REG: Improving the Implementation of Environmental Safeguards in Central and West Asia

Technical Assistance Consultant’s Report

Project Number: 43333-012 July 2014

Environmental Safeguards Training Consultant and Third Party Auditor - Armenia, Azerbaijan and Georgia

Armenia Country Report

Prepared by” Eco Spectri” Ltd. (Georgia)

For Asian Development Bank

This consultant’s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents.

ASIAN DEVELOPMENT BANK ECO-“PECTRI LTD.

ASIAN DEVELOPMENT BANK

RETA 7548: Improving of Environmental Safeguards in Central and West Asia

IDC: Environmental Safeguards Training Consultant and Third Party Auditor - Armenia, Azerbaijan and Georgia

ARMENIA COUNTRY REPORT

Prepared by “Eco-Spectri” Ltd. (Georgia) For Asian Development Bank

July, 2014

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

TA-7548 REG: IMPROVING THE IMPLEMENTATION OF ENVIRONMENTAL SAFEGUARDS IN CENTRAL AND WEST ASIA

ARMENIA COUNTRY REPORT

For consideration:

Asian Development Bank 6 ADB Avenue, Mandaluong City, Metro Manila, Philippines

Prepared by: Ltd. “Eco-Spectri” 7 Chavchavadze Ave. Tbilisi 0179, Georgia www.eco-spectri.ge 2

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

TABLE OF CONTENTS

TABLE OF CONTENTS 3 ABBREVIATIONS 5 EXECUTIVE SUMMARY 7 I. 18 TRAININGS CONDUCTED IN ARMENIA 1.1 Training Needs 18

1.2 Purpose and Objectives of the Training Course 18

1.3 Scope and Content of the Trainings 18

1.4 Training Methodology and Preparation 19 1.5 Review of Documentation 20 1.6 Preparation of Training Materials 20 1.7 Preparatory Activities 20 1.8 Project Implementation Team Composition and Detailed Tasks 22

1.9 Training Assessment & Evaluation 22 1.10 Execution of the Trainings and Observations 22 1.11 Staff Trained 22 1.12 Main Observations and Conclusions 27

1.13 Main Findings and Recommendations 34

II. ENVIRONMENTAL AUDITS CONDUCTED IN ARMENIA 36 1. CWPF 45230-001: WOMEN ENTERPRENEURSHIP SUPPORT PROJECT 36 1.1 Brief Project Description (CWPF - 45230-001) 36 1.2 Project Status 36 1.3 Institutional Aspects on Environmental Safeguards Implementation 36 1.4 Project Document Analysis 39 1.5 Meeting with the German - Armenian Fund (GAF) 41 1.6 Main Findings and Recommendations 41 2. CWEW 424117-023: SUSTAINABLE URBAN DEVEOPMENT INVESTMENT 43 PROGRAM, PROJECT 1, TENDER 1 - CONSRUCTION/REHABILITATION OF ARSHAKUYATS STREET 2.1 Brief Project Information 43 2.2 Institutional Aspects on Environmental Safeguards Implementation 44 2.3 Project Document Analysis 46 2.4 Project Site Audit 52 2.5 General Findings and Recommendations 59 3. CWTC 42145-023, 42145-033: NORTH–SOUTH ROAD CORRIDOR INVESTMENT 65 PROGRAM – TRANCHE 1 AND TRANCHE 2: YEREVAN-ASHTARAK, YEREVAN- ARARAT AND ASHTARAK-TALIN

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

3.1 Brief Information on the project (42145-023; 42145-033) 65 3.2 Institutional Aspects on Environmental Safeguards Implementation 66 3.3 Project Document Analysis 68 3.4 Project Site Audit 73 3.5 Main Findings Revaled during the Documents Review and Site Visits 80 3.6 Non-Compliances and Recommendations 80 4. CWUW 45299-001: WATER SUPPLY AND SANITATION SECTOR PROJECT – 83 PHASE 2 4.1 Brief Information on the Project 83 4.2 Institutional Aspects on Environmental Safeguards Implementation 84 4.3 Project Document Analysis 85 4.4 Project Site Audit 90 4.5 Main Findings Revealed During the Documents Review and Site Visits 98 4.6 Non-Compliances and Recommendations 100 APPENDIXES 102 Appendix 1. Environmental Safeguards Compliance Monitoring Checklist for the 102 Construction/Rehabilitation of Arshakunyats Street Project Appendix 2: Environmental Safeguards Compliance Monitoring Checklist For North– 107 South Road Corridor Investment Program Appendix 3. Environmental Safeguards Compliance Monitoring Checklist For Water 111 Supply and Sanitation Sector Project

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

ABBREVIATIONS

ADB Asian Development Bank

ARMRM Armenian Resident Mission

AWSC Armenia Water Sewerage Company

CWRD Central and West Asia Department

EA Executive Agency

EIA Environmental Impact Assessment

EIAF Environmental Impact Assessment Framework

EMP Environmental Management Plan

ES Environmental Safeguards

ESMS Environmental and Social Management System

GAF German Armenian Fund

IA Implementation Agency

IEE Initial Environmental Examination

IFC International Financial Corporation

LA Loan Agreement

LLC Limited Liability Company

MES Monitoring and Evaluation Specialist

“NSRP” PMU “North-South road Corridor Investment Program PMU” SNCO SNCO

OJSC Open Joint Stock Company

PAM Project Administration Manual

PIU Project Implementation Unit

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

PMCSC Project Management and Construction Supervision Consultant

PMU Project Management Unit

PPTA Project Preparation Technical Assistance

PPMU Project Preparation and Management Unit

RETA Regional Technical Assistance

SE Safety Engineering

SEMP Site-Specific Environmental Management Plan

SEPE Social and Environmental Protection Expert

SIEE Summary Initial Environmental Examination

SME DNC Small and Medium Entrepreneurship Development National Center

SPS Safeguard Policy Statement

SS Safeguard Specialist

SUDIP Sustainable Urban Development Investment Program

TA Technical Assistance

YM Yerevan Municipality

YMPIU Yerevan Municipality Project Implementation Unit

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

EXECUTIVE SUMMARY

1. ADB helps developing member countries (DMCs) to strengthen their safeguard systems and develop their capacity to address environmental and social issues in development projects. Since the approval of the Safeguard Policy Statement (SPS) in 2009, ADB has been providing technical assistance to help strengthen the legal and institutional framework for effectively implementing safeguards.

2. Work undertaken by ADB's Central and West Asia Department (CWRD) highlighted a number of deficiencies preventing effective implementation of environmental safeguards. Foremost among the challenges is insufficient capacity in executing agencies to prepare, implement, and monitor the implementation of EMPs. The lack of effective implementation means that there is a credible risk that projects are not in compliance with the SPS.

3. Under the TA of ADB, it was decided that a number of environmental service providers will be trained to deliver the training course in each country and will do so through an on-call basis. This approach will ensure that the type and content of training is consistent across all projects, providing a more cost effective approach by avoiding the costs of international consultants, developing an in-country training capability, providing an opportunity to undertake refresher training, and it will also allow contractors to commission the same training, at their cost.

4. In scope of the project three training courses - Training of Trainers (ToT) in Improving of Environmental Safeguards in Central and West Asia have been delivered in Kazakhstan, Georgia and Pakistan in 2012. 33 Trainers from 6 firms undergone development of tracking system training of third party auditors on effective environmental management and monitoring during the job training. The trainings were based on the Environmental Safeguards Training course developed by the ADB.

5. Few companies have been selected on tender basis to conduct on-the-job trainings and environmental audits in 10 countries of Central and West Asia: Afghanistan, Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Pakistan, Tajikistan, Turkmenistan, and Uzbekistan. In the countries of Caucasus region - Armenia, Azerbaijan and Georgia the project is accomplished by “ECO-SPECTRI” LTD (Georgia). At the first stage, 4 trainings were conducted in Tbilisi, Georgia, 4 Trainings in – Baku, Azerbaijan and 4 trainings – in Yerevan, Armenia for PIUs, Supervising Consultant and Construction Contractor.

6. At the second stage, the “Eco-Spectri’ Ltd. (the Consultant) conducted Environmental Audits of ADB funded projects in Georgia in the framework of Regional Technical Assistance (RETA) “Improving the Implementation of Environmental Safeguards in Central and West Asia”. At present, 18 projects are implemented by three PIUs, in particular: Armenia Water Sewerage Company (PIU), North-South Road Corridor Investment Program (PMU) and Municipality of 7

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Yerevan. At this stage it is not decided how many sub-projects will be implemented in scope of “Women Entrepreneurship Support Project” by the German - Armenian Fund.

7. The Environmental Audit was conducted after 9 months of training activities held for Executing/Implementing Agencies’ (EA/IA), Project Management Unit/Project Implementation Units (PMU/PIU)’s, Supervision Consultants, and Contractors involved in implementing ADB funded projects. During the training activities, all participants were informed about approach and steps to be taken during the Environmental Audit. In addition, a list of documents, which would be reviewed during the Environmental Audit, was included into the training materials distributed among participants.

8. The main goal of the Environmental Audit was an assessment of execution of environmental safeguards during the project preparation and implementation stages as well as development of recommendations for EA, PMUs/PIUs and ADB to improve environmental performance of the projects based on findings revealed during the Environmental Audit. Generally, the Environmental Audit consisted of two parts: (i) review of institutional and regulatory bases of EA/IAs established for safeguards implementation; and (ii) assessment of Site Environmental Management Plans (SEMP) implementation by Contractors at the construction sites.

9. As the module of trainings covered new approaches to be considered both, by the Construction Contractor and other Project-implementing organizations, it was decided to organize the Environmental Audits for the Project owner, Supervising Company and Construction Contractor. The environmental audit was conducted by using the questionnaire developed by the Asian Development Bank.

10. As a first part of Environmental Audit, the following project documents were reviewed to check if environmental requirements are included: Loan/Project Agreements, Project Administration manual, Bidding Documents, Contracts between Project Management/Implementation Units (PMU/PIU) and Supervision Consultant/Contractors. In addition, the results of environmental monitoring, which needs to be conducted by Contractor/PMU/Supervision Consultant per concerned requirements indicated in each Environmental Management Plan (EMP) and PMU/PIU’s working papers related to environmental performance were observed.

11. In order to assess Site-Specific Environmental Management Plan (SEMP) or EMP implementation, a joint team comprised from representatives of the Consultant, PIUs, Supervision Consultant, and Contractors visited construction camps and sites of all projects. During those visits, sites with on-going and recently completed project activities were observed.

12. The following paragraphs and chapters give a detailed description of the summary of non- compliances fixed with the trainings and environmental audits held in Azerbaijan, and relevant conclusions and recommendations.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Summary of Findings, Non-Compliances, and Recommendations of Conducted Trainings in Armenia

13. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU representatives, 4 of them being the representatives of the Construction Contractor, 2 of them being the representatives of the Supervising Consulting Company and 3 of them being the representatives of RM of ADB. The rest 6 attendees were representatives of national banks under the “Women Entrepreneurship Support Project”. 9 months after the trainings, 4 people (21%) having taken the training, did not work in their previous positions, being either retired, or moved to other positions with the same office (in short, they are not concerned with the environmental issues any more). 14. In the course of the trainings, the participants stated about the problems hampering meeting the environmental requirements. In the participants’ opinion, the problems existing in the country associated with the environmental protection are as follows: (a) Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; (b) Environmental specialist is not involved in the review of the tender proposal; (c) There is no real mechanisms for PIU for penalization of the construction contractor for non-compliances.

15. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (14 %) made 1 mistake each, 16 of them (86 %). made 2 mistakes each. 16. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (12.5%) made 1 mistake each, 15 of them (62.5%) made 2 mistakes each and 6 of them (25%) made 3 mistakes each. 17. The training evaluation questionnaires did not identify the respondents. As Table 9 shows, the absolute majority of the participants are content both, with the developed training module and method of delivery.

18. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the same view, and the trainings desirable by them were about: (a) Preparation of environmental documents and their implementation; and (b) Description of entire monitoring process.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

19. Unfortunately, there were no international environmental specialists of a supervising company of either project attending the trainings.

Summary of Findings, Non-Compliances, and Recommendations of Conducted Environmental Audits in Armenia

Findings:

20. There are 18 ongoing projects on the territory of Armenia financed by the ADB, and there are 3 PIUs engaged in their realization: Armenia Water Sewerage Company, North-South Road Corridor Investment Program PMU and Municipality of Yerevan. At present, 18 projects are implemented by three PIUs, in particular: Armenia Water Sewerage Company (PIU), North- South Road Corridor Investment Program (PMU) and Municipality of Yerevan. At this stage it is not decided how many sub-projects will be implemented in scope of “Women Entrepreneurship Support Project” by the German - Armenian Fund;

21. The Loan Agreements prepared under the projects envisage the obligation of the authority of the Republic of Armenia to realize the project in line with the ADB safeguard policies and requirements of the environmental legislation of Armenia;

22. The FAM/PAM developed within the scope of the projects gives the necessity of fulfillment of environmental requirements in different degree. The FAM developed within the scope of the NSRP project gives a detailed description of the qualification necessary for the environmental specialists and their rights and obligations, as well as all major requirements to be considered by any organization engaged in the project. The FAM/PAM developed within the scope of other projects gives fewer details related to the environmental requirements;

23. In each PIU, besides German-Armenian Fund, Environmental Unit is created or environmental specialist is hired with relevant qualification. The obligations of environmental specialist of GAF are performed by the Head of PFIs Audit Division;

24. International Supervision Consultant Company is hired under the North - South Road Program (NSRP) and Sustainable Urban Development Investment Program (SUDIP) projects. Local Supervision Consultant is hired under the “Water Supply and Sanitation Sector Project”;

25. No environmental specialist of PIU is engaged in tender evaluation committee. Only under the (SUDIP) an environmental specialist was included in the bid evaluation committee. The mentioned specialist had been invited from American University of Armenia.

26. All companies engaged in the realization of NSRP and SUDIP projects are staffed both, with local and international environmental specialists of relevant qualification. Only the PIU implementing the Water Supply and Sanitation Sector Project and Consultant/Supervision Company are staffed with local environmental specialists. As for the construction contractors, 10

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

within the scope of the said project, they (the construction contractors) have not employed qualified environmental specialists (the bidding documents do not give such a requirement).

27. The Baseline Analyzes ate accomplished within the scope of projects NSRP and SUDIP. The Framework Initial Environmental Examination Report developed within the scope of Water Supply and Sanitation Sector Project immediately gives the requirements for not accomplishing such measurements (“No new baseline monitoring is required”, Clouse VIII – “Framework Environmental Management Plan”);

28. EMP is updated within the scope of NSRP and Water Supply and Sanitation Sector Project. As for SUDIP, the EMP is not updated within its scope. There is also SEMP within the scope of NSRP project by using the new methods of risk assessment developed by the Bank. There are some inaccuracies fixed with the risk assessment methods;

29. Within the scope of NSRP and SUDIP projects, all planned monitoring are being accomplished. The said monitoring are accomplished by the environmental specialist of both, Construction Contractor and Consulting Company and PIU. There are no daily monitoring envisaged by the EMP accomplished by an environmental specialist of Construction Contractor within the scope of Water Supply and Sanitation Sector Project;

30. All planned environmental reports are developed and submitted within the scope of all projects. The environmental data contained in the Monthly Progress Report within the scope of Water Supply and Sanitation Sector Project is developed by the environmental specialist of the Consulting Company. As per the requirement, the Progress Report is drafted by the Construction Contractor and is submitted to the Consulting Supervision Company. But in this case, it looks like the monthly environmental reports envisaged by the progress reports are drafted by the Consulting Company to be submitted to itself;

31. The environmental trainings were conducted to the Construction Contractor within the scope of NSRP. No environmental trainings were held within the scope of other projects despite the fact that the documents for all of them (IEE and EMP) envisage such a requirement quite strictly;

32. Within the scope of all projects, there are agreements drafted with the local authority and relevant organizations concerning the following issues: disposal of inert and municipal waste, use of borrow pits (if the company has its own borrow pits), removal of sewage silt, etc.

33. Within the scope of NSRP and SUDIP projects, the books of complaints are available on the construction site. There is no book of complaints found at any construction site of the three sub- projects within the scope of Water Supply and Sanitation Sector Project;

34. In scope of the NSRP there are permanent meetings held with the locals to consider the environmental issues interesting to the population, who are under the project impact. This action can be considered as good practice for other ongoing projects (in Armenia and other countries). 11

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Within the scope of other projects, the results of environmental monitoring and audits are not informed to the local population. However, it should be considered that no such requirement is envisaged officially by any document;

Non-Compliances:

35. In scope of the project NSRP the inert waste is disposed on the existing topsoil. The developed inert waste disposal plan does not envisage the removal of the topsoil on the territory where the inert waste is to be placed. In fact, according to the developed plan, the topsoil on the territory where the inert waste is to be disposed is to be totally destroyed;

36. In scope of the project NSRP there is a violation of standards at the territory of topsoil disposal, in particular the height of the temporarily disposed topsoil significantly exceeds permissible standards;

37. In scope of the Water Supply and Sanitation Sector Project neither of the Construction Companies have an environmental specialist on staff. Consequently, within the scope of any project, no daily inspections are conducted and no relevant records are made by the employees of the Construction Contractor; 38. In scope of the Water Supply and Sanitation Sector Project the Consultant/Supervising Company has not provided any training related with the environmental issues. It is necessary in scope of the mentioned projects, because none of the Construction Contractor does not have environmental specialist on staff.

Recommendations:

39. One of the documents developed under the project by ADB (Loan agreement, PAM/FAM) shall necessarily contain the detailed description of the following environmental requirements: (a) the rights and obligations of the environmental specialists of all organizations engaged in the implementation of the project, (b) the need for the environmental specialist’s participation in the evaluation of the bid proposals and assessment criteria, (c) reporting and terms (regularity) of reporting, (d) categories of non-compliance and sanctions for the failure to meet the environmental requirements, (e) the requirement for the need to include all the above-listed clauses in the biding documents and contract.

40. After the loan agreement is approved, PIU and/or the environmental specialist of the consultant company shall be engaged in all following phases of the project implementation (drafting the project detailed design, developing and assessing the tender bids, concluding the agreement with the construction contractor);

41. The bid proposal developed within the scope of the Water Supply and Sanitation Sector Project shall envisage the requirement for the Construction Contractor to hire a qualified

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

environmental specialist. Despite the fact that the project, under the Framework Initial Environmental Examination Report developed within the scope of the project, has no great impact, the said project belongs to category “B” and its scales are quite large covering 110 settled areas.

42. As practice evidences, despite the fact that in all cases, the bidding proposal is enclosed by EIA or IEE and the obligation to meet the environmental requirements is specified by the terms of the tender, most construction contractors do not read it, but they draft the project cost estimate based on the list presented in the “Scope of Works”. It is necessary for the PIU and/or consulting company in the “Scope of Works” to give the detailed description of the necessary actions to be accomplished to meet the environmental requirements;

43. The positions of the professional safety and health specialist and environmental specialist are desirable not to be occupied by the same person. If following the financial and technical conditions of the project this seems necessary, the specialist is better to be an environmentalist rather than the professional safety and health specialist (Water Supply and Sanitation Sector Project);

44. An environmental inspection checklist is to be developed and records during the environmental inspection are to be made. All relevant records must be kept on the construction site. During the audit, the environmental specialist was given the sample daily or weekly questionnaire and was explained the principles of filling it in (Water Supply and Sanitation Sector Project);

45. Book of Complaints should be prepared and maintained on the site Water Supply and Sanitation Sector Project);

46. A module of the environmental training is to be developed by the environmental specialist of the Consulting Company and the training shall first of all be given to environmental specialist of the Construction Contractor Water Supply and Sanitation Sector Project and SUDIP);

47. Under the ADB guidelines, the IEE document is developed and approved before the detailed design is developed. Consequently, all negative environmental impacts of the project implementation phase cannot be identified at this stage. It is clear that the EMP developed within its limits cannot give all necessary mitigation measures. Consequently, the Construction Contractor must update and not copy existents EMP (SUDIP);

48. SEMP does not envisage all the new requirements developed by the Asian Development Bank. In addition, there are some inaccuracies fixed with the risk assessment methods and using the requirements making it obviously necessary to update the documents (NSRP);

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

49. The results of the environmental monitoring are to be distributed among the project affected settlements (in the language familiar to them). The reports of the environmental monitoring are possible to hand over to the local NGOs (if any), local authorities, informal associations, religious organizations, etc (SUDIP and Water Supply and Sanitation Sector Project);

50. Based on the Environmental Audit findings, the Consultant has developed a summarized table of recommendations for the each reviewed sub-project. The table provides data on implementer and timing when recommendations should be applied during the project cycle (Table 1).

Table 1: Recommendations Matrix

# Recommendation Responsible/Actions Implementation Terms 1. The loan agreements concluded ADB - gives the During preparation of within the scope of the project, PAM, environmental relevant Documents IEE, bidding proposal, contract and requirements in greater – PAM, IEE and EIA. other relevant documents must give details in PAM. the environmental requirements in Construction/Supervision greater details. Consultant - gives the environmental requirements in greater details in IEE/EIA. 2. It is necessary to update EMP. Construction Contractor: Within one month EMP should be updated on after receiving the the basis of detailed Environmental Audit design. Report. 3. Monthly progress reports and Construction Contractor: Within one week quarterly environmental reports Disseminates monthly and after receiving the should be provided to all quarterly reports prepared Environmental Audit stakeholders, including local media under the project among all Report to elaborate interested stakeholders procedure for including media disseminating of representatives. monthly and quarterly reports among the local population. 4. All environmental specialists Consultant Company: Within one week engaged in the project shall take the prepares training module after receiving the training developed within the scope on the basis of the Environmental Audit of RETA project. trainings conducted under Report the RETA program and conducts trainings for Construction Company employess including every 14

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

new hired employees. 5. Place 0.24 m3 waste containrs wihin Construction Contractor: Within one week the territory of construction site for Placement of 0.24 m3 after receiving the collection of municipal waste. waste containrs wihin the Environmental Audit territory of construction Report. site. 6. SEMP should be updated. Construction Company: Within one month Risk assessment table is to after receiving the be improved, assessment Environmental Audit methodology has to be in Report. compliance with ADB requirements. 7. Inert Waste Management Plan has Construction Company: Within one month to be updated. Updates Inert Waste after receiving the Management Plan in Environmental Audit accordance with the Report. presented recommendations. 8. Construction Contractor shall have Consultant Contractor: During the environmental specialist on staff. Includes in bidding preparation stage of document requirement for the bidding the Contractor to hire a documents for the qualified environmental next sub-projects. specialist on staff.

9. Armenia Water Sewerage Company PIU - Armenia Water Within one month shall hire at least two more Sewerage Company: after receiving the environmental specialists. Announces tender for Environmental Audit hiring of two additional Report. environmental experts within the PIU under the project.

51. The Consultant has prepared Environmental Audit Reports for all 3 projects and shared with to each PMU/PIUs for review and comments. Based on the comments provided by PIUs, the Consultant incorporated necessary clarifications into the final version of Environmental Audit Reports.

52. Following the above-mentioned, the present Country Environmental Audit Report considers 9 sub-projects. Brief information on implementation status of audited projects is presented in Table 2.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 2: Brief Information on Implementation Status of ADB Funded Projects in Armenia

# Project Identification Project Implementation team Project Location Project Status Remarks (PIU, Construction (Project Company, Consultant Implementation Company) Percentage) 1. CWPF - 45230-001: PIU: German -Armenian Fund Armenia 0% The project has not been started Women Entrepreneurship Support Project (GAF) yet.

2. Tranche 1 - Tender 1: PIU: Municipality of Yerevan; Yerevan 8% Construction/Rehabilitation of Consultant Company: EGIS Arshakunyats Street International; Consultant Company: Vahagn and Samvel LLC 3. Tranche 1 - Tender 2: PIU: Municipality of Yerevan; Yerevan 0 % A construction contractor has not Construction/Rehabilitation of New Shirak Consultant Company: EGIS been selected yet. Street-Artashat Highway International; Construction Company: EGIS International Consultant Company: not selected yet. 4. CWTC 42145-023: South Road Corridor PIU: North-South Road Ashtarak-Yerevan- 95% 1. The construction works are almost Investment Program, Tranche 1: Yerevan- Corridor Investment Program Talin completed and restoration works Ashtarak and Yerevan-Ararat PMU; are in progress. Construction Company: Corsan–Corviam Construction S.A Consultant Supervision: Safege S.A. Eptisa JV 5. CWTC 42145-033: South Road Corridor PIU: North-South Road Ashtarak - Talin 55% 2. The construction works are in Investment Program, Tranche 2: Corridor Investment Program progress. Ashtarak-Talin PMU; Construction Company: 3. . Corsan–Corviam Construction S.A Consultant Supervision: 16

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Safege S.A. Eptisa JV

6. CWTC 42145-043: South Road Corridor PIU: North-South road Talin-Gyumri 0% No construction actions have been Investment Program, Tranche 3: Talin- Corridor Investment Program started yet. A tender to identify a Gyumri PMU; Construction Contractor is Construction Company: announced. Corsan–Corviam Construction S.A Consultant Supervision: Safege S.A. Eptisa JV 7. Improvement of Water Supply Systems in PIU: Armenia Water Vedi and Ararat 81% 4. Vedi and Ararat Towns and Banavan GMF, Sewerage Company towns Ararat, Volketap Villages. Construction Company: Ararat-Chanshin LLS - Artezia LLS Consultant Supervision: JV of HGSN LLS and JINS LLS 8. Improvement of Water Supply Systems in PIU: Armenia Water Hrazdan town 78% 5. Hrazdan Town, Qaghsi Village. Sewerage Company Construction Company: LLS&Ashotsg LLS Consultant Supervision: JV of HGSN LLS and JINS LLS 9. Improvement of Water Supply Systems in PIU: Armenia Water Metsavan, 70% 6. Metsavan, Sarchapet and Lernahovit Sewerage Company Sarchapet and Villages and Reconstruction of Hovdra Construction Company: Lernahovit villages External Water Main. Agat 777 LLS Consultant Supervition: JV of HGSN LLS and JINS LLS

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

I. TRAININGS CONDUCTED IN ARMENIA

1.1 Training needs

53. The ADB Safeguard Policy Statement (SPS 2009) contains a revealing paragraph that discusses the environmental management of previous projects.

54. Three major reasons why projects fail to effectively implement environmental safeguards requirements are:  Poorly prepared EMPs that do not provide enough details for the environmental staff of PIUs to know what measures to implement on the ground;  Lack of direction of guidelines from ADB as to what is required and when, and  Poorly prepared tenders and contracts that do not provide that not provide adequate environmental management requirements.

55. There is thus a need to train project staff in how to implement environmental requirements, understand what should be done, when and by whom; have the ability to incorporate environmental management requirements into tender and contract documents and have the ability to prepare and assess a site-specific environmental management plan (SEMP) so that construction workers can have a clear picture of what is required on the ground.

1.2 Purpose and Objectives of the training course

56. Purpose of the training is to strengthen the environmental management and monitoring capability of the executive agency and project implementing organizations, as well as construction contractor and supervision consultant in the region through on the job trainings.

57. The objectives of on-the-job trainings are thus to ensure that the PIU, contractor companies and consultants environmental staff responsible for preparation, adoption and implementation of EMP/SEMP.

1.3 Scope and Content of the trainings

58. According to the contract between Asian Development Bank and Ltd. “Eco-Spectri” (The Consultant), the Consultant commenced the services on 5th of June, 2013. Training schedule for Georgia has been prepared by Ltd. “Eco-Spectri” and agreed with ADB.

59. It was envisaged to conduct 4 on-the-job trainings in Yerevan, Armenia of executive agency staff, project supervision consultant and contractors in environmental management, monitoring and reporting based on the Environmental Safeguards Training course developed by ADB as per the schedule detailed in Table 3 below.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 3: Training Schedules for Armenia

# Executive Agency/PIU Dates of Training 1. North-South Road Corridor Investment Program 10-11 September, 2013 2. “Armenian Water & Sewerage” CSJC 12-13 September, 2013 3. Sustainable Urban Development Investment Program 16-17 September, 2013 4. Women Entrepreneurship Support Project 18-19 September, 2013

60. The duration of each training was 2 days. Each day of the training lasted from 9:00 o’clock/am – till 6:00 o’clock/pm. The Training program consisted of 12 modules including national case study and exercises. The following modules considered during the training were as follows:

Module 1 - Introduction Module 2 - ADB’s Relationship with Partners Module 3 - Environmental Specialist/Roles and Responsibilities Module 4 - Loans, Tenders and Contracts Module 5 - Bid Evaluation Module 6 - Introduction to Risk Assessment Module 7 - Construction Impacts & Mitigations Module 8 - Case study (particular cases for relevant sectors) Module 9 - Environmental Monitoring Module 10 - Reporting Module 11 - Inspection and Audit Module 12 - Final Exercise, Questions and Lahore Case Study/SEMP Group Training Exercise 61. The following knowledge products has been already prepared by ADB for on-the-job training: (i) environmental management inserts for the PAMs that cover the different lending modalities; (ii) guidelines on drafting environmental management clauses for tender documents and contracts; (iii) handbook on Environmental Mitigation Measures for Construction; and (iv) handbook on Environmental Management for Construction sites.

1.4 Training Methodology and Preparation

62. Project implementation team has decided to conduct the trainings in the conference room rented for this special purpose, outside the PIU’s offices to avoid the frequent movement (absence) from the side of the training participants, which may negatively affect the training quality.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

63. The trainings involved a lot of advance preparations and were highly participatory. It included case studies for relevant sectors, focus group discussions, group presentations and on-the-job trainings during environmental audits on sites. The Consultant team assessed the participants at the end of the training course to evaluate their understanding of the subject matter using questionnaires prepared by ADB and Consultant. At the end of each training, each participant completed a questionnaire to evaluate the content, and the conduct of the training.

64. It was determined that the quantity of training attendees should not exceed 10 participants. Project focus group consisted of: Executive agency, PIU and supervision company. The environmental specialists of the construction contractor were provided with on-the-job training during the audit time at the project site.

1.5 Review of Documentation

65. As part of the advance preparation, the following documents were reviewed by the Consultant: i) ADB’s Safeguard Policy Statement (SPS 2009); ii) ADB Strategy 2020; iii) Environmental Impact Assessments of relevant projects; iv) Training module – Environmental Safeguards Information Kit; v) Environmental management inserts for the PAMs that cover the different lending modalities; vi) Guidelines on drafting environmental management clauses for tender documents and contracts; vii) Handbook on Environmental Mitigation Measures for Construction; viii) Handbook on Environmental Management for Construction sites.

1.6 Preparation of Training Materials

66. Training materials, questionnaires, practical exercises, etc were prepared in line with the documents reviewed. Project implementation team has prepared English-Russian (for Armenia) power point presentations based on the training modules and training materials provided by ADB. The following materials have been also translated into Russian for Armenia: 1. Environmental Safeguard Compliance Monitoring Checklist; 2. PIU tools and Templates for EMP Supervision; 3; Training Course Effectiveness Questionnaire.

67. At the end of each training course an exercise was carried out to ensure that the participants understood the concepts & could implement them. The exercises covered all the aspects of the training.

68. Hands on practical exercises were conducted with the teams in preparing Site Specific Environmental Management Plan (SEMP).

1.7 Preparatory Activities

69. Contact persons from Executing and Implementing Agencies of the relevant projects have been identified from the very beginning:

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

1. Ministry of Transport & Communication: N. Sargsyan; E-mail: [email protected]

2. Armenian Water Sewerage Company: Patric Lorin; E-mail: [email protected]

3. Yerevan Municipality. Nora Martirosyan; E-mail: [email protected]

4. The German-Armenian Fund: Ishkhan V. Karapetyan; E-mail: [email protected]

70. Lists of ongoing projects in Armenia have already been provided by the ADB (see table 4 below).

Table 4: List of Ongoing Projects in Armenia

Country Div Project No. Project Name Project Milestone Dates Category Loan/Grant Team No. PTL Approval Effectivity Closing Env.

ARM CWPF 45230-001 Women A. Schou- 25-Oct- 31- FI L2922/2923 Entrepreneurship Zibell 12 Dec-17 Support Project CWTC 42145-023 North-South Road P. 6-Oct-09 24-Feb- 30-Jun- B L2561 Corridor Investment Seneviratne 10 14 Prog - Tranche 1 CWTC 42145-033 North-South Road P. 21-Dec- 18-Jul-11 30-Jun- A ARM L2729 Corridor Investment Seneviratne 10 15 Prog - Tranche 2 CWTC 42145-043 North-South Road P. 12-Mar- NYE 30-Jun- A L2993 Corridor Investment Seneviratne 13 17 Prog - Tranche 3 ARM CWUW 42417-023 Sustainable Urban C. Llorens 9-May- 19-Jul-11 30-Jun- B L2752 Development 11 16 Investment Program, Tranche 1 ARM CWUW 45299-001 Water Supply and C. Llorens 12-Apr- 14-Sep- 31-Oct- B L2860 Sanitation Sector 12 12 17 Project-Phase 2 (Additional Financing)

71. Cost estimate of the scheduled trainings in Armenia was prepared and submitted for approval to the ADB on 20 of August, 2013.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

1.8 Project Implementation Team Composition and Detailed Tasks

72. Project implementation team was mobilized in a couple of days after contract signing. No changes have been made to the project implementation team and all persons mentioned in tender proposal are involved in project implementation.

73. The detailed tasks of the experts involved in the trainings in Armenia are the following:

Irakli Kaviladze - Environment Specialist (Team Leader)

- Lead the assignment/work - Finalize the reports for submission to ADB - Oversee the timely implementation of the assignment/work - Conduct on the job training on Environmental Safeguards, Monitoring and Reporting for - Executing Agencies, relevant government agencies, supervision consultants, and contractors

Keti Dgebuadze - Environmental Auditor – International

- Assist in the conduct on the job training on Environmental Safeguards, Monitoring and Reporting for Executing Agencies, relevant government agencies, supervision consultants, and contractors - Prepare training report

1.9 Training Assessment & Evaluation

74. At the end of each training, all participants completed a questionnaire to evaluate the content, and the conduct of the trainings. This was aimed at giving feedback on the relevance of the training, adequacy of the training content in addressing the training needs, competence of the trainers in impacting knowledge and knowledge transfer.

1.10 Execution of the Trainings and Observations

75. The on-job trainings scheduled for the PIU -“German-Armenian Fund”, PIU - Erevan Municipality, PMU - North-South Road Corridor Investment Program and PMU - Armenia Water Sewerage Company were conducted during the period of September, 2013 in the conference room of “Ani Plaza” Hotel located at #19 Sayat Nova Avenue, Yerevan, 1500 Armenia.

1.11 Staff Trained

76. The participants trained were selected based on their functional responsibilities in line with the scope of the training program. Table 5 below shows summary of staff trained of relevant PIUs (“Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor 22

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Investment Program” - State Non-Commercial Organization (PIU), Sustainable Urban Development Investment Program” (PIU), “Women Entrepreneurship Support Project”), Supervising Companies and Construction Contractors.

Table 5: Summary of total number of staff trained in Armenia

# Name Work Place Position Tel/Mob E-mail

I. Armenian Water & Sewerage Company” CJSC (PIU)

1. Alice Savadyan “Armenian Water & Environmental and 091 [email protected] Sewerage Company” Social Impact 204215 CJSC (PIU) Specialist

2. Zara Khachatryan JINJ Ltd. Social Specialist 091 [email protected] 343578

3. Arevik Havsepyan JINJ Ltd. Environmental 091 [email protected] Specialist 539202

4. Mkrtchyan Nazik HGSHN Ltd. Environmental 093 [email protected] Specialist 969908

5. Kristine Sahakyan “SOS MM” Ltd. Environmental 091 [email protected] Specialist 529317

II. “North-South Road Corridor Investment Program” State Non-Commercial Organization (PIU)

1. Armine Yedigaryan “North-South Road Social Safeguard 095 111364 [email protected] Corridor Investment and Environment m Program” State Non- Officer Commercial Organization (PIU) 2. Gevarg Afyan “North-South Road Environmental 095 111428 [email protected] Corridor Investment Specialist Program” State Non- Commercial Organization (PIU) 3. Viktor Bakhtamyan “Corsan-Corviam Environmental 095 111046 vbakhtamyan@isoluxcorsa Construction” S.A. Specialist n.com 4. Sos Yedigeryan “North-South Road Social Relation 095 111045 samirkhanyan@isoluxcorsa Corridor Investment Specialist n.com Program” State Non- 23

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Commercial Organization (PIU) III. Sustainable Urban Development Investment Program” (PIU)

1. Ruzanna Voskanyan “SUDIP” (PIU) Environmental +374940830 ruzanna.voskanyan@yerev Specialist 88 an.am 2. Edita Vardgesyan SUDIP–PMIC Environmental +374936060 [email protected] (Supervising Company) Specialist 17

IV. “Women Entrepreneurship Support Project”

1. Georgi Davtyan “ACBA Credit Agricale Credit Specialist 055909808 [email protected] Bank” 2. Hasmik Yegoryan “ARARAT BANK” Environmental 077 180391 [email protected] Management Specialist 3. Marine Badalyan “ARMECONOMBANK” Senior Specialist, 055191219 [email protected] OJSC Ecologist 4. Arusiak Gasparyan German-Armenian Fund Auditor (091) [email protected] 484536 5. Satenik Ghevondyan German-Armenian Fund Auditor (091) [email protected] 537132 6. Manuk Petrosyan “CARD AgroCredit Senior Loan Officer 093 115599 [email protected] “UCO 7. Nina Avetisyan Armenia Resident Senior Project Assistant (374 10) [email protected] Mission, 546371 ext. Asian Development 102 Bank 8. Gohar Tadevosyan Armenia Resident Resettlement Specialist (374 10) [email protected] Mission, 546371 Asian Development Bank

77. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU representatives, 4 of them being the representatives of the Construction Contractor, 2 of them being the representatives of the Supervising Consulting Company and 3 of them being the representatives of RM of ADB. The rest 6 attendees were the representatives of national banks under the “Women Entrepreneurship Support Project”. 9 months after the trainings, 4 people (21%) having taken the training, did not work in their previous positions, being either retired, or moved to other positions with the same office (in short, they are not concerned with the environmental issues any more).

78. Summary of training photos of the participants in Armenia is provided in Table 6 below.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 6: Summary of Training Photos in Armenia

“Armenian Water & Sewerage Company” CJSC (PIU)

“North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU)

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Sustainable Urban Development Investment Program” (PIU)

“Women Entrepreneurship Support Project”

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

1.12 Main Observations and Conclusions

79. This section highlights the main observations made during the training execution.

80. The involvement of the attendees into the training process was conducted thrice to check their opinion and the level of comprehension of the material, namely: (i) once through inquiry, (ii) once through filling in a questionnaire and (iii) once – through discussion of an example.

(i) Inquiry:

81. As it has been mentioned in the “Training Needs” chapter, ADB identified the three impeding reasons why the quality of meeting the environmental requirements of the bank is lower than needed. Despite the already made conclusions of the bank, the attendees were asked if they see any reasons why the environmental requirements are not met at a needed level by the contractor. The reasons named both by project implementing agencies (PIUs) and consultant companies were mainly identical and are given in the Table 7 below:

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 7: Summary of the results of inquiry in Armenia

# PIUs I. “Armenian Water & Sewerage Company” CJSC - (PIU) 1. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal. As the representatives of the company explained, they had repeatedly appealed to the management explaining that environmental specialist should be included in the tender evaluation commission, but their claim was rejected because facilitation of environmental information separately is not required by the RFP, namely, inclusion of CV of environmental specialist is not mandatory, while the environmental expenses are part of the construction expenses in the budget. Consequently, the management of the company thinks that there are no criteria according to which the tender proposal is evaluated in environmental terms; 3. The construction contractor, as a rule, uses CVs of strong respectively expensive specialists, but after being awarded with tender hires environmental specialists with relatively low qualification; 4. Construction contractor does not employ qualified ecologists. The functions of ecologists are exercised by engineers; 5. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances. II. “North-South Road Corridor Investment Program” - (PIU) 1. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal; 3. The construction contractor, as a rule, uses CVs of strong respectively expensive specialists, but after being awarded with tender hires environmental specialists with relatively low qualification; 4. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances. III. Sustainable Urban Development Investment Program”- (PIU) 1. There is a lack of environmental specialists throught the country, this speciality is less prestigious in the country; 2. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; 3. Environmental specialist is not involved in the review of the tender proposal. 4. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances. IV. “Women Entrepreneurship Support Project” 1. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal; 3. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

82. Among the problems named by the training participants of different PIUs, there were the problems common to all organizations and problems typical to the organization engaged in some or other project. 100% of the attendants explain the low quality of meeting the environmental requirements by two major reasons, in particular: 1. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal; 3. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances. 83. 50 to 75% of the attendants think that:

1. Environmental specialist of PIU or Environmental Unit (EA) is not involved in the preparation of the tender proposal, hence, environmental requirements are not distinctively and clearly determined in the proposal.

84. As Consultat revealed, the main reasons of above-mentioned problems are: poor national environmental legislation and incomplete ADB guidelines. None of the documents give the detailed description of the rights and obligations of the PIU or EA environmental team or environmental specialist within the scope of the project. The detailed information delivered by us at the trainings about the rights and obligations of the PIU environmental specialist for the management of the project implementing organization, is not considered as an obligation, and unless the relevant requirements are fixed under the guidelines of the ADB or Project Administration Manual, they will be always ignored by the management of the organizations.

85. Recommendation: A very good example was given in Georgia within the scope of project: “Urban Services Improvement Investment Program”, Tranche 1 and Tranche 2, implemented by UWSGC, as PAM was updated and all the requirements communicated to the training participants at the trainings were given in details in the newly developed document.

(ii) Filling of the Questionnaires

86. Training attendees were provided with questionnaires on the second day of training. The questionnaire was prepared by ADB based upon the new attitudes, which were explained and discussed during the training course.

87. The attendees had the right to use the provided material for answering the questions. They also could consult with one another, which influenced the result, because except for some cases all of them made the same mistakes. However, it should be noted that majority of the answers were correct.

88. The results of the questionnaires answered by training attendees of “Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor Investment Program” - State 29

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Non-Commercial Organization (PIU), Sustainable Urban Development Investment Program” (PIU) and “Women Entrepreneurship Support Project”, are given in Table 8 (“+” – correct answer; “-“ – wrong answer).

Table 8: Summary of the results of the answers of training participants in Armenia

Name of Participant 1 2 3 4 5 6 7 8 9 10

“Armenian Water & Sewerage Company” CJSC (PIU)

Alice Savadyan + + + + + + + - + -

Zara Khachatryan + + - + + + + + + - Arevik Havsepyan + + - + + + + + + - Mkrtchyan Nazik + + - + + + + + + - Kristine Sahakyan + + - + + + + + + - “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU)

Armine Yedigaryan - + + + + + + - + + Gevarg Afyan - + + - + + + + + + Viktor Bakhtamyan - + + - + + + + + + Sos Yedigeryan + + + - + + + + + + Sustainable Urban Development Investment Program” (PIU)

Ruzanna Voskanyan + + + + + - + + - +

Edita Vardgesyan + + + + + - + + + +

“Women Entrepreneurship Support Project”

Georgi Davtyan + + - + + + + + + - Hasmik Yegoryan + + - + + + + + + - Marine Badalyan + + - + + + + + + - Arusiak Gasparyan + + - + + + + + + - Satenik Ghevondyan + + - + + + + + + - Manuk Petrosyan + + - + + + + + + - Nina Avetisian + + + + + + + + + - Gohar Tadevosian + + + - + + + + + -

89. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. The results of the survey to evaluate the degree of mastering the training materials

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (14 %) made 1 mistake each, 16 of them (86 %) made 2 mistakes each. The best results were fixed with PIU representatives having vast work experience in the field of environmental protection with state organizations or in the private sector.

(iii) Practical Exercises

90. The evaluation of environmental impact risks and implementation of mitigation measures were discussed based on the different practical examples by training participants of “Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU), Sustainable Urban Development Investment Program” (PIU) and “Women Entrepreneurship Support Project”, namely: construction process of one section of the rehabilitation project of “North-South Road Corridor Investment Program”” - by “Armenian Water & Sewerage Company” CJSC (PIU) participants; construction process of one section of the rehabilitation project of “North-South Road Corridor Investment Program” by “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU) participants; One section of the rehabilitation project of “Argavand Highway to Shirak Street Upgrade“ by Urban infrastructure and Sustainable City Development Program” by Sustainable Urban Development Investment Program” (PIU) participants and after the consultation with the group “North-South Road Corridor Investment Project” was taken as a practical example by “Women Entrepreneurship Support Project” participants, thus, as of today none of the projects were not defined to be financed under the mentioned program. The working groups prepared, identified and assessed environmental risks for the mentioned projects and planned respective mitigation measures.

91. The participants of the training having many years of experience in the environmental field were mainly active during the answering process of the training. The mentioned participants were the representatives of PIUs.

92. After the training the training participants were provided with the training effectiveness assessment questionnaire. The summary of answers to the questionnaire is given in Table 9. In addition, the attendees were asked which type of training they would like to attend in the future in the end of the questionnaire.

Table 9: Summary of answers to the questionnaire in Armenia

# Question Answer Comment

Yes No

1 Did this course achieve the education 19 objectives?

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

2 Did the training course meet your expectation? 19

3 Was the classroom environment conductive 19 the learning?

4 Was the instructional method effective? 19

# Question Points Quantity of attendees

5 Please rate (1-5)1 quality of training content 5 18

4 1

6 Please rate quality of information delivery? 5 18

4 1

7 Please rate quality of clarity and usefulness of 5 16 visual? 4 3

8 Please rate quality of opportunity to ask 5 16/ 1 no questions? answer

4 2

9 Please rate quality of opportunity to hands-of 5 15 training? 4 3

3 1

93. The training evaluation questionnaires did not identify the respondents. As Table 9 shows, the absolute majority of the participants are content both, with the developed training module and method of delivery.

94. The training participants listed the topics for trainings they desired to attend in the future (see Table 10):

1 5 point is - excellent, 2 point is – bed.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 10: Summary of list of topics for future trainings in Armenia

# PIUs I. “Armenian Water & Sewerage Company” CJSC (PIU) 1. Training related with the preparation and implementation of Environmental Monitoring Plan (EMP); 2. To discuss our project in more detail and review respective examples; 3. More detailed criteria in risk assessment; 4. Training in ecological audit and monitoring; 5. Facilitation of the same training for the construction contractor environmental expert and training in environmental audit and inspection. II. “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU) 1. Training related with management of construction wastes; 2. ADB guidelines related with classification of construction wastes; 3. ADB environmental guidelines; 4. Preparation of Environmental Impact Assessment (EIA). III. Sustainable Urban Development Investment Program” (PIU) 1. Both participants required to conduct training in Professional Health & Safety. IV. “Women Entrepreneurship Support Project” 1. All of training participants requested to conduct training for them in environmental audit and report writing.

95. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the same view, and the trainings desirable by them were about: (a) Preparation of environmental documents and their implementation; and (b) Description of entire monitoring process.

Main Observations:

96. This section highlights the main observations made during the trainings execution for PIUs in Armenia. The summary of following observations is listed below (see Table 11).

Table 11: Summary of main observations in Armenia

# PIUs I. “Armenian Water & Sewerage Company” CJSC (PIU) 1. Environmental specialist of fairly good qualification is employed in PIU; 2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working 33

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

experience in respective state or private entities; 3. The construction contractor does not have an environmental specialist as a member of staff. II. “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU) 1. Special division is established within the Project Implementing Unit (PIU) comprising two professional environmental specialists with a good experience and a resettlement specialist; 2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working experience in respective state or private entities; 3. Moreover, the team of the construction contractor employs two environmental specialists with satisfactory qualification and experience; 4. Only the local environmental specialists of the consulting company did not attend the training from the environmental team involved in the implementation of the mentioned project. As we found out the specialist will attend trainings to be held on September 16- 17 proceeding from the fact that the specialist also participates in Sustainable Urban Development Investment Program. III. Sustainable Urban Development Investment Program” (PIU) 1. Environmental specialists of fairly good qualification is employed in Supervising Company as well as in PIU; 2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working experience in respective state or private entities; IV. “Women Entrepreneurship Support Project” 1. Most of the training participants did not have experience in preparation and implementation of environmental documentation. Representatives of German-Armenian Fund as well as bank sector were mainly from procurement and audit devisions with relevant qualification; 2. It should be mentioned that projects planned to be financed under the above-mentioned program have less environmental risks; 3. It is desirable to hire one environmental specialist at German-Armenian Fund.

1.13 Main Findings and Recommendations

97. Based on the conducted trainings the Consultant revealed the following general findings: I. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU representatives, 4 of them being the representatives of the Construction Contractor, 2 of them being the representatives of the Supervising Consulting Company and 3 of them being the representatives of RM of ADB. The rest 6 attendees were the representatives of national banks under the “Women Entrepreneurship Support Project”. 9 months after the trainings, 4 people (21%) having taken the training, did not work in their previous 34

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

positions, being either retired, or moved to other positions with the same office (in short, they are not concerned with the environmental issues any more); II. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. The results of the survey to evaluate the degree of mastering the training materials were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (14 %) made 1 mistake each, 16 of them (86 %). made 2 mistakes each; III. The training evaluation questionnaires did not identify the respondents. As Table 9 shows, the absolute majority of the participants are content both, with the developed training module and method of delivery;

IV. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the same view, and the trainings desirable by them were about: (a) Preparation of environmental documents and their implementation; and (b) Description of entire monitoring process.

98. Based on the findings observed during the trainings the Consultant elaborated the following Recommendations:

For Asian Development Bank: I. The new requirements developed within the scope of the training are to be shown in the documents developed by the ADB within the scope of the project (Loan Agreement, FAM or PAM), or such requirements should be added to Safeguard Policy Statement developed by the ADB in 2009 as an annex.

For Project Implementation Units (PIUs):

I. The environmental specialists of all the companies engaged in all new projects shall be given the training developed by the ADB. The said trainings are to be attended by the international environmental specialists as well engaged in the implementation of the project. The first part of the trainings should be also attended by the employees of the Procurement Department;

II. All new environmental specialists engaged in the implementation of the project are to be given training “Environmental Safeguards Requirements” under the projects financed by ADB within the limits of the RETA Project.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

II. ENVIRONMENTAL AUDITS CONDUCTED IN ARMENIA

1. CWPF 45230-001 WOMEN ENTERPRENEURSHIP SUPPORT PROJECT

1.1 Brief Project Description (CWPF - 45230-001)

99. The proposed Women’s Entrepreneurship Support Sector Development Program is a sector development program which comprises an integrated approach to enable women entrepreneurs and micro, small and medium-sized enterprises (MSMEs) in Armenia to play a greater role in economic development. The program has two components: (i) a policy-based loan to help fund budget allocations to strengthen the business environment and the Small and Medium Entrepreneurship Development National Center (SME DNC) and its support for women entrepreneurs and MSMEs; and (ii) a financial intermediation loan to enable participating financial institutions (PFIs) to provide medium-term local currency loans to MSMEs, of which at least 50% are women’s MSMEs. The program is supported by capacity development TA to improve the entrepreneurial capacity of women and to increase the capacity of the SME DNC, the project management unit of the German-Armenian Fund (PMU GAF) and PFIs to provide support for women entrepreneurship. The program period is 2013-2017. The program’s impact will be women benefitting from increased economic opportunities. The program’s outcome will be an improved enabling environment for women entrepreneurs.

100. The policy-based loan will have four outputs: (i) improved institutional framework supports women entrepreneurs and MSMEs, (ii) improved capacity of women entrepreneurs and MSMEs, (iii) improved access to finance by women entrepreneurs and MSMEs, and (iv) improved business environment supports MSMEs.

1.2 Project Status

101. At the given stage, the project implementation has not started yet. There is a Loan Agreement between the Asian Development Bank and Republic of Armenia concluded within the scope of the project. In addition, the ADB has concluded individual loan agreements with all national banks engaged in the project. There is a document titled “Project Administration Manual” (PAM) developed within the scope of the project. In addition, the document titled “Recommendations of President” was developed by the ADB within the scope of the project.

1.3 Institutional Aspects on Environmental Safeguards Implementation

102. On July 27, 1998, the Governments of the Federal Republic of Germany and the Republic of Armenia executed an Agreement on Financial Co-operation. On this basis, KfW and the Central Bank of Armenia (CBA) entered into a long-term loan agreement for a loan in the amount of DM 6 million on September 25, 1998. Under the Agreement an apex fund was created: German-Armenian Fund (GAF). Eight months after the inter-governmental agreement was signed, in March 1999 the project began its operations.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

103. The main objective of the activity of Project Manamgement Unit - GAF is the implementation and management of the loan programs of the "German-Armenian Fund" in accordance with the loan agreements and the separate agreements forming an integral part of them concluded between the Central Bank of the Republic of Armenia and the KfW Development Bank (KfW Bank) belonging to the KfW-Bankengruppe the promotional bank of the Federal Republic of Germany within the framework of the intergovernmental agreements between the governments of the Republic of Armenia and the Federal Republic of Germany.

104. GAF-MSME program has been implemented since 1999, GAF-RE and GAF-HF were launched in 2006, and GAF-CGF was launched by the GAF in 2007 and closed in 2010. During the last few months of 2008 the RA Government and the World Bank joined the PMU GAF as new donor organizations with new loan programs. The program: "Support to Small and Medium Enterprises" financed by the RA Government was launched in December 2008, GAF- WB/AFSME financed by the World Bank and GAF-RF financed by the RA Government have been implemented since 2009. In 2012 GAF is planning to initiate new "Agricultural Finance" Program under the funding of KfW and RA Government.

105. The project implementing organizations are: Ministry of Finance, Ministry of Economy and Central Bank of Armenia through the PIU German-Armenian Fund (GAF).

106. The responsibilities of the Ministry of Finance of Armenia are the following: Act as executing agency for the program; Provide overall policy direction and guidance; Facilitate cooperation and coordination among the government agencies involved in the program; Responsible for executing the Guarantee Agreement between Armenia and ADB for the FIL;

107. The responsibilities of the Ministry of Economy are the following: Act as implementing agency for the policy-based loan and technical assistance grant; Implement and monitor timely achievement of the conditions in the policy-based loan’s policy matrix; Submit annual progress reports on achievement of performance targets and indicators in the program design and monitoring framework; Prepare a program completion report for the policy- based loan and submit to ADB within 6 months after program closing date;

108. The responsibilities of the German-Armenian Fund are the following: Act as the borrower and implementing agency under the FIL; Execute subsidiary loan agreements with PFIs; The PMU GAF under the CBA shall: Act as oversight body for overall implementation and monitoring of the FIL; Facilitate coordination between ADB and PFIs; Monitor compliance of the PFIs to the subsidiary loan agreement and the project agreement conditions, including compliance to the sub borrower selection criteria and sub loan features; Conduct initial screening of sub loan applications that are above the sub loan free limit; Manage the project imprest account and ensure timely transfer of the FIL proceeds to the PFIs; Submit to ADB annual audited financial statements that include an audit management letter and an audit opinion on the use of loan proceeds, and on the imprest fund and SOE procedures; Submit to ADB consolidated quarterly progress report using the format in Attachment 1 within 30 days from the end of each quarter;

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Prepare a project completion report for the FIL and submit to ADB within 6 months after program closing date.

109. The following national banks will be engaged in the first phase of the project implementation: ACBA-Credit Agricole Bank, CARD AgroCredit UCO, Araratbank, Armeconombank. The list of the national banks engaged in the second phase of the project will be specified at the project implementation stage (see Figure 1).

Figure 1: Program Organization Structure

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

1.4 Project Document Analysis

A) Loan Agreement Between ABD and Republic of Armenia

110. Loan Agreement dated 25 January 2013 between Republic of Armenia ("Borrower") and Asian Development Bank ("ADB") says nothing about the obligation to meet the environmental requirements. As for the requirement for monitoring at the stage of the project implementation, the reference in the document states as follows: „The Borrower shall carry out review of the Program with the participation of ADB in accordance with the review procedures described in the Project Administration Manual for the Program“ (Paragraph 6 - “Monitoring and Review” pp- 16).

111. Though, it should be mentioned that PAM developed within the scope of the project gives a detailed description of the environmental obligations to be performed by the organizations engaged in the project.

B) Loan Agreement between ADB and Central Bank of the Republic of Armenia

112. Loan Agreement dated 25 Jenuary 2013 between Central Bank of the Republic of Armenia ("Borrower") and Asian Development Bank ("ADB"). The obligation to meet the environmental requirements is given in schedule 3 - “Execution of Project Financial Matters”, paragraph 10 - “Environment”, according which: „The Borrower shall cause the PFIs to ensure that the preparation, design, construction, implementation, operation and decommissioning of each Qualified Subproject comply with (a) all applicable laws and regulations of the Guarantor relating to environment, health, and safety; (b) the ESMS; and (c) all measures and requirements set forth in the respective IEE and EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring Report“.

113. The said agreement also envisages the monitoring and reporting obligations of Participating Financial Institutions (PFI).

C) Loan Agreement between ADB and ACBA-Credit-Agricol Bank

114. Loan Agreement dated 25 January 2013 between ACBA-Credit-Agricol Bank ("Borrower") and Asian Development Bank ("ADB"). Neither does the developed document state about the obligation to meet the environmental requirements, but the main body of the document envisages the following obligation only: „ACBA-Credit-Agricol Bank shall promptly and effectively exercise its rights in relation to each Qualified Subproject in accordance with the standards of a prudent lender and in such manner as to protect the interests of the Borrower, ACBA-Credit-Agricol Bank and ADB (Section 2.05) “.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

D) Loan Agreement between ADB and Ararat Bank

115. Loan Agreement dated 25 January 2013 between Ararat bank ("Borrower") and Asian Development Bank ("ADB"). Neither does the developed document state about the obligation to meet the environmental requirements, but the main body of the document envisages the following obligation only: „Ararat bank shall promptly and effectively exercise its rights in relation to each Qualified Subproject in accordance with the standards of a prudent lender and in such manner as to protect the interests of the Borrower, ACBA-Credit-Agricol Bank and ADB (Section 2.05) “.

E) Project Administration Manual (PAM)

116. In October of 2013, the Project Administration Manual (PAM) was developed within the scope of the „Women Entrepreneurship Support Project“. The necessity for meeting the requirements envisaged by the said document is given by the Loan Agreement. The necessity for meeting the requirements of the ADB SPS of 2009 for the companies engaged in the project is given in the IX Chapter of the said document. The document also envisages the criteria used in the financing process of the projects. The projects belonging to Category A in an environmental respect, according to the environmental classification developed by the ADB, will not be financed.

117. Next to the necessity for meeting the requirements of the national environmental legislation, the document fixes the necessity for meeting the requirements of the ADB Safeguard Policy Statement of 2009: „Safeguards due diligence has been carried out according to ADB SPS requirements for FIs. The assessed PFIs selected shall have staff capacity and established ESMSs. PMU GAF and the PFIs should ensure that the needed improvement in the safeguards categorization, screening and review procedures, social inclusion and performance monitoring and reporting to process category B projects (for environmental safeguards) are incorporated into the PFI’s ESMS” (Article IX “Safeguards”, Paragraph 6).

118. The document is enclosed by „Environmental and Social Management System“guidelines as annex (Annex IV). The given Annex provides a detailed description of a) Environmental and Social Management Policy and Applicable Requirements (b) Environmental and Social Management Procedures (d) Organizational Responsibilities, Resources, and Capacity developed by the ADB.

F) Report and Recommendation of the President to the Board of Directors

119. The said document within the scope of the project was developed in October of 2012. The document has a special chapter dedicated to the environmental issues, according which: “The policy-based loan will not trigger safeguard policies and is categorized C for environment, involuntary resettlement, and indigenous peoples. The FIL is categorized as financial intermediation for environment and indigenous peoples, and financial intermediation (treated as

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

C) with respect to involuntary resettlement. Subprojects categorized A for environment and indigenous peoples or having involuntary resettlement impacts will not be eligible for financing under this program. Activities included in ADB’s Prohibited Investment Activities List are excluded. Each PFI will implement an ESMS acceptable to ADB to ensure proposals for subprojects are screened for environmental and social impacts and (if applicable) mitigating measures are in place. Each PFI is required to designate at least one staff member to be responsible for implementation of its ESMS” (IV.Due Diligence, asticle D. Safeguards).

1.5 Meeting with the German - Armenian Fund (GAF)

120. The meeting at the office of German- Armenian Fund with Head of PFIs Audit Division - David Mikayelian (Figures 2, 3) was held on April 27, 2014.

Figures 2 and 3: Meeting at GAF office

121. As it became clear during the meeting, the implementation of the said project has not started yet, but the preparatory period has started. There are 4 national banks of Armenia engaged in the project with relevant agreements concluded with all of them.

122. There is a PIU established within the scope of the project, and no environmental specialist is hired yet. At this stage, Mr. David Mikayelian, Head of the Audit Service, performs the duties of an environmental specialist.

123. As for the national banks engaged in the project, they have the specialists with relevant qualification on staff.

1.6 Main Findings and Recommendations

124. Based on the projects documents review the Consultant (Audit Team) revealed the following general findings:

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

I. The project implementation has not started yet, but the preparatory works are in progress;

II. The training developed by the ADB within the scope of RETA 7548 was taken by 2 employees of German-Armenian Fund. The training was also attended by environmental specialists of all four National Banks;

III. The German-Armenian Fund (GAF), as the project implementer, has vast experience in implementing similar projects. Under the financing of various international financial institutions and state budget, the GAF has implemented more than one similar project: (a) "Support to small and medium enterprises" (GAF-MSME-Government) program (financed by the RA Government) (b) "Access to finance for small and medium enterprises" (GAF-WB/AFSME) program (financed by the World Bank) (c) "Economy stabilization lending" (GAF-RF) program (financed by the RA Government);

IV. Within the scope of the said project, the projects belonging to Category A in an environmental respect will not be financed;

V. The project implementing body has no environmental specialist on staff, and such specialist’s rights are enjoyed and obligations are performed by the head of the audit service;

VI. The Project Administration Manual (PAM) developed within the scope of the project gives quite a detailed description of all environmental requirements and mechanisms to meet the requirements to be met by the organizations engaged in the project.

125. Based on the above-mentioned findings the Consultant made the following recommendations:

I. The Project Implementing Organization - GAF has to employ an environmental specialist with the relevant qualification;

II. The environmental specialist of PIU shall be engaged in all phases of the project development, including the development of bidding documents, evaluation of the bidding proposal, monitoring and audit of the course of the project, as well as in the process of the Final Environmental Monitoring Report;

III. The bidding documents and contracts particularly, should repeat the environmental requirements and ways to meet them envisaged by the PAM developed within the scope of the project.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

2. CWTC 42417-023: SUSTAINABLE URBAN DEVEOPMENT INVESTMENT PROGRAM, PROJECT 1, TENDER 1 - CONSRUCTION/REHABILITATION OF ARSHAKUYATS STREET

2.1 Brief Information on the Project

126. The Arshakunyats Avenue road project under the Sustainable Urban Development Investment Program (SUDIP) is financed through the multitranche financing facility (MFF) of the Asian Development Bank (ADB). The investment program will be implemented over a period of 9 Years.

127. The Project falls within component A and has been divided into two separate construction tenders: Tender 1, the widening of Arshakunyats street on approximately 1.3km; Tender 2, the construction of a link from Argavand Highway to Shirak Street, the construction of New Shirak Street, and the widening of Artashat Highway.The Arshakunyats Avenue project site is located in Yerevan’s Shengavit district, approximately 6km south-west of the City centre of Armenia’s capital (refer to Site location plan on the following page). Arshakunyats Avenue connects with Artashat Highway via the new Shirak Street. The 1.3 km length of Arshakunyats Avenue connects with Artashat Highway (M-2) to New Shirak Street (Figure 4).

Figure 4: Location of Arshakunyats Avenue, Tender 1

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

128. The Works comprises the widening of Arshakunyats Avenue over approximately 1.3 km long, from dual 2 lanes to dual 3 or 4 lane carriageways with central reservation. The Works include (but is not limited to) the following: Diversion of exiting utilities including water supply, electricity and trolley line power supply; Site clearance and demolition of existing structures within the proposed expropriation limits; Demolition and reconstruction of existing carriageway; The construction of a new carriageway to cater for traffic in one direction; Associated drainage works; Ancillary works including lighting, signs and markings; Demolition and reconstruction of boundary wall and checkpoint to Department of Defense institute; and Temporary Works including traffic management works and maintenance of access. Construction will be undertaken over a period of 10 months.

2.2 Institutional Aspects on Environmental Safeguards Implementation

129. Yerevan Municipality is implementing the Asian Development Bank (ADB) funded project - „Sustainable Urban Development Investment Program“. Within the IA, the Yerevan Municipality Project Implementation Unit (YMPIU) will be responsible for day-to-day management of this project. It is headed by a full-time Project Director. The YMPIU includes the following specialists: Institutional, Technical, Financial, Monitoring and Evaluation, Legal/Contract administration, Procurement, Resettlement, Environment, Communication and public relations, assistant/translator. Responsibilities of the YMPIU include: preparing and updating procurement plan; tendering, evaluating bids and awarding works; contracting administration; managing the DESC; supervision; quality control; obtaining copies of the approvals and permits from relevant agencies; inspectingthe Contractor’s implementation of mitigation measures as specified in the EMP; prepareing and submiting semi-annual environmental reports regularly to the EA for ADB; responding to emergencies and notifying the relevant authorities within reasonable times.

130. A Management Board of the Sustainable Urban Development Investment Program (SUDIP) is chaired by the Prime Minister. It is comprised of the Minister of Economy, Minister of Finance, Minister of Territorial Administration, Minister of Justice, Minister of Transport and Communications, Mayor of Yerevan, and representatives of the Central Bank, the Real Estate Cadastre Agency, and Yerevan Municipality PIU. The Management Board has been set up to follow up the implementation of the Program. The Management Board is meeting every month.

131. The Executing Agency (EA) of the SUDIP is the Ministry of Economy (MOE). The EA will oversee the implementation of the Program and the disbursement of the loan.

132. Implementing Agency (IA) for the services is the Municipality of Yerevan (The Client) which will be responsible for the overall technical supervision and execution of the Projects. The Municipality also has the responsibility for waste management services that include organization of waste collection, assigning dump sites for construction waste.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

133. Detailed Engineering and Construction Supervision Consultant’s (DESC) key responsibilities include: update or prepare the final Environmental Impact Assessment (EIA) or Initial Environment Examination (IEE) as applicable), along with the relevant Environment Management and Monitoring Plan (EMP), and other documents as required; submit the updated EIA, EMP and EARF for the MOE, MTA, or YM and ADB’s review and approval; conduct the necessary consultations in compliance with the Environment Assessment and Review Framework (EARF) approved in 2010 between ADB and the Government of Armenia; and apply for and get a positive environmental expertise conclusion from the Environmental Expertise of the RA Ministry of Nature Protection for the EIA/IEE report and EMP as prescribed by the Armenian legislation (including, agreement on route with the RA Ministry of Culture, etc.). During construction the key tasks of the DESC will include also supervision and monitoring of construction activities of the project including the implementation of the Site Specific EMP.

134. The Contractors’ key responsibilities are listed below but are not limited to the following: update the EMP as a working construction document based on the EIA and the EMP report, update the EMP during the construction when needed and obtain the DESC approval of the updated part; hire the services of an Environment Specialist as defined in the tender document; implement the EMP as a special part of the contract, particular conditions; coordinate with the DESC for the implementation of the various components of the EMP including monitoring; in cases of emergencies and accidents or extraordinary situations notify the DESC and the relevant emergency authorities; obtain permits and approvals from relevant agencies and provides copies to DESC; and report on EMP.

Figure 5: Institutional Chart of the Environmental Safeguards Arrangement

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

2.3 Project Document Analysis

A) Loan Agreement, Facility Administration Manual (FAM)

135. According to Schedule 5 - “Execution of Project and Operation of Project Facilities; Financial Matters”, clause 2 - “Environment” of the Loan Agreement # 2752-ARM (19 May, 2011) between Republic of Armenia ("Borrower") and Asian Development Bank ("ADB"), „…The Borrower shall ensure that the preparation, design, construction, implementation, operation and decommissioning of each Subproject comply with (a) all applicable laws and regulations of the Borrower relating to environment, health, and safety; (b) the Environmental Safeguards; (c) the EARF; and (d) all measures and requirements set forth in the respective IEE and EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring Report“.

137. The same document includes those environmental requirements that are necessary to be included at the preparation of the bids (Schedule 5: “Safeguards – Related Provisions in Bidding Documents and Works Contracts”, pp-17). The same annex (Schedule 5: “Safeguards Monitoring and Reporting”, pp -18) includes all the requirements related to the process of the monitoring and reporting on the above-mentioned project, these are: (a) “Submit semi-annual Safeguards Monitoring Reports to ADB and disclose relevant information from such reports to affected persons promptly upon submission.

138. On May 19, 2011 a contract was concluded between the ADB and Yerevan Municipality. According to Section 2.04 of the contract: „Yerevan shall carry out the Project in accordance with plans, design standards, specifications, work schedules and construction methods acceptable to ADB“.

139. In March of 2011, the Asian Development Bank developed and approved Facility Administration Manual (FAM). The mentioned document (Clause VII “Safeguards”, article A – “Environment”) sets forth the requirements that are mandatory at the project implementation stage, these requirements are: “Tranche 1 classified as environmental category B under ADB's Safeguard Policy Statement, 2009. The environmental assessment and review and framework (EARF) is detailed in RRP Linked document 11 and will be updated before every PFR signing. The initial environmental examinations (IEE) are detailed in RRP Linked document 10 and will be updated every 6 months if necessary. The Environmental Management and Monitoring Plan will be updated during detailed engineering design and incorporated in bidding documents and civil works contracts“.

140. The Loan Agreement and FAM also gives the requirements for conducting permanent environmental audits and for regular reporting. In whole the environmental requirements in Loan Agreement and FAM are reflected satisfactorily.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

B) Bidding Documents

B.1) Supervision Consultant

141. The tender to select the Consulting Firms for Detailed Engineering, Management and Supervision of The Construction of Two Road Links of The Yerevan Western Ring Road announced on 23 January 2012.

142. The obligations on the environmental safeguards implementation are included in the bidding documents in Section 5 – “Terms of Reference”, clause C - “Scope of Work and Detailed Terms of Reference”, sub clause f - „Preparation of Environment Documents” which set forth the requirements that are mandatory for the Supervision Consultant at the project implementation stage, these requirements are: „The Consultant will review the preliminary design prepared and will update the environmental assessment in accordance with ADB’s SPS 2009 and the Environment Assessment Review Framework (EARF) agreed between the Government of Armenia and ADB. The key responsibilities of the Consultant will be: (i) update or prepare the final IEE or Environmental Impact Assessment (EIA) as applicable, along with the relevant EMP, and other documents as required, (ii) submit the updated IEE, EIA, EMP and EARF for the YM, YDPIU and PMIC’s review and approval, (iii) conduct with the PMIC the necessary consultations in compliance with the Environment Assessment and Review Framework (EARF) approved in 2010 between ADB and the Government of Armenia; (iv) assist the PMIC and YM in getting required approvals for the IEE or EIA and EMP as prescribed by the Armenian legislation (v) assist the PMIC in the implementation of the Site Specific EMP.

143. The mentioned document also includes (Section 5 – Terms of Reference, clause C “Scope of Work and Detailed Terms of Reference” sub clause f- „Staffing Requirements“) requirement related to the involvement of international and local experts in the project. Under the first tranche, at the project construction stage, according to the requirement, one international environmental specialist should be involved in the supervising consulting company for 1 month, as well as a local environmental specialist – for 4 months, and under the second tranche, respectively, international environmental specialist should be involved for 3 months and a local specialist – for 4 months.

B.2) Construction Contractor

144. The tender to select the Construction Contractor (2752 - ARM (MFF)) of Sustainable Urban Development Investment Program, Tranche 1 - announced on 28 September 2013. An EPM documents were attached to the tender documentation as an annex 1. The obligation of the contractor to meet the requirements of the document as well as contractor’s reporting responsibility are given in part 8 of the tender documentation - „Specific Provisions“, stating: “The Contractor shall comply with (i) all applicable environmental laws and regulations of the Republic of Armenia; (ii) Asian Development Bank’s environmental safeguards; (iii) all measures and requirements relevant to the Contractor set forth in the EIA and EMP. The EMP 47

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

updated by Contractor and (iv) any corrective or preventative actions set out in the safeguards monitoring reports that the Employer will prepare from time to time to monitor the implementation of and compliance with environmental management plan, resettlement plan, and indigenous people plan (as applicable). The Contractor shall allocate the budget required to ensure such measures, requirements and actions“.

C) Bidding Proposals

C.1) Consultant/Supervision Company – EGIS International

145. The technical part of the bid submitted by the consulting company has the entire chapter (Clause 4B.2 5) dedicated to the obligations about the fulfillment of environmental requirements. In addition to other commitments the consulting company has taken the following key obligations in the environmental field, in particular: “review and update the existing IEE report in accordance with ADB SPS (2009); carry out field visits in order to gain first-hand knowledge of existing environmental conditions; estimate the costs of the proposed environmental mitigation measures and of the implementation of the EMP’s for Task 1 and Task 3; prepare a detailed EMP and monitor the implementation of mitigation measures and the impact of the proposed works during construction; update the archeological statues carried out for preparation of the project”.

146. The presented proposal includes CVs of international as well as local environmental specialists, as well as the schedule of involvement of the mentioned specialists in the project.

D) Evaluation of Bids

147. Project Implementing Unit (PIU) environmental specialist is not involved in the bids evaluation process. There is no official requirement to have an environmental specialist in the bid evaluation committee. In spite of this, under the mentioned project an environmental specialist was included in the bid evaluation committee. The mentioned specialist had been invited from American University of Armenia. No special criteria had been developed for the evaluation of bids in terms of environmental issues.

148. Recommendation:

149. For ADB: In one of the documents developed under the project (Loan Agreement, PAM/FAM) the requirement about the involvement of environmental specialist in the bid evaluation committee shall be stipulated.

150. For PIU: The following criteria developed by ADB are desirable to use for the evaluation of environmental aspects of the tender bid (for example: Does the bid address the findings of the EIA; Does the bidder have sufficient resources to implement the EMP; Is the bidder qualified; Is the bidder proactively addressing environmental issues, including waste management; Does the bidder have a past history of significant environmental compliance/or noncompliance).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

E) Contracts

E.1) Contract with EGIS International (Consulting Company)

151. The contract for consultancy services was concluded with EGIS International on September 4, 2012. The activities to be accomplished by the contractor are given in Appendix A. The contract contains all those requirements that were included in the Bidding Document.

152. Furthermore, the requirement about having international and local environmental specialists and the schedule of their involvement has been fully transferred from the bidding documents into the contract.

E.2) Contract with Construction Contractor - Vahagn and Samvel LLC

153. Agreement with local Company Vahagn and Samvel LLC“was concluded on December 10, 2013. The necessity of the fulfillment of environmental requirements is stipulated in the contract part: „Particular Conditions of Contract“, Clouse F - “Safeguard Provisions”, stating that: “The Contractor shall comply with (i) all applicable environmental laws and regulations of the Republic of Armenia; (ii) Asian Development Bank’s environmental safeguards; (iii) all measures and requirements relevant to the Contractor set forth in the EIA, EMP, the EMP updated by Contractor and the resettlement plan and (iv) any corrective or preventative actions set out in the safeguards monitoring reports that the Employer will prepare from time to time to monitor the implementation of and compliance with EMP, RAP, and indigenous people plan (as applicable). The Contractor shall allocate the budget required to ensure that such measures, requirements and actions”.

154. The contract has the following annexes: Appendix 1: Ref DTO 101144 – 06 Environmental Impact Assessment with Annex 5 - Environmental Management Plan.

155. Recommendation: The contract with the construction company was concluded in December, 2013. By now the training developed by the ADB under RETA: 7548 has already been held. Training materials contained quite detailed overview of all those requirements inclusion of which in the construction company contract would better underline the necessity of fulfillment of all environmental requirements. The contract also does not envisage the determination of the levels of inconsistency by the ADB in case of the failure to fulfill environmental requirements and the imposition of a fine per each level.

F) Preparation of Pre-Construction Documents 156. According to the IEE prepared under the project (IEE, Clouse - I.1.Mitigation): “During the Mobilization period, the Contractor submits for approval by the DESC the updated EMP that will include: Occupational Health and Safety Plan; Public Consultation and Communications Plan; Vegetation Clearing Plan; Utilities Protection and Relocation Plan; Environmental Protection Plan; Construction Work Camps Plan; Site Management Plan (Quarry and borrow pit, dumping

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

sites, concrete batching and asphalt plants); Traffic and Access Management Plan; Emergency Response Plan; Waste and Material Disposal Plan; Site Reinstatement, Landscaping, and Revegetation Plan”.

157. The construction contractor has developed EMP and submitted to the PIU for approval. The presented document contains all environmental management plans required under the IEE.

158. Recommendation: In fact, the EMP has not been updated, the construction contractor has simply copied and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at the stage of the design of the mentioned document, when a detailed project design has not been developed. EMP is updated prior to the commencement of construction, when project detailed design is in place. Respectively, a contractor has to also elaborate specific activities to meet environmental requirements. For example, the following mitigation measure: „Obtain all the permits for waste disposal and dispose only in permitted sites“, that is acceptable for an IEE as a planned mitigation activity. EMP prepared by construction contractor under the project should not have this requirement copied as a requirement; rather, the document shall contain the outcome of the fulfillment of this requirement. Hence, the EMP should contain a permit issued by a relevant agency about the disposal of waste, as well as the description as to how, when and who will collect, transport and dispose the waste.

159. During the audit of a construction site Construction Contractor, based on the Consultant’s request, has provided the contract with the City Municipality about the disposal of waste. Further, it has verbally described to the Consultant the way and the frequency of the collection and removal of the mentioned waste from the construction site. Effectively, the construction contractor had stipulated everything that had to be included in the EMP for this concrete case. It was only the mentioned documentation and procedure that were not included in the EMP document.

G) Monitoring, Reporting and Trainings

160. The environmental monitoring and reporting of the construction contractor as well as of PIU is done within the terms specified by the agreement.

161. Investigations of baseline quality have been carried out during the environmental assessment study, during April 2012, in accordance with the Contract in four points of two sections along the Arshakunyats Street, in Yerevan, measurements of noise and vibration levels were taken. The measurements have been taken by Sergey Karapetyan, Head of Sanitary- Hygienic Department of “Disease Control & Prevention Center” CJSC, M. of HC, RA and by Moses Yeritsyan, an engineer of the same department. In taking measurements first-class OKTAVA 110A MAXIMA sound level meter produced in 2009 was used. Every year including 12.11.2012 it was calibrated by the National Institute of Metrology of Ministry of Economics, RA, which has been entitled to carry out activities of the kind.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

162. At the construction stage Construction Contractor’s environmental specialist is performing the inspection of the construction site on a weekly basis. Relevant checklist has been developed and the records are entered. The records are stored at the construction site.

163. The environmental specialist of the Roads Department also undertakes monthly monitoring, inter alia studying the degree of correction of the facts of non-compliance.

164. According to the requirement Construction Company should „Provide community leaders and local newspapers with notices on project progress and anticipated issues“ (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-7).

165. Recommendation: Monthly progress reports and quarterly environmental reports should be provided to all stakeholders, including local media.

166. As has been mentioned, the project implementation has commenced recently, respectively, quarterly environmental reports have not been presented yet. As for the bi-annual reports two such reports have been prepared under the project and sent to the ADB. Both reports are approved.

167. PIU and PMIC ESs participated in the ADB training session held on 16 - 17 September 2013, under the Regional Technical Assistance RETA: “Improving the Implementation of Environmental Safeguards in Central and West Asia”. The aim of the training was to provide knowledge of ADB environmental safeguard requirements during project implementation strengthen the environmental management and monitoring capability of PIU and PMIC. Unfortunately, the construction contractor had not been identified as of the day of the training and their representative did not attend the mentioned training. Further, consulting company environmental specialist who attended the training is no longer involved in the implementation of the mentioned project.

168. Recommendation: All environmental specialists engaged in the project shall take the training developed within the scope of RETA project.

169. A number of environmental trainings are required according to the IEE document developed as part of the project, these trainings are: (a) training to all staff on Health, Safety and Environment (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-3); (b) training program on waste management for Contractor’s Personnel (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-18); (c) Job-specific training for workers with responsibility for activities that could have adverse impacts on the environment or humans (e.g., PAH) (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-5); (d) Health risks and prevention.

170. Recommendation: It is not mentioned in IEE document when the above-mentioned trainings should be conducted for he employees of the Consruction Contractor. Despite of this, it

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

is desirable to conduct all the mentioned trainings from the beginning of the project, duration of which is 10 months.

2.4 Project Site Audit

171. Site visits were organized on 29.04.2013. A meeting with the environmental specialists and technical staff was organized (Figures 6, 7). The environmental audit was conducted by using the questionnaire developed by the Asian Development Bank (see Appendix 1).

Figures 6 and 7: Meeting with PIU

172. The environmental plans developed and relevant records drafted by the contractor were considered and evaluated during the meeting. These were the documents the construction contractor was responsible to develop under the agreement.

A) Construction Site

173. As has been mentioned above the project has been launched recently and at currently street expansion works in the first section of the project territory are underway; the expansion works include the removal of the existing asphalt cover, replacement of old infrastructure (mainly old underground systems) and the dismantlement of the existing walls and building new walls in order to expand the street.

174. The safety requirements are fully met at the construction site, the construction site is enclosed adequately and a person is standing on each side regulating the movement of the vehicles entering and exiting the site (Figures 8, 9, 10 and 11).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 8 and 9: The man regulating the traffic

Figure 10: The man regulating the traffic Figure 11: The warning signs

175. At one location a secondary road links to the project site, while at another place the project blocks the enterprise entrance gate (Figures 12, 13). According to the developed project alternative options to solve the mentioned problem have not been identified. Respectively, currently both the enterprise entrance and the section linking with the secondary road are open. Motor vehicles that use the above-mentioned secondary road or are entering the enterprise has to cross the construction site, which is associated with additional risks.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figure 12: The entry of the secondary road Figure 13: The entry to the enterprise

176. As can be seen from the pictures the warning signs have not been installed in the mentioned sections. The problem is quite severe in terms of safety. As can be seen from Figure 13 pedestrian employees of the enterprise use the mentioned entrance as well, and they have to pass the construction site involuntarily.

177. Recommendation: Several alternative recommendations can be considered:

1. Identify or organize temporary access road to the factory that will enable the transport and especially the employees to enter the factory territory without crossing the construction site; 2. The construction company to identify an individual who will regulate the mentioned problem and warn not only the vehicles and employees that appear on the construction site about the expected threat but will also halt the operation of construction equipment in case of the entry of every vehicle or individual to the construction site. 3. It is desirable that the factory employees undergo special training in safety issues.

178. As mentioned, with the purpose of expanding the road the existing walls were being dismantled and the new walls are built. Although the walls are not very high construction workers still had to use the scaffolds. The construction workers use self-made scaffolds that are not acceptable in terms of safety or stability.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figure 14: Self-made scaffolds

179. Recommendation: Although the height on which the workers are working is not considered as the working on height according to international standards (height of 2 meters and below) the construction contractor has to use more solid and safe scaffolds.

B) Dust

180. It was not dry and sunny weather on the day of the audit; respectively, the formation of dust was not observed at the time of the movement of construction equipment. The company had implemented a number of activities for the reduction of dust. Specifically, the sections of the construction site where earth works had been planned had a cellophane protective wall around them that will significantly reduce the area of the spread of emerged dust (Figures 15 and 16).

Figures 15 and 16: Walls protecting against dust around the construction sites.

181. Furthermore, as they have explained to the Consultant on dry and hot weather special equipment will work on the site. This equipment will water the construction site with certain frequency based on necessity. As can be seen from the pictures the construction site borders 55

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

one of the central roads of the city, respectively, there is a high risk that the soil reaches the city area through the tires of the vehicles, which will be additional source for deriving dust, leave along the pollution of the city. The soil adhered to the tiers of construction equipment may also be carried by those vehicles that are involuntarily crossing the construction site in order to reach the enterprise territory or home.

Figures 17 and 18: Construction site continues the road

182. Recommendation: The best method of removing soil from car tiers is washing the tires. Although in this specific case this method may not be effective since in addition to the construction equipment, as has been mentioned the vehicles destined to the enterprise as well as those of local residents appear on the construction site. The number of the vehicles of local residents will not be insignificant. Due to understandable reasons one cannot force private vehicles to stop to wash tires at every entry or exit of the construction site. In the mentioned case the most effective way will be the installation of simple structures shown on Figure 19 or simply pour medium gravel (Figure 20).

Figure 19 and 20: Simple ways of removal of soil attached to vehicle tires

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

C) Construction Waste

183. Main waste derived at this stage as a result of performance of ongoing works is: a) removed asphalt; b) soil; c) existing old pipes, d) household waste.

184. It should be mentioned that the construction site looked quite clean. Save minor and insignificant exceptions we did not see any waste disposed without control. The construction company has a contract with the relevant municipal office on the disposal of removed asphalt and soil. According to the contract the mentioned waste are disposed at a specifically designated location. Until the removal from the construction site the mentioned waste are placed on a temporary basis at the locations where they are produced (Figure 21 and 22).

Figures 21 and 22: Removed asphalt is placed temporarily on the construction site

185. Dysfunctional metal pipes are collected at their locations (Figure 23), later they are taken and warehoused in specifically designated places (Figure 24), following which they are given to the contractor.

Figure 23: Removed old pipes Figure 24: Warehoused metal pipes

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

186. As has been mentioned the Consultant has not observed the facts of placing the mentioned waste without control. If the existing pipes contain asbestos they are not removed.

187. Recommendation: As the Consultant has been told that they remove metal pipes (waste) frequently. Still, it is desirable to use sheltered place for temporary storage of metal waste in order to avoid their contact with rain water.

188. Municipal waste produced on the construction territory is collected on a daily basis by a construction contractor. First they are placed in relevant bags and at the end of the day the city cleaning service removes and takes the waste to the municipal dumpsite (Figure 25).

Figure 25: Municipal waste stored temporarily

189. Recommendation: It is necessary to place 0.24 m3 waste containrs wihin the territory of construction site for collection of waste creating, which will be a pre-condition to avoid contact of the insects and stray dogs with the waste.

E) Construction Camp

190. At this stage of project implementation the construction company had not set up own construction camp. According to the contract a Military Aviation Institution located adjacent to the construction territory had allocated a well-organized territory to the contractor.

191. A cafeteria and lavatory are located on the mentioned territory (Figures 26 and 27), they are linked to the relevant municipal network. The location for storing equipment is also allocated on the territory of the institution. Construction equipment is fueled at a petrol station located opposite the construction site (Figure 28).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figure 26: Kitchen Figure 27: Toilet

Figure 25: Petrol Station

D) Book of Complaints

192. The site with ongoing construction works had the Book of Complaints and Suggestions. According to the PIU and Contractor, there were no complaints received from the citizens.

2.5 General Findings and Recommendations

193. Based on the project documents review and conducted site visits the Consultant (Audit Team) revealed the following general findings:

I. Project implementation has been commenced recently. A PIU has been established by the Yerevan Municipality and the environmental specialist is included within the PIU. Both the construction company and a consulting/supervisor company have hired qualified environmental specialists;

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

II. Project Implementing Unit (PIU) environmental specialist is not involved in the bids evaluation process. There is no official requirement to have an environmental specialist in the bid evaluation committee. Besides that, under the mentioned project an environmental specialist was included in the bid evaluation committee. The mentioned specialist had been invited from American University of Armenia; III. The contract with the construction company was concluded in December, 2013. By now the training developed by the ADB under RETA: 7548 has already been held. Training materials contained quite detailed overview of all those requirements which inclusion of which in the construction company contract would better underline the necessity of fulfillment of all environmental requirements. The contract also does not envisage the determination of the levels of inconsistency by the ADB in case of the failure to fulfill environmental requirements and the imposition of a fine per each level; IV. A number of environmental trainings are required according to the IEE document developed as part of the project, these trainings are:  Provide training to all staff on Health, Safety and Environment (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-3);  Organize a training program on waste management for Contractor’s Personnel (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-18);  Job-specific training for workers with responsibility for activities that could have adverse impacts on the environment or humans (e.g., PAH) (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-5);  Health risks and prevention. Training should include information and education on sexually transmitted diseases and HIV/AIDS for construction workers as part of the health and safety program at campsites (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-5);  Ensure that the ERT receives emergency response training (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-17). V. In fact, the EMP has not been updated, the construction contractor has simply copied and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at the stage of the design of the mentioned document, when a detailed project design has not been developed. EMP is updated prior to the commencement of construction, when project detailed design is in place. Respectively, a contractor has to also elaborate specific activities to meet environmental requirements. For example, the following mitigation measure: „Obtain all the permits for waste disposal and dispose only in permitted sites“, that is acceptable for an IEE as a planned mitigation 60

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activity. EMP prepared by construction contractor under the project should not have this requirement copied as a requirement; rather, the document shall contain the outcome of the fulfillment of this requirement. Hence, the EMP should contain a permit issued by a relevant agency about the disposal of waste, as well as the description as to how, when and who will collect, transport and dispose the waste; VI. According to the requirement a construction company should: „Provide community leaders and local newspapers with notices on project progress and anticipated issues“(Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-7); VII. According to the IEE document prepared under the project a number of environmental trainings should be provided, the delivery of these trainings has not yet commenced under the project; VIII. At one location a secondary road links to the project site, while at another place the project blocks the enterprise entrance gate. According to the developed project alternative options to solve the mentioned problem have not been identified. Respectively, currently both the enterprise entrance and the section linking with the secondary road are open. Motor vehicles that use the above-mentioned secondary road or are entering the enterprise have to cross the construction site, which is associated with additional risks; IX. With the purpose of expanding the road the existing walls were being dismantled and the new walls are built. Although the walls are not very high construction workers still had to use the scaffolds. The construction workers use self-made scaffolds that are not acceptable in terms of safety or stability; X. The construction site looked quite clean. Other than very few and minor exceptions the Consultant did not see waste placed without control; XI. At this stage of project implementation the construction company had not set up own construction camp. According to the contract a Military Aviation Institution located adjacent to the construction territory had allocated a well-organized territory to the contractor; XII. The site with ongoing construction works had the Book of Complaints and Suggestions. According to the PIU and Contractor, there were no complaints received from the citizens.

194. Along with the above-mentioned findings the Consultant made the following recommendations:

I. For ADB: In one of the documents developed under the project (Loan agreement, PAM/FAM) the requirement about the involvement of environmental specialist in the bid evaluation committee shall be stipulated; II. For PIU: The criteria developed by ADB are desirable to use for the evaluation of environmental aspects of the tender bid;

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

III. The contract with the construction company was concluded in December, 2013. By now the training developed by the ADB under RETA: 7548 has already been held. Training materials contained quite detailed overview of all those requirements which inclusion in the construction company contract would better underline the necessity of fulfillment of all environmental requirements. The contract also does not envisage the determination of the levels of inconsistency by the ADB in case of the failure to fulfill environmental requirements and the imposition of a fine per each level; IV. In fact, the EMP has not been updated, the construction contractor has simply copied and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at the stage of the design of the mentioned document, when a detailed project design has not been developed. EMP is updated prior to the commencement of construction, when project detailed design is in place. Respectively, a contractor has to also elaborate specific activities to meet environmental requirements. For example, the following mitigation measure: „Obtain all the permits for waste disposal and dispose only in permitted sites“, that is acceptable for an IEE as a planned mitigation activity. EMP prepared by construction contractor under the project should not have this requirement copied as a requirement; rather, the document shall contain the outcome of the fulfillment of this requirement. Hence, the EMP should contain a permit issued by a relevant agency about the disposal of waste, as well as the description as to how, when and who will collect, transport and dispose the waste; V. According the IEE request: “Monthly progress reports and quarterly environmental reports should be provided to all stakeholders, including local media” VI. A;ll environmental specialists engaged in the project shall take the training developed within the scope of RETA project; VII. It is not mentioned in IEE document when the mentioned trainings should be conducted (finding iv) for he employees of the Consruction Contractor. Despite of this, it is desirable to conduct all the mentioned trainings from the beginning of the project, duration of which is 10 months; VIII. (For finding viii) Several alternative recommendations can be considered:

 Identify or organize temporary access road to the factory that will enable the transport and especially the employees to enter the factory territory without crossing the construction site;

 The construction company to identify an individual who will regulate the mentioned problem and warn not only the vehicles and employees that appear on the construction site about the expected threat but will also halt the operation of construction equipment in case of the entry of every vehicle or individual to the construction site.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

 It is desirable that the factory employees undergo special training in safety issues.

IX. Although the height on which the workers are working is not considered as the working on height according to international standards (height of 2 meters and below) the construction contractor has to use more solid and safe scaffolds; X. The best method of removing soil from car tiers is washing the tires. Although in this specific case this method may not be effective since in addition to the construction equipment, as has been mentioned the vehicles destined to the enterprise as well as those of local residents appear on the construction site. The number of the vehicles of local residents will not be insignificant. Due to understandable reasons one cannot force private vehicles to stop to wash tires at every entry or exit of the construction site. In the mentioned case the most effective way will be the installation of simple structures or simply pour medium gravel; XI. As the Consultant has been told that they remove metal pipes (waste) frequently. Still, it is desirable to use sheltered place for temporary storage of waste metal in order to avoid their contact with rain water; XII. It is necessary to place 0.24 m3 waste containrs wihin the territory of construction site for collection of waste creating, which will be a pre-condition to avoid contact of the insects and stray dogs with the waste;

195. More detailed recommendations with indication of the entities responsible for their implementation as well as the terms of recommendations implementation are provided in the Table 12.

Table 12: Recommendations Matrix

# Recommendation Responsible/Action Implementation Terms

1. The loan agreements ADB - gives the During preparation of relevant concluded within the scope of environmental requirements Documents – PAM, IEE and the project, PAM, IEE, bidding in greater details in PAM. EIA. proposal, contract and other relevant documents must give Construction/Supervision Consultant - gives the the environmental requirements in greater environmental requirements details. in greater details in IEE/EIA.

2. It is necessary to update Construction Contractor: Within one month after EMP. EMP should be updated on receiving the Environmental

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

the basis of detailed design. Audit Report.

3. Monthly progress reports and Construction Contractor: Within one week after quarterly environmental Disseminates monthly and receiving the Environmental reports should be provided to quarterly reports prepared Audit Report to elaborate all stakeholders, including under the project among all procedure for disseminating local media interested stakeholders of monthly and quarterly including media reports among the local representatives. population.

4. All environmental specialists Consultant Company: Within one week after engaged in the project shall prepares training module on receiving the Environmental take the training developed the basis of the trainings Audit Report within the scope of RETA conducted under the RETA project program and conducts trainings for Construction Company employess including every new hired employees.

5. Place 0.24 m3 waste Construction Contractor: Within one week after containrs wihin the territory of Placement of 0.24 m3 waste receiving the Environmental construction site for collection containrs wihin the territory Audit Report. of municipal waste. of construction site.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

3. CWTC 42145-023; 42145-033: NORTH–SOUTH ROAD CORRIDOR INVESTMENT PROGRAM – TRANCHE 1 AND TRANCHE 2: YEREVAN-ASHTARAK, YEREVAN-ARARAT AND ASHTARAK-TALIN

3.1 Brief Information on the project (42145-023; 42145-033)

196. The RA has selected the Bavra-Yerevan-Agarak route as the north-south road corridor to be rehabilitated, reconstructed and expanded and has appointed the “North-South Road Corridor Investment Program PMU” SNCO (“NSRP” PMU SNCO) of the Ministry of Transport and Communications (MOTC) to co-ordinate the work. The Program is funded by the Asian Development Bank (ADB) under a multi-tranche funding facility (MFF). The MFF is designed to rehabilitate and upgrade national north-south roads to form a new, upgrade and expanded North-South highway. The main objective is to widen the existing 2-lane roads (often in poor condition) to become 4-lane divided roads along existing alignments wherever possible or to construct new alternate 2-lane roads where a single 4-lane road would not be feasible.

197. Tranche 1 Project is to improve two road sections of the North-South Corridor, namely, the M-1 section of road north from Yerevan to Ashtarak from km 18+370 to km 29+773 (Section 3 in the contract with Contractor) and the M-2 section of road south from Yerevan to Ararat from km 9+312 to km 47+400. The Tranche 2 Project starts at km 29+600 in Ashtarak and ends at km 71+500 close to Talin (Section 1 in the contract with Contractor). Two bypasses will be constructed in Agarak starting at km 29+934 to km 32+600, and in Ujan from km 36+600 to km 40+300. The Project will also have a new road alignment (8.95 kilometres) at Katnagbyur starting from km 59+950 to km 68+900 that will be located on the left side of the existing highway to join the existing alignment in Talin.

Figure 26: Project Area

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

3.2 Institutional Aspects on Environmental Safeguards Implementation

198. The Executing Agency (EA) is the Ministry of Transport and Communication (MOTC). The MOTC set up a North-South Road Corridor Investment Project Implementation Unit SNCO. The Project Management Unit is implementing day-to-day management of project execution including, among other things, (i) monitoring the progress of Project implementation; (ii) preparing withdrawal applications and Project progress reports; (iii) maintaining Project accounts and completing financial records for auditing the Project; and (iv) carrying out procurement, including advance contracting activities. The PMU includes a Social and Environmental Unit whose responsibilities include the management of all environmental aspects of the project.

199. The Project Management Consultant is providing Technical Assistance to the PMU in the management and reporting of the project. Environmental Safeguards Unit of the PMC is responsible for supervising the construction works in relation to environmental and archaeological impact and, in particular, for supervising and reporting on the Contractor’s performance in the implementation of the EMP.

200. Contractor is implementing construction works. Contractor’s Environmental Unit is responsible for implementation of the EMP, monitoring of the construction activities and reporting.

201. During the reporting period the PMU Social and Environmental Safeguards Unit consists of: Social Safeguards and Environmental Officer; Social Safeguards Specialist and Environmental Specialist:

- Ms. Armine Yedigaryan - Social Safeguards and Environmental Officer, is responsible for environmental, resettlement and social management of the project; - Mss. Sona Poghosyan - Social Safeguards Specialist is responsible for the compliance of the project to ADB’s Safeguard Policy and RA Legislation; - Mr. Gevorg Afyan - Environmental Specialist is responsible for the compliance of the project to ADB’s Environmental Policy and RA Legislation.

202. Presently the PMU Environmental Safeguard Unit consists of:

- Ms. Edita Vardgesyan, the National Environmental Specialist (NES), manages the unit after the departure of the International Environmental Specialist. Allocation of the NES came to an end and was renewed in October 2013; - Mr. Boris Gasparyan, the National Archaeological Specialist, is responsible for the consultancy on archaeological issues in Tranche 2, compliance of the construction activities to the Armenian archaeological related legislation and inspection visits to the borrow pit, dumping and concrete plant sites with archaeological evaluation purposes;

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

- Mr. Charles Adamson, the International Environmental Specialist (IES) is responsible for the provision of consultation on international best practices on environmental safeguards. His recent input was from 26 April 2014 to 22 May 2014;

203. The Contractor’s Environmental Unit is staffed by four people:

- The Quality and Environmental Manager - Mr. Javier Gomez Moreno, the Quality and Environmental Manager, commenced work in Jan 2014 replacing the former manager; - Mr. Viktor Bakhtamyan, the Environmental Specialist, is responsible for the assistance to the Quality and Environmental Manager as a local counterpart; - Mr. Sos Amirkhanyan, the Social Relation Specialist, is responsible for the compliance of the Contractor’s activities to social part of the ADB Safeguard Policy Statement; - Mrs. Patricia Ortega Gonzalez, Health and Safety Manager, replaced Ana Maria Del Hoyo Figaredo and commenced work in March 2014. She is responsible for the compliance of the Contractor’s activities to health and safety part of the ADB Safeguard Policy Statement.

Figure 27: Institutional Chart of the Environmental Safeguards Arrangement

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

3.3 Project Document Analysis

A) Loan Agreement (Tranch 1)

204. According to the obligation to meet the environmental requirements given in schedule 5, clause 14 of the Loan Agreement # 2561 - ARM(SF) (October 12, 2009) between Armenia ("Borrower") and Asian Development Bank ("ADB"), „…The Borrower shall ensure that the Project is designed, carried out, maintained, and monitored in compliance with (a) all applicable environmental laws and regulations; (b) ADB’s Environment Policy (2002); and (c) the EMP, including the mitigation measures and monitoring requirements arising from the implementation of the IEE. The Borrower shall also cause ARD to ensure that: (y) Works contractors’ specifications include requirements to comply with the environmental mitigation measures contained in the IEE and EMP, and (z) Works contractors are supervised to ensure compliance with the requirements of the IEE and EMP“.

205. The said loan agreement was concluded in 2009, when the Asian Development Bank Safeguard Policy Statement (SPS 2009) was not put to action. Consequently, the said agreement contains a requirement for meeting the 2002 environmental safeguard policy. Within the limits of the project, in 2013, the FAM was drafted, which covered the first tranche of the project as well. Under the new FAM, the “North–South Road Corridor Investment Program” of the project (including Tranche 1) shall be accomplished in line with the requirements of ADB SPS (2009).

B) Loan Agreement (Tranche 2)

206. According to the obligation to meet the environmental requirements given in schedule 5, clause 2 “Environment” of the Loan Agreement # 2729-ARM (May 30, 2011) between Armenia ("Borrower") and Asian Development Bank ("ADB"), „…The Borrower shall also ensure that the design, construction, and operation of the Project are in accordance with the environmental safeguards and requirements set forth in the ADB’s Safeguards Policy Statement (2009) and the Borrower’s environmental laws and regulations. The Borrower shall ensure that potential adverse environmental impacts arising from the Project are minimized by implementing all the mitigation measures presented in EIA and EMP. The Borrower shall further ensure that (i) during construction, the contractor has primary responsibility for implementing the EMP and mitigation measures, and MOTC has access to sufficient resources to ensure that all environmental management provisions are included in the relevant contract; (ii) MOTC monitors and records the implementation of the EMP; (iii) MOTC, with the assistance of the project management consultants, prepares semiannual environmental monitoring reports, satisfactory to ADB, and submits such to ADB, within 3 months of the end of each half of the calendar year, from the start of project implementation and until the Project completion“.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

C) Facility Administration Manual (Tranche 1, 2 and 3)

207. In January of 2013, the “Facility Administration Manual” (FAM) was developed by the ADB within the scope of project „North–South Road Corridor Investment Program“ covering all three tranches of the project. The document gives a detailed description of all environmental requirements to be met by all organizations engaged in the project. The document is attached by ToR (Annex 2) giving a detailed description of the qualification necessary for environmental specialists and their rights and obligations, and Appendix 3 gives a detailed description of all major requirements to be considered by any organization engaged in the project.

D) Bidding Documents

208. On April 29, 2014, a meeting was held at the office of the project implementing company, where the according o the requirement of the Consultant the bidding documents and contracts were presented (Figures 28 and 29).

Figures 28, 29: Meeting with North-South Road Corridor Investment Program PMU

E) Contract with Supervition Company (Safege S.A. Eptisa JV)

209. An agreement with the supervision company „Safege S.A. and Eptisa JV“ was concluded on May 18, 2012. Out of environmental requirements, the agreement includes the following issues: Appendix A – “Description of services”, Clause B – “Scope of Consulting Services” – (a) to hold permanent project monitoring to identify the compliance of the Safeguards with the IEE/EIA, EMP and EARF, (b) to draft monthly and quarterly progress reports, (c) to document any environmental non-compliance and inform MOTC and ADB of them, (d) to develop the training module and hold the trainings about the safety issues. Clause F – “PMC Team Composition” gives the qualification requirements of the environmental specialists (education, experience, skills and training). Clause G – sub-chapter “Tasks and Responsibilities of Each Team Member” describes the rights and obligations of the local and international environmental specialists; Appendix B gives the engagement schedule of the international and national 69

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environmental specialists in the project, with 12 months (4 months at home and 8 months on site) for the national sp and 12 months (12 months on site) for the international expert.

F) Bidding Documents (Construction Contractor)

210. Within the scope of Tranche 1 and 2 of the „North–South Road Corridor Investment Program“ a tender for the Construction Contractor was announced in August 19, 2011.

211. The obligations on the environmental safeguards implementation are included in the bidding documents in the following sections: Section 7 - General Conditions of Contract, Sub- Clouse 4.18; Section 8 - Particular Conditions of Contract, Sub-Clouse 4.21 “Progress Reports”; and Part II Volume 2b - Special Technical Specifications for Sections 2 and 3. Sub Clouse 101.16. The said sub-chapter gives a detailed description of the obligations the Contractor will have to perform at the project implementation stage. In addition, sub-chapter 101.44.3 „Protection of the Environment“envisages the requirements for necessary measurements to control the qualitative indicators of the environment.

212. The bidding documents have the EIA documents developed within the scope of all three sub-projects attached as annexes.

G) Contract with Construction Company (Corsan Corviam Construction, S.A)

213. The contract with Construction Company - Corsan Corviam Construction, S.A was concluded on April 27, 2012. The necessity for meeting the environmental requirements under the contract concluded with the Construction Contractor is more superficial than it is in the Bidding Document. The environmental issues under the contract are limited to several sentences only, in particular: Part A – Particular Conditions of the Contract, Sub-Clouse 4.1 “Contractor general obligations”, states: “The contractor shall comply with requirements of the national and ADB’s SPS (2009) to the extent applicable”. Also, Part A – “Particular Conditions of the Contract”, Sub-Clouse 4.18 “Protection of Environment”, states: “The Contractor shall take all reasonable steps to protect the environment (both on and off the Site) and to limit damage and nuisance to people and property resulting from pollution, noise and other results of his operations. The Contractor shall ensure that emissions, surface discharges and effluent from the Contractor’s activities shall not exceed the values stated in the Specification or prescribed by applicable Laws”.

214. The Contract concluded with the Construction Contractor (Particular Conditions of the Contract) does not show the obligation of the Contractor to accomplish the mitigation measures and monitoring plan under EIA/IEE and EMP. In addition, the Contract fails to give the sanctions for the failure to meet the environmental requirements.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

215. Recommendation: The Contract concluded with the Construction Contractor (Particular Conditions of the Contract) shall envisage the obligation to accomplish the mitigation measures and monitoring plan under EIA/IEE and EMP.

H) Evaluation of Bids

216. No environmental specialist is engaged in the evaluation of the submitted tender proposals.

217. Recommendation: After the loan agreement is approved, PIU and/or the environmental specialist of the consultant company shall be engaged in all following phases of the project implementation (drafting the project detailed design, developing and assessing the tender bids, concluding the agreement with the construction contractor).

I) Preparation of Pre-Construction Documents 218. As already mentioned, there is one EIA and two IEEs developed within the scope of the project. Under the requirements of these documents, the Construction Contractor had to develop a number of environmental plans and submit them to the PIU for approval.

219. The Construction Contractor developed the environmental management plans listed below: Waste Management Plan; Site Management Plans For Borrow-Pits And Dump Sites; Traffic Management Plan; Concrete Plant Site Development Plan; Site Protection and Stabilisation – Site Work Plan; Emergency response Plan; Community Consultation and Communications Plan; Site Clearing, Flora and Fauna Plan; Dust, Noise And Vibration - Mitigation Measures; Physical Cultural Resources Plan for introducing the Archaeological Issues along km 59.400 – km 71.500 (Tr. 2, Ashtarak-Talin) of the “North-South Road Corridor” Investment Program.

220. All the plans were developed and submitted to the PIU for approval by the Construction Contractor, and all of the said plans were submitted during the audit.

221. The Construction Contractor also developed SEMP and submitted it to the PMC for approval. One of the components of this plan is risk assessment table developed for all sections of the project.

222. Recommendation: The risk assessment table, according to the ADB methods, cannot use ‘zero’ (0), as the minimal point is ‘one’ (1) (0 was used for assessment in document „Topsoil Stockpile Site In Davtashen community (Davtashen 3“); 5 points in graph „Likelihood“ are used to assess the activities, which are planned and realized in fact every day. „Likelihood“ of „Spillages during transportation“ cannot be evaluated by ‘5’ point. A vehicle with permanent oil or fuel leakage must be removed from the project (Davtashen -1 Dumping Site).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

K) Monitoring, Reporting and Trainings

223. The environmental monitoring and reporting of the construction contractor as well as of PIU is done within the terms specified by the agreement.

224. A daily checklist is developed by the Construction Contractor and agreed with the Consultant, which is used by the Construction Company when inspecting the project sites. The given checklist consists of 89 questions and is quite detailed.

225. On his turn, the environmental specialist of the supervising company holds monitoring twice a month, while PIU undertakes monitoring once a month.

226. The Construction Contractor develops monthly environmental reports to be submitted to the consultant. The report gives quite a detailed description of all the activities in the field of environmental protection to be accomplished by the construction consultant during the month.

227. An International Consultant Company - Eptisa JV hired by for construction supervision South Road Corridor Investment Program, undertakes environmental monitoring of project progress and submits quarterly Environmental Monitoring Report to North-South road Corridor Investment Program PMU.

228. The Bi-Annual Report 2 developed on the request of the North-South Road Corridor Investment Program PMU. The presented report was drafted in line with the requirements of Asian Development Bank. All the above-listed reports are available both, on the construction site and at the head office of the North-South Road Corridor Investment Program PMU. As for the Bi-Annual Reports, which ARS North-South Road Corridor Investment Program PMU submits to the ADB, they are available on the ADB web-site.

229. The companies engaged in the project hold frequent meetings with the local population to acquaint them with the course of the project, monitoring results and accomplished mitigation measures.

230. On March 04, 2014 Public Consultation (PC) was held in the Administrative Centre of Shamiram and Aruch communities. During the PCs different environmental, social and safety issues were discussed related to the construction and further maintenance works of the carriageway (41.9 km, PK29+600 – PK71+500) of Ashtarak-Talin M1 road section.

231. A training schedule is developed within the scope of the project. There are records about the trainings available. As per Consultant requirement, we were presented the list of the trainings held in March of 2014 and relevant records.

2 The reports are placed on the ADB web-site.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

232. On March 20, 21, 2013 Environmental Team of “Corsan Corviam Construction” S.A. organized and implemented emergency plan and safety, environmental and HIV course training for the workers of “Hormigones y Morteros Serrano” Armenian Branch, “Dental Import” LLC, “Arpa Sevan” OJSC, “Mirada” LLC, “Nivecotrans” LLC subcontractors, and “Corsan Corviam Construction” S.A. During the different courses constructions workers were informed about possible negative environmental impacts as well as their mitigation measures. A number of participants of the training were 70.

3.4 Project Site Audit

233. The Consultant conducted construction site environmental audit on April 30, 2014 in presence of representatives from PMU and Contractor. The first meeting to get acquainted with environmental documents available on the site was held at the office of the Construction Contractor (Figures 30 and 31).

Figures 30 and 31: Meeting with project implementation team

234. The environmental audit of project site was conducted by using the questionnaire developed by the Asian Development Bank (see Appendix 2).

A) Book of Complaints

235. There is a book of complaints compiled by the company and it is kept at the construction camp. The book of complaints includes some complaints filed at the stage of construction, but neither of them is associated with the environmental issues (Figures 32, 33).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 32, 33: Book of Complaints

B) Baseline Analyzes

236. The relevant analyses to assess the baseline data of the environment were held during the preparation of EIA, in particular:

 Air Quality - Measurements were taken from 9 June 2010 to 16 June 2010. Specialists from Armecomonitoring (SNCO - under the MNP) were engaged to obtain and analyze air quality samples at all communities with potential receptors located no more than 250 m from the highway. Sulphur dioxide (SO2) and nitrogen dioxide (NO2) concentrations were measured in receptors representative of the 6 communities close to the highway;  Noise - Representative receptors of the 6 communities that are within 250 m of the existing or planned highway are affected by noise from traffic and potentially, from construction activities. Noise measurements were taken at all 6 locations between 4 and 10 June 2010;  Water Quality - Specialists from Armecomonitoring were engaged to obtain and analyze physical chemical and biological water quality samples of all 7 streams that are crossed by the existing and new highway and the samples were analyzed in Armecomonitoring’s laboratory;

237. At the construction stage Contractor implements monthly monitoring for the following components: (i) Dust monitoring, (ii) Noise monitoring, (iii) Vibration monitoring, (iv) Water quality monitoring.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

C) Business Yard

238. The Construction Company has no construction camp, where the workers can live. Most of the workers are locals and go to the construction site from their homes. As for the non-local staff engaged in the project, there are buildings hired for them. Along the project line, the Construction Contractor has opened two business yards. Besides accommodating the concrete plants on the given territory, the business yards are used for some other purposes by the Construction Contractor.

239. The workers dine at the dining halls adjacent to the project line. The same dining halls are used by the workers for sanitary purposes.

240. If there are no dining halls near the working sites, the construction company takes the workers to the nearest dining hall during the break. At the same time, the bio-toilets are being installed in the construction site. During the audit, the said bio-toilets were located on the territory of the business yard (Figures 34 and 35).

Figures 34, 35: Bio-toilets located on the territory of the business yard

241. There are concrete plants located on the territory of the business yard owned by the Construction Contractor. Under the legislation of Armenia, the operation of a concrete plant needs no EIA document.

242. The plants are built with concrete foundations and have drainage system and sedimentation basins (Figures 36 and 37).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 36, 37: Concrete plans located on the territory of business yard

243. The business yard is also used to dispose inert waste in it. The inert waste is disposed in the specially allotted area (Figures 38, 39 and 40).

Figure 38: Concrete Plant Figure 39: Metal Waste

244. There are plastic containers placed in the business yard for separated collection of the municipal waste.

Figure 40: Plastic Containers Figure 41: Concrete Waste

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

245. There is a vehicle tire washing area arranged at the entrance of the business yards and in line with the environmental requirements, it is located on a concrete pillow, has a drainage system and sedimentation basin (Figures 42 and 43).

Figures 42, 43: Vehicle tire washing area

246. There is no fueling station in the area. The construction techniques are fuelled at the fueling stations located the adjacent to the construction corridor.

D) Borrow Pits

247. The Construction Contractor has not opened its own borrow pits. The contractor uses the existing borrow pits. At present, the Construction Contractor has concluded an agreement on raw materials supply with 6 companies owning the borrow pits. These companies are:

1. “AAB Project” LLC.- with the permit issued on 20.10.2012 (valid until 25.07.2036) 2. “Khochar” LLC – with the permit issued on 20.11.2003 (valid until 20.11.2034) 3. “Macdzavan” LLC – with the permit issued on 22.03.2012 (valid until 24.07.2028) 4. “Nairi CHSHSH” OSSC – with the permit issued on 20.10.2012 (valid until 24.12.2032) 5. “Stavn Lord” LLC – with the permit issued on 01.09.2012 (valid until 16.07.2032) 6. “TNA-SHIN-ASHOT” LLC - with the permit issued on 03.09.2012 (valid until 21.07.2022)

248. All companies have a license to mine the construction materials.

D) Site Inspection

249. During the audit, the drainage systems were installed at some locations of the construction site. The safety requirements were fully observed on the construction site (Figures 44 and 45).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 44, 45: Installation of drainage systems

250. There was no dust or noise on the site and there were no uncontrolled waste or spills fixed.

E) Inert Waste

251. In the environmental respect, one of the major problems during the construction was disposal of the inert waste (see Figure 46).

252. The construction company has a relevant permit to dispose the inert waste adjacent to the project site. There are inert waste management plans developed for all such sites. All the mentioned permits and management plans are kept at the construction camp.

Figure 46: Disposal of inert waste

F) Non-Compliance # 1:

253. Existing situation: Figure 25 shows that the inert waste is disposed on the existing topsoil. The developed inert waste disposal plan does not envisage the removal of the topsoil on

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

the territory where the inert waste is to be placed. In fact, according to the developed plan, the topsoil on the territory where the inert waste is to be disposed is to be totally destroyed.

254. Corrective action: The existing inert waste disposal plans should be updated. Before the onset of placement of the inert materials, the topsoil must be removed in the allotted area and stored in the adjacent area. After the inert waste is placed, the stored topsoil should be used to restore the territory.

F) Temporal disposal of the topsoil 255. Under the project, the topsoil will be removed on the construction site and placed temporarily. After the completion of the project, the stored topsoil should be used for the restoration works.

256. The company has an agreement concluded with the local authority about temporal disposal of the topsoil. There are some areas allotted for the temporal disposal of the topsoil, and there are relevant agreements concluded and relevant plans developed for every area.

G) Non-Compliance # 2:

257. Existing situation: As Figures 47 and 48 shows, the height of the topsoil disposed in the allotted area varies from 3 to 5 m.

258. Requirement: The height of the disposed topsoil must not exceed 2.5 m. (Technical Specification 1002 TOPSOIL, Part II Volume 2a, and Special Technical Specifications).

Figures 47, 48: Temporarily disposed topsoil

259. There was an extra meeting held with the management of the Construction Contractor in connection to this issue. The Consultant asked the Construction Contractor for two months to develop the corrective actions and accomplish relevant activities.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

3.5 Main Findings Revaled during the Documents Review and Site Visits

260. Based on the projects documents review and conducted site visits the Consultant (Audit Team) revealed the following general findings:

I. The Loan Agreement envisages the obligation of the authority of the Republic of Armenia to realize the project in line with the ADB safety requirements and requirements of the environmental legislation of Armenia. The FAM developed within the scope of the project gives a detailed description of the qualification necessary for the environmental specialists and their rights and obligations, as well as all major requirements to be considered by any organization engaged in the project; II. The Contract concluded with the Construction Contractor (Particular Conditions of the Contract) does not show the obligation of the Contractor to accomplish the mitigation measures and monitoring plan under EIA/IEE and EMP. In addition, the contract fails to give the sanctions for the failure to meet the environmental requirements; III. All the companies engaged in the project are staffed with high-quality international and local environmental specialists; IV. All needed environmental documents are developed within the scope of the project. The project is permanently inspected, monitored and audited by both, construction and supervision consultant company and environmental specialist of PIU; V. There is a book of complaints kept at the construction camp, containing the complaints of the local people. Neither complaint is about the environmental issues; VI. There are permanent meetings held with the locals to consider the environmental issues interesting to the population, who are under the project impact. This action must be considered as good practice for other ongoing projects (in Armenia and other countries); VII. The basic analyses were accomplished within the scope of the project, and monthly analyses envisaged by the EIA are accomplished permanently to assess the baseline data of the environment (air, water, noise). The results of the analyses are available at the construction camp; VIII. There are agreements concluded with the local authority about the disposal of inert waste and temporal disposal of the topsoil; IX. A number of legislative requirements are violated during the disposal of inert waste and temporal disposal of the topsoil.

3.6 Non-compliances and Recommendations

261. Along with the above-mentioned findings the Consultant fixed the following general non- compliances and made the following recommendations:

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Non-Compliances:

I. The inert waste is disposed on the existing topsoil. The developed inert waste disposal plan does not envisage the removal of the topsoil on the territory where the inert waste is to be placed. In fact, according to the developed plan, the topsoil on the territory where the inert waste is to be disposed is to be totally destroyed; II. There is a violation of standards at the territory of topsoil disposal, in particular the height of the temporarily disposed topsoil significantly exceeds permissible standards.

Recommendations:

I. The Contract concluded with the Construction Contractor (Particular Conditions of the Contract) shall envisage the obligation to accomplish the mitigation measures and monitoring plan under EIA/IEE and EMP; II. After the loan agreement is approved, PIU and/or the environmental specialist of the consultant company shall be engaged in all following phases of the project implementation (drafting the project detailed design, developing and assessing the tender bids, concluding the agreement with the construction contractor); III. The risk assessment table, according to the ADB methods, cannot use ‘zero’ (0), as the minimal point is ‘one’ (1) (“0” was used for assessment in document „Topsoil Stockpile Site In Davtashen community (Davtashen 3“); IV. 5 points in graph „Likelihood“ is used to assess the activities, which are planned and realized in fact every day. „Likelihood“ of „Spillages during transportation“ cannot be evaluated by ‘5’ point. A vehicle with permanent oil or fuel leakage must be removed from the project (Davtashen -1 Dumping Site); V. The inert waste management plans shall be permanently updated. Before the onset of placement of the inert materials, the topsoil should be removed in the allotted area and stored in the adjacent area. After the inert waste is disposed, the stored topsoil should be used to restore the territory; VI. Aiming at eliminating the violation of the standards of disposal on the territory of temporal placement of the topsoil, the corrective actions shall be developed and implemented.

262. More detailed recommendations with indication of the entities responsible for their implementation as well as the terms of recommendations implementation are provided in the Table 13.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Table 13: Recommendations Matrix

# Recommendation Responsible/Action Implementation Terms

1. The loan agreements ADB - gives the During preparation of relevant concluded within the scope environmental requirements Documents – PAM, IEE and of the project, PAM, IEE, in greater details in PAM. EIA. bidding proposal, contract and other relevant Construction/Supervision Consultant - gives the documents must give the environmental requirements environmental requirements in greater details. in greater details in IEE/EIA.

2. SEMP should be updated. Construction Company: Within one month after Risk assessment table is to receiving the Environmental be improved, assessment Audit Report. methodology has to be in compliance with ADB requirements.

3. Inert Waste Management Construction Company: Within one month after Plan has to be updated. Updates Inert Waste receiving the Environmental Management Plan in Audit Report. accordance with the presented recommendations.

4. Corrective actions related to Construction Company: Within two months after the topsoil disposal have to Elaborates and implements receiving the Environmental be elaborated and corrective actions related to Audit Report. implemented. the topsoil disposal.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

4. CWUW 45299-001: WATER SUPPLY AND SANITATION SECTOR PROJECT – PHASE 2

4.1 Brief Information on the project

263. Water supply infrastructure in Armenia dates back to the Soviet era and has suffered from lack of investment since the collapse of the Soviet Union. The systems were constructed using cast iron and steel components and are now well past their normal life. Corrosion of pipelines result in water losses of up to 90% in some cases, e.g. Vayq, with the result that water supplies have to be turned off for extensive parts of the day.

265. Water is extracted from some sources that cannot provide the required quantities year round. Abstraction from new or supplementary sources is required to provide year-round water supply. Within many reasonably sized towns the citizens collect water from stand pipes or from bulk tankers as water supply does not reach their homes. A Phase 1 program of works has already been implemented with ADB funding, along with parallel projects under the auspices of other IFIs. These projects were limited by the capacity for implementing the works, and hence in many cases the Phase 1 works form the foundation for Phase 2 and future works that will realize the benefits in the context of the overall program.

266. The proposed Project will be implemented in 18 towns and 92 villages throughout Armenia, distributed through the territory, excluding Yeravan Gyumri and Vanadzor Cities. The objective of the project is improved public health and environment for households and other consumers in 18 towns and 92 small villages through safe and reliable water supply. The project is grouped into ten sub-projects, clustered around these following towns: Vedi & Ararat; Ecmiatsin; Artik; Alaverdi, Tashir & Stepanavan; Gavar & Martuni; Noyemberan & Berd; Kapan & Meghri; Veyq & Jermuk; Talin; Hrazdan & Tsahkadzor. The location of these named centers is shown in Figure 1.

Figure 49: Project Area

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

4.2 Institutional Aspects on Environmental Safeguards Implementation

267. The Executing Agency (EA) is the State Committee for Water Economy (SCWE). Roles and Responsibilities of the SCWE are: i) Responsible for oversight and administration; ii) Hold monthly meetings with AWSC to review progress; iii) Convene regular meetings in consultation with the Company Board of Directors and AWSC; iv) Facilitate the approval procedures within the Government.

268. The Implementing Agency is Armenia Water Sewerage Company. The Project Management Unit is implementing day-to-day management of project execution including, among other things: (i) Oversee accounting and auditing; (ii) Oversee implementation and management; (iii) Secure technical and environmental approvals for all civil works prior to bidding; (iv) Ensure compliance with covenants; (iv) Invite bids, evaluate and prepare bid evaluation reports for ADB‟s approval: (v) Award contracts; (vi) Oversee contractor’s works (vii) Prepare and submit quarterly progress reports.

269. The Project Management Consultant is providing Technical Assistance to the PMU in the management and reporting of the project. Environmental Safeguards Specialist of the PMC is responsible for supervising the construction works in relation to environmental impact and, in particular, for supervising and reporting on the Contractor’s performance in the implementation of the EMP.

270. Contractor is implementing construction works. Contractor’s Environmental Unit is responsible for implementation of the EMP, monitoring of the construction activities and reporting.

Figure 50: Institutional chart of the environmental safeguards arrangement within the project

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

4.3 Project Document Analysis

A) Loan Agreement & Project Administration Manual (PAM)

271. According to the obligation to meet the environmental requirements given in schedule 5 “Execution of Project; Financial Matters”, clause 6 of the Loan Agreement # 2860-ARM (may 2 12, 2012) between Armenia ("Borrower") and Asian Development Bank ("ADB"), “…The Borrower shall ensure and shall cause AWSC to ensure that the preparation, design, construction, implementation, operation and decommissioning of the Project and all Project facilities comply with (a) all applicable laws and regulations of the Borrower relating to environment, health and safety; (b) the Environmental Safeguards; and (c) all measures and requirements set forth in the IEE, the EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring Report.”

272. In addition, the Loan Agreement contains the safety requirements, both for the need for permanent monitoring and reporting and including the safeguard issues in the Bidding Documents and contracts.

273. In February of 2012, within the scope of the project, the ADB developed and approved PAM. Part B of the document: “Capacity Building and Public Awareness Campaign” gives the rights and obligations of the environmental specialist of PIU, which are as follows: “The Environmental Specialist will carry out the initial environmental examination (IEE) of all subprojects in accordance with ADB SPS (2009), and Armenia Environmental Guidelines, and accordingly prepare the EMPs to monitor the sub-projects both at the design and implementation stages. The environmental mitigation and monitoring measures should ensure that (a) any adverse environmental impacts are minimized by the mitigating measures and monitoring program detailed in the environmental management plan (EMP) in the IEE; (b) implementation of the EMP and any violation of environmental standards are reported to ADB (c) EMP is incorporated in the bidding documents. The Specialist will also be responsible for the safeguards issues during construction and EMP’s proper implementation”. In article B - “Monitoring”, AWSC will undertake the monitoring of safeguard covenants compliance to be included in the quarterly project progress report and submitted to ADB.

B) Bidding Documents

274. On April 29, 2014, a meeting was held at the office of the project implementing company, where the audit team members were presented the tender documents and contracts required by the Consultant.

275. The Bidding Document was submitted by the Supervision Consulting Company in July of 2012. The document contains quite a thorough description of the obligations of the environmental specialist (Chapter 4.2.2.9. “Environmental Protection”). However, there are a

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

number of obligations, which are not clear for the specialist working for the Consulting Company.

276. According to the submitted Bid Proposal the environmental specialist should carry out Environmental Impact Assessment process, for which the specialist should study the ADB’s environmental assessment procedures – Initial Environmental Assessment (2002), Environmental Policy (2002), Environmental Assessment Guidelines (2003). The specialist also should study existing Armenian laws regulated environmental impacts regulated environmental impacts of the works implemented for water supply and wastewater systems improvement”.

277. As the documents drafted within the scope of all projects state, the realization of the given project will cause a minimum impact on the environment. Despite this, following the scales of the project (the project is to be accomplished in 110 settled areas and it engages 14 construction companies), the environmental specialist of the Consulting Company shall have quite good experience, background and skills within the scope of the project. His obligation is to explain and consult others, not to learn himself, particularly, the basic international or national legislative base.

C) Contract with Supervision Company

278. The contract with Supervising Company - JV of HGSN LLS and JINS LLS (Armenia) was concluded on December 26, 2012. Neither “General Condition of the Contract”, nor “Special Conditions” of the Contract gives the environmental obligations of the Consultant. The environmental obligations are given in Annex A: “Description of Servicies”. The given chapter is totally copied from the Bidding Documents.The different chapters of Annex A give the following obligations of the environmental specialist of the Consulting Company: (iii) conducting Initial Environmental Examination IEE; (vii) developing of the Environmental Management Plan (EMP) for the each sub-project (Annex a, Part A “Design and construction supervision of the civil works”); Preparation of IEE as a basis for the future development of the EMP in DD phase (Annex A, Brief Description of the consultant activities); The consultant shall exercise control over implementation of environmental impact mitigating and safety measures including in EMP and present information thereon in the separate semiannual safeguard monitoring reports (Annex A, Brief Description of the consultant activities); The consultant shall prepare and submit IEE and EMP reports (Annex B “reporting Requirements”).

279. Within the scope of the contract, annex C “Personnel Schedule” also gives the schedule of the environmental specialist’s engagement in the project, making 36 months.

D) Construction Contractors

280. There are 14 tenders announced and the same number of contracts concluded with the Construction Contractors within the scope of project “Water Supply and Sanitation Sector Project”. The obligations to meet the environmental requirements are the same in all 14 86

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Bidding Documents, as well as in the Bid Proposal of the winning construction company and all contracts are found in the same chapters. The only difference lies in the dates of declaring the tender and terms of submitting the Bid Proposals and concluding the contract.

281. As already mentioned, based on the agreement with the ADB, the site audit within the scope of the project was accomplished for three sub-projects. Table 14 shows the statistics for the three sub-projects. Table 14: Statistics for three sub-projects

# Project name Winner Construction Company Date of tender announcem ent Date of submission of bid proposals Contract conclusion date 1. Improvement of water Ararat-Chanshin LLS - Artezia 24 May, 9 July, 21 August, supply systems in Vedi and LLS 2013 2013 2013 Ararat towns and Banavan GMF, Ararat, Volketap Villagies. 2. Improvement of water LLS & Ashotsg LLS 28 May, 9 July, 11 October, supply systems in Hrazdan 2013 2013 2013 town, Qaghsi village. 3. Improvement of water Agat 777 LLS 26 7 26 supply systems in August, October, November, Metsavan, Sarchapet and 2013 2013 2013 Lernahovit villages and reconstruction of Hovdra external water main.

D.1) Bidding Documents for Construction Contractor

282. The Bidding Documents of all sub-projects envisage the obligation to meet the environmental requirements by the Construction Contractor. According to Chapter 8 - “Special Conditions of the Contract” – GCC 63 “Safeguards”: “The Contractor shall: (a) comply with the measures relevant to the contractor set in the Initial Environmental Examination (IEE), Environmental Management Plan (EMP) and any applicable Resettlement Plan (RP), and any corrective or preventative actions set forth in a Safeguards Monitoring Report;(b) make available a budget for all such environmental and social measures; (c) provide the Employer with a written notice any unanticipated environmental or resettlement risk or impacts that arise during construction that were not considered in the IEE, EMP and RP; (d) adequately record the condition of roads, agricultural land and other infrastructure prior to starting to transport materials and construction; and (e) reinstate pathways, other local infrastructure, and agricultural land to at least their pre-project condition upon the completion of construction”.

283. The Bidding Documents are annexed by EMP (Section 6 – “Works Requirement – 87

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Environmental Management Plan”). This document is drafted by the environmental specialist of the Consulting Company based on the detailed design.

284. The Bidding Documents: Section 3 – “Evaluation and Qualification Criteria”, Clause - 2.5, “Personnel” give the qualification requirements for the specialists engaged in the project. The document contains no requirement for the Construction Contractor to hire an environmental specialist on staff.

D.2) Bid Proposals of Construction Companies

285. All Bid Proposals submitted by the winning Construction Company repeat (in fact, word by word) (Clause - “Environmental Protection”) the obligation given in the Bidding Document to meet the environmental requirements as the one undertaking by them.

286. None of the Construction Contractors have included an environmental specialist on the Personnel.

D.3) Contracts with Construction Companies

287. All the contracts concluded with the Construction Contractors are annexed by EMP developed within the scope of all sub-projects. In addition, all contracts give the obligation of the Construction Contractor to meet the environmental requirements. The wording of this requirement is identical for all contracts. In fact, the wording about the obligation to meet the environmental requirements by the Construction Contractor is identical in all documents associated with the Construction Contractor (Bidding Documents, Bid proposal and Contract) (See Chapter D.1 for the wording).

E) Evaluation of Bids

288. No environmental specialist is engaged in the evaluation of the submitted tender proposals.

289. Recommendation: After the loan agreement is approved, PIU and/or the environmental specialist of the consultant company shall be engaged in all following phases of the project implementation (drafting the project detailed design, developing and assessing the tender bids, concluding the agreement with the construction contractor).

I) Preparation of Pre-Construction Documents 290. As already mentioned, within the scope of the project, there was one EIA document (Framework Initial Environmental Examination Report) developed in January of 2012. Consequently, the environmental management plans, which are necessary to develop before the realization of the project, are the same for all projects.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

291. The only document to be developed before the onset of the project is EMP. There are EMPs developed based on the detailed designs within the scope of all sub-projects. The developed documents are also annexed to the contracts concluded with the Construction Contractor within the scope of each sub-project.

F) Monitoring, Reporting and Trainings

292. Requirement: As already mentioned, the EMPs are developed within the scope of all projects. A part of this document is a monitoring table giving quite a detailed description of the Construction Contractor’s obligations of ensuring daily environmental monitoring. The said document also contains a checklist to be used by the environmental specialist during the environmental monitoring. For example, the relevant requirement in the contract concluded within the scope of the first sub-project is given in annex J – “Environmental Manajement Plan”, Clause 8 – “Intuitional framework of Environmental management”, according which: “NGSN Ltd and JINJ Ltd Joint venture will also implement control of implementation of mitigation measures during the construction. The environmental specialist shall make visits to control the EMP and SSEMP implementation and assess the situation according the Mitigation compliance & inspection monitoring form”.

293. The existing situation: None of the Construction Contractors have a qualified environmental specialist on staff. Consequently, no qualified daily inspections of the sites are accomplished and no relevant records are made by the employees of the Construction Contractor.

294. Corrective actions: The Construction Contractor shall hire an environmental specialist on the basic staff, or some Company employee shall be charged with the duties of an environmental specialist. The Construction Contractor shall have a designated person, who will be officially responsible for the environmental issues.

295. The project monitoring is accomplished by an environmental specialist of the Consulting Company at least once a month. The said specialist uses the checklist developed within the scope of the project.

296. Reporting within the scope of the project is done by the following organization with the following regularity: monthly progress reports are drafted by the Construction Contractor and submitted to the Consulting Supervision Company. As per the existing requirements, this document shall also cover the environmental issues. As none of the companies have an environmental specialist, the environmental reports are drafted by the environmental specialist of the Consulting Company.

297. Recommendation: The Construction Contractor shall hire an environmental specialist on the basic staff, or some Company employee shall be charged with the duties of an 89

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

environmental specialist. It will be the obligation of such a specialist to draft the monthly environmental reports and submit them to the Consultant.

298. A Consultant Company - JV of HGSN LLS and JINS LLS hired in scope of Water Supply and Sanitation Sector Project undertake environmental monitoring of project progress and submit quarterly Environmental Monitoring Report to Armenia Water Sewerage Company.

299. The Bi-Annual Report3 developed by Armenia Water Sewerage Company. The presented report was drafted in line with the requirements of Asian Development Bank. All the above-listed reports are available both, on the construction site and at the head office of the Armenia Water Sewerage Company. As for the Bi-Annual Reports, which Armenia Water Sewerage Company submits to the ADB, they are available on the ADB web-site.

300. The proper specialists of the Construction Contractors have not been given the trainings about the environmental issues.

L) Non-Compliance #1:

301. Requirement: “The mitigation measures above will be strengthened and supported by the delivery of compulsory training for successful Construction Contract bidders. This training has been prepared to educate the Contractors‟ Personnel on the implementation of the mitigation measures of the EMP and on relevant good construction practices” (Framework Initial Environmental Examination Report, Clouse D - Mitigation Measures, sub clause 7 - Community and Worker Safety).

302. Existing Situation: The Consulting/Supervision Company has not been given the trainings related with the environmental issues.

303. Corrective Actions: The Consulting Company shall develop the module of environmental trainings, as well as schedule of trainings and shall start organizing the trainings without delay.

4.4 Project Site Audit

304. The Consultant conducted construction site environmental audit on May 2-3, 2014 in presence of representatives from PMU and Contractors. As already mentioned, the site audits were organized only within the scope of three sub-projects. Within the scope of all three sub- projects, the water-supply and water drainage pipes were replaced and connected to the residential houses.

3 The reports are placed on the ADB web-site.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

305. The work schedules were identical for all sub-projects. The trenches were excavated along 50 to 150 m distance, the pipes were laid and trenches filled. Then, the construction activities were accomplished along the next section with the same works done with it.

A) Improvement of water supply systems in Vedi and Ararat towns and Banavan GMF, Ararat, Volketap Villagies

A.1) Baseline Analyzes

306. According to the Framework Initial Environmental Examination Report elaborated under the Project: “No new baseline monitoring is required” (Clouse VIII – “Framework Environmental Management Plan”). In addition, the EMPs developed within the scope of all projects say that the noise level is to be measured only in case there is a complaint.

A.2) Business Yard

307. The Construction Contractor has no construction camp for the workers to live in. Most of the workers are locals and go to the construction site from their homes. As for the non-local staff engaged in the project, there are buildings hired for them. Along the project line, the Construction Contractor has opened a business yard. Besides accommodating the concrete plants on the given territory, the business yards are used for some other purposes by the Construction Contractor. As there are 10 to 12 workers working at every construction site, and not all of them are locals, they dine at the nearest dining hall during the break.

308. There is a concrete plant in the business yard (the area of the business yard is 7 ha) (Figures 51, 52) owned by the Construction Contractor. Under the legislation of Armenia, the operation of a concrete plant needs no EIA document to develop. There is also office buildings, crushing plant and oil station located within the territory (Figures 53, 54).

Figures 51 and 52: Concrete Plant within the territory of business yard

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figure 53: Crushing Plant Figure 54: Crushing Plant

309. There is also a fueling station for the construction techniques on the territory of the business yard. The station is not located over the concrete pillow and it seems that no secondary container is used during the fueling operations (Figure 55, 56). Consequently, there are spilt fuel spots seen in the area.

Figure 55: Fueling Station Figure 56: Construction Techniques Park

310. The Construction Company owns a sand quarry, which is located in the riverbed. There is the proper license issued to the quarry allowing the company to mine the sand only for some months during the year. As for the rest of the year, as the license states, the quarry is filled in with the inert material transported by the river, i.e. in a natural way (Figures 57 and 58).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 57, 58: Sand Borrow Pits

A.3) Site Inspection

311. During the audit, the water-supply pipes were being replaced on the construction site. The construction activities were accomplished along the areas under strong anthropogenic impact (Figures 59 and 60). The soil excavated from the trenches was placed in the adjacent area. The soil was disposed by meeting the relevant requirements. This soil is used to fill in the trenches and the excess soil is placed in the areas specially designated under the agreement with the local authority as inert waste.

Figures 59, 60: Site Inspection

312. The water-supply pipes were also being replaced and wells were being installed in the streets of the city of Vedi. The construction soil was fenced with relevant tapes and proper warning signs were in place (Figures 61, 62). There were design works accomplished in the city streets.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 61, 62: Design works accomplished in the city streets

313. The connection of the water-supply pipes to the houses was accomplished within the scope of the project, and the relevant trenches were filled in with the soil (Figures 63, 64). Laying new asphalt over the road sections damaged due to the project is planned in the near future.

Figures 63, 64: Trenches filled with soil

A.4) Noise and Dust

314. Following the methods of the project realization, the ground works on one site are accomplished for at most two weeks. Consequently, the impact with dust and noise following the construction activities is short.

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

B) Improvement of Water Supply Systems in Hrazdan Town, Qaghsi Village

315. In April 2014, a meeting with the representative of the Construction Contractor was held at the construction site (Figures 65, 66).

Figures 65, 66: Meeting at construction site

316. As already mentioned, the construction activities within the scope of all sub-projects were accomplished along short sections (50-150 m). The methods to replace the water-supply pipes by the Construction Contractor in the city of Hrazdan were the same as in any other cases. There was a trench of an approximately 150 m length with the pipes being laid in it (Figures 67, 68).

Figures 67, 68: Construction Site

317. There was no topsoil in the project area, where the trenches were excavated. Consequently, the excavated soil is being placed along the trenches. The soil placed

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

temporarily is used to fill in the trenches. As the photos show, the construction site is fenced with warning tapes and the workers are duly equipped.

B.1) Business Yard

318. The business yard of the Construction Contractor is located in the former industrial area in the city. This area was under impact for years. There is a park for the construction techniques (Figure 69), fueling station (Figure 70) and storage area and area for temporal storage of waste on the said territory (Figures 71, 72).

Figure 69: Construction Techniques Park Figure 70: Fueling Station

Figure 71: Storage Area Figure 72: Waste Disposal Area

319. Like with other sub-projects, the major problem in this sub-project is the absence of the relevant documents evidenced as follows: (a) the environmental specialist of the Construction Contractor fails to accomplish daily monitoring and has no checklists accordingly, (b) there is no 96

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book of complaints on the construction site, and (c) the monthly environmental reports are drafted by the PIU environmental specialist instead of the environmental specialist of the Construction Contractor.

C) Improvement of Water Supply Systems in Metsavan, Sarchapet and lernahovit Villages and Reconstruction of Hovdra External Water Main

320. The meeting with the Construction Contractor’s team was held at the construction object. The length of the construction object did not exceed 100 m this time, too (Figures 73, 74).

Figures 73, 74: Meeting with Construction Contractor

321. The methods of construction were identical to those with the two former sub-projects. The soil gained during the excavation of trenches is disposed in the adjacent area and used to fill in the trenches after the pipes were laid in the trenches. Any excess ground was placed in the areas specially designated by the local authority. The relevant agreement is available on the construction site.

C.1) Business Yard

322. The business yard of the Construction Contractor is located in the former industrial area in the city. The Construction Contractor uses the mentioned territory for temporary disposal of construction materials, construction techniques and non-hazardous waste (Figures 75, 76, 77, 78).

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

Figures 75, 76: Business Yard

Figures 77, 78: Business Yard

323. Like with the two former subprojects, the major problem in this sub-project is the absence of the relevant environmental documents leading to the absence of the environmental specialist with the relevant qualification at the Construction Contractor.

4.5 Main Findings Revaled during the Documents Review and Site Visits

324. Based on the projects documents review and conducted site visits the Consultant (Audit Team) revealed the following general findings:

I. The Loan Agreement envisages the obligation of the authority of the Republic of Armenia to realize the project in line with the ADB safeguard policies and requirements of the environmental legislation of Armenia; II. The Contract concluded with the Construction Contractor (Particular Conditions of the Contract) does not show the obligation of the Contractor to accomplish the mitigation

RETA 7548: Improving of Environmental Safeguards in Central and West Asia Armenia Country Report

measures and monitoring plan under EIA/IEE and EMP, as well as the sanctions envisaged by the given document for the failure to meet the environmental requirements; III. None of the documents drafted within the scope of the project contains a requirement for the Construction Contractor to hire an environmental specialist. Consequently, the majority of the construction companies within the scope of the 14 sub-projects have no environmental specialists; IV. For each sub-project, the environmental specialist of the Consulting Company has developed an EMP document based on the detailed design, which is enclosed to the contract concluded with the Construction Contractor as an annex; V. Within the scope of all three projects, which were audited, the Construction Contractor, despite the requirements in place, fails to accomplish the daily environmental monitoring envisaged by EMP; VI. The only qualified environmental specialist engaged in the project permanently undertaking the environmental monitoring within the scope of all 14 projects, is the environmental specialist of the Consulting Company. If considering that at the given stage, the construction works within the scope of the project are being accomplished in about 50 m from the settled area, one environmental specialist is not sufficient indeed to conduct a thorough environmental monitoring. Even more so when the number of sub- projects will reach 120 as the project is fully launched; VII. The Framework Initial Environmental Examination Report of every sub-project contains the requirement for providing the trainings in the field of environmental protection to the Construction Contractor. The said requirement is not met within the scope of any of the sub-projects; VIII. The EMP developed for every project contains the form of the book of complaints as an annex. Despite this, no book of complaints was found at any of the construction sites audited; IX. Within the scope of all projects, there are agreements for disposal of the inert waste concluded with the local authorities. There is also an agreement about the supply of the construction materials concluded with the licensed quarries. Only one Construction Contractor owns a borrow pit and concrete plant; X. All construction sites look clean and are duly fenced. The workers wore relevant uniforms (PPE). Within the scope of all three sub-projects audited, no violations of the environmental requirements during the construction were fixed; XI. As a conclusion, the Consultant may say that the major environmental problems within the scope of Water Supply and Sanitation Sector Project are associated with the lack of the environmental specialists of the companies engaged in the said project. There are only two qualified environmental specialists actively engaged in the development and realization of 110 sub-projects.

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4.6 Non-Compliances and Recommendations

325. Along with the above-mentioned findings the Consultant fixed the following general non- compliances and made the following recommendations:

Non-Compliances:

I. Neither of the Construction Companies have an environmental specialist on staff. Consequently, within the scope of any project, no daily inspections are conducted and no relevant records are made by the employees of the Construction Contractor; II. The Consultant/Supervising Company has not provided any training related with the environmental issues.

Recommendations:

I. The Construction Contractor shall hire an environmental specialist within the basic staff, or some Company employee shall be charged with the duties of an environmental specialist. The Construction Contractor shall have a designated person, who will be officially responsible for the environmental issues; II. When developing the Bidding Documents for the Construction Contractor within the scope of the following sub-projects, the document (chapter “Personnel” in particular) shall contain the requirement for the Contractor to hire a qualified environmental specialist on staff; III. Armenia Water Sewerage Company shall hire at least two more environmental specialists; IV. After the loan agreement is approved, PIU and/or the environmental specialist of the consultant company shall be engaged in all following phases of the project implementation (drafting the project detailed design, developing and assessing the tender bids, concluding the agreement with the construction contractor); V. The Supervision Consulting Company shall develop the module of environmental trainings, as well as schedule of trainings and should start organizing the trainings without delay;

326. More detailed recommendations with indication of the entities responsible for their implementation as well as the terms of recommendations implementation are provided in the Table 15.

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Table 15: Recommendations Matrix

# Recommendation Responsible/Action Implementation Terms

2. Construction Contractor shall Consultant Contractor: During the preparation stage have environmental Includes in bidding of the bidding documents for specialist on staff. document requirement for the next sub-projects. the Contractor to hire a qualified environmental specialist on staff.

3. Armenia Water Sewerage PIU - Armenia Water Within one month after Company shall hire at least Sewerage Company: receiving the Environmental two more environmental Announces tender for hiring Audit Report. specialists. of two additional environmental experts within the PIU under the project.

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APPENDIXES:

Appendix 1. Environmental Safeguards Compliance Monitoring Checklist for the Construction/Rehabilitation of Arshakunyats Street Project

Country safeguard review

Country : Armenia

Audit Date :

Project Data

Project Name:

Project Progress (%) : 100%

Environmental Safeguards Categorization A B C

Overall Status of Compliance

 X 

Not compliant – Remedial action Mostly compliant - Minor Fully compliant & monitoring required remedial action & monitoring required

A. Safeguards Loan/Grant Covenants

Item No. Covenant Status of Compliance

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B. Environmental Management Planning (Preconstruction)

Item Status4 Follow up Comments/Actions required (Y/N) required (Y/N)

Environment Unit (EU) established Y Y An Environmental and Social within Project Implementation Unit Safeguards Unit was established within (PIU ) Project Implementation Unit.

Environmental recording system Y Y Environmental issues reported established in EU regularly in the monthly reports by the Contractor and to be commented on by the environmental specialist.

In addition, PIU Ecologist conducts monthly visits to the construction site for seeing whether it is complied with the requirements on environment protection. The survey is conducted with the station ecologist with PIU.

Baseline monitoring completed Y N Within the framework of EIA, which was prepared in June-July 2009, baseline environmental monitoring was conducted.

EMP design requirements included Y N EMP design requirements included in in design brief. (Evidence that EU design brief. There is no evidence that has checked design brief in this ES has checked design brief in this regard) regard.

EMP requirements included in Y N An EIA and EPM documents were tender documents attached to the tender documentation as an annex. The obligation of the contractor to meet the requirements of the document as well as contractor’s reporting responsibility are given in part B of the tender documentation- „Specific Provisions“.

4 Documentary evidence of each item to be maintained in EU’s environmental recording system and made available for audit.

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Part of the tender documentation “Bill of Quantities” does not give thorough budget necessary to meet the environmental requirements under the EIA document

EU involvement in bid evaluation Y N Project Implementing Unit (PIU) environmental specialist is not involved in the bids evaluation process. Besides that, under the mentioned project an environmental specialist was included in the bid evaluation committee. The mentioned specialist had been invited from - American University of Armenia.

Contractor’s SEMP(s) reviewed Y Y SEMP document developed, needs and approved by PIU prior to further elaboration and update. contractor commencing work.

C. Construction Environmental Management Compliance (to be completed as relevant)

Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Monitoring data as per EMP monitoring Y Y The continuous monitoring plan requirements.5 of the SEMP implementation was carried out.

Unanticipated environmental impacts N Y Unanticipated environmental identified and assessed and options to impacts are not identified. address them evaluated.

Significant EHS incidents reported. N Y Cases of serious violations of environmental requirements were not found.

EMP reviewed and updated Y Y EMP is reviewed and updated (see

5 To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

recommendations).

Site inspection records ( Mitigation Y Y The Contractor’s field Compliance & Inspection Monitoring inspectors performed daily Forms) site visits to the project sites. YM Environmental team visited on project sites minimum once a weak. Environmental Consultant performed weakly site inspections.

Site inspection non-compliance Y Y No one noncompliance fixed notifications and corrective action requests. yet.

Complaints log. Y Y There is Compliance Books on sites

Environmental safeguard compliance Y Y Contractors prepare monthly included in project progress reports reports, which contain monitoring form on implementation of EMP in project.

Training/Capacity building activities N Y Required trainings are not undertaken as per EMP requirements. conducted yet (Training records)

Overall current status of project Y Y Contractors prepare monthly EMP/SEMP implementation reports, which contain monitoring form on (All mitigation measures identified in implementation of EMP in approved SEMP(s) to be itemized and project. evaluated as per implementation status)

Six monthly Environmental Monitoring Y Y Bi-Annual Reports, which Reports submitted to ADB and posted on YM submits to the ADB, they ADB website are available on the ADB web-site.

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Monitoring reports disclosed to local N Y All the above-listed reports communities and relevant government are available both, on the agencies6 construction site and at the head office YM. As for the Bi-Annual Reports, which YM submits to the ADB, they are available on the ADB web-site.

Final post construction Audit Report N Y Project is under completed development activities.

6 Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general perception of project impacts

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Appendix 2: Environmental Safeguards Compliance Monitoring Checklist For North– South Road Corridor Investment Program

Country safeguard review

Country : Armenia

Audit Date :

Project Data

Project Name: North–South Road Corridor Investment Program

Project Progress (%): 40%

Environmental Safeguards Categorization A B C

Overall Status of Compliance

 X 

Not compliant – Remedial action Mostly compliant - Minor Fully compliant & monitoring required remedial action & monitoring required

D. Safeguards Loan/Grant Covenants

Item No. Covenant Status of Compliance schedule 5, Implementation of environmental requirements Yes clause 2 included in the IEE.

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E. Environmental Management Planning (Preconstruction)

Item Status7 Follow up Comments/Actions required (Y/N) required (Y/N)

Environment Unit (EU) established N Y Within PMU the Environmental Unit within Project Implementation Unit (EU) was established. (PIU )

Environmental recording system Y Y The system of the environmental established in EU activity documentation was established in PMU. Engineering Consultant prepares the monthly environmentall reports for PMU on the project progress, containing information on the environmental requirements implementation. Documentation is also maintained on the results of the monitoring carried out by the PMU M&E Specialist and submitted in form of internal memo to the Project Manager, after that the relevant actions are taken against Contractors, if necessary.

Baseline monitoring completed Y Y The basic monitoring of environmental conditions was accomplished. Such requirements had been included in the EIA documents and it was responsibility of constructor company.

EMP requirements included in Y N The requirements of EMP observance tender documents were included in the bidding documents, the EMP itself was included in the bidding documents as

7 Documentary evidence of each item to be maintained in EU’s environmental recording system and made available for audit.

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the Annex 1.

EU involvement in bid evaluation N Y There is no ecologist in the bidding board composition.

Contractor’s SEMP(s) reviewed Y Y The contractor has submitted updated and approved by PIU prior to EMP, which now includes the issues contractor commencing work. identified in the project detailed design.

SEMP was prepared by Construction Contractor.

F. Construction Environmental Management Compliance (to be completed as relevant)

Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Monitoring data as per EMP monitoring Y Y Analyzes required by IEE plan requirements.8 are done by Construction Contractor.

Unanticipated environmental impacts N Y Unanticipated environmental identified and assessed and options to impacts are not identified. address them evaluated.

Significant EHS incidents reported. N Y There are no records.

EMP reviewed and updated Y Y The contractor has submitted updated EMP, which now includes the issues identified in the project detailed design.

Site inspection records ( Mitigation Y Y 7. There is quite a detailed Compliance & Inspection Monitoring questionnaires developed, Forms) which are used during the weekly inspections. There are relevant filled-in questionnaires on the construction site.

8 To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Site inspection non-compliance Y Y 8. Any fixed non-compliance is notifications and corrective action requests. officially registered and the contractor develops relevant corrective actions. All non- compliances and realized corrective actions are shown in the monthly reports. 9. Complaints log. Y Y Complaints book is placed at construction site.

Environmental safeguard compliance N Y The contractor drafts the included in project progress reports monthly reports about the environmental issues on their own.

Training/Capacity building activities Y Y 10. The trainings are held undertaken as per EMP requirements. permanently and there are (Training records) relevant records.

Overall current status of project Y/N Y 11. There are some problems EMP/SEMP implementation with placing the inert materials and topsoil. In all (All mitigation measures identified in other fields, all developed approved SEMP(s) to be itemized and mitigation measures are evaluated as per implementation status) undertaken.

Six monthly Environmental Monitoring Y Y 12. Semi-annual reports are Reports submitted to ADB and posted on permanently submitted to ADB website the bank and they are available on the ADB web- site. Monitoring reports disclosed to local Y Y 13. The environmental communities and relevant government specialists of all agencies9 organizations engaged in the project actively cooperate with the local population. In this respect, the actions accomplished within the scope of the project can be considered as a good example not only for

9 Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general perception of project impacts

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Armenia, but for other countries as well. Final post construction Audit Report N Y The final environmental completed audits have not been accomplished.

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APPENDIXES:

Appendix 3. Environmental Safeguards Compliance Monitoring Checklist For Water Supply and Sanitation Sector Project

Country safeguard review

Country : Armenia

Audit Date :

Project Data

Project Name: Water Supply and Sanitation Sector Project

Environmental Safeguards Categorization A B C

Overall Status of Compliance

 X 

Not compliant – Remedial action Mostly compliant - Minor Fully compliant & monitoring required remedial action & monitoring required

A. Safeguards Loan/Grant Covenants

Item No. Covenant Status of Compliance schedule 5, Implementation of environmental Yes clause 2 requirements included in the IEE.

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B. Environmental Management Planning (Preconstruction)

Item Status10 Follow up Comments/Actions required (Y/N) required (Y/N)

Environment Unit (EU) established Y Y One environmental specialist was hired within Project Implementation Unit within the PMU under the Project. (PIU )

Environmental recording system Y/N Y The system of the environmental established in EU activity documentation was established in PMU. In fact, there are no records about the environmental problems developed by the Construction Contractor. Documentation maintained on the results of the monitoring carried out by the PMU M&E Specialist and submitted in form of internal memo to the Project Manager, after that the relevant actions are taken against Contractors, if necessary.

Baseline monitoring completed Y Y According to the Framework Initial Environmental Examination Report prepared under the Project: “No new baseline monitoring is required” (Clouse VIII – “Framework Environmental Management Plan”).

EMP requirements included in Y N The requirements of EMP observance tender documents were included in the bidding documents, the EMP itself was included in the bidding documents and contract.

10 Documentary evidence of each item to be maintained in EU’s environmental recording system and made available for audit.

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EU involvement in bid evaluation N Y There is no ecologist in the bidding board composition.

Contractor’s SEMP(s) reviewed Y Y The PIU has submitted updated EMP, and approved by PIU prior to which now includes the issues contractor commencing work. identified in the project detailed design.

C. Construction Environmental Management Compliance (to be completed as relevant)

Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Monitoring data as per EMP monitoring N Y Under the monitoring plan of plan requirements.11 EMP, the responsibility for organizing the monitoring is the obligation of the Construction Contractor. The Construction Contractor does not organize environmental monitoring. The environmental monitoring is done by the PIU environmental specialist instead. Unanticipated environmental impacts N Y Unanticipated environmental identified and assessed and options to impacts are not identified. address them evaluated.

Significant EHS incidents reported. N Y There are no records.

EMP reviewed and updated Y Y The environmental specialist of PIU has submitted updated EMP, which now includes the issues identified in the project detailed design.

Site inspection records ( Mitigation N Y Quite detailed checklists are Compliance & Inspection Monitoring prepared. The mentioned Forms) checklists are the part of the Contract. Anyway,

11 To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Construction Contractor does not use the mentioned checklists. The mentioned checklists are used by the environmental specialist of PIU.

Site inspection non-compliance Y Y Non-compliance is fixed notifications and corrective action requests. officially and corrective actions are elaborated.

All non-compliances and implemented corrective actions are included in monthly environmental reports.

Complaints log. N Y The Complaints Book is not kept at construction site.

Environmental safeguard compliance Y Y Construction Contractor included in project progress reports does not prepare monthly environmental monitoring reports. The mentioned reports are prepared by the environmental specialist of PIU.

Training/Capacity building activities N Y None of the trainings were undertaken as per EMP requirements. conducted. (Training records)

Overall current status of project Y/N Y The majority of mitigation EMP/SEMP implementation (All mitigation measures are implemented. measures identified in approved SEMP(s) to be itemized and evaluated as per implementation status)

Six monthly Environmental Monitoring Y Y Bi-annual reports are Reports submitted to ADB and posted on submitted to the ADB ADB website permanently. They can be find at ADB web-site.

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Item Status Follow up Comments/Actions required (Y/N) required (Y/N)

Monitoring reports disclosed to local N Y Dissemination of monitoring communities and relevant government results among local agencies12 population is not implemented.

Final post construction Audit Report N Y The final environmental completed audits have not been accomplished.

12 Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general perception of project impacts

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