeting are presented in Annex 2.

43 14. ANNEXES

44 Annex 1. NATIONAL ENVIRONMENTAL LEGAL and ENVIRONMENTAL IMPACT ASSESSMENT FRAMEWORKS

Environmental protection in Republic of Serbia is regulated by several national and municipal laws and by-laws. The main legal documents are the following: • Constitution of Serbia (“Official Gazette of RS” No. 98/06). • National Strategy for Sustainable Development (“Official Gazette of RS” No. 72/09, 81/09) • Law on Environmental Protection (“Official Gazette of RS” No. 135/04, 36/09, 43/2011, 14/2016) • Law on Environmental Impact Assessment (“Official Gazette of RS” No. 135/04) • The Law on Waste Management (“Official Gazette of RS” No. 36/09, 88/2010, 14/2016) • The Law on Protection against Environmental Noise (“Official Gazette of RS” No. 36/09, 88/10) • Law on Water (“Official Gazette of RS” No. 30/10, 93/12) • Law on Occupational Safety and Health (“Official Gazette of RS” No. 101/05, 91/2015) • Law on Planning and Construction (“Official Gazette of RS” No. 72/09, 81/09, 64/2010, 24/2011, 121/2012, 42/2013, 50/2013, 98/2013, 132/2014, 145/2014) • Law on Nature Protection, (“Official Gazette of RS” No. 36/09, 88/2010, 91/2010, 14/2016) • Law on Strategic EIA (“Official Gazette of RS” No. 135/2004, 88/2010) • Law on Forest (“Official Gazette of RS”, 30/2010, 93/2012 and 89/2015), • Law on Air Protection (“Official Gazette of RS”, 36/09, 10/2013) • Agricultural Land Law (“Official Gazette of RS” No. 62/06, 65/2008, 41/2009, 112/2015))

Regulations related to EIA procedure include the following: • Law on EIA (Official Gazette of the Republic of Serbia No.135/2004, 36/2009); • Law on Environmental Protection (“Official Gazette of RS”, No. 135/04, 36/09, 43/2011, 14/2016); • Decree that prescribes list (I) of projects for which an impact assessment is mandatory and list (II) of projects for which an impact assessment may be required (Official Gazette of the Republic of Serbia No. 114/2008); • Law on Ratification of the Convention on Environmental Impact Assessment in a Transboundary Context (Espoo Convention)- („Official Gazette of the Republic of Serbia“, No. 102 /07); • Law on Ratification of the Aarhus Convention („Official Gazette of the Republic of Serbia“, No. 38/09) • Law on Free Access to Information of Public Importance, („Official Gazette of the Republic of Serbia“, No. 120/04, 54/07, 104/09 and 36/10); • Law on Planning and Construction ("Official Gazette of RS", No. 72/09, 132/14 and 145/14). • In 2005, the following areas have been regulated through by-laws („Official Gazette of the Republic of Serbia“, No. 69/05): o Rulebook on public insight, presentation and public discussion about the study; o Rulebook on the work of the expert commission in assessment of the study; o Rulebook on the content of application for determining screening and on the content of application for determining scope of the EIA study; o Rulebook on the content of the EIA study and on the content of appearance, manner of keeping public register regarding the act decisions about the EIA; o Rulebook on manner of keeping public register regarding the act decisions about the EIA. • Rulebook on the contents of requests for the necessity of Impact Assessment and on the contents of requests for specification of scope and contents of the EIA Study (“Official Gazette of RS” No. 69/05) • Rulebook on the contents of the EIA Study (“Official Gazette of RS” No. 69/05)

45 • Rulebook on the procedure of public inspection, presentation and public consultation about the EIA Study (“Official Gazette of RS” No. 69/05) • Rulebook on the work of the Technical Committee for the EIA Study (“Official Gazette of RS” No. 69/05) • Regulations on permitted noise level in the environment (“Official Gazette of RS” No. 72/10) • Decree on establishing classification of water bodies (“Official Gazette of SRS” No. 5/68) • Regulations on hazardous pollutants in waters (“Official Gazette of SRS” No. 31/82)

46 Annex 2. Public consultations related documents

Photo from the start of the Public Consultations held on 5 March 2019.

Photo of the orginal List of Participants

47

Additional photo of the orginal List of Participants

Photo of the Invitation notice for the Public Consultations held on 5 March 2019.

48