AFRICAN DEVELOPMENT BANK GROUP

SANITATION PROGRAMME FOR MUNICIPALITIES WITH LESS THAN 10 000 INHABITANTS - PHASE I

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK SUMMARY

July 2018

Programme Name : Sanitation Programme for Programme Number: P-TN-EB0-004 Municipalities with Less Than 10 000 Inhabitants Country : Department: RDGN Division : RDGN.2 Programme Environmental Category: 2 ------

1. INTRODUCTION

In compliance with the country’s Strategic Development Plan “Tunisia 2016-2020” and to improve the socio-economic, environmental and health conditions of Tunisia’s population by generalising sanitation services in all of the country’s municipalities, ONAS has embarked on the construction of sanitation facilities (systems, pumping stations and treatment plants) in 33 municipalities (Phase I) with less than 10 000 inhabitants.

The sanitation of these 33 municipalities will help to improve living, hygiene and environmental health conditions in small urban centres and contribute to protecting natural resources (water, soil, wildlife and flora) by reducing the negative impact of discharging crude wastewater into the natural environment (rivers, lowlands, wadis, etc.). It will adequately address the aspirations and grievances of citizens affected by the lack of a collective and reliable sanitation system that complies with health protection and environmental hygiene requirements.

The objective of the programme is to construct new wastewater treatment facilities, and renovate and modernise existing sanitation systems. These investments will improve wastewater treatment services for about 150 000 inhabitants, according to estimates, and contribute to limiting soil pollution in the programme areas.

Once the programme becomes operational, it is expected to generate significant benefits not only environmentally and socially, but also in terms of health and safety, especially through pollution prevention. However, the commissioning of sub-projects implemented under the programme may lead to some environmental and social problems that should be rapidly solved by mitigation and management measures.

Based on the outcomes of the environmental assessment conducted, ONAS’s capacity to manage this type of programme and the size of the facilities to be constructed, the programme has been classified under Environmental Category 2, in accordance with the Bank’s Environmental and Social Assessment Procedures (ESAPs 2015). It should be noted that any sub-project that may be classified under Environmental Category 1 will be excluded from the programme and will not be eligible for financing.

The programme has an Environmental and Social Management Framework, an Environmental, Social, Health and Safety Procedure, and a Land Procurement and Loss Compensation Plan.

This document is the summary of the programme’s Environmental and Social Management Framework (ESMF), which seeks to:

• Establish a specific environmental and social monitoring framework for sanitation projects with (i) the definition of procedures for preparing, disseminating, implementing and updating the environmental and social guidelines used; (ii) the institution of a system of socio-economic surveys to be conducted prior to works; and (iii) the establishment of a complaints management procedure;

• Develop a mechanism for the environmental, social monitoring and evaluation of ONAS’s activities with: (i) the development of environmental and social indicators for

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monitoring programme activities; (ii) the establishment of a sanitation sector environmental and social databank; and (iii) the retrospective supervision and evaluation of activities for the assessment of the effective consideration of environmental and social measures;

• Develop an environmental and social surveillance mechanism within ONAS based on: (i) information, education and communication (IEC) on the quality of ONAS’s projects and environmental actions; (ii) coordination, environmental and social exchanges between the sanitation sector and other government and non-government institutions; and (iii) management of complaints from programme beneficiaries and local residents.

2. PROGRAMME DESCRIPTION

The programme comprises three components: (i) Sanitation Facility Development (primary and secondary systems, transfer systems, pumping stations and treatment plants); (ii) Capacity Building and Institutional Support; and (iii) Programme Management (engineering studies, land procurement, operation and technical assistance).

2.1 Sanitation Facility Development

The works to be carried out in small municipalities include:

• The establishment\extension\rehabilitation of sanitation systems, including pumping stations;

• The construction of new treatment plants and rehabilitation of existing ones.

Table 1: Various Components of Sanitation Sub-Projects in Small/Medium-sized Municipalities Waste Water Pumping Backflow System Governorate Municipality Treatment Plant Transfer System Station (lm) (WWTP) (lm) Greater Department Khlidia Yes 2 2 000 2 000 North Regional Department Haouria WWTP 2 4 825 3 350 Menzal Horr Korba WWTP 3 3 740 2 000 Haouria WWTP 1 Ongoing 1 700 Jbel el Oust New WWTP 1 1 560 1 560 Nathour New WWTP Ongoing Ongoing 3 930 Le Kef New WWTP 1 760 3 600 Kalâa Khisba New WWTP Ongoing Ongoing 1 300 New WWTP 2 500 500 Sedjnene New WWTP 0 0 6 700 Béja Amdoun New WWTP Ongoing Ongoing Guebollat New WWTP 0 0 2 000 Oued Mliz New WWTP Ongoing Ongoing 1 120 Beni Mtir New WWTP 2 780 1 200 Centre Regional Department Hidra New WWTP Ongoing Ongoing 1 800 Nasrallah New WWTP 1 3 600 3 600 Menzil Mhiri Common WWTP 0 0 3 250 El Alâa WWTP 0 1 060 15 800 Monastir Amiret el Hojjej WWTP 2 572 4 200 Sidi Bennour Moknine WWTP 1 4 740 4 740 Manzel Hayet New WWTP Ongoing Ongoing 0

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Waste Water Pumping Backflow System Governorate Municipality Treatment Plant Transfer System Station (lm) (WWTP) (lm) Mehdia Mallolech WWTP 0 0 0 New WWTP Ongoing Ongoing 0 Manzel Hayet Ongoing Karkar Ongoing Ongoing New WWTP Sidi El Héni New WWTP 4 7 845 10 870 South Regional Department Dhhiba New WWTP 1 1 351 1 351 Rmeda New WWTP 3 2 620 1 800 Bir A Ben Khalifa New WWTP 1 1 200 2 000 New WWTP 1 800 800 Hammet Jrid New WWTP 1 200 200 Gabes Matmata Jedida New WWTP Ongoing Ongoing Ongoing Médenine Beni Khdech New WWTP Ongoing Ongoing Ongoing Kébili Faouar New WWTP 1 1 400 Ongoing 2.2 Capacity Building and Institutional Support - Study on the operation of sanitation systems in small municipalities (private sector participation); - Study on the reuse of treated wastewater (TWW) (with pilot sites); - Design and application of a software package for project planning and implementation; - Procurement audit and procedures manual. 2.3 Programme Management (engineering studies, land procurement, operation and technical assistance) At the regional level (regional departments - RDs): - Technical assistance for bid opening, monitoring and works control; - Monitoring of working design; - Monitoring of land, goods and works procurement; - Monitoring of works; - Monitoring of ESMP implementation and any abbreviated resettlement plans (ARPs).

At the central level (central departments): - General programme coordination; - Coordination of RD activities (procurements, studies, works monitoring, etc.). - Programme financial and accounting management; - Technical assistance to RDs.

The programme is implemented by an Operational Programme Management Unit (OPMU) based at the ONAS Headquarters.

The programme cost is estimated at EUR 163.3 million.

2.4 Programme Alternatives

The only programme alternative explored is the "without programme" situation, which consists in maintaining the current situation where domestic or industrial wastewater is discharged mostly into the natural environment without treatment (wadis or simply streets in front of houses). In practice, maintaining the current situation would mean further degradation of sanitary conditions and increase in the pollution load in programme areas, leading to more diseases and deepening poverty that is not consistent with Tunisia’s sanitation development policy.

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For each sub-project and during detailed engineering studies, the selection of the WWTP construction site alternatives, the transfer/backflow systems layout and the treatment process alternatives will be analysed. The selection will be based on environmental and social criteria to give preference to the most natural and human environment-friendly alternative.

3. NATIONAL AND REGIONAL BASELINE ENVIRONMENTAL AND SOCIAL INFORMATION

At end-2016, the key national sanitation indicators were as follows:

• Total urban population of about 7 million; • Population connected to the ONAS system: 6.3 million, representing 90.3 % of the total population. It should be noted that ONAS is not designed to cater for non-urban localities. • Number of WWTPs: 115 • System length: 16 337 kilometres. • Out of 260 million cubic metres of wastewater collected, 255.2 million cubic metres are treated annually, that is a 98.15% treatment rate. The programme impact area covers 33 municipalities in 19 governorates. These are mostly rural municipalities whose population does not exceed 10 000.

Table 2: Characteristics of Programme Municipalities Municipality Population Population\Male Population\Female Households Housing Units Khelidia 4 356.0 2 206.0 2 150.0 1 049.0 1 201.0 5 473.0 2 714.0 2 759.0 1 395.0 1 687.0 Azmour 5 057.0 2 486.0 2 571.0 1 281.0 1 545.0 Dar Allouch 4 547.0 2 343.0 2 204.0 1 229.0 1 617.0 Jebel Oust 5 325.0 2 757.0 2 568.0 1 284.0 1 476.0 En 7 567.0 3 764.0 3 803.0 1 806.0 2 176.0 Sedjnane 5 228.0 2 602.0 2 626.0 1 290.0 1 498.0 Amdoun 5 356.0 2 655.0 2 701.0 1 324.0 1 672.0 4 128.0 2 091.0 2 037.0 965.0 1 092.0 Beni M'tir 504.0 248.0 256.0 113.0 154.0 Oued Meliz 2 388.0 1 146.0 1 242.0 600.0 838.0 Nebeur 3 557.0 1 720.0 1 837.0 954.0 1 060.0 Kalâat Khasba 2 558.0 1 216.0 1 342.0 692.0 804.0 Kesra 2 729.0 1 315.0 1 414.0 739.0 888.0 Sidi El Héni 2 706.0 1 315.0 1 391.0 639.0 778.0 3 137.0 1 604.0 1 533.0 701.0 935.0 Sidi Bennour 4 520.0 2 149.0 2 371.0 1 045.0 1 199.0 Amiret El Hojjaj 8 121.0 4 119.0 4 002.0 1 679.0 1 778.0 7 478.0 3 749.0 3 729.0 1 602.0 1 866.0 Ouled Chamekh 5 120.0 2 262.0 2 858.0 1 126.0 1 420.0 Melloulech 6 919.0 3 338.0 3 581.0 1 536.0 2 030.0 Bir Ali Ben Khelifa 4 905.0 2 426.0 2 479.0 1 208.0 1 421.0 Skhira 11 912.0 5 967.0 5 945.0 2 506.0 2 851.0 El Alâa 3 276.0 1 564.0 1 712.0 783.0 875.0 Nasrallah 5 012.0 2 446.0 2 566.0 1 241.0 1 475.0 Hidra 3 451.0 1 668.0 1 783.0 929.0 1 080.0 7 526.0 3 607.0 3 919.0 1 798.0 2 380.0 Beni-Khedech 2 930.0 1 317.0 1 613.0 695.0 909.0 Dhehiba 4 295.0 2 145.0 2 150.0 777.0 986.0 6 289.0 3 101.0 3 188.0 1 084.0 1 344.0 Hamma el Jarid 4 074.0 1 970.0 2 104.0 953.0 1 048.0

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The sanitation situation in programme municipalities is characterised by:

- A sanitation system connection rate that varies from 0% to 40 % in the best case scenario. Black water (from toilets) from households and collective entities (primary schools, secondary schools, slaughterhouses, public coffee shops, etc.) are channelled to drainage ditches in the form of cesspools that are cleaned at various frequencies, depending on the usage. Municipal technical services are responsible, under state control or subcontracting, for draining off the ditches using cesspool emptying equipment;

- Disposal of effluents into the natural environment (effluents from wadis, spray areas, public landfills, etc.) or supplied to farmers as soil admendment products or fertilisers in spite of all the attendant health risks;

- Disposal of grey water (from sinks, showers and kitchens) outside households into gutters or directly into the streets, leading to permanent flow of wastewater that causes the proliferation of disease vectors and odours, especially during warm periods;

- Pollution and wastes that create all kinds of nuisances, especially in the rainy season, namely: (i) proliferation of odours and disease vectors (mosquitoes and flies); (ii) production of loaded and highly fermentable licheates; (iii) degradation of the living environment; (iv) health problems at several levels, etc.;

- In some areas, rise in the water table due to the infiltration of wastewater through many porous ditches;

- Infiltration of pollutants from ditches to stormwater collection reservoirs (Majels or Festkia), which poses a health risk;

- Uncontrolled use of faecal sludge by farmers for soil admendment, thereby generating a disproportionate health risk for them and consumers of any contaminated agricultural produce;

- Increased financial burden for poor and average-income families as well as public institutions and collective groupings considering the cost they have to bear to clean their septic tanks (close to TND 300/month for heavy water consumers, TND 6 to 7/month for households) ;

- Outbreak of diseases caused by the general lack of hygiene in unclean environments particularly affecting vulnerable people and school children who are exposed to the risk of contracting hepatitis A, typhoid fever and diarrhoea, leading to loss of schooling time;

- Undermining of the well-being and the quality of the environment of the people living near crude wastewater outlets (around natural drainages) or during the accidental overflow of septic tanks as a result of clogging or lack of means to ensure regular emptying, etc.

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4. REGULATORY FRAMEWORK

Tunisia’s domestic policies accord paramount importance to the environment in general, and environmental and social management arrangements in particular. Specifically, the new 2014 Constitution addresses issues related to climate, environment and natural resource management. Articles 12 and 45 of the Constitution respectively focus on "the judicious exploitation of national resources" and the role of the State in ensuring "the right to a healthy and balanced environment and participation in environmental protection".

Tunisia has put considerable effort into developing a varied legal and regulatory arsenal. The legal instruments governing environmental protection and applicable to the implementation of the Sanitation Programme for Municipalities with Less Than 10 000 Inhabitants include:

- Tunisia’s new Constitution adopted in 2014 ;

- Law No. 88-91 of 2 August 1988 establishing the National Environmental Protection Agency (ANPE);

- Law No. 2001-14 of 30 January 2001 simplifying the administrative procedures for the issuing of authorisations by the Ministry of Environment and Territorial Development;

- Decree No. 2005-1991 of 11 July 2005 repealing the 1991 decree on Environmental Impact Assessment (EIA);

- Water Code No. 76-75 ;

- Law No. 82-66 of 6 August 1982 on standardisation and Decree No. 85-86 on the regulation of discharges into the receiving environment;

- Law No. 83-87 on the protection of agricultural land, as amended by Law No. 96-104 of 1996 ;

- Law No. 95-70 of 17 July 1995 on water and soil conservation;

- Forestry Code No.88-20 of 13 April 1988;

- Law No. 30 of 6 March 2000 on the development of agricultural land in public irrigation areas;

- Law No. 2016-53 of 11 July 2016 laying down conditions for land use and the expropriation of property for public purpose, which repeals Law No. 76-85 of 11 August 1976 and Law No. 2003-26 of 14 April 2003;

- Law No. 96-41 of 10 June 1996 on wastes and the control of waste management and disposal;

- Law No. 2007-34 of 4 June on air quality.

Decree No. 2005-1991 of 11 July 2005 repealed the 1991 decree on EIA and introduced many major changes. It is being revised to incorporate the social dimension. The programme does not require environmental impact assessment or approval by the ANPE. In accordance with national regulations, only new water treatment facilities, irrespective of their capacity, are subject to an ESIA. Moreover, and in accordance with the same decree, existing WWTP connection projects are not subject to an EIA, but rather to specifications whose content complies with best practice.

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Table 3: Classification of Sanitation Projects by Decree No. 2005-1991 ANNEX I ANNEX II Category A Category B Specifications (Plant subject to a notice not (Plant subject to a notice not exceeding 3 (Low environmental impact exceeding 21 days) months) project) 1) Projects EXPLICITLY subject to EIA and EMP or specifications in accordance with Decree No. 2005- 1991 Project in areas irrigated by treated wastewater for agricultural purposes (explicit) RS Urban wastewater treatment plants RS (explicit) Industrial wastewater treatment plants (explicit) 2) Projects subject to EIA and ESMP or specifications by ANALOGY in accordance with Decree No. 2005- 1991 Household refuse management Household refuse management plants > Water transmission and plants < 20 T/D (sludge 20 T/D (sludge management plants by transfer canals (wastewater management plants by analogy) pipes by analogy) analogy)

It is worth noting that Decree No. 2005-1991 is being revised to incorporate social aspects and comply with international environmental and social standards.

Overall, environmental management is the responsibility of the Ministry of Local Governments and Environment and the various agencies under its supervision, namely:

• The National Sanitation Board (ONAS); • The National Environmental Protection Agency (ANPE); • The National Waste Management Agency (ANGED); and • The Coastline Protection and Development Agency (APAL).

Other ministries and entities concerned by environmental issues include: the Ministry of Public Health; the Ministry of Agriculture and Water Resources; the Ministry in charge of Budget; the Ministry in charge of Land Tenue, industrialists and non-governmental organisations (NGOs).

5. IDENTIFICATION OF POTENTIAL PROGRAMME ENVIRONMENTAL AND SOCIAL IMPACTS

In general, the impacts of a sanitation project are positive. They help to improve the quality of life of the population directly concerned, in addition to contributing to preserving the natural environment and providing an unconventional source of irrigation water and sludge for reuse in agriculture and industry (reuse of dry sludge in cement factories). Therefore, the programme will implement TWW reuse pilot projects in at least five municipalities. These projects that are consistent with the country’s integrated water resources management policy will help not only to meet the needs of some regions that lack water, but also to promote the use of TWW in various sectors, create new uses and contribute to settling the populations in small localities by offering them the opportunity to locally enhance their existing resources or create new sources of income.

Regarding risks and negative impacts, the ESMF considered ONAS’s various activities as comparable to those to be carried out under the programme and the impacts already identified in previous studies and projects.

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5.1 Impacts during the Construction Phase

Sanitation facility development and construction project works generate nuisances for the natural and human environment. These nuisances include: (i) land use and change of land use; (ii) alteration of the natural and biological environment by soil and biodiversity degradation; (iii) generation of various nuisances, especially the production of various wastes, construction site effluents, noises and vibration; and (iv) traffic disruption by the movement of machines and vehicles, and dust and combustion gas emissions. The level of these impacts is measured based on their scope, intensity and extent that vary according to their environment. A preliminary analysis shows that the scope of these impacts should be limited and restricted in space and time, considering that the programme will comprise no facility that generates major or irreversible negative impacts.

Aspects Major Potential Negative Impacts Land issue Procurement of small land and rights of way, change of land use and land tenure regularisation Environmental nuisances Noise and vibration, dust and combustion gas emission (greenhouse gases), production of wastes (household, special and hazardous, construction site excavations, etc.), water discharges Social impacts Disruption of road traffic and the movement of persons Danger, safety and Exposure to various on-site risks and hazards: working at a height without occupational health risks protection, risk of asphyxia while working in closed areas, insufficient protection while working at depth (trench, fall, etc.), road accident, hydrocarbon storage, employment not compliant with the labour code

5.2 Impacts during the Operation Phase

Impacts during the operation phase are controlled by ONAS, considering that its trade is the operation of WWTPs. ONAS manages over 170 WWTPs and is already establishing an ISO 14001 environmental management system in treatment plants. The impacts identified are summarised in the table below.

Facility Environmental and Social Aspects Environmental and Social Impacts Concerned Wastewater • Land • Drop in the value of land around WWTPs treatment plant • Production of screening, cleaning and • Environmental nuisances and health risks (WWTP) desilting by-products related to the management of cleaning products • Water bypass in the event of a and equipment maintenance breakdown or other hazards • Risk of surface water, water table and marine • Quality of effluents at the inlet and environment contamination outlet of the WWTP and performance • Risk of treated water contamination by trace measure metals • Air quality analysis (existence or • Bad odours and complaints from local absence of an air freshener system) inhabitants • Energy consumption • High energy cost (cost of a cubic metre treated) • Decanting of other effluents (non- • Disruption of the WWTP process, output and collective systems and others) performance • TWW intended for reuse (agriculture, • Health and trace metal accumulation risk (soil replenishment of water tables) and water table) Pumping • Odours • Bad odour-related nuisances and complaints stations • Disposal of cleaning and screening from local inhabitants wastes • Effluent bypass in the natural environment and • Effluent quality risk of environmental and health nuisances • Industrial effluents and intrusion of • Environmental contamination by wastes, illegal discharges sludge and cleaning sand • Energy consumption • Relatively high cost of lifting a cubic metre of effluent (energy) Wastewater and • Domestic wastewater • Health risks for facility operators and users, effluents • Stormwater especially farmers • Industrial effluents • Surface water contamination

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• Cooling water • Water table contamination • Marine and beach pollution • Risks related to trace elements (heavy metals) Collection and • De-clogging activities and cleaning of • Exposure health risks for operators and supply systems collectors, manholes, inlets and sewer workers drains, and as appropriate, stormwater • Production of wastes (wastes, sludge and sand) overflows and grit and connection and their impacts on the natural environment chambers and health • Waste disposal • Disruption of traffic and the movement of • Industrial effluent monitoring people during maintenance works and • Control of intrusions and accidents maintenance of systems (illegal discharges) Sanitation • Wastewater sludge • Risk of water table contamination (leachates sludge • Industrial effluent sludge and metals) management • Bad odours and complaints from local dumps inhabitants • Health risks for operators

6. PROCEDURES FOR ASSESSING POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS SPECIFIC TO PROGRAMME SUB-PROJECTS AND PROCEDURAL MEASURES

The programme has identified 33 sub-projects based on the strategic sanitation study conducted in 2015 on 80 municipalities with less than 10 000 inhabitants. The list includes 24 new WWTPs and 9 sub- projects for connection to existing WWTPs and, eventually, rehabilitation. Considering that detailed engineering studies (including specific impact assessments in accordance with national law) are ongoing, the ESMF has developed a procedure to take into account Donor environmental procedures in the environmental analysis approach. The process is summarised below.

6.1 Stage 1: Description and Eligibility

The objective of Stage 1 is to ascertain that each sub-project is eligible for financing based on the E&S policies of the AfDB and its financial partner EBRD, which exclude any Environmental Category 1 sub- project. In this regard, the procedure has developed specific forms to be filled to guide the work of the Environmental and Social Monitoring Unit (ESMU).

6.2 Stage 2: Risk Assessment and Management, and Environmental, Social, Health and Safety (ESHS) Impacts

This stage includes the process to be followed to conduct environmental and social assessments. In that connection, ONAS will consult the general terms of reference defined by ANPE for the activity sectors concerned by the preparation of an ESIA as well as any supplementary social assessments according to Donor requirements.

The ESIA and the ESMP must be prepared using a progressive and iterative approach to help ONAS to decide on the feasibility of its sub-project or envisage other alternatives to arrive gradually at a least risk solution.

The content of the ESIA must be participatory and comprise the following elements at least: (i) a detailed project description; (ii) an analysis of the initial project site and its environment; (iii) an analysis of project environmental impacts; (iv) proposal of recommended negative impact mitigation measures and related cost estimates; and (v) proposal of an Environmental and Social Management Plan (ESMP) together with an environmental monitoring programme.

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Review and approval of environmental and social assessment reports: at the national level, for projects subject to an ESIA according to Decree No. 2005-1991, the review of the ESIA and the ESMP is the responsibility of ANPE, which notifies its approval by issuing an environmental compliance certificate. The ESIA/ESMP as well as any other supplementary study will also be transmitted to AfDB and its financial partner for approval.

Information and dissemination of environmental and social assessment reports: once the ESIA, the ESMP and, eventually, the ARP, if required, are approved, ONAS, for purposes of transparency and accountability, particularly regarding the key stakeholders, will place the said documents at the disposal of the public in municipalities, delegations, governorates and regional sanitation offices, and on its website. Donors will provide support for such dissemination.

The procedure states that consultation timeframes must enable the consideration of useful feedback from persons and groups that would also have consulted the key documents produced (ESIA, ESMP and ARP) and the revision of the documents.

As part of strengthening ONAS’s communication policy, ESMU will establish a database for monitoring the environmental and social status of ONAS’s activities. The database will be fed with data provided and communicated by environment focal points. The data will help to inform ONAS’s key environmental and social indicators. An annual environmental and social status report will be produced by ESMU and posted on ONAS’ website. The template of the ONAS annual environmental and social status report has been specified in the procedure.

6.3 Stage 3: Project Implementation and Monitoring

E&S clauses: the procedure provides for the incorporation of subproject-related additional environmental and social clauses (as identified in the ESMP(s)) in the bidding documents during project launching in the studies or works phase, or when leasing out the operation of ONAS’ WWTPs and other facilities. A sample price schedule has been prepared and provided in the procedure.

Implementation of environmental and social measures: the contractors legally and contractually responsible for implementing the ESMP during the construction phase will also undertake to strengthen: (i) the participation of the local population concerned; (ii) the mainstreaming of the gender dimension; and (iii) complaints management. In addition, as project owner, ONAS will strengthen social communication through its current citizen space on its website.

Measures implementation monitoring/evaluation: during programme implementation, the contractor(s) responsible for programme implementation will report to ONAS on the implementation of the environmental and social measures provided for, in accordance with the programme documents (ESMP), the status of mitigation measures and the outcomes achieved. Monitoring the implementation of programme environmental, social, health and safety measures is described in the table below.

Responsibility Monitoring Reference Framework Periodicity Reporting Works contractor’s Construction site’s Monthly report to Works contract terms health, safety and Continuous ONAS’ Regional ESHS contractor’s HSE Works contractor’s HSE environmental during works Officer Officer Management Plan performance (form available) approved by ONAS Wastewater Monthly report to ESHS performance of the Works contractor’s HSE treatment plant ONAS’ Regional ESHS wastewater treatment Management Plan Continuous operator’s HSE Officer plant approved by ONAS Officer

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Responsibility Monitoring Reference Framework Periodicity Reporting ESHS performance of the wastewater collection Semi-annual report to and treatment facilities of Tunisia’s legislation Monthly visit ONAS’ Regional ESHS ONAS’ Regional small towns of the region to each small Officer ESHS Officer covered by the Sanitation Programme ESHS town and to OPMU’s ESHS Programme for Procedure Team Municipalities with Less Than 10 000 Inhabitants Field control of six sub- Good and bad practice OPMU’s ESHS Programme ESHS Semi-annual projects: 3 most efficient sharing note to all Team Procedure during works and three least efficient Regional ESHS Officers ONAS’ Central Tunisia’s legislation ESHS Officer AfDB and EBRD E&S Semi-annual report to policies During works AfDB and EBRD OPMU’s ESHS ESHS procedure of the Programme’s ESHS Team Sanitation Programme for Performance Municipalities with Less ONAS’ Central Than 10 000 Inhabitants Annual report to AfDB ESHS Officer After works Environmental and Social and EBRD

Action Plan

To ensure its implementation, the programme has included a technical assistance that will solicit the services of an independent expert/ group of experts responsible for ascertaining contractors’ compliance with the actions and measures provided for in the ESMPs that will be adjusted if necessary, or in case of failure to comply.

7. ADDITIONAL MEASURES TO BE INCLUDED IN SUB˗PROJECT ESMP

Based on programme environmental impact assessment, a battery of measures has been proposed for each sub-project development phase.

7.1 Measures during WWTP Design

During WWTP design study and sizing, some rules and recommendations contained in the technical specifications of facilities should be considered to facilitate the management of facilities and ensure their efficiency in producing a discharge that complies with standards.

Table 4: General Recommendations and Specifications to be Considered in the Design and during the Operation of the Sanitation System Ref. Elements Recommendations and Specifications to be Considered I General Recommendations and Specifications for the Sanitation System 1.1 Selection of ❖ Based on the comprehensive study of the physical features of the study area and socio- sanitation system economic conditions 1.2 Stormwater drainage ❖ Must be sized to dispose of runoff rates resulting from the heaviest rainfall at a given system frequency (2.5 years or 10 years, depending on the size of the urban centre) 1.3 Disposal plan layout ❖ The water disposal plan layout must be prepared by making utmost use of the topography of the land to ensure, as much as possible, a gravitational flow with sufficient flow speeds. It is necessary to limit the number of lift and pumping stations for economic reasons and owing to operating conditions 1.4 Selection of receiving ❖ As much as possible, avoid discharging wastes into closed water environments (lakes, environment ponds, etc.), owing to their fragile ecological balance ❖ Avoid directly discharging wastes into seashore sensitive areas (near beaches, gulfs, unfavourable sea currents, etc.) ❖ Ensure the watertightness of the system at the crossing of water tables to avoid their pollution and control the volume of infiltrated water ❖ Avoid constructing the plant in a flood-prone area 1.5 Limit the release of ❖ Provide for sufficient flow speeds to avoid the formation of permanent deposits nauseating odours ❖ Provide system head sections with a flush ❖ Avoid cascade lifting

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Ref. Elements Recommendations and Specifications to be Considered ❖ Increase the flow speed in airlift pumps (reduce wastewater residence under anaerobic conditions) II Specifications for Wastewater Treatment Plants (WWTPs) 2.1 Screening ❖ The flow speed through partially plugged screens must be maintained within the range of 0.6 m/s and 1.2 m/s ❖ Change screen wash pumps from manual to automatic ❖ Provide for the possibility of isolating screens to ensure their maintenance and repair (cofferdam). 2.2 De-silting ❖ Use mechanised aerated grit chambers each time that the size of the plant so requires ❖ Schedule frequent sand extraction and washing ❖ Increase the size of aerated grit chambers, with an appropriate hydraulic loading ❖ Adjust the scheduling of sand extraction sequences 2.3 Primary settling ❖ Apply low hydraulic loading to avoid carrying sludge during hydraulic overloading (during rain) ❖ Schedule frequent extraction of decanted sludge to avoid foul odour 2.4 Aeration ❖ Give preference to membrane diffusers for efficient aeration management ❖ Immersed railings with bubble diffusers must be isolable and adjustable ❖ Use double speed boosters for maximum management flexibility ❖ Sound insulation and ventilation of booster compartments are compulsory ❖ Where many settling tanks are used, each tank should have a booster. Air circuits must be interchangeable (adapted winnowing system) ❖ An emergency booster is advisable even for small facilities ❖ Provide for dust filters ❖ Drain cocks should be fixed at low points ❖ Steel and stainless steel should not be juxtaposed (corrosion cell) ❖ The presence of compounds that are aggressive to elastomers (hydrocarbons) in wastewater should be checked 2.5 Agitation ❖ The aeration and agitation functions must be separated to optimise nitrogen elimination and prevent deposits during the shutdown of aeration ❖ Mixed liquor flow speed at the tank bottom must be above or equal to 35 cm/s ❖ The capacity of stirrers varies depending on the geometry of the tanks 2.6 Clarification ❖ Frequently extract sludge from the bottom of clarifiers to prevent their fermentation. Sludge residence at the bottom of clarifiers must not exceed 2 hours ❖ Ensure extensive upstream denitrification to prevent denitrification in the clarifiers that could lead to sludge flotation ❖ The bottom scraper should be easily pulled out by the operator, especially without having to empty the decanter. Bottom rollers are forbidden ❖ Louvre-like bottom scrapers (discontinuous) increase sludge residence. Scrapers made of a single continuous blade are recommended III Specifications for Sludge Treatment 3.1 Sludge thickening ❖ Sludge must not be resident in the thickener for long to prevent its fermentation ❖ Preferably use cover thickeners ❖ Hydraulic loading must not be high to avoid sludge overflow 3.2 Sludge digestion ❖ Digester sludge intake must be regular and, as much as possible, continuous ❖ There should be a scum breaker mechanism to prevent the consolidation of the floating layer on the surface of the digester 3.3 Lagooning ❖ The plant must be located at a low point (to ensure gravity supply), at a place where dominant winds contribute to aerating surface water column ❖ There should be no trees within 10 metres of the plant as their roots could create preferential flows in the dykes ❖ The land should be selected in such a way as to ensure gravitational flow right to the receiving environment ❖ The geometry of the lagooning tanks must be selected so as to minimise dead bands and short circuits ❖ Dykes surrounding tanks must be sufficiently large to enable the movement of machines

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7.2 Mitigation Measures during the Construction Phase

7.2.1 Framework for Mitigating Impacts on the Construction Site

In general, the construction site should be installed on an authorised site selected beforehand by ONAS. It should be easily accessible, located near the project site and at least 400 metres from residential areas, fenced and clearly signalled. The measures include provisions to limit impacts and nuisances related to the movement of machines and impacts on the soil, particularly farmland. Construction materials (sand, gravel, debris, etc.) should be stored on the construction site far from the workers’ camp to avoid dust emissions and sound nuisances caused by the movement of machines and vehicles.

The impact mitigation framework includes the storage of hydrocarbons, flammable and/or hazardous products (hydrocarbons, mineral oils and other flammable and/or hazardous products) and specifies, among other things, storage conditions and the control of accidental spills.

In case of an accident and/or a fire on the construction site, an Emergency Response Plan (ERP) prepared beforehand by the Contractor in charge of works will be implemented.

7.2.2 Framework for Mitigating Construction Site Noises and Sound Nuisances

The ESMF specifies the thresholds for noise exposure as defined by World Health Organization (WHO) standards for residential (local residents) and work (employees) areas. It also includes monthly campaigns to measure the noise level on the construction site and its surrounding areas. The measured noise level will be compared with the level recommended by WHO and levels recommended for various occupational settings by the International Organization for Standardization (ISO).

7.2.3 Construction Site Solid Waste Management

Solid waste will be managed in accordance with Law No. 96-41 of June 1996 backed by the following additional measures:

Inert waste, household and similar waste: the procedure in force specifies the methods of collecting (containers) and sorting waste: (i) inert waste, depending on the existence of a waste recycling sector, especially construction waste; (ii) household and similar waste to be disposed of in municipal landfills; (iii) unused excess debris to be channelled to the nearest municipal landfill and/or ANGED.

Hazardous waste: the appropriate measures considered concern waste oils at the Tunisian Lubricants Company (SOTULUB), which is the main company that processes and recycles waste, oil-contaminated rags, filters and other special waste to be channelled to the Hazardous Waste Treatment Centre for processing after informing and consulting ANGED, and used batteries collected and stored at the construction site before returning them to producers (for example, the Tunisian Battery Company – ASSAD).

7.2.4 Construction Site Liquid Waste and Wastewater Management

Workers’ camp liquid waste management: installation of watertight drainage ditches for wastewater collection to be drained periodically, and channelling of wastewater to the nearest wastewater treatment plant (WWTP) by an approved company.

Construction site liquid waste management: where the construction site has a machine cleaning and maintenance platform, clear water from the machine and vehicle washing water collection ditch will be collected and reused in watering roads to reduce dust emissions.

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7.2.5 Gas and Dust Emission Mitigation Measures

The Tunisian Standard NT 106.04 for ambient air quality will be applied, in addition to the watering of roads and traffic areas, and the maintenance and regular technical control of all construction site machines and vehicles in accordance with the regulations in force to avoid excessive fuel consumption and reduce exhaust fumes, particularly greenhouse gases (GHGs).

7.2.6 Soil Erosion and Facility Silting Control Measures

The Contractor will endeavour to limit the risk of soil erosion, flooding of the construction site, roads and feeder roads, farm-to-market roads and the silting of water works. The Contractor must prevent groundwater contamination by draining stormwater and excavation floor water towards existing drainage channels.

7.2.7 Management of Concession Holder Networks

The Contractor is contractually obliged to take all the necessary measures to prevent any damage to the piping, pipes, various cables, roads and road networks crossed during works execution. As-built drawings will be prepared in full consultation with the concession holders concerned to implement the potential system displacement operations.

7.2.8 Hygiene and Safety Measures

Proper construction site organisation includes taking appropriate safety measures to protect local residents and workers against the risk of accidents associated with the execution of works and the movement of machines, ensuring strict compliance with safety and hygiene instructions in accordance with the regulations in force and signs on the construction site (prohibition of access, speed limits for machines on the construction site and roads, and the shoring up of excavations).

The Contractor is contractually obliged to provide personal protective equipment – PPE (helmets, gloves, protective footwear, goggles, etc.) to construction site workers and to sensitise workers and visitors on their use.

7.2.9 Site Restoration upon Completion of Works

Site restoration is a contractual clause reinforced by a special mention in case of accidental damage, which the Contractor is bound to correct at his own expense.

7.3 Measures during the Operational Phase

7.3.1 WWTP Water Quality Monitoring Framework

A programme to control and monitor the quality of crude water before the WWTP inlet and after treatment will be designed to monitor the plant’s performance. Analyses and observations will be conducted upstream and downstream of the WWTP. The aim will be to monitor the flow and quality of water at the WWTP inlet (crude water) and outlet (treated wastewater) to identify anomalies that may affect the performance of the WWTP. Water samples will be collected and analysed using an automated sampler as much as possible to ensure that treated wastewater is consistent with the NT 106.02 standard. The frequency of water collection and analysis is specified in the section on environmental monitoring. ONAS has a non-compliance early warning mechanism that involves the intervention of the WWTP manager.

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Regarding the storage pond containing treated wastewater to be reused to water public spaces, the parameters of analysis also concern the biological and bacterial quality of treated wastewater: heavy metals, Escherichia coli, faecal coliforms and salmonella and helminthic eggs, vibrio cholerae and viruses, in keeping with the NT 106.03 standard.

7.3.2 Framework for Monitoring Water Quality in the Receiving Environment

Where WWTP wastewater is discharged into a river or lake receiving wastewater from the upstream basin, biological and bacterial quality analysis will be carried out in three plants, namely: the ONAS discharge point (WWTP outlet), a plant downstream of the ONAS discharge point (where there is natural flow) and a plant after mixture with the wastewater released upstream (wastewater from a source other than the WWTP). The main parameters to be monitored are suspended solids (SS), chemical oxygen demand (COD), five-day biochemical oxygen demand (BOD5), nitrogen, phosphorus and bacteriological parameters.

Two piezometers will be placed on the water table located near the WWTP and the receiving environment: one in the WWTP and the other near the WWTP downstream wastewater-receiving environment in the direction of flow of the water table1. A control piezometer should be selected upstream of the WWTP discharge point and adopted as a baseline to measure the impact on the water table. Two piezometer readings will be taken yearly, one at the end of the rainy season and the other at the end of the dry season. The readings will concern: (i) the piezometric level; and (ii) the physico- chemical quality (BOD5, COD, salinity, total nitrogen, total phosphorus and the biological water quality: Escherichia coli, total coliforms, faecal coliforms and salmonella).

On the water table located near water reuse areas, a control piezometer will be placed in/near each reuse perimeter in the direction of the water table flow to monitor the water quality and the impact of reuse. The piezometer will preferably be placed within the perimeter or on a site within a radius not exceeding 400 metres around the perimeter in the direction of the water table flow. Two readings will be taken yearly, one at the end of the rainy season and the other at the end of the dry season. The readings will concern: (i) the piezometric level; and (ii) the physico-chemical quality (BOD5, COD, salinity, total nitrogen, total phosphorus and the biological water quality: Escherichia coli, total coliforms, faecal coliforms and salmonella).

A groundwater point will be selected upstream of the perimeter and/or reuse area to serve as control in order to monitor the impact of reuse on the water table.

7.3.3 Framework for Climate Change Adaptation

As a climate change adaptation measure, the programme includes a Wastewater Reuse Component under which five pilot sites will be set up. This action will enable ONAS to implement some actions in the small municipalities alongside the works executed to improve the quality of wastewater from major WWTPs.

7.3.4 Framework for Risk and Hazard Management

WWTPs are classified, unhealthy and hazardous facilities and, hence, require the adoption of strict safety and hygiene measures from design to personal protection, hygiene and control of hazards. The WWTP operator must provide personal protective equipment (PPE) such as mono-frame goggles, respiratory protective equipment (disposable FFP 2 half-mask respirators, gas filters, full-face masks, etc.), waterproof gloves, etc., as well as work clothes. This equipment should be selected based on the risks incurred by workers and adapted, regularly maintained and stored in a clean and dry place. Personal protective equipment supplement collective prevention measures. Hygiene measures help to limit risk of contamination faced by workers. They should be simple, well-known and implemented by workers.

1 Use existing wells if they are located within 400 metres to 500 metres from the WWTP in the direction of the flow of the water table.

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In keeping with the regulations governing classified facilities, WWTPs should be the subject of hazard studies, as well as a plan for the prevention of accidents included in works execution studies. These studies should include:

- The hazards and risks incurred in interventions in sanitation facilities; - The prevention of risks in interventions in confined spaces; - Regulatory requirements and related documents, in keeping with the Labour Code; - The protective equipment necessary for the operation of WWTPs; - Measures to prevent the main risks associated with the operation of WWTPs and sanitation facilities (falling, drowning, noxious gases, etc.).

7.4 Summary of Environmental and Social Measures:

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Table 5: The Environmental and Social Management Framework to be used during the Execution of Sanitation Works Entity Control/ Potential Environmental Impact Proposed Actions Estimated Cost (TND) Timeframe Responsible Monitoring 1. Institution Building Appoint an environmental and social focal point (ESFP) in ONAS. ONAS FP Considered by ONAS Immediate Disruption of the natural and socio- Appoint a hygiene and safety (HSE) officer within the Company. Contractor ONAS Included in the contract At project start-up economic environment in the Recruit an environmental consultant to provide technical support to ONAS in project area ONAS PF/ONAS ONAS At project start-up supervising ESMP implementation. Train the senior officers of ONAS in construction site ESMP implementation and monitoring procedures. At project start-up Building the capacity of ONAS and Train the technicians of public works and civil engineering companies in the and periodically companies in construction site mainstreaming of the environmental and social aspects at the construction site ONAS ONAS ONAS during the environmental management and compliance with regulations. execution of procedures and guidelines. Sensitize construction workers on compliance with environmental, safety and works. hygiene rules and regulations. 2. Construction Site Installation Select a location for the installation of the construction site. RPGES Before project Contractor Included in the contract Approve the construction site selected by ONAS’ ESFP, in consultation with the ANPE start-up ESMU. Installation of the construction site Define storage areas for building materials, hydrocarbons, water, and waste. Comply with product storage rules. RPGES Contractor Included in the contract At project start-up Adopt best practices for managing nuisances at the construction site (dust ANPE emissions, wastewater, waste, traffic, noise, etc.). 3. Construction Site Impact Management Measures Land tenure regularisation: ONAS/Land Considered by the Land tenure- and land use-related Compensate project-affected persons. ONAS Tenure Immediate project issues. Service Changes in land use. Restore land. RPGES Restore access roads. Contractor Impact on the population. ANPE Restore the networks of project-affected concession holders. Restore land near the project area. Collect, reuse and/or evacuate excess debris from the construction site to an approved landfill. Contractor/ Upon project start- Modification of the landscape. Restore installations (SP, technical premises, buildings, WWTPS, etc.) on the Contractor Included in the contract RPGES up construction site natural landscape by planting hedges in green spaces. Avoid traffic in the farmlands located near the construction site right-of-way. Reinforce signals at the construction site. Risk of water table and soil ANPE/ Upon project start- Dig a watertight wastewater drainage ditch. Contractor Included in the contract contamination by construction site RPGES up

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Entity Control/ Potential Environmental Impact Proposed Actions Estimated Cost (TND) Timeframe Responsible Monitoring sewage: wastewater, contaminated Ensure that the ditch is drained regularly by a company approved by ONAS and water from the construction site that wastewater is transferred to the nearest WWTP for treatment. (cleaning of vehicles and machines, Dig a machine and car wash water drainage ditch and build a machine emptying of excavations, etc.). maintenance platform on the construction site, if necessary. Equip the machine and car wash water drainage ditch with an oil separator/degreaser. Drain clear water and reuse it to water roads. Regularly maintain the oil separator and channel the waste grease to approved treatment centres. Equip fuel storage tanks and watertight waste oil retention tanks with sand. Risk of contamination of surface Drain oil-contaminated sand to a specific landfill. ANPE/ Upon project start- water, the water table and soil by Contractor Included in the contract RPGES up waste oil and fuel leakages. In the absence of a specific platform, prohibit the execution of equipment maintenance operations at the construction site. Design a traffic plan for the movement of machines and vehicles in the project area. Risk related to machine and vehicle Provide for the required safety and security measures during the transportation ANPE/Traffic movement. of construction site equipment and materials. Upon project start- Contractor control police/ Included in the contract Cover trucks transporting debris and building materials (sand, gravel, etc.) with up Disruption of road traffic and the RPGES movement of people and animals tarpaulins. Install the required roads signs (machine and truck exit and speed limit). Water access roads to the construction site and near urban centres and farmlands. Impact of the accumulation of Collect and dispose of household waste into a controlled landfill. construction site waste on water Ensure the collection and recovery of used oils and filters by SOTULUB. resources, farmlands and the health Collect and store excess debris and construction waste in an area reserved for of workers and local residents. that purpose at the construction site and dispose of them into an appropriate Household waste. landfill (authorisation by ANGED and municipalities). ANPE Miscellaneous waste: wood, metals, Reuse topsoil to develop green spaces. ANGED Upon project start- Contractor Included in the contract plastics, etc. Collect, sort and place waste (plastics, metal, wood, cardboard, etc.) at the Municipalities up Special waste: used oils, used oil disposal of recyclers. RPGES filters and grease towels, batteries Prepare an appropriate area to store waste before channelling it to the landfill for and tyres, etc. treatment. Construction waste. Traceability: register the various types and monthly quantities of waste produced Excess debris. at the construction site. Occupational hazards at the Sensitize and train construction workers on safety and hygiene rules and ONAS Upon project start- Contractor Included in the contract construction site. regulations. RPGES up

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Entity Control/ Potential Environmental Impact Proposed Actions Estimated Cost (TND) Timeframe Responsible Monitoring Protect hazard-prone areas by adopting appropriate safety measures (work at a height or in excavations, risk of falling objects, etc.). Equip workers with PPE (helmets, protective footwear, gloves, goggles, etc.). Provide for a first aid kit. Install signs on roads and construction site access roads. Strengthen control, safety, security and hygiene measures. 4. Rehabilitation and Restoration of the Construction Site Upon Completion of Works Disruption of farmlands. Dismantle construction site installations. Contamination of soil by Rehabilitate septic tanks. wastewater, waste, etc. Rehabilitate pits and construction site water collection basins, and treat Contractor ANPE Upon project Included in the contract Contamination of water by contaminated sludge. ONAS RPGES completion hydrocarbons and waste oil Rehabilitate the fuel storage site. leakages. Collect and channel waste to appropriate landfills.

Table 6: Environmental and Social Management Framework to be used during the Operation of Sanitation Facilities Frequency and Institution Responsible/ Entity Estimated Cost Proposed Measure Monitoring and Control Actions Assessment Concerned Responsible (TND) Appointment of ONAS’ Environmental and Social Focal Point (ESFP). Appointment of an EO in the WWTP’s Operating Service (sub- ONAS (RPGES/EO-WWTP branch). CRDA/Focal Point Appointment of focal points (CRDA, municipalities, Industry, Health/Focal point Health, etc.). Envisaged by Monthly Industry/Focal Point ONAS Fielding of a periodic environmental intelligence mission upstream ONAS Municipality/Focal Point and downstream of the WWTP. ANPE/Focal Point Periodic reporting (monthly, quarterly and yearly). Technical Institutional support and TA/ESMP assistance in environmental and social management, if need be. capacity building Designation of a civil society association (if necessary) to support public consultation, communication and complaints management. Building the capacity of the RPGES and the EO of the WWTP. ONAS (RPGES/EO-WWTP Building the capacity of the Operating Service and the Health, CRDA/Focal Point Health/Focal Point Safety and Environment (HSE) Officer of the concession holder Provided in Periodic Industry/Focal Point ONAS (in case of a private operation). technical assistance Municipality/Focal Point Information, Education and Communication (IEC) of actors, ANPE/Focal Point beneficiaries and civil society. TA/ESMP

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Frequency and Institution Responsible/ Entity Estimated Cost Proposed Measure Monitoring and Control Actions Assessment Concerned Responsible (TND) Industrial waste control: major classified facilities producing heavy metals, hydrocarbons, oils and fats/phenols. ONAS (RPGES/EO-WWTP Monitoring of the volume and quality of water at the inlet/outlet of CRDA/Focal Point Monitoring water quality the WWTP. Monthly Health/Focal point (CWW, TWW, Monitoring the volume and quality of treated wastewater intended Monthly Industry/Focal Point ONAS ** groundwater (EDN), to be reused for agricultural purposes: storage station and basin. Monthly Municipality/Focal Point surface water (EDS)) Monitoring the quality of water tables: 3 stations: control, at the Half-yearly ANPE/Focal Point WWTP and in the irrigation area using treated wastewater. TA/ESMP Monitoring the quality of surface water (wadi, lake, sea, etc.): 2 stations: upstream and downstream of ONAS’ discharge points. Monitoring of noise and Measurement of noise in at least two plants: the WWTP (premises sound nuisances at the ONAS (RPGES/EO-WWTP and work areas): dB01 and SP: dB02 ... B0i. WWTP, SP and other Monthly Health/Focal Point ONAS ** Measurement of noise 200 metres around the WWTP and SP (at equipment (vehicles and TA/ESMP least 2 plants) maintenance equipment) ONAS (RPGES/EO-WWTP Measurement of H2S in at least two plants: WWTP and SP. Monitoring the quality of Monthly Health/Focal Point Fuel consumption during operation (rolling stock and generators). ambient air and foul odours: Monthly Municipality/Focal Point ONAS ** Energy consumption (electricity and gas) H2S and other GHGs Monthly ANPE/Focal Point Calculation of WWTP GHG emissions. TA/ESMP Collection, storage and disposal of pretreatment waste into ONAS (RPGES/EO-WWTP approved landfills and implementation of SP and system Health/Focal Point Management of WWTP maintenance operations (sand, grease, oil, etc.) Daily Municipality/Focal Point ONAS ** waste and sludge Management of sewage sludge: quantity, quality, quantity reused ANGED/Focal Point and reuse sector TA/ESMP Monitoring of moisture content and soil organic matter CRDA Monitoring soil quality Monitoring of heavy metals in the soil (compare with a control Annual CRDA ** TA/ESMP (if necessary) metal). Preventive measures: ONAS (RPGES/EO-WWTP ONAS Monitoring of the health status of workers in the WWTP. CRDA/Focal Point Monthly CRDA ** Monitoring of the health status of workers in the irrigation area. Health/Focal Point Health Health & safety Monitoring health status in the project area. TA/ESMP surveillance Emergency Response Programme (ERP): ONAS (RPGES/EO-WWTP

Treatment of mosquito breeding grounds within the WWTP site. Health/Focal Point Monthly ONAS ** Treatment of mosquito breeding grounds outside the WWTP Municipality/Focal Point (systems and SP) TA/ESMP **: The financial estimate is being done, in consultation with ONAS.

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8. SUB-PROJECT MONITORING AND SUPERVISION ARRANGEMENTS

8.1 Institutional Arrangements

The Environmental and Social Monitoring Unit (ESMU) will control and supervise the implementation of the ESMF. It will be backed by the services of technical assistance experts provided for under the programme.

At the local level, institutional arrangements will be organised in ONAS regional departments. An environmental and social focal point (ESFP) will be part of the staff of each department concerned. He/she will be in charge of implementing the environmental and social management framework. ESFPs will also receive support and advice from the central services of ONAS in general, and ESMU in particular, as well as from the decentralised services of various ministries and national agencies.

An Environment Officer (EO) will be appointed in each WWTP (branch). The EO will be the only interlocutor of the ESFP and ESMU for ONAS and various project stakeholders. Where a project is implemented by a construction company or through an operation lease, a Hygiene, Safety and Environment (HSE) Officer will act as the interlocutor of the focal point and the environment officers of the WWTP. HSE experts will be responsible for updating the ESMP at project start-up, under the supervision and guidance of ESMU. These experts will ensure that the Contractor implements the ESMP. It should be noted that ANPE will also be responsible for control, which falls within its remit as a public entity, during the construction and operation phases.

Figure 1 below presents a diagram of the relationships between ESMU and various stakeholders and partners.

Figure 1: Institutional Organisation Chart

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8.2 WWTP Environmental and Social Surveillance and Monitoring Procedures Manual

The following monitoring templates and forms have been developed for the programme: - Pro-ESMP.01 : Recruitment of an EMP Consultant - Pro-ESMP.02 : Appointment of the Environment Officer of the WWTP - Pro-ESMP.03 : Appointment of focal points - Pro-ESMP.04 : Template of WWTP ESMP supervision reports - Pro-ESMP.05 : Template of ONAS’ annual environmental and social management report - Pro-ESMP.06 : Capacity building - Pro-ESMP.07 : Monitoring of the quality of wastewater discharges - Pro-ESMP.08 : Monitoring of noise nuisance within and around the WWTP - Pro-ESMP.09 : Monitoring of gas emissions - Pro-ESMP.10 : WWTP waste management - Pro-ESMP.11 : Monitoring of soil quality in PPI

The table below summarises the environmental surveillance criteria used in a WWTP and in related facilities. Table 7: Environmental Surveillance of Sanitation Facilities Components/Activities Monitoring and Evaluation Indicators Responsibility Rate 1. Air quality Station manager H2S content Pumping station Environmental and Social 5/7 days Quantity by instrument Focal Point (ESFP) Station manager H2S content WWTP Environmental and Social 5/7 days Quantity by instrument Focal Point (ESFP) 2. Noise pollution Station manager Sound level measurement Pumping stations Environmental and Social Weekly (<80 dB) Focal Point (ESFP) Station manager Sound level measurement WWTP boosters Environmental and Social Weekly (< 80 dB) Focal Point (ESFP) 3. Measures envisaged for the management of non-recoverable waste Screening products Quantity stored Station manager Weekly De-oiling products Quantity stored Station manager Weekly Grit removal products Stock position Station manager Weekly Non-marketed digested /dry Stock position Station manager Weekly sludge 4. Measures to protect ground water, surface water and receiving water bodies Overflow of pumping stations Registered, date and reason Station manager Occasionally Overflow of the WWTP Registered, date and reason Station manager Occasionally 5. Monitoring the quality of wastewater and sludge in the WWTP Quality analysis/Average 24-hour Wastewater at the inlet WWTP Laboratory 5/7 days sample Treated water from the Quality analysis/Average 24-hour WWTP Laboratory 5/7 days secondary sedimentation tank sample Quality analysis/Average 24-hour Stabilised/dry sludge WWTP Laboratory 5/7 days sample Quality analysis/Average 24-hour Gas composition WWTP Laboratory 5/7 days sample

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9. COMMUNICATION AND CONSULTATION ARRANGEMENTS

The ESMF has proposed a public consultation framework that aims to ensure the social acceptability of projects and activities at the community level by establishing a network for sharing information on environmental issues and on the projects among all actors. The consultation process addresses the need to fully involve the population in identifying needs and monitoring/evaluating activities to promote control by citizens, the sharing of knowledge and expertise, participation, and social efficiency. Similarly, the involvement of local inhabitants guarantees project sustainability inasmuch as it enables them to own the project and its objectives.

To comply with this comprehensive approach, ONAS is expected to prepare two master plans, namely:

- A plan for communicating with non-governmental organisations;

- A plan for coordinating activities with stakeholders.

The ESMF will be open for public consultation through the Validation Committee comprising the main donors and representatives of various ministries involved in environmental and social management in Tunisia. The public will also be involved to express their opinion regarding the design of the environmental impact assessments of sub-projects and to peruse the ESIA reports systematically posted on ONAS’ official website.

10. REQUIREMENTS FOR TRAINING AND BUILDING CAPACITY IN ESMF IMPLEMENTATION

To ensure the sound implementation of the ESMF, the institutional framework hinges on the establishment of a new Department of Quality, Safety and Environment (DQSE). The Environmental and Social Monitoring Unit (ESMU) in charge of environmental and social management in general will be attached to the new DQSE.

ONAS’ Environmental and Social Monitoring Unit (ESMU) will play its environmental and social management role only if it is provided, on a regular basis and as much as possible in real time, with the required skilled human resources and information on the status of projects being implemented, and equipment and infrastructure being operated and their performance, as well as any anomalies and malfunctions that may occur. To that end, it is necessary to prepare an organisational and technical capacity-building plan that includes:

- Reinforcing the central level with qualified human resources (a socio-economist responsible for communication, complaints management, etc.);

- Appointing, at the regional level, focal points as Environment Officers in ONAS’ departments as well as environmental and social branches in each WWTP;

- Organising various training sessions on environmental and social management for ESMU senior officers and workers.

Since the participatory process instituted by this ESMF will involve the local population, national entities (ministries and institutions involved), local NGOs and regional partners, the framework provides for a training and capacity-building plan. The plan is aimed at helping various target groups to understand public consultation procedures and to ensure the implementation of various phases of public consultation in accordance with the principles of this ESMF and the requirements of various international donors by:

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- Preparing a simplified guide for various target groups to enable them to better understand and apply the provisions contained in the ESMF regarding the participatory approach;

- Organising training sessions on public consultation. It is important for the trainers involved in these training sessions to have the required skills in managing relations with the public and NGOs, interactive communication, mediation and synthesis.

Concerning complaints management and despite the presence of a “civic interface” on ONAS’ official website and a toll-free number, the complaints management practices in force are not harmonised, monitored or evaluated. It is necessary to adopt an action plan to strengthen the communication and complaints management systems. The plan will include:

- Upgrading the existing system to include the complaints management mechanism (CMM), ensure information reciprocity to address citizens’ complaints and resolve any potential social conflict in time;

- Preparing practical and didactic guides to: (i) provide concise information aimed at facilitating the understanding of the different elements of a communication and complaints management system; and (ii) present concrete examples to receive, process and handle various claims. These guides and others will be used as materials for providing training and assistance for understanding and implementing this ESMF;

- Providing training and technical assistance to build the skills of ONAS’s senior officers and workers in the participatory approach, environmental and social communication, and complaints management.

11. ESMF IMPLEMENTATION COST

The ESMF implementation cost covers mainly the training of senior staff, the design and production of communication and awareness leaflets, the recruitment of environmental and social approach specialists who will be incorporated into the ESMU as technical assistance staff, and the land procurement plan. The overall cost estimate is broken down as follows:

Table 8: Breakdown of Programme Cost by Component, including ESMF Implementation Cost Estimated Cost in Million Component/Sub-component TND EUR A Development of Sanitation Facilities 446.9 148.6 B Capacity Building and Institutional Support (including E&S aspects) 3.0 1.0 C Programme Management: - Environmental and social technical assistance over a 4-year period, of which 18 months of permanent presence of the 41.3 13.7 Technical Assistance staff (TA) - Land Procurement Plan implementation cost Total 491.2 163.3

12. CONCLUSION

The environmental assessment is deemed positive considering that each sub-project is relatively small, Tunisian regulations provide for the conduct of an ESIA and the implementation of an ESMP for each new WWTP, as well as the environmental and social management procedures established and adopted by ONAS. Programme implementation will significantly contribute to improving the living conditions of inhabitants of target municipalities and protecting the natural environment against the sources of pollution and degradation. The programme will have no major negative impact on the environment.

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It will be recalled that any sub-project that has been classified under Environmental Category 1 following the conduct of specific environmental impact assessments will not be included in the programme, in keeping with the eligibility criteria for financing under this programme. The measures recommended and arrangements proposed for managing various sub-projects are vital elements for leveraging and ensuring the sustainability of sanitation facilities, and will help to properly manage environmental and social risks.

13. REFERENCE DOCUMENTS AND CONTACT PERSONS

13.1 Reference Documents

- Mission for the Design of an Environmental and Social Management Master Plan and Assistance to ONAS’ Environmental and Social Monitoring Unit – CEFED/SEETE Group, January 2018 edition.

- Land Procurement and Loss Compensation Framework – ONAS, June 2018.

- Tunisia: Small Towns Sanitation Programme – ONAS –Environmental, Social, Health and Safety Procedures – Alpage Environmental and Social, March 2018 edition.

- Tunisia: ONAS’ Small Towns Sanitation Programme –– Stakeholder Participation Plan – Alpage Environmental and Social, April 2018 edition.

- Tunisia: ONAS’ Small Cities Sanitation Programme –Environmental and Social Assessment Report – Alpage Environmental and Social, March 2018 edition.

- ONAS’ Environmental Policy.

13.2 Contact Persons

For ONAS Mrs Waslati Dhouha, Programme Monitoring Officer, E-mail: [email protected]

For the AfDB Mr BenSassi Belgacem, Chief Water and Sanitation Engineer, RDGN.2, E-mail: [email protected] Mrs Beya BCHIR, Environmentalist, SNSC/RDGN, E-mail: [email protected]

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