SFG3470 v2 Public Disclosure Authorized
THE KINGDOM OF LESOTHO
MINISTRY OF PUBLIC WORKS AND
Public Disclosure Authorized TRANSPORT (MoPWT)
LESOTHO ROADS DIRECTORATE
TRANSPORT INFRASTRUCTURE AND CONNECTIVITY PROJECT (TICP) (PROJECT NUMBER: PE-P155229-LEN-BB)
ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) Public Disclosure Authorized JULY 2017
Original Draft: -Michael Mhlanga, 2 Loop Street, Ladybrand 9745 Tel :( +266) 58 858791 (+27) 72 984 2320 E-mail: [email protected]
Revised and updated by: Tito Kodiaga Email: [email protected] URL: http://www.emconsultants.org Public Disclosure Authorized
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TABLE OF CONTENTS TABLE OF CONTENTS ...... 2 LIST OF TABLES ...... 4 LIST OF FIGURES ...... 4 ACRONYMS ...... 5 1 EXECUTIVE SUMMARY ...... 6 2 INTRODUCTION...... 7 2.1 Background ...... 7 2.2 ESMP Structure and Organization ...... 8 3 PROJECT DESCRIPTION ...... 10 3.1 Project Overview ...... 10 3.2 Project Components Summary Description ...... 16 4 KEY ENVIRONMENTAL AND SOCIAL IMPACTS ...... 17 4.1 Environmental and Social Management Plan (TICP) ...... 18 4.1.1 Social ...... 18 4.1.2 Ecology and Biodiversity ...... 21 4.1.3 Water Resources and Water Quality ...... 23 4.1.4 Materials and Waste Management...... 23 4.1.5 Noise and Air Quality ...... 24 4.2 Project Planning and Design ...... 25 4.2.1 Activities in advance of construction ...... 25 4.3 Project Construction ...... 27 4.3.1 Fencing of Work Areas ...... 27 4.3.2 Clearing of Topsoil ...... 28 4.3.3 Personnel ...... 29 4.3.4 General Requirements for Work/Assembly Areas ...... 31 4.3.5 Protection of Flora and Fauna ...... 33 4.3.6 Cultural Heritage ...... 34 4.3.7 Construction Waste, Potentially Oil Contaminated (POC) Wastewater and Spillages36 4.3.8 Builders Rubble ...... 37 4.3.9 Domestic Waste and Wastewater ...... 38 4.3.10 Sanitation ...... 39 4.3.11 Storage and Management of Fuel ...... 39 4.3.12 Nuisance Management ...... 40 4.3.13 Construction in the River Channel ...... 41 4.3.14 Borrow Pits and Sand Quarrying ...... 42 4.3.15 Rehabilitation ...... 43 4.4 Operational Phase ...... 44 4.4.1 Maintenance ...... 44 5 ESMP ROLES AND RESPONSIBILITIES ...... 45 5.1 Roles and Responsibilities for ESMP Implementation ...... 45 5.1.1 ESMP Responsibilities ...... 45 6 INSTITUTIONAL ARRANGEMENTS AND IMPLEMENTATION ...... 47 6.1 Organizational Structure...... 47 6.2 Roads Directorate, MoPWT- Environmental Health and Safety Management ...... 48 6.3 Contractor Environmental Health and Safety Management ...... 48 6.3.1 Environmental Health and Safety Officer ...... 48 6.3.2 Contractor Construction Manager ...... 49 7 CAPACITY INSTITUTIONAL REQUIREMENTS ...... 50 7.1 Introduction ...... 50 7.2 EHS Systems ...... 50
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7.3 Capacity Building for the Roads Directorate, MoPWT ...... 50 7.3.1 Environmental Health and Safety Staff ...... 50 7.3.2 Social Staff ...... 51 7.4 Capacity Building for Construction Contractor...... 51 7.5 Independent Environmental Monitoring Consultant ...... 52 7.6 Technical Assistance ...... 52 8 COMMUNICATION AND REPORTING REQUIREMENTS ...... 53 8.1 Introduction ...... 53 8.2 Adaptive Management ...... 53 9 ESMP REVIEW MONITORING AND REPORTING BY ROADS DIRECTORATE AND OTHERS ...... 54 9.1 Review of the EMP ...... 54 9.2 Contractor Monthly Internal Reports ...... 54 9.2.1 External Reporting For Regulatory Compliance ...... 55 10 ESMP BUDGETS ...... 56 10.1 Indicative budgets ...... 56
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LIST OF TABLES Table 1: Prioritized footbridges for the TICP ...... 15 Table 2: Summary for Social Management ...... 18 Table 3: Summary of Key Significant Impacts on Ecological Features ...... 21 Table 4: Water Resources and Water Quality...... 23 Table 5: Materials and Waste Management...... 23 Table 6: Noise and air quality Management (Construction) ...... 24 Table 8: Responsibility matrix for construction and ESMP Implementation ...... 45 Table 9: Preliminary Estimate of EMP Costs ...... 56
LIST OF FIGURES Figure 1: The existing footbridge on the southern Phuthiatsana River ...... 11 Figure 2: The existing footbridge on th esouthern Phuthiatsana River...... 12 Figure 3: Typical Footbridge in the Lesotho Foothills (S29°47´32˝ E27°39´08˝) ...... 12 Figure 4: Proposed footbridge locations in the Lowland, Foothill and Mountain regions 14 Figure 5: Overall Project Structure ...... 47
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ACRONYMS CLO Community Liaison Officer ECA Environmental Control Advisor EHS Environment Health and Safety ESIA Environmental and Social Impact Assessment ESMP Environmental and social management Plan EU European Union GBV Gender Based Violence GOL Government of Lesotho IFC International Finance Corporation ITP Integrated Transport Project KPI Key Performance Indicators MoPWT Ministry of Public Works and Transport NCR Non Compliance Report RRMP Road Rehabilitation and Maintenance Project TICP Transport Infrastructure and Connectivity Project
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1 EXECUTIVE SUMMARY The Transport, Infrastructure and Connectivity Project (TICP) includes the construction of nineteen (19) footbridges in selected locations in rural areas of Lesotho. This Environmental and Social Management Plan (ESMP) for the TICP identifies the project activities, impacts, mitigation measures and methods that will be used to control and minimize the environmental and social impacts of all construction and operational activities associated with the construction of the 19 footbridges. The ESMP also include the responsible parties and cost budget for ESMP implementation as well as a monitoring programme.
This is a generic ESMP which will be part of the contract agreement and which will form the basis for preparing the Site-Specific Environmental Management, Health and Safety Plans by the Contractors and to be used in ensuring environmental and social compliance in all the 19 footbridges to be constructed under the TICP and all the contractors selected to undertake construction will include and adhere to this ESMP which will be part of the contract agreement. Brief Program Description The ESMP involves multiple organizations and responsibilities shared between Roads Directorate (a division of the Ministry of Public Works and Transport), the Supervising Engineer, the Construction Contractor, the Works Supervisor and the Independent Environmental Monitoring Consultant and the Health and Safety Officers.
Environmental and social supervision shall be completed during project construction to ensure compliance of the construction contractor with ESMP provisions and other regulatory requirements. Monitoring shall also be done during construction and operations to verify the success of mitigation measures and to conduct additional baseline sampling.
The ESMP outlines reporting and communication procedures to ensure that ESMP provisions are communicated and reported at all levels of the project, including local communities.
A key component of ESMP success depends on effective capacity building of the TICP and the training of staff and all others involved in the ESMP. These efforts will also be assisted by the implementation of technical assistance by outside consultants.
The ESMP shall be considered a controlled document and should be updated annually, following a reportable incident or plan update.
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2 INTRODUCTION
2.1 Background The primary objective of an Environmental and Social Management Plan (ESMP) is to safeguard the environment, site staff and the local population from site activity which may cause harm or nuisance. This ESMP for the Transport, Infrastructure and Connectivity Project (the ‘Project’) is intended to address mitigation, monitoring and institutional measures to be taken during construction and operation of the footbridges, so as to ensure that the benefits of the project are achieved with minimum impact on the environment.
This is a generic ESMP for all the proposed 19 footbridges to be constructed under the project. The impacts associated with all the 19 footbridges are generally expected to be similar in view of the fact that the biophysical and socio-economic environment of the proposed site for the footbridges are similar and not warranting the preparation of independent ESMPs for each footbridge.
This ESMP, which also covers monitoring, will therefore form the basis of the environmental and social protection measures for Transport, Infrastructure and Connectivity Project (TICP) implemented by Lesotho Roads Directorate (a division of the Ministry of Public Works and Transport) and its Contractors. The implementation of the ESMP ensures that environmental, health and safety (EHS) and social performance is in accordance with international standards including World Bank safeguard policies, the relevant International Finance Corporation (IFC) Performance Standards, and World Bank Group sector EHS general guidelines.
This Environmental and Social Management Plan (ESMP) for the Transport, Infrastructure and Connectivity Project (TICP) identifies the principles, approach, procedures and methods that will be used to control and minimize the environmental and social impacts of all construction and operational activities associated with project development. It is intended to complement the project Environmental and Social Impact Assessment (ESIA) and ensure that commitments made by the TICP to minimize project related environmental and social impacts are upheld throughout all project phases.
As part of their ongoing commitment to excellence in environmental and social performance for this project, the Roads Directorate, through the TICP will ensure the following:
• Fulfill all environmental and social conditions associated with project approvals; • Develop, promote and foster a shared sense of responsibility for environmental and social performance of the project; • Promote environmental awareness and understanding among employees and contractors through training, identification of roles and responsibilities towards environmental and social management and linking project performance to overall environmental performance;
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• Encourage an understanding of social and cultural sensitivities in local communities and the importance of minimizing project impacts on local lifestyles and culture; • Monitor environmental and social performance throughout the project and implement an adaptive management approach to continuous improvement; • Work with local communities and project affected stakeholders to ensure that they benefit as a result of project development; and • Maintain an ongoing commitment to informing, engaging and involving local stakeholders throughout all phases of the project.
Responsibilities for implementation are outlined in the ESMP and fall on the Contractors. The Roads Directorate will actively seek to monitor, audit and assess the compliance of the Contractor(s) and ensure that corrective actions are taken when necessary to maintain environmental and social performance in line with international standards.
This management plan presents the key management principles that then defines a scope of the plan implementation. The principles in the ESMP will be included in the individual contracts with contractors who will then prepare Site-Specific Environmental, Health and Safety Plans, which will be updated and continuously reviewed, as necessary, throughout the implementation period. The Environmental Control Advisor (ECA) and the Community Liaison Officer (CLO) will be responsible for field monitoring, approvals and reviews of site specific protocols of the Environmental and social aspects respectively. This will be done while working closely with the contractor’s EHS contacts. Their activities will report to the project environmental officer and the project sociologist with the ultimate responsibility for all Environmental and Social aspects resting the Environmental Manager at the Roads Directorate. 2.2 ESMP Structure and Organization The ESMP contains guiding environmental principles and procedures for communication, reporting, training, monitoring and plan review to which relevant Roads Directorate staff, contractors and sub-contractors are required to comply with throughout the preconstruction, construction and operation phases of the TICP. The ESMP is structured as follows:
Section 3 of this ESMP presents an overview of the description of the project
Section 4 of this ESMP presents the various mitigation measures as identified through the ESIA process. For each of the mitigation measures, relevant monitoring measures are identified together with Key Performance Indicators (KPI’s). For each mitigation activity, an implementation route has been identified.
Section 5 of the ESMP provides the ESMP roles and responsibilities
Section 6 of this ESMP outlines the various institutional arrangements to be put in place by the Project to enable the implementation of the ESMP. Where relevant, a number of capacity building measures have been identified to ensure that the institutional
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arrangements are appropriate and qualified for the allocated tasks.
Section 7 of the ESMP provides the capacity building requirements
Section 8 of the ESMP provides the communication and reporting for the ESMP
Section 9 of the ESMP provides an overview of monitoring and reporting requirements associated with the activities and commitments contained within the ESMP documentation. The monitoring and reporting requirements include a “management of change” capacity to the ESMP reflecting that it is intended to be a live document subject to regular review and update as the Project evolves. Furthermore, it includes various commitments to external project monitoring to satisfy the requirements of the IFC and to ensure transparency in terms of delivery of environmental and social mitigation.
Section 10 of the ESMP identifies the overall indicative budget for implementation of the ESMP through construction and into operation. The budget as identified is subject to revision / change depending on evolution of various detailed plans but is considered to be broadly indicative of the level of commitment by the Project to mitigate environmental and social impacts identified through the ESIA process and to provide enhancement to environmental and social indices in the Project region where relevant.
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3 PROJECT DESCRIPTION
3.1 Project Overview Communities in rural Lesotho continue to endure hardships in accessing socio-economic services due to low coverage of all-weather and well-maintained roads and lack of access across rivers, often resulting in long deviations on foot. Enabling rural communities to access basic socio-economic services ranks highly in Lesotho's transport sector policy.
The Government of Lesotho (GOL), with financing from the World Bank, is proposing to address these inadequacies through the Transport Infrastructure and Connectivity Project (TICP), which includes, the construction of nineteen (19) footbridges distributed in three regions as follows: seven (7) bridges in Lowlands, three (3) bridges in Foothills region and nine (9) bridges in the Mountain region of Lesotho.
Through the construction of the footbridges, the TICP will contribute directly to the implementation of national development programmes, helping to reduce poverty by enabling communities to access socio-economic services1, creating better access to areas of tourism potential, and creating employment amongst rural communities, particularly through labour-based methods in construction, maintenance and rehabilitation that is normally used in Lesotho. In addition, the improved infrastructure will facilitate service provision such as rural water supply technicians, extension agents, disaster relief personnel, telecommunications staff, health and sanitation staff, and local government personnel in accessing remote and isolated rural communities all year round.
The construction of the footbridges will be done using labour based methodologies. Lesotho has a long history of using labour-based construction methods for a variety of transport infrastructure projects. The general model that is applied is that of the International Labour Organization (ILO).
Labour based methods involve the use of available human and material resources for the construction and maintenance of infrastructure. For a number of activities an appropriate mix of labour and equipment is required to provide products of adequate quality in a cost effective manner. A labour-based technology aims to apply a labour/equipment mix that gives priority to labour, but supplements it with light equipment where necessary for reasons of quality or cost. The term “labour based” thus indicates that a flexible and optimal use is made of labour as the predominant resource, while cost effectiveness and quality aspects are ensured.
The footbridges will be built under standard Roads Directorate Civil Contract agreements. The Roads Directorate has developed standard bridge designs which it will
1 Tanga1, P. T. et al, "The Impact of Improved Road Infrastructure on the Livelihoods of Rural Residents in Lesotho: The Case of Phamong " in Stud Tribes Tribals, 12(2): 209-218 (2014), p.216.
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use in all cases but two, which are the Hlotse and Senqu crossings, requiring longer spans. Where roads exist, materials for the footbridges are brought in by vehicle but in the Mountain areas, where access is poor, there are no plans to construct road access and all necessary materials will be brought in on horseback. Stonework to clad the abutments requires material which in the Lowlands may have to be brought in from considerable distances away. Stone and sand for concrete is required, which will be sourced by the Contractor, probably from existing suppliers in the area. The abutments are built entirely by hand, including all necessary excavation, mixing and pouring of concrete and steel cladding. The bridge sections are assembled on site and a small working area at the crossing is required, typically no more than 0,25 ha (50 m x 50 m). The steel girders are painted with a weather-resistant paint. Typical equipment and materials in the contractor’s working area would include: -
LDV (supervisor, site engineer) Tipper truck for stone, cement and sand Water truck (to make concrete or damp dust) Sand, stone, cement Rock cladding Steel girders, pre-cut Electric arc welder Petrol generator (for arc welder) Cement mixer (diesel)
For the standard footbridges, construction typically takes one to two months. This period may be considerably extended for the larger non-standard bridges.
Figure 1: The existing footbridge on the southern Phuthiatsana River
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Figure 2: The existing footbridge on th esouthern Phuthiatsana River. Communities have requested further protection below the railings to prevent children from climbing through them
Figure 3: Typical Footbridge in the Lesotho Foothills (S29°47´32˝ E27°39´08˝)
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Figure 4. overleaf shows the proposed foot bridge locations in the Lowland, Foothill and Mountain regions. Table 3-1 gives the prioritized footbridge projects for the TICP.
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Figure 4: Proposed footbridge locations in the Lowland, Foothill and Mountain regions
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Table 3-1: Prioritized footbridges for the TICP Ecological Ranking Priority District Name of Footbridge RD Code River Crossing Degrees South Degrees South Zone Points Ranking Thaba- Seroalankhoana - Mpokochela TT/FB/27 Senqu Mountains 29029'22" 28045'24" 19 3 Tseka Mpharane - Masokoaneng TT/FB/39 Linakeng Mountains 29035'52" 29004'11" 15 6 Khetši - Matšosa TT/FB/41 Lesobeng Mountains 29046'10" 28018'29" 23 1 Kolberg - Matsoetsoe TT/FB/42 Mashai Mountains 29036'48" 28059'22" 21 2 Noha - Auplaas TT/FB/44 Nkhoaneng Mountains 29033'16" 28010'04" 16 5 Lulang - Tiping TT/FB/46 Manamaneng Mountains 29032'43" 28058'45" 17 4 Kokoana - Montmarter TT/FB/47 Likotopong Mountains 29045'11" 28022'40" 12 9 Koebung - Peterose TT/FB/49 Koebung Mountains 29052'05" 28017'39" 21 2 Tsoelike - Thaba-Bosiu TT/FB/53 Senqunyane Mountains 29020'20" 28012'16" 15 6 Maseru Tšoeneng - Leralleng MS/FB/31 Sebolu Lowlands 29032'52" 27023'40" 15 6 Tšilo - Morumotšo MS/FB/33 Mampentsi Foothills 29⁰33´32” 29⁰36´57″ 12 9 Mekateng - Leutsoa MS/FB/50 Mafemekoane Lowlands 29031'58" 27029'13" 12 9 Berea Bosco - Makhaola BR/FB/45 Liotloaneng Foothills 29010'21" 28008'55" 14 7 Tuke-Mokomahatsi BR/FB/46 Mokomahatsi Lowlands 29001'00" 27059'39" 13 8 Khasane - Thaba-Lesoba BR/FB/47 Khasane Foothills 29⁰01´40″ 28⁰03’54″- 13 8 Leribe Hlotse - Likhakeng LE/FB/23 Hlotse Lowlands 28052'50" 28003'45" 19 3 Seetsa - Fobane LE/FB/36 Linyane Lowlands 29002'09" 27051'21" 8 11 Tšekelo - Mofeli LE/FB/55 Phuthiatsana Lowlands 29004'19" 27046'57" 16 5 Mosamo - Mothamahane LE/FB/56 Maqhu Lowlands 28059'22" 27053'45" 11 10 Source: Roads Directorate, 2016
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3.2 Project Components Summary Description Enabling rural communities to access basic socio-economic services ranks highly in Lesotho's transport sector policy. In 1996 the country launched a US$129 million 5-year Road Rehabilitation and Maintenance Programme (RRMP) that was funded by the IDA, the EU and the Government of Lesotho (GOL). Issues of access also featured prominently under the Integrated Transport Project (ITP), which was launched in 2006 as a successor to the RRMP, with a combined budget of US$38.2 million. A 2015 World Bank evaluation mission concluded that the implementation of the ITP was a success, the objective of improving access to services and market opportunities having been fully achieved through a better managed and affordable transport system2.
The Transport Infrastructure and Connectivity (TIC) Project is the proposed successor to the ITP. Funding for the project is under consideration by the IDA. Building on the achievements and lessons learnt from the ITP and other earlier initiatives, its overall objective is to improve access to social services and markets in targeted rural areas of Lesotho, strengthen road safety management capacity, and provide immediate and effective response in the event of an eligible crisis or emergency. The infrastructure component of the TIC project consists of the construction of footbridge infrastructure. The TIC Project will consist of three components: -
1. Component 1- Improving the infrastructure access. The first component will include the construction of footbridges to improve access of rural population to markets and social services in isolated areas. 2. Component 2:-Improving road safety. This component will address road safety in a more integrated manner in order to achieve the Government’s objective to meet the global decade of road safety aim of halving road deaths between 2010 and 2020. 3. Component 3:-Implementation support and capacity building. This component will include the necessary project implementation support, including implementation of citizen engagement mechanisms, HIV/AIDs and gender targeted activities, and capacity building support to the Road Directorate and MoPWT.
Component 1 will involve civil works (physical works for construction of footbridges to improve access) and thus triggers World Bank’s environmental assessment policy (OP.4.01). The potential adverse impacts will range from small scale and site specific to medium scale infrastructure investments associated with Environmental Assessment Category B projects of the World Bank. The TICP is thus determined to be a Category B project.
2 The World bank (April 2015), Lesotho Integrated Transport Project: Implementation Status and Results Report, p.1
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4 KEY ENVIRONMENTAL AND SOCIAL IMPACTS The TICP will have beneficial impacts to the Government of Lesotho during the implementation of the 3 components.
The project is expected to benefit women and men, girls and boys, children and the elderly by improving access to markets, health services, and better access to additional social services (school, administration and police offices). Direct project beneficiaries are people from communities provided with access to the roads and footbridges rehabilitated under the project, within a 2-kilometer range. Indirect project beneficiaries are the tradable sectors of the economy and the private sector, whose growth will be supported by the job creation opportunities and market opportunities supported by enhanced connectivity.
The footbridge designs will be prepared cognizant of the needs of women and girls, as well as elderly residing in the adjacent neighborhoods during the construction phase. A specific attention will be devoted to children’ safety in the footbridges design to prevent cases of unintended injuries or fatalities while using the bridge.
Women-targeted interventions will address the main gender-related concerns in transport, such as women’s unemployment, GBV and HIV prevention, especially among female population between the ages of 10-24.
Table 4-1- overleaf summarizes the potential adverse impacts likely to be associated with the TICP sub projects especially the physical construction works associated with new footbridges, operation, and maintenance.
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4.1 Environmental and Social Management Plan (TICP)
4.1.1 Social
Table 4-1: Summary for Social Management Objective Project Activity/Project Mitigation/Enhancement Timescales Responsibility for Affected Area Mitigation Implementation Opportunities Employment Adhering to the labour intensive Prior to and during Contractors for construction associated with generation approach and conducting construction. recruitment. local employment in all towns affected by employment The contracts for the the project. benefits bridge sites will employ some 20 unskilled workers per site, all of whom will be sourced from local areas.
Procurement Localized disclosure of need for staff Contractor - Prior Contractor and labourers in advance of to and during opportunities arising; and contractors construction to support local enterprises. Local skills Employment Skills training programme for local To be Contractor. development / generation residents. implemented and promote completed in the life cycle development of construction Project Employment Follow Lesotho labour Contractor – Prior to and Roads Directorate/Contractor commitment on conditions laws/guidelines during construction workers’ rights Also include Procedures to monitor and Prior to and during enforce safety plans and report operation. accidents and incidents; and Provide all workers with a summary of their service and training activities.
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Objective Project Activity/Project Mitigation/Enhancement Timescales Responsibility for Affected Area Mitigation Implementation
Code of Use of Training Program particularly Prior to and during Contractor / Conduct for the equipment, covering health and safety, construction Roads Directorate labour force procedures preferably in the local language; and training encourage safety by implementing penalties for violation of rules learnt during the training. Labour Labour Staff grievance mechanism; Prior to and during Contractor / Grievance management construction Roads Directorate Mechanism Tool box talks on the rights of the workers and the grievance mechanism; A worker grievance record to be maintained. Protecting the Labour Provide appropriate PPE (as Prior to and during Contractor / workforce management identified through risk assessment); construction Clear training on site specific EHS . procedures and guidelines. Inform workers of Labour management HIV/AIDS and STDs awareness and At start of construction and Contractor HIV/AIDS and sexually prevention briefings. updated for new workers Transmitted disease (STD) risks and protection to minimize risk of infection to workers and communities Restrict access Safeguarding Site security measures Prior to and during Contractor to sites, especially community including: construction hazardous areas health, safety and security Appropriate fencing; and Signage around site perimeter and where identified through risk Assessment process. Damage to Cultural No known cultural heritage Consultation with local communities Heritage Sites sites exist at or near the when the final bridge locations are bridge crossing. determined is to verify this
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Objective Project Activity/Project Mitigation/Enhancement Timescales Responsibility for Affected Area Mitigation Implementation
Loss of community It is unlikely that any Impact significance will be infrastructure community infrastructure negligible. No resettlement is will be lost as a result of expected. the construction of the footbridges. Loss of cultivated land or Most of the bridge sites are Compensation is to be carried out in Once the possible paths are Roads Directorate crops closely associated with accordance with World Bank identified. cultivation. Due to the guidelines. small footprint of the construction site, it is likely that this impact can be minimized but some crop losses are possible. In addition, depending on the location of the footbridge site, pedestrian routes may develop through cultivated lands. Impact on community Communities are curious There are no major safety risks safety about construction work associated with labour based and safety is an issue that construction that cannot be managed. needs to be managed. Impact on Social These impacts are most All personnel will reside at home and Pathologies typical of construction report for work on site each day. contracts where personnel This minimizes the risk of social camps of single make pathologies affecting the surrounding workers are established, communities. particularly when the personnel are not from the local area. The small contracts for the bridge sites will employ some 20 unskilled workers per site all of whom will be
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Objective Project Activity/Project Mitigation/Enhancement Timescales Responsibility for Affected Area Mitigation Implementation sourced from local areas.
4.1.2 Ecology and Biodiversity
Table 4-2: Summary of Key Significant Impacts on Ecological Features Objective Impacts Mitigation/Enhancement Timescales Responsibility for Mitigation Implementation Management of Loss of vegetation cover on Stakeholder consultation, suggest a series At the project inception Roads biodiversity identified sites and on of one to one meetings and local and review at the Directorate/Contractor Issues, Habitat material storage sites communities’ stakeholder engagement in completion of project conservation deciding the location of the foot bridges to And management Top stripping removing minimize losses. grass and shrubs coverage on the foot bridge locations Plan for landscaping and beautification upon completion of project. Vegetation / Checking for nesting birds, During construction Contractor Forestry clearance mammals, amphibians and reptiles prior to vegetation Clearance.
No clearance of sites prior to approval and surveys. Minimise All of the site of the bridge No vehicle access will be created to those Site preparation Contractor habitat loss and crossings are in landscapes remote sites where road access is not works and disturbance that are disturbed, Habitat feasible. In these cases, equipment and construction (aquatic losses will be minor due to supplies will be brought into the site on ecology) the work site (generally horseback. 0,25 ha) and the hand excavation causes very limited riparian habitat loss. Most of the crossings are infested with invasive aliens (Acacia dealbata,
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Objective Impacts Mitigation/Enhancement Timescales Responsibility for Mitigation Implementation Acacia mearnsii, Populus alba). Impact on aquatic fauna Impacts on aquatic fauna If sediment is generated in the river at this Continually during Contractors will depend on water site it must be contained with sediment construction quality impacts. Small screens. quantities of sediment over short periods are unlikely to cause significant impact. With management impacts should be of low significance. In the case of the Bosca bridge site on the Tsheljane River, Maluti minnow have been recorded. These are the last records of this specied anywhere other than the eastern highland areas, mainly due to the impact of trout in other catchments. Impact on Endemic and There are unlikely to be any The impact will be negligible Threatened Flora endemic or threatened flora at any of the footbridge sites.
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4.1.3 Water Resources and Water Quality
Table 4-3: Water Resources and Water Quality Objective Impacts Mitigation/Enhancement Timescales Responsibility for Mitigation Implementation Protection of Abstraction of construction Small water quality risks exist as a result During Contractor surface water water of use of materials (cement spillages, construction quality from degradation minor oil spillages, and paint spillages). (where rivers exist) Minimal cement spillage, There is no intention to service vehicles paint spillage on site and the only vehicles expected in the work areas are the supervisor’s vehicle Contamination of surface and trucks bringing sand, stone, cement, water downstream of the steel bridge supports and reinforcing and construction site. rock cladding. Some sediment generation is likely if there are in stream piers constructed. Impacts could be of moderate significance but can be reduced to low or negligible with management. Good practice construction measures.
4.1.4 Materials and Waste Management
Table 4-4: Materials and Waste Management Objective Impact Mitigation/Enhancement Timescales Responsibility for Mitigation Implementation Minimization Waste generated as All waste will be disposed During Contractor and safe a result of general of in a marked disposal site construction disposal of construction construction activities for each project location waste Packaging material for Good housekeeping and operating construction materials practices General waste
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4.1.5 Noise and Air Quality
Table 4-5: Noise and air quality Management (Construction) Objective Project Activity/Project Mitigation/Enhancement Timescales Responsibility for Affected Area Mitigation Implementation Avoid Site preparation Restricted general hours of During Contractor Nuisance impacts generated Excavation and working to daytime only to avoid construction by foundations, construction sensitive periods; on-site plant and increased human and construction activity around the Undertaking construction activities construction area activities in accordance with good practice; The use of labour based methods minimizes this Ensure deliveries arrive and depart so as impact. Nuisance impacts not to disturb residents at inconvenient are likely to be minor and times; none of the bridges are close to houses, schools or Providing the public with advance notice other sensitive of planned noise-generating activities. infrastructure
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4.2 Project Planning and Design 4.2.1 Activities in advance of construction Table 4-6-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Final location of The exact location of the footbridge sites shall be RD Engineer Pre-construction - Site verification of each footbridges finalized by a Roads Directorate engineer and the as a basis for footbridge location 4.2.1.1 Environmental environmental consultant Consultant licensing of the activity Final footbridge The final positioning of all bridge sites shall be RD Engineer Preparation of final site selection determined so as to: Environmental footbridge location plans criteria Minimise the risk of bridge damage or Consultant with supporting loss due to active bank erosion documentation Minimise the bridge span Minimise any potential damage to 4.2.1.2 adjacent cultivation Minimise damage to any large indigenous trees remaining along the river embankments Be as close as possible to the existing crossing point that people use to cross the river Confirmation of The suitability of the final location of the bridge RD Engineer Pre-construction Record of meeting with suitability of site site shall be confirmed with the local chief. Environmental during site Chief 4.2.1.3 with local chief Records of these discussions shall be kept. Consultant
Location of work A suitable location for the Contractor’s work site RD Engineer RD Engineer As per requirement sites shall be identified and demarcated on the maps of Environmental Environmental each bridge site. Wherever possible this site shall Consultant Consultant be in disturbed habitat, but should not impact on 4.2.1.4 cultivated lands. The approximate area of any potentially affected cultivation and any other community improvements or infrastructure shall be estimated.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Abbreviated RAP The information prepared under Item 5.2.1.4 shall Roads Directorate Pre-construction Information provided to be made available for use in an abbreviated RAP, Sociologist team responsible for to be prepared on the basis of World Bank OP/BP Resettlement and 4.2.1.5 4.12 Resettlement shall be prepared on the basis Compensation under WB the RFP and information confirming the intended OP/BP 4.12 location of the work sites. Compensation for Compensation for loss of crops or input costs Roads Directorate Pre-construction Entitlement matrix lost crops or input shall be according to MoPWT's 2010 Sociologist Payment to affected parties 4.2.1.6 costs Compensation and Resettlement Policy and Procedures and World Bank OP/BP 4.12
Cultural Heritage If a heritage site is found during the final location RD Engineer Pre-construction Record of confirmation of no planning of the footbridges, which could be Environmental heritage sites by Local Chief affected by the construction works, an alternative Consultant Change in bridge location if footbridge location shall be sought unless there is heritage sites known. 4.2.1.7 no realistic alternative. On determining the final location, the local chief shall be asked to verify that there are no places of cultural significance at the work area or crossing site that could be affected by construction of the footbridge.
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4.3 Project Construction 4.3.1 Fencing of Work Areas Table 4-7-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Installing fences at The work area shall be fenced to prohibit access Contractor Establishment on Independent verification of lay down areas by livestock, unauthorized people and local fauna site suitability of project 4.3.1.1 and to contain all working activities within a infrastructure location specified area. DEA approval Selection and The work site shall be in accordance with the Contractor Establishment on Location of per area changing of work provisionally selected site indicated by the RD RD Environmental site specified site locations Engineer/Environmental Consultant. Should the Officer Authorization Contractor wish to change the location of the 4.3.1.2 worksite, it shall be selected to minimize any possible risk to surrounding crops or any other community assets and shall be confirmed to be suitable by the RD before establishment Unauthorized entry Unauthorized entry into the working area shall not Contractor At all times As per requirement 4.3.1.3 to lay down areas be permitted Maintenance of Fencing shall be maintained at all times and shall Contractor At all times As per requirement 4.3.1.4 fencing be repaired if damaged Repair of fencing If temporary fencing at the work site is removed Contractor As required due to As per requirements for the purpose of maneuvering steel girders or site activities 4.3.1.5 other made up bridge sections, it shall be replaced as soon as reasonably practical
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4.3.2 Clearing of Topsoil Table 4-8-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Removal of Any woody vegetation and alien vegetation within Contractor Establishment on Independent verification of woody and alien the work site shall be removed. Advice shall be Roads Directorate site suitability of project 4.3.2.1 vegetation sought from the Roads Directorate about the infrastructure location application of a contact herbicide, such as DEA approval Roundup to kill alien vegetation. Stripping of topsoil Topsoil within the area of the worksite shall be Contractor Establishment on As per requirement cleared prior to any equipment or materials being site 4.3.2.2 brought in. Natural herbaceous vegetation may be cleared and left in the topsoil. Location of topsoil Topsoil stockpiles shall be situated within the Contractor Establishment on As per requirement 4.3.2.3 stockpiles fenced area of the work site. site Depth of topsoil Topsoil shall be considered to be the top 300 mm Contractor Establishment on As per requirement 4.3.2.4 stripping of soil. site Avoidance of Topsoil shall be stripped when it is in as dry a Contractor Establishment on As per requirement 4.3.2.5 topsoil stripping condition as possible in order to prevent site when wet compaction Ripping of topsoil The topsoil, including the existing grass cover, Contractor Establishment on As per requirement shall be ripped before removal. This is to ensure site 4.3.2.6 that organic plant material, and the natural seed base is included in the stripped material Topsoil stockpile Soil stockpiles shall not be higher than 2.5 m. Contractor Establishment on As per requirement 4.3.2.7 dimensions The slopes of soil stockpiles shall not be steeper site than 1 vertical to 2.5 horizontal Preventing damage No vehicles shall be allowed access onto the Contractor At all times As per requirement 4.3.2.8 to topsoil stockpiles after they (stockpiles) have been placed Preventing Stockpiles shall not be contaminated with oil, Contractor At all times As per requirement contamination of diesel, petrol, garbage or any other material which 4.3.2.9 topsoil may inhibit the later growth of vegetation.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Measures to The contractor shall apply soil conservation Contractor Establishment on As per requirement prevent topsoil measures to the stockpiles to prevent erosion. site 4.3.2.10 erosion This may include the use of erosion control fabric or grass seeding.
Cultural heritage If at any stage of the clearing operations Contractor During topsoil As per requirement archaeological artifacts or subsoil habitats are stripping and site unearthed or identified the RDs Environmental excavations Officer is to be contacted immediately to arrange a thorough scientific investigation of the finding, 4.3.2.11 in accordance with the Chance Find requirements of Section 5.3.6. Contractor’s and contract workers shall be given instruction at induction training of the nature of the material that could be found.
4.3.3 Personnel Table 4-9-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Protection of Normal working hours should be observed, any Contractor At all times As per requirement indigenous flora deviations should be done in consultation with the Consultation with Labour 4.3.3.1 relevant Labour authorities Department where deviations occur Warning signs Warning signs must be placed on and around the Contractor Site Establishment As per Contract OHS 4.3.3.2 site as per the Occupational Health and Safety requirements (OHS) requirements in the Contract.
Cooking facilities Cooking facilities shall be provided for the Contractor Site establishment As per requirement 4.3.3.3 construction staff within the confines of the construction camp. Collection of wood No trees may be removed for the making of fires Contractor At all times As per requirement 4.3.3.4 and fires and no collection of wood will be allowed.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) External food Where possible, local kitchens/food services Contractor Negotiated at or Use of external kitchen/food 4.3.3.5 services should be utilized for the provision of food to prior to site services laborers establishment Cooking fires No fires shall be permitted unless a specifically Contractor At all times As per requirement 4.3.3.6 designated area has been identified and set aside by the RD for that purpose. Fire hazard No fires shall be permitted outside of the work Contractor At all times As per requirement area and adequate firefighting equipment, according to the fire hazard standards during the 4.3.3.7 construction period, must be available on site in good working order (at least one all-purpose 12.5 kg extinguisher) Fire hazard Where there is a particular fire hazard at any point Contractor Induction training As per requirement training in the construction works, the contractor shall 4.3.3.8 ensure that his employees are properly trained in the use of the appropriate firefighting equipment and that such equipment is on hand at all times Trespass Personnel shall not trespass outside of the project Contractor At all times As per requirement 4.3.3.9 working areas and shall take special care to avoid harming livestock and crops. Theft of Under no circumstances shall personnel harvest Contractor At all times As per requirement 4.3.3.10 agricultural or any cultivated produce or natural foot sources natural produces growing in the area for their own use. Safety The contractor shall ensure that suitable safety Contractor At all times As per Contract safety requirements regulations and precautions are established and requirements 4.3.3.11 brought to the attention of the personnel and that these are complied with.
Creation of access Approved safety helmets, steel toed boots, Contractor At all times As per Contract at remote reflective jackets and other protective clothing requirements 4.3.3.12 footbridge sites shall be worn, the full requirements to be specified by the RD.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Personnel illness The Contractor shall ensure that as far as Contractor At all times As per requirement practically possible, suitable arrangements are made on the site for protecting employees from 4.3.3.13 illness and assisting them to recovery from illness. Adequately equipped first AID kits should be available on site Security of work All security arrangement to ensure that equipment Contractor At all times As per requirement site and personnel’s personal belongings, while 4.3.3.14 working on site, are safe are the responsibility of the Contractor Behaviour of The contractor is responsible for the behaviour Contractor At all times As per requirement employees and discipline of all personnel while they are 4.3.3.15 present on the site and shall exercise strict supervision over them at all times.
4.3.4 General Requirements for Work/Assembly Areas Table 4-10-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Minor creation of The contractor shall, at his own cost, provide for Contractor At all times As per requirement 4.3.4.1 access potable water for personnel consumption to the working sites. Chemical testing of The contractor shall allow for chemical testing of Contractor Monthly or as Water quality meets potable water water samples on a monthly basis, or more determined by water standard (Appendix frequently if contamination of the water is ECA/EO xx) 4.3.4.2 suspected by the ESA. The water shall comply with specifications set out in the Environment Act (2008) and included as Appendix 2 of this document) Building Any site buildings should be of a container or Contractor Site Establishment As per Contract 4.3.4.3 construction prefabricated type. requirements
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Welding locations Welding, gas cutting or cutting of metal shall only Contractor At all times As per requirement 4.3.4.4 be permitted inside the working areas or, where required, on the bridge structures themselves
Payment of Any damages caused by negligence of the Contractor At all times As per requirement 4.3.4.5 damages due to Contractor shall be paid for by the Contractor to negligence the affected parties
Erosion prevention Appropriate and active measures to prevent Contractor As required to As per requirement erosion resulting from activities at the work site, prevent erosion operations and activities, as well as storm water 4.3.4.6 control measures to the satisfaction of the ECA/EO. Should these measures not be reasonably implemented, restoration costs will be to the contractor's account**. Erosion control During construction any erosion at the work site Contractor As required to As per requirement works shall be prevented by installing any necessary prevent erosion temporary drainage works as soon as possible. All such measures must be discussed with and be 4.3.4.7 approved by the RDs Project Supervisor. These measures may include cut-off trenches, straw stabilizing, brush packing and other methods of erosion control. Vehicle parking All vehicles and plant must be allocated a Contractor At all times As per requirement 4.3.4.8 dedicated parking area in the work area
Storage outside of No storage of plant and vehicles shall be Contractor At all times As per requirement 4.3.4.9 the work area permitted outside of the fenced designated work area.
Diversion of clean The work area shall be designed to prevent clean Contractor Site establishment Storm water diversion 4.3.4.10 storm water storm water draining into the work site from structures, where required upslope
** Aspects normally covered in construction contracts in terms of “protection of works” are standard and are not to be billed or confused with any details covered under environmental and social management requirements
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4.3.5 Protection of Flora and Fauna Table 4-11-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Protection of No contract activities shall take place outside of Contractor At all times As per requirement indigenous flora the immediate working environment of the fenced 4.3.5.1 working area and the footbridge work site. No cutting of brushwood or trees for firewood shall be permitted Approved cutting The contractor shall not harm or clear trees or Contractor At all times As per requirement of trees shrubs to any extent other than that necessary for 4.3.5.2 the works and as indicated by the EO for the execution of the contract.
Persecution of Trapping, snaring, hunting and harassment of wild Contractor At all times Inclusion in induction 4.3.5.3 fauna animals is prohibited. These aspects shall be Induction training training included in personnel’s induction training. As per requirement
Reporing of All incidents of harm to any animal or natural Contractor At all times As per requirement 4.3.5.4 accidental harm vegetation (apart from the agreed areas) must be reported to the ESA/EO
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4.3.6 Cultural Heritage Table 4-12-Activities in advance of construction Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Employee training All employees shall be made aware that it is Contractor Induction training Employee understanding of regarding heritage possible that cultural heritage sites may be found cultural heritage issues during excavation for the piers on the river embankments and when topsoil is removed to create the working platform in the fenced work site (refer to induction training requirements in Section 8). A poster shall be prepared which 4.3.6.1 includes information and photographs about the nature of the sites that could feasibly be exposed (chance finds), annotated with photographs and explanations, and what to do in the event that such remains are excavated. This poster shall be kept on site in a prominent place as a reminder to employees.
Stopping work and During construction, if any possible finds such as Contractor (all During topsoil As per requirement notifying the EO stone tool scatters, ceramics or bone and fossil employees) clearing or remains are made, the chance find shall be excavations for 4.3.6.2 reported to the Contractor’s Site Supervisor who bridge columns shall ensure that work in that area stops immediately and the Environmental Officer of the RD is contacted.
Involvement of a If the site is within cell phone range and Contractor On chance As per requirement heritage specialist transmission of photographs can be arranged on a RD EO discovery of 4.3.6.3 cell phone, these shall be sent to the EO, who heritage remains shall forward them to a recognized Lesotho heritage specialist.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Determination of In the event that the heritage specialist considers Heritage Specialist On receipt of As per requirement significance of the finds shown in the photographs are, in fact, of photographs 4.3.6.4 chance find on site heritage significance, or is unsure of the showing heritage significance from the photographs, he/she shall remains immediately arrange a site visit. Checking If it is verified by the heritage specialist that the Roads Directorate If a conservation- Documentation on alternative site is worthy of conservation, the RD shall worthy heritage consideration of bridge implementation determine whether there is any possibility of chance find is alternatives 4.3.6.5 possibilities to changing the project implementation to avoid the found avoid a site. conservation - worthy chance find Use of best If the bridge site cannot be relocated, the best Roads Directorate Grave / heritage As per requirement available practice available techniques must be used to remove the Contractor site removal to remove heritage site, In collaboration with affected stakeholders, Heritage Specialist sites that are the RD shall develop a re-interment programme unavoidably (in the event of graves) and other suitable 4.3.6.6 affected proposals for any other objects that can be relocated or reconstructed. Culturally appropriate ceremonies shall be undertaken for the removal and transfer of graves, sacred sites and other objects.
Allocation of time Appropriate time and resources shall be allocated Roads Directorate On discovery of Budgets and time allocation and resources for by the RD to allow for removal of graves or unexpected for removal of finds 4.3.6.7 removal of graves salvaging and studying of any significant heritage resources or salvage of artifacts. artifacts
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4.3.7 Construction Waste, Potentially Oil Contaminated (POC) Wastewater and Spillages Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Welding rods All waste welding rods, flux and other welding Contractor Daily Daily cleanup of site and 4.3.7.1 waste shall be collected and stored in drums for waste drums for collection later disposal off-site of waste Concrete mixing Concrete shall be mixed within the designated Contractor At all times As per requirement work area. Any drainage from concrete mixing 4.3.7.2 shall be contained in a lined sump to prevent the release of sediment into the environment Wastewater from Wastewater from washing or repair of vehicles or Contractor During equipment As per requirement vehicle washing and mechanical equipment shall be undertaken on a repair or servicing 4.3.7.3 servicing/repair of concrete plinth, draining to an oil separator equipment before being released into a settlement pond Soil contaminated by Any soil accidentally contaminated by oil, fuel or Contractor In cases of soil As per requirement hydrocarbons chemicals shall be removed and disposed of at a contamination 4.3.7.4 permitted landfill site or bio-remediated in situ. Bioremediation methods shall be approved by the RD.
Absorbant material Absorbant material shall be maintained on site to Contractor At all times As per requirement 4.3.7.5 on site assist in the cleanup of any hydrocarbon spillages
Worker induction All workers shall be trained at induction Contractor Induction training As per requirement regarding understand the importance of avoiding 4.3.7.6 hydrocarbon hydrocarbon spills near river systems pollution Maintenance of oil Oil separators shall be checked regularly (at least Contractor Weekly As per requirement 4.3.7.7 separators weekly) Storage and disposal All hydrocarbon waste recovered shall be stored Contractor At all times As per requirement of recovered in sealed drums in a bunded area to be removed 4.3.7.8 hydrocarbon waste by an authorized petroleum recycling company/agent (or transported as otherwise agreed with the RD)
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Compliance with Any effluent discharge from the settling ponds Contractor At all times As per requirement effluent quality shall not exceed the relevant effluent quality standard standards in terms of Section 36(1)(b) of the 4.3.7.9 Lesotho Environment Act of 2008, as specified under Section 36(1)(b)(iii) – water for agricultural purposes
Testing of effluent If instructed to do so, the Contractor shall take Contractor As required by EO Compliance with standard water water quality samples of any final effluent Environmental 4.3.7.10 leaving the settlement pond for analysis by an Officer accredited laboratory.
4.3.8 Builders Rubble Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Storage of building Any non hazardous building waste shall be stored Contractor Decommissioning As per requirement 4.3.8.1 waste within the work area for future removal to an of construction site approved waste disposal site Disposal of The contractor shall be responsible for the Contractor Decommissioning As per requirement building waste removal and transport of all the waste material off of construction site Transport manifest 4.3.8.2 site to an approved disposal site; Records of receipt of waste at disposal site
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4.3.9 Domestic Waste and Wastewater Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Organic vegetable Organic kitchen waste shall be composted, using Contractor At all times As per requirement 4.3.9.1 kitchen waste domestic composters Disposal of meat to Meat, bones and other non-compostable organic Contractor At all times Separation of organic waste avoid pests food waste shall be collected in pest-proof bins 4.3.9.2 Pest proof site bins for disposal at an approved domestic waste disposal site on a weekly basis Disposal of kitchen In the event that food is provided to employees, Contractor At all times As per specification grey water any grey water from domestic kitchen use shall be 4.3.9.3 drained into French drains prepared for this purpose Laundry water In the event that project personnel are provided Contractor At all times As per requirement with overalls, and a laundry facility is provided, the grey water from this system shall be directed to the French drain referred to in Section 5.3.6.4 4.3.9.4 above. No direct drainage of grey water into the river shall be permitted. The location of the French drain shall be approved by the RD Environmental Officer prior to construction Clean-ups The contractor shall on a daily basis do site clean- Contractor Daily General waste bins ups of litter other than construction spoil, and Clean and litter free site 4.3.9.5 temporarily store it in designated refuse bins provided on site.
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4.3.10 Sanitation Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Provision of toilets Adequate chemical latrines or Ventilated Contractor Site establishment As per requirement Improved Pit-latrines (VIPs) shall be provided for 4.3.10.1 all staff. They shall be serviced regularly to prevent overflow. Maintenance of All latrines provided by the contractor shall be Contractor At all times Absence of unpleasant odour 4.3.10.2 sanitary conditions efficient, sanitary and non-offensive
Number of toilets A minimum of one toilet shall be provided per 10 Contractor Site establishment As per requirement based on 4.3.10.3 persons at each working area. personnel complement
4.3.11 Storage and Management of Fuel Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Above ground fuel All fuel shall be stored above ground Contractor Site establishment Above ground fuel storage 4.3.11.1 storage and at all times Protection of Fuel An impermeable surface surrounded by bund Contractor Site establishment As per requirement Storage Areas walls shall be constructed for the purposes of fuel 4.3.11.2 storage. The bunding shall provide sufficient capacity to capture 110 % of the contents of the fuel storage facilities in the event of a spill. Fuel spillages Fueling of equipment, such as diesel generators, Contractor During re-fueling As per requirement brush cutters and concrete mixers shall be done on 4.3.11.3 a plastic liner or above drip trays in order to contain any fuel spillages Capture and Any spillages contained within fuel storage areas Contractor At all times As per requirement temporary storage shall be evaporated or, if large enough, shall be of spillages captured and drummed in sealed containers, 4.3.11.4 labelled as hazardous, and stored in a bunded area for collection and removal to an accredited hazardous waste disposal site.
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4.3.12 Nuisance Management Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Noise nuisance Noise nuisance shall be determined in Contractor During noisy Consultation with consultation with communities. Night activities communities construction activities shall be prohibited. If any Action taken to minimize activities potentially affect communities nuisance in the event of 4.3.12.1 negatively, as a result of noise, community complaints leaders shall be informed in advance and advised of the period of time over which the noise will persist. Most communities respond well to courteous behaviour in this regard. Dust nuisance Dust nuisance shall be controlled to prevent Contractor During activities Consultation with nuisance in neighboring communities. that generate dust communities nuisance Action taken to minimize 4.3.12.2 (including nuisance in the event of transport of complaints materials) Dust control in If considered necessary by the EO, in Contractor As required Consultation with consultation with communication with local communities, communities communities additional dust damping shall be undertaken to Action taken to minimize 4.3.12.3 minimize nuisance in the event that dust caused nuisance in the event of by any project activity is insufficiently controlled. complaints
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4.3.13 Construction in the River Channel Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Prevention of All work on the river banks and in the river to Contractor During Confinement of working damage to the river establish bridge columns, set up scaffolding, and construction of area 4.3.13.1 embankments weld metal components on the bridge deck in situ bridge columns on Absence of spoiling into the shall be done so as to create a minimum of the river banks river environmental damage. Silt screen Any construction work to excavate foundations Contractor During column Minimization of sediment deployment for pillars in the river channel shall minimize the construction in the generation 4.3.13.2 impact of sediment downstream as a result of the river channel generation of sediment. Maintenance of The flow of the river shall not be restricted during Contractor At all times As per requirement 4.3.13.3 water flow construction and under no circumstances shall the stream be blocked Silt control In the Senqunyane River, where the threatened Contractor Column As per requirement measures on the Maluti minnow occurs, silt generation shall be construction in the Containment of downstream Sequnyane River controlled in the river at all times and silt screens, Senqunyane River 4.3.13.4 sediment plumes during to protect the anchored hay bales or other appropriate methods column construction Maluti minnow shall be deployed in order to minimize the spread of sediment downstream. Prohibition of re- No re-fueling of equipment or storage of Contractor At all times As per requirement fueling of hydrocarbons shall be undertaken at the working 4.3.13.5 equipment in the areas on the river embankments or in the channel. river channel All such work shall take place in the defined work/lay down area. Daily collection of Waste shall be prevented from falling from the Contractor Daily As per requirement welding and other working areas on the bridge deck into the river waste on the bridge below. All welding rods and other waste 4.3.13.6 platform associated with welding on the bridge platform shall be collected daily, bagged and returned to the fenced work area for storage and later disposal in accordance with Section 5.3.7.
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Concrete or cement Spillages of cement and concrete during Contractor As required As per requirement spillage construction of the pillars shall be minimized and 4.3.13.7 where significant be cleaned up and returned to the building waste disposal areas of the fenced work site.
Washing of clothes No washing of clothes or vehicles shall be Contractor At all times As per requirement 4.3.13.8 in the river permitted in the rivers.
4.3.14 Borrow Pits and Sand Quarrying Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Use of existing Wherever possible, existing sources of supply Contractor Project inception Use of existing borrow areas borrow areas shall be used to provide materials for concrete or evidence of efforts to 4.3.14.1 source material from existing borrow areas Authorization of Where new borrow pits are required, all necessary Contractor Pre-construction - Independent verification of new borrow areas authorizations shall be obtained prior to opening as a basis for suitability of project for aggregate of the area. A comprehensive plan of the final licensing of the infrastructure location 4.3.14.2 slopes and rehabilitation of the excavated area borrow pit approval shall be provided in the application for authorization Stripping and Topsoil shall be removed and stored in Contractor Before opening the Topsoil removed and storage of topsoil accordance with the methodology described in borrow pit stockpiled in accordance 4.3.14.3 Section 5.3.2, prior to the opening of any borrow with specification pit Excavation of sand Any excavation of sand from the river shall be Contractor As required As per requirement 4.3.14.4 authorized by the Environmental Officer prior to Roads Dir. EO the start of the activity. Rehabilitation of All borrow pits shall be rehabilitated after use, Contractor During 4.3.14.5 borrow pits including battering and shaping, top soiling and decommissioning re-vegetation
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Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Ponding of water No areas where water will pond will be allowed at Contractor After As per requirement 4.3.14.6 in decommissioned any borrow pit after use due to the risk of children decommissioning borrow pits drowning
4.3.15 Rehabilitation Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Clean up of any Prior to rehabilitation, the fenced work area shall Contractor Decommissioning As per requirement remaining spills be checked for spills of oil, fuel, cement, concrete waste or any other material that may prevent the 4.3.15.1 successful rehabilitation of the area. If so, they shall be bagged in accordance with their hazard characteristics and placed in the waste storage area for removal. Removal of Any concrete plinths, oil separators or other Contractor Decommissioning As per requirement concrete structures for the containment of pollution or for any other purpose shall be broken up and removed 4.3.15.2 to the waste area. Temporary buildings and any other infrastructure shall also be removed. All litter and other waste shall be cleared up and the fencing removed. Above ground fuel Topsoil shall be spread to reinstate the natural Contractor Decommissioning As per requirement 4.3.15.3 storage topographical form of the site and immediate surroundings.
Protection of Fuel Re-vegetation of the fenced work area and the Contractor Decommissioning As per requirement Storage Areas work areas on the river embankments shall be RD Environmental done with an indigenous grass mix; similar to 4.3.15.4 Officer what is found in the vicinity of the site. No exotic species shall be used on site unless approved by the RD Environmental Officer. Contouring to Contours of the slopes approaching the stone Contractor Decommissioning As per requirement prevent erosion cladded ramp to the bridge shall be carefully 4.3.15.5 around the stone shaped to prevent gulleying of storm water down clad bridge ramps the slope and under cutting the ramp
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4.4 Operational Phase 4.4.1 Maintenance Ref. Activity Requirements / specifications Responsibility Scheduling Performance indicator(s) Maintenance and The Roads Directorate shall ensure that bridge Roads Directorate Every 5 years Report on bridge repair of bridges sites are visited at least every 5 years in order to maintenance and erosion determine the condition of the bridge and Any necessary bridge repairs environmental or social issues associated with it. and erosion control measures These shall include: completed The integrity of the bridge structure Alien plants removed (where these were probably caused Any threats to the bridge caused by by construction of the bridge 4.4.1.1 active erosion of the river banks Erosion around the bridge columns and on the embankments and along the footpaths approaching the bridges Invasion of alien plants around the bridge
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5 ESMP ROLES AND RESPONSIBILITIES
5.1 Roles and Responsibilities for ESMP Implementation
5.1.1 ESMP Responsibilities Table 5-1 below describes the responsibilities of various organizations and project stakeholders towards the implementation of the Environmental and Social Management Plan.
Table 5-1: Responsibility matrix for construction and ESMP Implementation Personnel Based Description of Responsibilities Roads Directorate Personnel Environmental Manager Maseru Responsible for the overall management of environmental and social issues on the project. Responsible for reviewing Contractor’s performance based on monitoring reports prepared by RD project staff and signing off the Contractor’s site rehabilitation before decommissioning Bridge Engineer Maseru Responsible for finalizing footbridge locations with the Environmental Consultant TIC Project Sociologist Maseru Appointed to provide senior social monitoring capacity in the RD. A proportion of time spent is to be dedicated to the monitoring of footbridge construction. The Sociologist is to coordinate the activities of the TIC Project CLO; is to assist the CLO to set up the Community Liaison Committee; is to schedule the CLO monitoring site visits and is to review the two weekly monitoring reports produced by the CLO and ESA. In the event of any significant issues arising, the Sociologist may attend site meetings. The final monitoring site visit prior to decommissioning shall be attended by the sociologist and, who shall prepare the Final Monitoring Report with the TIC Project Environmental Officer TIC Project Environmental Maseru Appointed to provide senior environmental monitoring Officer capacity in the RD. A proportion of time spent is to be dedicated to the monitoring of footbridge construction. The Environmental Officer is to coordinate the activities of the TIC Project ECA; is to schedule the ECA monitoring site visits and is to review the two weekly monitoring reports produced by the ESA and CLO. In the event of any significant issues arising, the Environmental Officer may attend site meetings. The final monitoring site visit prior to decommissioning shall be attended by the Environmental Officer, who shall prepare the Final Monitoring Report with the TIC Project Sociologist. TIC Environmental Control Field Responsible for field monitoring of environmental Advisor (ECA) impacts during footbridge construction and preparation of compliance monitoring reports, with the CLO TIC Community Liaison Field Responsible for field monitoring of social impacts during Officer (CLO) footbridge construction and preparation of compliance monitoring reports, with the ECA. With assistance from the TIC Project Sociologist, responsible for setting up the
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Personnel Based Description of Responsibilities Community Liaison Committee, scheduling meetings with the committee and assisting to resolve community issues. TIC Environmental Consultant Maseru Responsible for finalization of bridge locations with the RD engineer Contractor Personnel Supervising Engineer Maseru Responsible for management of construction of all footbridges Works Superintendent Site Responsible for all site activities related to bridge construction Health, Safety and Site Responsible for all HSE matters at bridge construction Environment (HSE) Officer sites
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6 INSTITUTIONAL ARRANGEMENTS AND IMPLEMENTATION
6.1 Organizational Structure The footbridges will be built by private contractors. The management structure for the footbridge contracts is indicated in the organogram (Figure 6-1) which has been discussed and agreed upon by the RD. For most transport infrastructure projects, the RD requires a permanent ECO on site. This is not normally the case for footbridges where in the past there has been no environmental oversight. For the proposed Transport Infrastructure and Connectivity Project, the RD will hire additional staff as depicted in the organogram below which has been deliberated, agreed upon, and budgeted for as part of the project under component 3 – Project Implementation Support. The permanent on- site staff (Environmental Control Advisor and Community Liaison Officer) will make two-weekly site visits to the footbridge construction sites, supported where necessary by the Sociologist and Environmental Officer in Maseru who will oversee these activities. The latter officers will be responsible for coordinating the activities of the ECA and CLO.
Roads Department SEU
Environmental Manager Maseru based
Environmental Environmental Sociologist Consultant Officer Maseru based Maseru based Maseru based
TIC Project Environmental Community Liaison Control Advisor Officer Site based Site based Footbridge Contractor
HSE Officer Works Supervisor Site based Site based
Supervising Engineer Maseru based Figure 5: Overall Project Structure
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6.2 Roads Directorate, MoPWT- Environmental Health and Safety Management The HSE department will be responsible for management and audit of the Contractors’ construction environmental and social management and monitoring responsibilities. This will be delivered through regular inspections and audits, and formal review and reporting as part of the overall construction monitoring process.
Whilst some evolution of the department structure, staff numbers and responsibilities will change as the Project moves through construction into operation the overall structure and roles and responsibilities will be defined during its inception and modifications implemented as required.
The Roads Directorate will be seeking external independent support from experienced environmental and social consultants in the development of its EHS department, policies, procedures and systems. 6.3 Contractor Environmental Health and Safety Management All Contractors will be encouraged to adhere to the laid down Health and safety principles based on international guidelines and best practice, where they are not accredited to traceable standards (ISO 14000 and 18000 series). The standards place strong emphasis on the need for continuous improvement of the environment and health and safety management systems and resultant environmental and health and safety management performance.
All contractors will be required to prepare Site-Specific Environmental Management, Health and Safety Plans mandatory based on this generic ESMP and WBG General EHS Guidelines. In addition, the contractors will be required to work hand in hand with the EHS officers on site, with the responsibility of ensuring implementation of suggested health and safety measures.
6.3.1 Environmental Health and Safety Officer The Roads Directorate will dedicate an Environmental Health and Safety Officer to carry out the following responsibilities:
• Take prime responsibility for practical implementation of the environmental management; • Review and report on the performance of the Contractor • Review contractors environmental protection/mitigation measures to ensure compliance with the ESMP; • Report non-compliances to the Contractor and Roads Directorate; • Carryout regular environmental awareness sessions and assist personnel in applying environmental standards on site;
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• Conduct regular audits/inspections to check that committed impact mitigation measures are being implemented; and • Act as the first point of contact on environmental matters for the Contractor, for the government authorities, other external bodies and the general public.
6.3.2 Contractor Construction Manager The Contractor Construction Manager will need to work to co-ordinate efforts based on inputs from the Environment Officer (s) and assist in the allocation of staff with the skills for applying the ESMP on site. Contractors will be required to hire an Environment and Health Safety Officer on site who will prepare and implement the Site-Specific Environmental Management, Health and Safety Plans.
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7 CAPACITY INSTITUTIONAL REQUIREMENTS
7.1 Introduction A key component of ESMP success depends of effective capacity building of the Roads Directorate, the training of staff and all others involved in the ESMP, including the construction contractor. These efforts will also be assisted by the implementation of technical assistance by outside consultants. The following training shall be considered. 7.2 EHS Systems The key capacity requirement will be development of an overarching Environmental and Social Management System by Roads Directorate that can encompass overall management of the construction phase and then evolve to provide a robust management system for management of environmental and social issues for all the Project components. 7.3 Capacity Building for the Roads Directorate, MoPWT The Roads Directorate has an established environmental unit, headed by the Environmental Manager to oversee the preparation, implementation and oversight of the ESMP. The environmental unit shall be provided with enough technical and financial resources to complete this oversight role; external resources or contractors may be required. Specific training to the environmental unit should be provided as follows:
• Principles and procedures for environmental impact assessment; • Fundamentals of environmental management; • Compliance assessment, monitoring and follow-up; • Environmental audits; • Social impact assessment and public consultation; and
7.3.1 Environmental Health and Safety Staff There is a requirement for capacity building within Roads Directorate and Contractor (s) to implement the ESMP and successfully manage EHS and social issues during the construction phase. The key responsibilities of the HSE Department will include: • Ensuring all commitments/requirements of ESIA are met; • Co-ordination with various government agencies during the construction phase; • Implementation of the ESMP and oversight of all on-site environmental engineers; and • Environmental training for on-site environmental engineers.
Adequate resource will be assigned to the HSE Department. The exact number of staff to be assigned environmental responsibilities will be established prior to the start of construction and kept under review to confirm that sufficient resources are available. Training for proposed on-site environmental engineer(s) will be undertaken in order to ensure they have adequate skills and knowledge to fulfil their roles.
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The environmental officers will carry out the following responsibilities: • Take prime responsibility for the environmental management of the Project as a whole in compliance with requirements of the Lenders Environmental and Social Performance Requirements and IFC Performance Standards; • Review reporting and compliance audits undertaken by Contractors environmental officer; • Prepare compliance reports on progress of achieving obligations identified in the ESMP for submission to the IFC/; • Report on a daily basis any ESMP non-compliances to the Contractor Manager; and • Act as community liaison officer representative for the Roads Directorate.
7.3.2 Social Staff Similar to environmental staff, there is a need for capacity building to provide staff to be responsible for social and community management. The Roads Directorate will appoint a community liaison officer (CLO) with responsibility for managing the stakeholder engagement plant and other social commitments included within this ESMP, e.g. implementation of the Community engagement processes, HIV/AIDS awareness programme, and impact enhancement commitments related to promoting the development of local communities. More details of the CLO’s role are provided below.
The role of the CLO is to develop and maintain good working relationships with the local communities.
Since their job will involve listening and responding to local concerns and suggestions, the CLO must have the following qualities and skills: • Good people and communication skills; • A good understanding of the local language and community/cultural dynamics; • Open-mindedness and respect for the views of others; • A solution-oriented approach; • A high integrity/degree of trustworthiness; and • A genuine commitment to the position and its goals.
In order to be effective, the CLO needs to have the authority to negotiate on behalf of the Roads Directorate. This requires a clear reporting structure and clarification as to which decisions CLO can take unilaterally, and which are to be passed on to higher levels within the company. Direct reporting lines should be used to enable senior managers to more effectively control risks by being kept informed of field-level information in a timely manner. The more likely it is that the concerns of local stakeholders might pose a risk or reputation issue for the Project.
7.4 Capacity Building for Construction Contractor The construction contractor shall have staff trained to ensure contractor compliance with ESMP requirements. Specific training to the construction contractor environmental unit
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should be provided as follows: • Principles and procedures for environmental impact assessment; • Fundamentals of environmental management; • Compliance assessment, monitoring and follow-up; • Construction impacts, including civil works, sediment and erosion control, soil handling and vegetation removal; • Waste management; • Community relations and public consultation procedures; and • Auditing and follow-up. 7.5 Independent Environmental Monitoring Consultant The Independent Environmental Monitoring Consultant shall be trained in the oversight and compliance assessment of large infrastructure projects, including the preparation of compliance reports and environmental sampling procedures, including the following:-
• Principles and procedures for environmental impact assessment; • Fundamentals of environmental management; • Compliance assessment, monitoring and follow-up; • Air, soil and water sampling procedures; • Construction impacts, including civil works, sediment and erosion control, soil handling and vegetation removal; • Waste management; • Community relations and public consultation procedures; and • Auditing and follow-up.
7.6 Technical Assistance In addition to staff training, technical assistance for outside consultants will be sourced as and when required to provide training seminars and workshops.
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8 COMMUNICATION AND REPORTING REQUIREMENTS
8.1 Introduction Effective reporting is essential for rendering an ESMP of practical value. Routine independent auditing provides the necessary impetus for continual improvement. Without these two fundamental elements, such systems simply degenerate into data collecting exercises. Performance monitoring, reporting and auditing should be carried out to ensure compliance with the requirements of this ESMP. The following provides an outline approach which is aligned to the requirements of ISO 14001. The final scope and format of all reports proposed herein will be agreed with the lender and Roads Directorate prior to them being required and produced. Furthermore, each of these reports will be submitted to the lender and the Roads Directorate for review and disclosure. 8.2 Adaptive Management The ESMP and plans contained herein will adopt an “adaptive management” approach throughout the life cycle of the Project. The creation of the plans at the outset is a fluid process with the management objectives and performance indicators tailored to the current design and objectives of the Project. The ESMP utilizes to the extent possible existing project knowledge to fully address the actual environmental and social impacts of the Project at the time and allow flexibility in environmental and social management decisions made on the Project.
To ensure adaptive management of the ESMP the following actions will be implemented: • The ESMP will be reviewed and amended in accordance to the Project design and status as it evolves.
• Key information about any changes to project description will be regularly reviewed (monthly) and site visits undertaken by the Road Department EHS staff, dedicated to the project, to identify the true impacts of the Project.
• Ongoing evaluation of the effectiveness of measures included in the ESMP will be undertaken on a regular basis as the Project evolves and develops and throughout design, construction, operation and decommissioning of the Project. Evaluation will be undertaken through ongoing communication with, contractors, stakeholders and lenders supplemented by site audits and monitoring data review to identify weaknesses and / or gaps in the management plan. The ESMP will be changed and/or updated accordingly to ensure appropriate, robust and effective environmental and social management commensurate to the scale of the Project through its lifetime.
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9 ESMP REVIEW MONITORING AND REPORTING BY ROADS DIRECTORATE AND OTHERS
The environmental unit of the Roads Directorate shall periodically review, monitor and audit the effectiveness of the ESMP. The audit program should adequately cover the scope, audit frequency of the project. The frequency of audits should reflect the intensity of activities (typically more common during construction), and non-compliances raised in prior audits. 9.1 Review of the EMP The environmental unit of the Roads Directorate shall review the ESMP to assess its effectiveness and relevance as follows: • A full review shall be undertaken annually; • Following a reportable incident, or a significant non-compliance; and • Following an addition, up-date or change order to the ESMP.
The review of the ESMP should consider the following: Adequacy of data collection, analysis and review;
• Reporting; • Non-compliances; and • Corrective actions implemented.
The ESMP shall also be reviewed periodically to evaluate environmental controls and procedures to make sure they are still applicable to the activities being carried out. Reviews will be undertaken by the Environmental Unit.
The review shall include analysis of the data collection and analysis of data, monitoring reports, incident reports, complaints/grievances and feedback from stakeholders, reports, consultation meeting minutes and training records to evaluate the effectiveness of ESMP procedures. Site visits, interviews and other auditing methods may also be used. 9.2 Contractor Monthly Internal Reports All contractors will be required to prepare a monthly report for issue to the Roads Directorate Environmental Manager. These reports should normally be no more than one or two pages in length, to summarize the following:
• Progress in implementing the ESMP and parallel management plans; • Findings of the monitoring programmes, with emphasis on any breaches of the control standards, action levels or standards of general site management; • Outstanding Non-Compliance Reports (NCRs); • Summary of any complaints by external bodies and actions taken/to be taken; and
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• Relevant changes or possible changes in legislation, regulations and international practices. • Any breaches of the acceptable standards specified by law/construction permits and/or this ESMP should be reported to The Roads Directorate, using a NCR Form.
9.2.1 External Reporting For Regulatory Compliance Adhering to the external reporting requirements as set out in Country Legislation is important. A register of all necessary external stakeholder reporting requirements under Lesotho Legislation and for regulatory compliance purposes should be developed. The frequency of reporting, the required reporting format and the person (s) responsible for producing the report (along with any necessary specialist service providers/constructors required to assist for data collection or interpretation purposes) is to be noted in the register.
The Roads Directorate will ensure that all the necessary reports are produced and submitted in a timely fashion in order to achieve ongoing regulatory compliance throughout the life of the Project. Meeting regulatory reporting requirements is to also form part of the scope for any internal audits and management reviews.
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10 ESMP BUDGETS
10.1 Indicative budgets The low impact nature of the projects, both in magnitude and footprint, has made it possible for the budgets around the projects to be largely personnel costs (Roads Directorate – EHS Department and the Contractor site managers) which have been built into the contracts.
Other budget items will include:
• Co-ordination and Communication; • ESMP Compliance Monitoring; • Roads Directorate & External auditors Environmental Monitoring; • Construction Social Management.
Table 10-1 shows its distribution over the different areas and over the key development periods of construction and outlines the nature of the activities included. The
Table 2: Preliminary Estimate of EMP Costs ESMP Component Estimated Cost ($US)
Contractor – built into contract 8-12% of total construction costs
Supervision – environment – to be built into the contract for Engineering 10-25% of engineering Supervision (includes EHS ) supervision cost
Independent Environmental Audits (Monitoring ) $20,000
Institutional Strengthening, Training and Capacity Building $65,000 • Local authorities, communities and other stakeholders • On-site training • Offsite training • Local capacity building • Equipment and logistics
Technical Assistance to Roads Directorate environmental unit $100,000 • Provision of outside consultants • Manual of functions and procedures • EMP protocols and procedures • Assist in implementation of updated management plans • Contractor liaison • TORs
Total Initial EMP Costs
It is expected that the cost associated with some measures may change. In the event of
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cost changes, an update of the overall environmental and social budget with suggestions on the way to reallocate funds will be done. These suggestions will be presented to lenders for review.
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