Environmental Monitoring Report

Project Number: 43309-013 Loan: 2839/8254/3442 and Grant: 0278

CAM: Provincial Roads Improvement Project

Environment Project Completion Report

October 2020

Prepared by Ministry of Public Works and Transport for the Asian Development Bank.

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

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

KINGDOM OF

MINISTRY OF PUBLIC WORKS AND TRANSPORT

PROVINCIAL ROADS IMPROVEMENT PROJECT ADB LOAN 2839-CAM (SF)/8254-CAM (SCF)

Environmental Project Completion Report

October 2020

Korea Consultants International (KCI) in association with Dainichi Consultant Inc., Sambo Engineering Co., Ltd. and Hankuk Engineering Consultants in Sub-consultancy with Moha Engineering & Consulting Co., Ltd., SBK, KACE and SAWAC

Contents

1. Project Description and Rationale ...... 7

2. Safeguards Implementation Arrangements and Loan Covenant ...... 8

2.1. Establishment of ESO ...... 8

2.2. Loan Covenants ...... 9

3. Design Phase Performance...... 9

3.1. 4.1 Safeguard activities ...... 9

4. Implementation Phase Performance ...... 9

4.1. Safeguard Activities ...... 9 4.1.1. Contract CW‐A: Improvement of NR13 in and Provinces ...... 9 4.1.2. CW‐A‐1 Improvement of Side Drainage on NR13 ...... 11 4.1.3. Contract CW‐B1: Improvement of PR314D in Svay Rieng ...... 11 4.1.4. Contract CW‐B2 (CBF) for Improvement of the Prey Var CBF ...... 11 4.1.5. Contract CW‐C: PR150B, NR53, and PR151B in Kampong Chhnang and Kampong Speu ...... 12 4.1.6. Contract CW‐D1: Climate Resilience, Reconstruction of Portanorn, Bakdao and Srok Dikes in Kampong Leaeng ...... 12 4.1.7. Contract CW‐D1‐1 Srok Dike Slope Protection ...... 13 4.1.8. Contract CW‐ D‐2 Climate Resilience; Dredging for Khsaet Lake ...... 13 4.1.9. Contract CW‐D3: Kampong Leaeng Water Supply ...... 13 4.1.10. Contract CW‐D3‐1: (Climate Change Resilience Additional 3 dikes) ...... 13 4.1.11. Contract CW‐D3‐2: Climate Change Resilience, Boeng Kruos dike ...... 14 4.1.12. Contract CW‐D4: Construction of Emergency Management Center and Safety Areas in Kampong Leaeng 14 4.1.13. Contract CW‐D5 Climate Resilience, Tree Planting Program ...... 15

4.2. Key Issues and Actions Taken ...... 15 4.2.1. Corrective Action Reports (CARs) ...... 15 4.2.2. Site Clearance ...... 16

5. Sustainability ...... 18

5.1. Contractors Performance ...... 18

5.2. MPWT Manual ...... 18

5.3. ESO Capability ...... 18

5.4. Trees Planting and wilting ...... 18

6. Lessons Learned ...... 19

7. Recommendations ...... 21

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8. Annexes ...... 22

8.1. Annex A Loan Covenants ...... 22

8.2. Annex B Environmental Parameters Contract Packages CW‐A, CW‐B1, CW‐ B2, CW‐C, and CW‐D .... 24

8.3. Annex C Tree Growth Monitoring Contract documents ...... 28

Figures

Figure 1-1 Location Map of PRIP ...... 7 Figure 4-1 Condition of Shinohydro main contractor campsite, on NR13 ...... 10 Figure 4-2 EMC building after construction and site clearance ...... 14 Figure 5-1 Tree Planting Confirmation ...... 19

Tables Table 4-1 Gumkang Visvakam Samnang JV Package CW-C Corrective Action Reports ... 15 Table 4-2 Overall Physical Progress and Site Clearance July 2020 ...... 17 Table 8-1: Environmental Parameters Contract Packages CW-A, CW-B1, CW- B2, CW-C, and CW-D ...... 25

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Abbreviations

AADT Annual Average Daily Traffic AASHTO American Association of State Highway and Transportation Officials ADT Average daily traffic ADB Asian Development Bank BER Bid Evaluation Report CBF Cross Border Facility CBR California Bearing Ratio CBRS Community Based Road Safety COI Corridor of Impact DBST Double Bituminous Surface Treatment DCP Dynamic Cone Penetrometer DDIS Detail Design and Implementation Supervision DFID Department for International Development (UK) DMF Design and Monitoring Framework DOE Department of Environment DPWT Department of Public Works and Transport EA Executing Agency EARF Environmental Assessment and Review Framework EIA Environmental Impact Assessment EIRR Economic Internal Rate of Return EMP Environmental Management Plan ESA Equivalent Standard Axle (identical to ESAL) ESAL Equivalent Standard Axle Load FRMR Fund for Road Maintenance and Repair GPS Global Positioning System GVW Gross Vehicle Weight HDM-4 Highway Development and Management Model HGV Heavy Goods Vehicle HH Household HHTP Human Trafficking Prevention Program HIV human immunodeficiency virus IBRD International Bank for Reconstruction and Development IEE Initial Environmental Examinations IMF International Monetary Fund IPDP Indigenous People Development Plan IOL Inventory of Losses IRC Inter-Ministerial Resettlement Committee IRI International Roughness Index

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IRR Internal rate of return JICA Japanese International Cooperation Agency ILO International Labor Organization LBAT Labor-Based Appropriate Technology LGAP Labor and Gender Action Plan MAG Mines Advisory Group MEF Ministry of Economy and Finance MMS Maintenance Management System MOE Ministry of Environment MPWT Ministry of Public Works and Transport MRD Ministry of Rural Development MOWRAM Ministry of Water Resources and Meteorology NCDM National Committee for Disaster Management NGO Non-Governmental Organization NAA National AIDS Authority NMT Non-motorized transport NPV Net Present Value NR National Road NRSC National Road Safety Committee NWRDP North-Western Rural Development project PK Point kilométrique. Chainage marker “5+123” means 5,123 metres from the start point PMU3 Project Management Unit 3 (of MPWT) PPCR Pilot Project for Climate Resilience PPTA Project Preparation Technical Assistance PRIP Provincial Roads Improvement Project PSA Poverty and Social Assessment RGC Royal Government of Cambodia RoW Right of Way RP Resettlement Plan RSAP Road Safety Action Plan RTAVIS Road Traffic Accident and Victim Information System SBST Single Bituminous Surface Treatment SEACAP South East Asia Community Access Program SEO Social and Environment Office UXO Unexploded Ordnance VDC Village Development Council VOC Vehicle Operating Costs WB World Bank WG Working Group

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1. Project Description and Rationale

1. Following a request from the Royal Government of Cambodia (RGC) the ADB approved Loan 2839-CAM in December 2011 for the Provincial Roads Improvement Project (PRIP). This will improve the roads and associated infrastructure such as border crossings of Prey Veng and Svay Rieng provinces in Southeastern Cambodia, and Kampong Chhnang and Kampong Speu provinces in the Mid-West of Cambodia. 2. The roads will connect national highways and provincial towns giving all weather access to basic facilities and services. The project has targeted existing unpaved and paved roads in poor condition in the four provinces and improved them to a paved road standard with double bituminous surface treatment (DBST) or single bituminous surface treatment (SBST). 3. The project also improved bridges and other drainage structures such as box culverts, pipe culverts, and side drainage systems. A new cross border facility was built at Prey Veng. 4. The works were extended in Kampong Chhnang to provide flood control and enhanced irrigation through new dikes and drains. An Emergency Response Centre was also constructed. 5. The Ministry of Public Works and Transport (MPWT) is the Executing Agency (EA). The Project Management Unit 3 (PMU3), part of the General Department of Public Works of MPWT, is the implementing agency. 6. The impact of the project is improved access to markets, jobs, and social services. The outcome of the project is a safe, climate-resilient and cost effective road network that provides all-year access in the agricultural areas of the project provinces. The project will help around 640,000 beneficiaries in local communes residing in the four provinces of Kampong Chhnang, Kampong Speu, Prey Veng, and Svay Rieng. The project locations are given below.

Figure 1-1 Location Map of PRIP

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7. The Project is classified as environment category B and an initial environmental examination (lEE) was conducted as part of project preparation in accordance with ADB Safeguard Policy Statement of 2009 (ADB SPS). This report examines the environmental aspects of the project now that it is completed.

2. Safeguards Implementation Arrangements and Loan Covenant

2.1. Establishment of ESO 8. MPWT established the Environmental & Social Office (ESO) as a division in the Department of Planning, MPWT in 2009. There are now 6 staff within Environmental and Social Office (SEO): 1 Chief, 1 Vice chief, 2 Resettlement, 2 Environment & Social Safeguards. It is considered that this now makes them effective. 9. The ESO, through the PMU3 of MPWT, has conducted environmental and social monitoring of all project activities. In the event of non-compliance with environmental issues related to project implementation, ESO as part of MPWT, can instruct contractors to comply with the environmental safeguard guidelines. 10. During detailed design an IEE was carried out which contained an EMP (Environmental Management Plan). The EMP was included in the bidding documents issued for civil works during procurement. The contractors were required to include the requirements of the EMP when submitting their bids. The conditions in the EMP then became contractually binding on the contractors. 11. The EMP included in the bidding documents is, of necessity, general in scope. Following selection of a contractor, the contractors were required to submit a CEMP (Contractors Environmental Management Plan). The CEMP had to be site specific and give details of mitigation and management measures taken to avoid, reduce, and mitigate any adverse environmental impacts and so achieve compliance with the EMP in the contract documents. 12. Construction supervision was implemented by the consultants. Their site inspectors carried out regular inspections on environmental performance. Checklists were established and controlled by the construction supervision inspectors who made daily spot checks and weekly formal checks on site operations. The checklists were used for record purposes and to ensure that any complaints or incidents were brought to the notice of the contractor immediately, verbally and with a follow up written notice. 13. To verify the environmental assessments done by checklist, site visits were conducted to several selected roads by the National Environmental and National Social-Gender Specialists in cooperation with Resident Engineers, Assistant Resident Engineers of the subprojects and contractors, and discussion held with site workers and local communities. 14. In the event of a non-compliance issue verbal warnings were given to the contractor followed by written instructions. These actions were recorded as Corrective Action Reports (CARs). (see below section 5.2) which were brought to the attention of the ESO and PMU. 15. Non compliance issues could result in financial penalties being imposed on the contractor by PMU. In the first instance this could be withholding scheduled payment. In the final case, for example if a site was not cleared properly, then PMU could authorize clean up actions and back charge the contractor. 16. Failure to comply with the EMP could ultimately result in MPWT not releasing the 5% retention (5% of total contract value) held by MPWT as a guarantee against good environmental performance.

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17. Poor performance is recorded and can be taken into account when assessing future bids and tender submissions. 18. For this project completion report, the national environmental specialist and national social-gender specialist of DDIS Consultants team conducted field monitoring in May, June and July 2020. They met with construction staffs/workers, site engineers and local people.

2.2. Loan Covenants 19. The project complies with the Loan Covenants as stipulated in the Loan Agreement related to environment.  Schedule 5, Para. 2; “the borrower shall ensure that any requirement under the Environmental Safeguards are applied and implemented..”.  Schedule 5, Para. 9 and 10; “the borrower shall ensure that all bidding and contract documents for consulting services …. and for contractors … include relevant provisions of the EMP..”.  Schedule 5, Para. 13: “the borrower shall submit semi-annual monitoring reports...”.

For full text of the loan covenants refer to Annex A.

3. Design Phase Performance

3.1. Safeguard activities 20. Changes were made to the original design to derive more environmental benefits. The climate resilience of the project roads was increased by following the MPWT Non-Mandatory Guidelines for Flood Proofing Roads prepared under Loan 2839-CAM (SF)/ 8254-CAM and Grant 0278-CAM Project Climate Resilience for Provincial Road Improvement Project. 21. The design was modified to give water capture and storage systems based on natural rain fall capture, gravity flow and dikes. An emergency management centre was designed and constructed in as a pilot community centre with participation of the Red Cross to sustain the emergency medical facilities.

4. Implementation Phase Performance

4.1. Safeguard Activities

4.1.1. Contract CW-A: Improvement of NR13 in Prey Veng and Svay Rieng Provinces 22. Contract CW-A is the improvement of National Road13 with structural works along the National Road No13. The starting point of the project is the junction of NR8 (designated Point Kilometre (PK 0+000) in and the end point is the junction of NR1 (PK62+430) in . 23. The road has been upgraded to DBST along a length of 62.43 km with reconstruction of structures. The local communities state they are happy with the DBST road and there are no key safety issues or complaints raised by local people. The main contractor Sinohydro Company has a main campsite for vehicles and materials. Location - PK 4 NR13

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Figure 4-1 Condition of Shinohydro main contractor campsite, on NR13 24. This camp has not been removed. Sinohydro prolonged the leasing contract with the owner as they wish to keep the site for their own purposes. They want to keep their equipment in this location until they mobilize to a new project. There are only a few Chinese staff standing by waiting for a new project. There were several subcontractors with campsites as well:  Subcontractor - Mr. Samnang - Location - PK 14 NR 13: This work camp is cleared and was removed in 2017. The land owner developed the area for their own business purpose since taking back after Mr. Samnang finished his works in 2017, removed his equipment and cleared the site.  Subcontractor - Mr. Ty- Location - PK 22 NR 13: This work camp was cleared in 2019 and all equipment removed. Subcontractor, Mr. Ty had rented land and a house during the working period. The areas were taken over by owner after work completed in 2019.  Subcontractor - Mr. Veasna - Location PK 24 NR 13: This work camp has been cleared of all equipment. Sinohydro and Mr. Veasna occupied this area during construction. The demobilized and removed everything after work finished in 2019.  Subcontractor - Mr. Kheang - Location - PK 40 NR 13: The work camp is removed and all equipment and materials cleared in 2019.  Subcontractor - Mr. Bunly - Location - PK 52 NR 13: This work camp is removed and was cleared of all equipment after the work finished. The house and land were taken back by the owner after Mr. Bunly finished works on NR 13 in 2019.

Key Issues:  The construction of NR 13 and road structures are completed. However, the main contractor Sinohydro campsite is not removed. The equipment and waste materials

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are not cleared. Sinohydro have extended the lease on the property in anticipation of future work.

4.1.2. CW-A-1 Improvement of Side Drainage on NR13 25. This work was carried out under the Climate Resilience packages to provide extra side drainage on NR13. The Contractor was 6 Star Construction Co. Ltd. whose camp was at PK 62 NR 13. There were no effects to land use or on local structures in these road sections because the drainage was installed in the road shoulder which is part of the RoW (Right of Way). 26. There was no campsite for the drainage installation. The construction staff rented a house for temporary accommodation of the workers. All the equipment and construction materials have been removed. There are no complaints from local people. Local people are happy and support the subproject as it will reduce the flood from run-off in their village areas. Land has been cleared and all materials moved from the site. No environmentally sensitive issues.

4.1.3. Contract CW-B1: Improvement of PR314D in Svay Rieng 27. The starting point of the project is the junction of NR1 at Svay Teap and the ending point is at Kampong Ro which is the Cambodia-Vietnam border, where the Prey Var CBF will be located. 28. SINOHYDRO Corporation Limited is the main contractor for the project. There was one subcontractor. The local communities are happy with this improved DBST road and there are no issues or complaints from local people. The work camp at PK8 is cleared and all equipment removed. The area was reinstated back to its original condition after of works were completed and the rental period finished. Subcontractor - Mr. Veasna had a camp at PK14 on PR314D. The equipment and waste were removed in May 2020. Other temporary work camps on Road 314D were cleaned and all equipment removed. One tank was remaining and Mr Sek Mony the subcontractor site supervisor was asked to remove it. The tank on the site was removed on 18 July 2020. Key Issues:  The subcontractor campsite has been removed. There are no polluting wastes or construction materials left on the site. One tank needed to be removed and has been taken away.

4.1.4. Contract CW-B2 (CBF) for Improvement of the Prey Var CBF 29. The Cross Border Facility (CBF) is being constructed at Bavet, Svay Rieng province to facilitate cross border transport between Cambodia and Vietnam. Work is substantially complete. Taking over certificate was issued on 21 July 2020. The main contractor is Tan Kim Eng Co. Ltd. There was no work camp for construction workers. The workers came from nearby communes and went back to their houses in the evening time, after working hours finished. The contractor rented a house for use as an office and for some staffs who stayed in the CBF building. A temporary work camp was established with tents in which workers could rest in the day time inside the CBF site. The contractor provided the tent and toilets for lunch time rest periods. Now the temporary work camp and tents have all been removed. Key notes and Issues:

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 The CBF site is located far from any village areas. There are only rice fields and the casino buildings around the CBF site. There are no forest and protected areas near the site  Construction workers were seen not using Personal Protective Equipment (PPE). A CAR form was issued and the situation corrected. Subsequent checks confirmed that PPE was being worn.  Most construction worker come from this area and go back home at night.

4.1.5. Contract CW-C: PR150B, NR53, and PR151B in Kampong Chhnang and Kampong Speu 30. CW-C is the improvement of PR150B, NR53, and PR151B with structures work along the provincial roads located in Kampong Chhnang and with the road upgraded to DBST. The local people are very happy with a good road, no dust and no mud in wet weather. The main contractor is a joint venture with Gumkang Construction Co., Ltd and Visvakam Samnang Construction Co.,Ltd. JV. Land for the contractor's worksite and campsite belongs to government office. One condition imposed on the contractor in the rental agreement was to backfill area, install a perimeter fence and erect buildings for the land owner. Most of the camp facilities and equipment was removed, there were two pieces of plant remaining and the contractor committed to remove all equipment by end of July 2020 and handover to the land owner. The contractor’s buildings will then become the property of the Land Owner. There are two subcontractors.  Subcontractor - Mr. Van Votha. Location - Main campsite. The work camp is cleared and all equipment moved. No equipment is left on the site.  Subcontractor - Mr. Um Ratha. Location - 150B. The temporary works camps on NR53, 150B, and 151B were removed in 2019, when the roads were completed. All are now cleared.

Key issues:  The subcontractor campsites are all moved out. There are no wastes and construction materials remaining on the site.  The main contractor campsite of Gumkang-Visvakam JV will remain as it will revert back to the owner. All equipment belonging to the contractor will be removed before handover at the end of July 2020. The contractor’s buildings will then become the property of the Land Owner. This is part of the rental agreement.  The contractor Gumkang-Visvakam JV was constantly reminded to improve his standard of general housekeeping and was issued many written reminders and CAR notices of EMP noncompliance. His attempts to correct the situation were minimal but the impacts were not severe enough to warrant issuing a stop work order. Also bad weather had delayed the works schedule and there was a desire to complete the works as soon as possible.

4.1.6. Contract CW-D1: Climate Resilience, Reconstruction of Portanorn, Bakdao and Srok Dikes in Kampong Leaeng 31. Royal Mekong Construction & Development Pte., Ltd is the Contractor for the project. The scope of works is;  Embankment work for 0.56km of Portanorn dike,

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 Embankment work for 2.3km of Bakdao dike  Embankment work for 2.65km of Srok dike  Reconstruction of 12 water gates, 2 spillways  Rip-rap and gabion boxes The community supported this project as it offers flood control and irrigation water. Some local villagers were employed on the site as unskilled workers. These staff stayed in their own houses at the nearest village. A few workers from other areas stayed in the work camp with equipment parked on the construction site. Now the temporary work camps are cleared and removed. There are no construction materials and waste remaining on the sites or on the dikes as all have been cleared and removed since 2018. There were no specific environmental safeguard issues on this site.

4.1.7. Contract CW-D1-1 Srok Dike Slope Protection 32. Taing Cheng Oing Construction & Import Export Co. Ltd is the Contractor for the project. Works were :  Embankment 2,926 m3  Grouted Riprap 6,720 m3 The rehabilitation of the Srok dike is finished in July 2020. The temporary work camp with tents and materials have been cleared and removed. A house was rented by the contractor in Svay Rumpear for use as a construction office and proving a place for staff to stay. This was a short contract with little interaction with local residents. There were no specific environmental safeguard issues on this site..

4.1.8. Contract CW- D-2 Climate Resilience; Dredging for Khsaet Lake 33. Tan Kim Eng Co., Ltd is the Contractor for the project. Scope of works is:  Dredging about 110,000m3 of lake bed material  7 water gates The dredging of the lake was completed at the beginning of 2018. The works uses little equipment, mainly an excavator and needed very few workers. There was no accommodation camp site, the temporary work camp was removed in 2018. There were no significant effects on the environment. No complaints or issues were raised from local communes, and they supported the project. There were no specific environmental safeguard issues on this site..

4.1.9. Contract CW-D3: Kampong Leaeng Water Supply 34. Contract CW-D3 was to be Construction of Kampong Leaeng Water Supply. However, after considered review by all parties it was cancelled and replaced with CW-D3-1: Dikes and CW-D3-2: Dredging both in Kampong Leaeng. No issues.

4.1.10. Contract CW-D3-1: (Climate Change Resilience Additional 3 dikes) 35. K.B.H. Construction Co., Ltd is the Contractor for the project. The scope of works is :  Embankment and Subbase works for 3 dikes  Construction of 14 water gates,  Rip-raps and gabion boxes All the dikes sites are located in dry rice field, far from village area and the rehabilitations follow existing dams or dikes. There are no conservation or forest areas nearby. Work was carried out in areas that are dry, with almost no water remaining in the reservoirs behind the dikes. Consequently, there was no adverse effects on local water quality from dikes rehabilitation activities. No complaints were received over noise and air quality. The dike rehabilitation

13 works could only be undertaken in the dry season. The equipment used was excavation machines with a small number of workers. There were no permanent accommodation camps in the dike sites. There was only small campsite with plastic tents which were used in day time. At night time the workers went back to their village which is 1-2 km from the dike. The contractor rented one house for use as a work site and for staffs working at the site. Equipment operators stayed at the same place as used for parking. Workers were local villagers who stayed at their own home. All the temporary work camp sites are cleared and all materials removed. There were no specific environmental safeguard issues on this site.

4.1.11. Contract CW-D3-2: Climate Change Resilience, Boeng Kruos dike 36. K.B.H. Construction Co., Ltd is the Contractor for the project. Scope of works:  Dredging 27,370m3 of material from lake bottom Several villagers were employed on the site. All villagers were in favor of the project. No complaints were received. There was no accommodation camp site due to the work site being near the village area. The site work was only dredging of the lake and all working was limited to within the boundary of the lake. The dredged material was used to raise the elevation of the embankment of the perimeter road. The works camp has been cleared. There were no specific environmental safeguard issues on this site..

4.1.12. Contract CW-D4: Construction of Emergency Management Center and Safety Areas in Kampong Leaeng 37. There is one Emergency Center (EMC) built in Kampong Hau Commune, Kampong Leaeng District Town, Kampong Chhnang Province and six Safety Areas. Scope of works was :  One (1Nos.) two-floor building  Raise the elevations of 6 safety areas  Retaining wall  Installation of toilet at agreed safety areas The contractor is Tan Kim Eng Co., Ltd. The EMC building has been cleared of all debris after construction in Kampong Leaeng District. The work camp is cleaned and all construction materials were removed in 2018. There were no adverse environmental issues and no complaints from local communities.

Figure 4-2 EMC building after construction and site clearance

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4.1.13. Contract CW-D5 Climate Resilience, Tree Planting Program 38. The planting began in November 2017. Planting for NR13 and PR314D was completed on schedule. The tree and grass planting followed the contract agreement:  Use local species of trees and grasses  Grass will be used to protect erosion from waves.  Planting near houses accepted by owners  Use local worker for tree planting, especially women and poor families. Khmer Global Tech is the contractor for the project. The scope of works was:  Plant 9,435 number of bushes  Plant 1,395 number of trees  Plant 7,477 m2 of grass Trees planted from January 2018 onwards were seriously damaged and withering to death due to shortage of water, on-going construction activities and eating by domestic animals feeding on them during the dry season. As required under the contract, the contractor replaced these at his own cost. No adverse responses were received from the community. Workers were hired locally. The contractor used workers (mostly women) from nearest villages to plant trees. As many of the workers were women from nearby villages, or lived alongside the roads, they came back to their homes at night. There were no accommodation camps. No work camps were needed for tree planting sites. No materials from tree plantings remain on the sites. No issues apart from tree mortality.

4.2. Key Issues and Actions Taken

4.2.1. Corrective Action Reports (CARs) 39. During the life of the project there have been no major incidents, complaints or occurrences of non-compliance with the EMP. Minor non-compliance issues concerned dust mitigation, safety signs and traffic signs at construction sites, and improving of the PPE for construction workers. When these occurred Corrective Action Reports (CARs) were issued and most contractors readily complied. One contractor, Gumkang Construction Co.,Ltd. -Visvakam Samnang Construction Co., Ltd. JV, gave poor environmental performance and needed to be continuously reminded to take action to comply with the requirements of the EMP. The correspondence was as given below starting with letters from KCI to Samnang JV. Table 4-1 Gumkang Visvakam Samnang JV Package CW-C Corrective Action Reports Date Action - KCI to JV October 1, 2015 Told to remove debris from side of road. October 8, 2015 Open burning of trash in a pit. Told open burning is not allowed and pit is to be filled in. November 3, 2015 Incorrect use of PPE. No gloves, no safety boots, welders without goggles, workers wearing helmets when not required, bare live

electrical cables near water spraying. Fuel tanks stored in direct sunshine; should be shaded. Litter in the concrete casting yard, waste paper cement bags lying around, chickens walking around the site; no animals are allowed on site. Lack of proper drainage

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was causing puddles in the casting yard. Lack of dust suppression by water sprays. A large square borrow pit was deep and villagers had requested it be left as a fish pond. Warning signs to avoid children drowning needed to be erected. Road safety signs were adequate in the daytime but hard to see at night. More signs and reflectors were installed. December 2, 2015 Reminder sent. December 14, 2015 Reminder sent noting they had been warned 4 times. Also, no EHS officer had been appointed on site. December 29, 2015 Fifth reminder sent. January 12, 2016 Sixth reminder sent. January 20, 2016 Another detailed reminder sent. Warning flag men for traffic control required at dangerous road crossing points. February 1, 2016 Samnang JV reply, apologizing and claiming to have now done everything. February 9, 2016 KCI rebutted the claim saying only minor improvements had been made. Added need for pedestrian road safety when children passing and more dust suppression. Chickens and cows now observed in the yard. December 2016 Contractor still not compliant. July 2017 Works delayed due to heavy rains. Still examples of non compliance. December 2017 Waste oil seen to be leaking. February 2, 2018 Reminder letter sent. April 9, 2018 Reminder letter sent. May 24, 2018 Reminder letter sent. July 2018 Solid waste management improved, oil still not securely stored. March 2019 Animals can walk across open campsite. August 2019 Construction works finished.

During site monitoring and discussions with local peoples no complaints were raised. All villagers are grateful for the improved roads, improved flood protection and irrigation and the new Emergency Response Centre. The only concern raised was over road safety as drivers and motorcyclist can now drive more quickly on the new improved road surfaces. However, it was acknowledged that the project included road safety training for schoolchildren.

4.2.2. Site Clearance 40. All work sites and accommodation campsites, including temporary tents, have been cleared of debris and waste materials. Two sites remain as vehicle parking areas and

16 materials storage sites. However, all waste materials connected with this project have been removed. On one the contractors (Sinohydro) wish to keep the site for their own purposes and have arranged with the owners to continue occupying the site in preparation for another works contract not connected with this project. On the second location (occupied by Gumkang) the site plus buildings will revert to the original owner. Copies of these agreements between the contractors and the land owners have been obtained for record purposes. The progress on site clearance and removal of any waste materials posing an environmental hazard is shown below. Table 4-2 Overall Physical Progress and Site Clearance July 2020

Progress Site Cleared of Site Vacated Component Contract Contractor (%) debris Y/N Y/N

Civil Works Roads

1 CW-A (NR13) 100.0 Sinohydro Yes No

CW-A-1 (Side 2 100.0 6 Stars Construction Yes Yes drainage on NR13)

3 CW-B1 (PR314D) 100.0 Sinohydro Yes No

4 CW-B2 (CBF) 99.5 Tan Kim Eng Yes Yes

CW-C (PR150B, Gumkang- Visvakam 5 100.0 Yes No NR53, PR151B) JV

Climate resilience

CW-D1 (Climate 6 100.0 Royal Mekong Yes Yes resilience, 3 dikes)

CW-D1-1 (Srok Dike 7 100.0 Taing Cheng Oing Yes Yes Slope Protection)

CW-D2 (Climate 8 resilience, Khsaet 100.0 Tan Kim Eng Yes Yes Lake)

CW-D3 Contract CW-D3: Kampong 9 0 Project Deleted Leaeng Water Supply

CW-D3-1 (Climate 10 resilience, additional 100.0 KBH Construction Yes Yes 3 Dikes)

11 CW-D3-2 (Climate 100.0 KBH Construction Yes Yes resilience, Dredging

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Progress Site Cleared of Site Vacated Component Contract Contractor (%) debris Y/N Y/N

of Boeng Kruos Lake)

CW-D4 (Climate 12 100.0 Tan Kim Eng Yes Yes resilience, EMC)

CW-D5 (Climate 13 resilience, Tree 100.0 Khmer Global Tech Yes Yes Planting)

Substantive Overall Progress (%) 100

41. Based on the site monitoring in May, June and July 2020, no significant issues have been found concerning environmental quality caused by construction activities.

5. Sustainability

5.1. Contractors Performance 42. Contractors in Cambodia have now been exposed to environmental requirements for many years and are learning that simple yet effective measures can be implemented without excessive costs. On one site a contractor was able to run an environmentally acceptable and hygienic campsite which cost less than US$2,000 in simple materials. 43. On another campsite the manager stated he was happy to provide bottled water and clean food for his workers plus clean sanitary conditions in toilets and showers as it kept them healthy and they worked harder. Another contractor berated his men for spilling diesel as not only was it causing pollution but also wasting his money as he had paid for the diesel fuel.

5.2. MPWT Manual 44. The use of the MPWT Manual on Climate Resilient Design is being implemented making designs more climate proof. In the past pipe culverts were often of a small diameter which quickly became blocked with debris and were hard to keep free of blockages. Now as a general rule all pipe culverts are sized at a minimum diameter of 1200mm which makes maintenance much easier.

5.3. ESO Capability 45. ESO staff and site inspectors have gained confidence in making decisions based on visual observations on site and contractors have gained familiarity in using checklists to demonstrate environmental compliance.

5.4. Trees Planting and wilting 46. Contract CW-D5: Tree planting was signed on 10 November 2017 but there was no specified completion date and guarantee period. The requirement of the works as stated in

18 the contract was ‘Tree planting’ to mean planting trees, bushes and grasses on slope of civil works. 47. Work areas were in Svay Rieng (CW-A, CW-B1), Kampong Chhnang (CW-C) and CW- D1 3 dikes under the climate resilience project. Some plants were observed to have died and contractor was instructed to nurture them, provide watering and keep away animals to fulfil the number of plantings as contract quantities. There were no official instructions, verbal instructions were given during inspection of works. 48. It is a requirement of the contract clause 15 that contractor must deliver the full number of plants as given in the contract. If any die due to neglect the contractor must replace them. This clause was obeyed. 49. The CW-D5 contractor carried out his works following completion of the civil works. Tree plantings on CW-A, B1, C were completed in early 2019. For CW-D1, contractor was allowed to finish his works for two dikes at Portnanon and Bakdao by August 2019. At the other location, Srok dike, the dike was damaged by floods during wet season of 2018. Consequently, the contractor had to wait until damage restoration and additional slope protection was completed by May 2020. Completion of CW-D5 was in June 2020 while loan closing date was on 30 June 2020. Some of the plants are still growing although the loan period has ended. 50. Before hand over photographic evidence is supplied that all the plants are in healthy conditions. PMU 3 have taken over responsibility for ensuring the plants are watered, nurtured and protected as instructed by Secretary of State MPWT. (see figure 5-1 and Annex C) This will guarantee that the planting is sustainable.

Figure 5-1 Tree Planting Confirmation 6. Lessons Learned

51. Under ADB financial support, MPWT produced a set of documents entitled “Non Mandatory Guidelines for Flood Proofing Roads” prepared under “Climate Resilience for Provincial Road Improvement Project” Loan 2839-CAM (SF)/ 8254-CAM and Grant 0278-

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CAM Project. These have been used in the feasibility studies and the designs and have proved extremely useful in calculating incremental costs for climate resilience. Also, under the same financial support the software “Flood Risk Management Interface” FRMI was produced by MPWT which is useful in feasibility studies where information on flood vulnerability is needed. 52. Although this was a road construction project funding was available under a Climate Change mechanism and this allowed water capture dikes and an Emergency Management Centre (EMC) to be built under the same financing. This was very effective and was welcomed by the local villagers. 53. The road resurfacing has improved connectivity and cut down travel times. Villagers are appreciative of this but the main benefit they express is dust reduction. Although they welcome the good non-muddy road surface in the rainy season, in the dry season the blacktop finish does not generate dust and they are very grateful for this. The improved road does increase traffic speeds and villagers expressed fears over road accidents due to speeding. Public awareness campaigns are held to educate school children on road safety when crossing roads. The opinions of the villagers vindicate the need for such campaigns. Cambodia has a major road safety campaign aimed at drivers. 54. All the water capture dikes were located in dry rice field, far from village area and the rehabilitations follow existing dams or dikes. There were no conservation or forest areas nearby. Work was carried out in areas that are dry, with almost no water remaining in the reservoirs behind the dikes. Consequently, there was no adverse effects on local water quality from dikes rehabilitation activities. Rehabilitation of dikes should be carried out and completed in the dry season and allowance should be made for this in the time scheduling. Contractors are required to hire female workers and give preference to local workers for unskilled jobs. This has the advantage of cutting down the need to provide accommodation on site for foreign workers and local workers can go home at the end of a shift. 55. If accommodation is required for construction staff, the contractors were encouraged to rent a house for temporary accommodation of the workers, rather than build a worker’s campsite. This avoids the need to install sleeping quarters, cooking facilities, showers, toilets and septic tanks on site. Renting accommodation has proved popular with contractors as it is less complicated and at the end of the contract, the premises are simply vacated whereas a camp site has to be decommissioned. 56. Hiring local workers has proved effective and reduced accommodation costs as workers from the area can go back home at night. At the CBF site a temporary work camp was established with tents in which workers could rest in the day time inside the CBF site. The contractor provided the tent and toilets for lunch time rest periods. At the end of the contract period the temporary work camp and tents were easily removed. 57. Contractors were encouraged to refuel vehicles at existing gas stations and not to store fuel on site. 58. All the equipment, construction materials and wastes have been removed from all sites. Land has been cleared and all debris moved from the site. There are no complaints from local people. Construction workers were often seen not using Personal Protective Equipment (PPE). Contractors need to be continually reminded to enforce the need to wear PPE. 59. The Sinohydro site will be kept operational by SInohydro for future work. The main campsite of Gumkang-Visvakam JV will remain as it will revert back to the owner. All

20 equipment belonging to the contractor will be removed before handover at the end of July 2020. The contractor’s buildings will then become the property of the Land Owner. This is part of the rental agreement. Copies of the lease conditions were obtained by the consultants to confirm this and are being kept on record in case of any future disputes.

7. Recommendations

60. Contractors are required to give preference to local workers for unskilled jobs. An advantage of this is it reduces the need to provide accommodation. Wherever possible contractors should rent existing premises for accommodation, offices or daytime rest areas to avoid the need to build a campsite and then have to remove it. 61. Contractors should be encouraged to refuel vehicles at existing gas stations and not to store fuel on site. Vehicle maintenance should be carried out in existing workshops to reduce the chances of oil pollution. It is recommended that whenever contractors wish to extend the life of a campsite beyond the life of a project, rental or lease agreement confirming this be obtained and that site clearance be proven by dated photos and verified site inspections. 62. Tree planting contracts include a clause requiring contractors to replace any plants that have died. This should be maintained and hiring of local villagers to protect bushes and trees should be considered. 63. One contractor, Gumkang Construction Co.,Ltd. -Visvakam Samnang Construction Co., Ltd. JV, gave poor environmental performance and needed to be continuously reminded to take remedial action to clean up his site, but his slow response and lack of Good Housekeeping was not bad enough to justify withholding payment or stopping work. 64. Issuing certificates of satisfactory performance at the end of a contract and then asking for such certificates in a tender submission bid and taking them into account in the Bid Evaluation Report (BER) would sanction poor performers.

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8. Annexes

8.1. Annex A Loan Covenants

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8.2. Annex B Environmental Parameters Contract Packages CW-A, CW-B1, CW- B2, CW-C, and CW-D

Note :  CW-A: completed on 28 February 2029  CW-B1: Completed on 28 February 2019  CW-C: Completed on 31 March 2019

There are 2 sub-projects are completed in 2020:  CW-B2: (Improvement CBF), Completed on 29 February 2020  CW-D3-1: (Rehabilitation 3 dikes), Completed on 31 May 2020.

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Table 8-1: Environmental Parameters Contract Packages CW-A, CW-B1, CW- B2, CW-C, and CW-D

Regulation Environmental Parameter Standard Contract Contract Contract Contract Contract

Issue Packages CW-A Packages CW-B1 Packages Packages CW-C Packages CW-D

CW-B2

ADB Notification of General ADB Social Completed. EMP Completed. EMP Completed. EMP Completed. EMP Completed. EMP requirements included in Tender included in Tender included in Tender included in Tender included in Tender requirement EMP to contractors Safeguards Policy Documents issued to Documents issued to Documents issued to Documents issued to Documents issued to Statement 2009 contractors. contractors. contractors. contractors. contractors.

ADB Submission of Specific details must ADB Social Submitted by Submitted by Submitted by Submitted by Submitted by be supplied by contractor. contractor. contractor. contractor. contractor. requirement CEMP from Safeguards Policy contractor on contractor to MPWT Statement 2009 construction camps, borrow areas and NR13 completed. PR314D completed. PR150B, NR53, CW-D1 completed. roads, quarries, PR151B crushing and Completed screening plants.

EMP Monthly All environmental As per individual Checklists completed Checklists completed Checklists completed Checklists completed Checklists completed by Engineer with by Engineer with by Engineer with by Engineer with by Engineer with requirement Checklists parameters checklists given in contractor for July to contractor for July to contractor for July to contractor for July to contractor for July to EMP December 2018. Decemeber2018. December 2018. December 2018. December 2018. Checklists reviewed Checklists reviewed Checklists reviewed Checklists reviewed Checklists reviewed and confirmed to be and confirmed to be and confirmed to be and confirmed to be and confirmed to be in order. No in order. No in order. No in order. No in order. No environmental issues environmental issues environmental issues environmental issues environmental issues identified. identified. identified. identified. identified.

Sub-decree on Water Quality BOD < 50mg/L No visual evidence No visual evidence No visual evidence No visual evidence No visual evidence Water Pollution was sighted of was sighted of was sighted of was sighted of was sighted of impacts on water impacts on water impacts on water impacts on water impacts on water Control SS < 50mg/L quality. No spills were quality. No spills were quality. No spills were quality. No spills were quality. No spills were observed. No observed. No observed. There are observed. No observed. Temperature <45 degrees C remedial action is remedial action is no major water remedial action is

pH 6-9 required. No required. No courses near project required. No sampling or sampling or roads. No remedial sampling or measurements of measurements of action is required. No measurements of Oil & Grease < 5mg/L water is required. water is required. sampling or water is required. measurements of Dissolved Oxygen > 4mg/L water is required.

Regulation Environmental Parameter Standard Contract Contract Contract Contract Contract

Issue Packages CW-A Packages CW-B1 Packages Packages CW-C Packages CW-D

Sub-decree on Air Quality TSP 3 No major air quality No major air quality No major air quality No major air quality No major air quality < 0.33 mg/m issues identified. Dust issues identified. Dust issues identified issues identified. Dust issues identified. Air and Noise suppression on roads suppression on roads suppression on roads Pollution Control Noise Quality Leq 75dB(A) improved by more improved by more improved by more water spraying. water spraying. water spraying. Leq 65dB(A)

No Regulation Vibration PPV < 1mm/sec No blasting taking No blasting taking No blasting taking No blasting taking No blasting taking place. Blasting will be place. Blasting will be place. place. Blasting will be place. carried out by carried out by carried out by commercial quarry commercial quarry commercial quarry owner with permission owner with permission owner with permission f f f Sub-decree on Solid Waste Food Waste Properly Removed Site camps Site camps Site camps Site camps not Site camps acceptable. Attention acceptable. Attention acceptable. Attention acceptable. Attention acceptable. Attention

Solid Waste Liquid Waste Waste Oil, Grease Properly to be given to oil to be given to oil to be given to oil to be given to oil to be given to oil Management storage and handling. storage and handling. storage and handling. storage and handling. storage and handling. Controlled After Removed by Subcontractor

No Regulation Septic Tank Smell, Sewage No Smell, No Workers camps Workers camps Workers camps Workers camps Workers camps acceptable. Where acceptable. Where acceptable. acceptable. Where acceptable. Where Overflowing possible houses are possible houses are possible installed on possible houses are being rented rather being rented rather the residential land are being rented rather than setting up camps. than setting up camps. being rented for setting than setting up camps. up camps.

No Regulation Borrow Pits Condition of Borrow Filled after Project No issues identified. No issues identified. No issues identified. No issues identified. No issues identified. Pits Completion, But shall be fenced But shall be fenced But shall be fenced But shall be fenced But shall be fenced after Project after Project after Project after Project after Project Topsoil resurfaced Completion Completion Completion Completion Completion

No Regulation Borrow Pits Depth of Borrow pits No Drowning No issues identified No issues identified No issues identified. No issues identified. No issues identified

Hazard No Regulation Borrow Road Location for Borrow No complaints No issues identified No issues identified No issues identified. No issues identified. No issues identified

Road from residents

No Regulation Quarries Condition of Quarries N/A N/A N/A N/A N/A Quarries reinstated

No Regulation Trees if Cut Number of Trees Tree Replanted N/A N/A N/A N/A N/A

8.3. Annex C Tree Growth Monitoring Contract documents