Contents The Way Forward ...... x Executive Summary ...... xiii List of Abbreviations ...... xviii Chapter 1: Conclusions and Recommendations ...... 1 1.1 Overview of the Activities ...... 1 1.2 Audit Observations and Conclusions ...... 3 1.3 Audit observations on Compliance to ESMF ...... 5 1.4 Recommendations ...... 11 Chapter 2: End of Term Environmental Audit for KLGSDP ...... 15 2.1 Background ...... 15 2.2 Environmental and Social Management Framework (ESMF) ...... 15 2.3 E&S Clearance Toolkit of the ESMF and the stages of application in project implementation ...... 16 2.4 Institutional Framework for EMSF implementation ...... 16 2.5 Revisions in ESMF after the Mid Term Audit...... 19 2.6 Objectives of Environmental Audit ...... 20 2.7 Scope of Work ...... 20 Chapter 3: Methodology ...... 22 3.1 Study Approach ...... 22 3.2 Audit Design ...... 22 3.3 Sampling Design ...... 22 3.4 Local Body Sampling Units (LB-SUs) ...... 23 3.5 Detailed Survey Methodology ...... 23 3.6 Training of field staff for Environmental Audit ...... 26 3.7 Data Analysis Plan ...... 26 3.8 Quality Control and Management ...... 26 Chapter 4: Field Training ...... 27 4.1 Training for Field Auditors ...... 27 4.2 Sample Coverage by Field Survey ...... 28 4.3 Stakeholder Consultations ...... 28 Chapter 5: Audit Observations ...... 29 5.1 Findings on ESMF Documentation and Implementation ...... 29 5.1.1. EMSF in the project planning stage ...... 30 5.1.2. Adoption of Mitigation Measures as per EMSF ...... 31 5.1.3. Feasibility of the Mitigation Measures in ESMF according to the IOs ...... 31 5.1.4. Feedback on any training programmes attended by IOs related to ESMF ...... 32 5.1.5. Feedback of the IOs on the adequacy of the training programs ...... 32 5.1.6. LESA for L2 (medium Impact) Activities ...... 33 5.2 Field Level Observations ...... 33 5.2.1. Buildings- New Construction and Expansion, Repair and Furnishings ...... 33 5.2.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance ...... 34 5.2.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance ...... 36 5.2.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste...... 37

ii

5.2.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools...... 38 5.2.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance ...... 39 5.2.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair 40 5.2.8. Storm Water Drains- Construction, repair and maintenance ...... 41 5.2.9. Agriculture/ Horticulture / Social Forestry - Management and extension ...... 41 5.2.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities ...... 42 5.2.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning ...... 42 5.2.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance ..... 43 5.2.13. Tiny and Small Industries – Establishment and Expansion ...... 44 5.2.14. Animal Husbandry dairy farming-construction and expansion facilities ...... 45 5.3 Comparison of Projects evaluated during the MT Audit and ET Audit ...... 45 5.4 Application of Index of Environmental and Social Integrity (IESI) ...... 48 5.4.1. Buildings- New Construction and Expansion, Repair and Furnishings ...... 48 5.4.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance ...... 49 5.4.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance ...... 50 5.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste...... 51 5.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools...... 51 5.4.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance ...... 52 5.4.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair 52 5.4.8. Storm Water Drains- Construction, repair and maintenance ...... 53 5.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension ...... 54 5.4.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities ...... 54 5.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning ...... 54 5.4.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance ..... 55 5.4.13. Tiny and Small Industries – Establishment and Expansion ...... 55 Chapter 6: Good and Bad practices ...... 57 6.1 GP/MN Office Building ...... 57 6.1.1 Good Practices ...... 57 6.1.2 Bad Practice ...... 57 6.2 Anganwadi Centres ...... 58 6.2.1 Good practices ...... 58 6.2.2 Bad practices...... 60 6.3 Family Welfare Centres ...... 60 6.3.1 Good Practice ...... 60 6.4 Foot Bridges ...... 61 6.4.1 Bad Practice ...... 61 6.5 Bus Waiting Sheds ...... 61 6.5.1 Good Practice ...... 61 6.5.2 Bad Practice ...... 62 6.6 Waste management Projects ...... 62 6.6.1 Good Practices ...... 62 6.6.2 Bad Practices ...... 64

iii

6.7 Drinking Water Supply projects ...... 66 6.7.1. Bad Practices ...... 66 6.8 Storm water Drains ...... 67 6.8.1 Bad Practices ...... 67 6.9 Public Markets ...... 68 6.9.1. Good Practices ...... 68 6.9.2. Bad Practice ...... 68 6.10 Open Well construction/ Renovation...... 68 6.10.1. Good Practices ...... 69 6.10.2. Bad Practice ...... 69 6.11 Road concreting ...... 70 6.11.1. Bad Practice ...... 70 6.12 Pond Maintenance ...... 70 6.12.1. Good Practices ...... 70 6.12.2. Bad Practices ...... 71 Chapter 7: Projects under onetime financial assistance to Backward LSGIs ...... 72 7.1 One time financial assistance ...... 72 Chapter 8: Capacity Building Programme ...... 77 8.1 Capacity Building Initiatives ...... 77 8.1.1. State Level Trainings ...... 77 8.1.2. District level Orientation Training on ESMF & Procurement Procedures for the Support Staff of LSGs: ...... 78 8.1.3. Capacity of environmental auditors, LSGI functionaries and Implementing Officers . 79 8.1.4. Orientation Training for the newly elected LSG functionaries & Refresher Training for the Implementation Officials: ...... 79 8.1.5. Orientation training to the newly recruited District Coordinators of KLGSDP under backward support grant ...... 79 8.2 Comments on the strength and weakness found in the existing capacity building initiatives...... 80

iv

List of Tables

Table 1.1: Brief overview of subprojects covered during the Environmental Audit (EA) ...... 1 Table 1.2: District wise distribution of major SPs surveyed during the ET Audit ...... 2 Table 1.3: Audit findings vis-a-vis the Audit Objectives ...... 3 Table 2.1: Institutional Structure for ESMF Implementation for GPs...... 16 Table 2.2: Institutional Structure for ESMF Implementation for MNs ...... 18 Table 4.1: Details of training for the Field Auditors ...... 27 Table 4.2: Subprojects covered during the field training of the Auditors ...... 27 Table 7.1: Projects funded under the onetime financial assistance to Backward LSGIs covered in the ET Audit ...... 73 Table 7.2: Backward Assistance Subprojects requiring Statutory Clearances ...... 76 Table 8.1: State Level Capacity Building Programmes ...... 77 Table 8.2: District Level Capacity Building Initiatives ...... 79

v

List of Plates

Plate 5.1: Renovation of Panchayat Office, Pananchry, Thrissur ...... 33 Plate 5.2: Anganwadi at Irikkur GP in Kannur District ...... 33 Plate 5.3: Keezhallur Ayithara Road tarring at Dharmadam GP in Kannur District ...... 34 Plate 5.4: Culvert construction in Narbona Church road at Punnpra South, Alapuzha District ... 34 Plate 5.5: Improvement of Thachakalipadi road in Kallooppara GP in Pathanamthitta District . 35 Plate 5.6: Kochuveli Foot Bridge at Muhamma GP in Alapuzha District ...... 35 Plate 5.7: Bus waiting shed at Karunapuram GP in Idukki District ...... 36 Plate 5.8: Bus waiting shed at Kummil GP in Kollam District ...... 36 Plate 5.9: Parking yard at Vazhathope GP in Idukki District ...... 36 Plate 5.10: Parking Yard at MN office at Malappuram MN in Malappuram District ...... 36 Plate 5.11: Biogas Plant at Kallooppara GP in Pathanamthitta District ...... 37 Plate 5.12: E-Toilet at Chavara GP in Kollam District ...... 37 Plate 5.13: Shed for waste dumping yard at Wadakkanchery MN in Thrissur District ...... 37 Plate 5.14: Vermicompost Shed at Kaduthuruthy GP in Kottayam District ...... 37 Plate 5.15: Public Market at Kulathupzha GP in Kollam District ...... 38 Plate 5.16: Chennalode Mini Stadium at Thariyode GP in Wayanad District ...... 38 Plate 5.17: Gas crematorium at Thodupuzha MN in Idukki District ...... 38 Plate 5.18: Smoke room for Crematorium at Chenglai GP in Kannur District ...... 39 Plate 5.19: Swimming pool construction at Kaduthuruthy GP in Kottayam District ...... 39 Plate 5.20: Park for Children, Thiruvalla MN in Pathanamthitta District ...... 39 Plate 5.21: Thevarakkadavu Check dam renovation at Kannambra GP in Palakkad District ...... 39 Plate 5.22: Venchakulam Lift Irrigation Project Chenkal GP in Trivandrum District ...... 39 Plate 5.23: Pampa valley community Irrigation project at Ward 12 at Kavalam GP in Alapuzha District ...... 40 Plate 5.24: Completion of Pulikuzhi drinking water scheme at Kallikadu GP in Trivandrum District ...... 40 Plate 5.25: Plumbing and Pump set to Thopilavi Drinking water scheme at Chenglai GP in Kannur District ...... 40 Plate 5.26: Pipeline extension to GP Office, Veterinary Hospital at Nedumudi GP in Alapuzha District ...... 40 Plate 5.27: Construction of drain with cover slab at Ward 2 in Chellanam GP in Ernakulam District ...... 41 Plate 5.28: Kattusheri Drainage Construction at Alathur GP in Palakkad District ...... 41 Plate 5.29: Protection wall to Mudakkuzha padam at Mudakuzha GP in Ernakulam District ...... 42 Plate 5.30: Fish Market at Muvattupuzha MN in Ernakulam District ...... 42 Plate 5.31: Side protection wall for Kuttikulangara Pond at Kayamkulam MN in Alapuzha District ...... 43 Plate 5.32: Construction of Borewell at Madavur GP in Trivandrum District ...... 43 Plate 5.33: Purchase of Generator for GP office at Velukkara GP , Thrissur District ...... 44 Plate 5.34: Purchase of Touch Screen for GP office at Veeyapuram GP in Alapuzha District ...... 44 Plate 5.35: Maniyarankudi Khadi industrial centre at Vazhathopu GP in Idukki District ...... 44 Plate 5.36: Construction of building to Kolkkalam Vanitha Thozhil Pariseelana Kendram at Ponmala GP in Malappuram District ...... 44 Plate 5.37: Building for Vanitha Vyayasaya Estate at Kannambra GP in Palakkad District ...... 45 Plate 5.38: Cattle feed godown at Karode GP in Trivandrum District ...... 45

vi

Plate 6.1: GP office at Mannanchery GP in Alapuzha District ...... 57 Plate 6.2: PHC building at Chettikulangara GP in Alapuzha District ...... 57 Plate 6.3: Vazhathoppe Anganwadi at Vazhathope GP, Idukki District ...... 58 Plate 6.4: Kuttooli Anganwadi at Keezhuparamba GP in Malappuram District ...... 59 Plate 6.5: Kavana Anganwadi at Avoli GP in Ernakulam District ...... 59 Plate 6.6: Madathinkadavu Anganwadi at Mariyapuram GP in Idukki District ...... 59 Plate 6.7: Manjappara Anganwadi at Nedumkandom GP in Idukki District ...... 60 Plate 6.8: Mugu Anganwadi at Puthige GP in Kasaragode District...... 60 Plate 6.9: Family Welfare Centre at Kallikadu GP in Trivandrum District ...... 60 Plate 6.10: Hosabettu Koppala Foot Bridge at Manjeshwaram MN in Kasaragod District ...... 61 Plate 6.11: Kallur Koppala Foot Bridge in Vorkady GP in Kasaragod District ...... 61 Plate 6.12: Bus Waiting Shed at Chakkittapara GP in Kozhikode District ...... 61 Plate 6.13: Bus waiting shed at Ayavana GP in Ernakulam District ...... 62 Plate 6.14: Bus waiting shed at Kalloorkad GP in Ernakulam District ...... 62 Plate 6.15: Dumping Yard at Division 19 in Karunagappally MN of Kollam District ...... 63 Plate 6.16: Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta District ...... 64 Plate 6.17: Biogas Plant at Taluk Hospital at Thodupuzha MN in Idukki District ...... 65 Plate 6.18: E-Toilet at Mavelikkara MN in Alapuzha District ...... 66 Plate 6.19: Kavilppadi Irrigation Project in Mariyapuram GP in Idukki District ...... 66 Plate 6.20: Mulamthandu Water Supply Scheme in Santhanpara GP in Idukki District ...... 66 Plate 6.21:Keezhur Pipeline extension in Chemnad GP in Kasargod district ...... 67 Plate 6.22: Construction of drainage at 4 cent Colony road Kadapuram GP in Thrissur District 67 Plate 6.23:Construction of Drain at Kulanmavu Ambalabhagom Road at Arakkulam GP in Idukki District ...... 67 Plate 6.24:Renovation of town market at Kulathupuzha GP in Kollam District ...... 68 Plate 6.25: New market construction at Nedumkandom GP in Idukki District ...... 68 Plate 6.26: Renovation and recharge of open well was undertaken at the MN office at Chittoor MN in Palakkad District ...... 69 Plate 6.27:Open well maintenance at Baison Valley GP in Idukki District ...... 69 Plate 6.28: Open well near Vallapuzha Railway Station at Vallapuzha GP in Palakkad District ... 70 Plate 6.29: Concreting of Pathichiripadi road at Mankulam GP in Idukki district...... 70 Plate 6.30: Ayyappankulam Renovation at Kollenkode GP in Palakkad District ...... 70 Plate 6.31: Renovation of Odangattkulam at Edayur GP in Malappuram District ...... 71 Plate 6.32: Maintenance of Panchayat pond at ward 3 at Kavalam GP in Alapuzha District ...... 71

vii

List of Figures Figure 5.1: Distribution of IOS responded to the questionnaire for IOs in the ET Audit ...... 29 Figure 5.2: Experience of the IOs in implementing KLGSDP subprojects ...... 30 Figure 5.3: Whether ESMF document is referred in the subproject planning stage: response from IOs ...... 30 Figure 5.4: Adoption of Mitigation Measures as per EMSF ...... 31 Figure 5.5: IOs feedback regarding the feasibility of mitigation measures mentioned in ESMF document ...... 31 Figure 5.6: IOs feedback on whether they have attended any training programs with respect to ESMF ...... 32 Figure 5.7: Feedback of IOs on the adequacy of training programs ...... 32 Figure 5.8: Percentage of building repair/furnishing projects under green/yellow/red categories as per IESI Scores and factors causing low scores for Red category projects ...... 49 Figure 5.9: Percentage of building construction projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 49 Figure 5.10: Percentage of road repair and maintenance projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects50 Figure 5.11: Percentage of road construction projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 50 Figure 5.12: Percentage of operation/repair and maintenance of waiting sheds and parking yards projects under green/yellow/red categories as per IESI Scores ...... 50 Figure 5.13: Percentage of sanitation and waste management projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects51 Figure 5.14: Percentage of repair and maintenance of public markets, crematorium, playgrounds and swimming pool projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 51 Figure 5.15: Percentage of construction of public markets, crematorium, playgrounds and swimming pool projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 51 Figure 5.16: Percentage of construction and maintenance of minor and micro irrigation projects and check dams under green/yellow/red categories as per IESI Scores...... 52 Figure 5.17: Percentage of maintenance and repair of drinking water supply projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 52 Figure 5.18: Percentage of construction and expansion of drinking water supply projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 53 Figure 5.19: Percentage of repair and maintenance of storm water drain projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 53 Figure 5.20: Percentage of construction of storm water drain projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects53 Figure 5.21: Percentage of agriculture/horticulture and social forestry projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 54

viii

Figure 5.22: Percentage of repair and maintenance of facilities for meat and fish production and marketing projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 54 Figure 5.23: Percentage of repair and maintenance of ponds/tanks/well/canals projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 55 Figure 5.24: Percentage of electrical and electronic items purchase, installation, operation and maintenance projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 55 Figure 5.25: Percentage of tiny and small industries-establishment and expansion under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects ...... 56

ix

The Way Forward

Kerala Local Government Service Delivery Project (KLGDSP)

A. Introduction

Government of Kerala, in partnership with the World Bank conceived the Kerala Local Government Service Delivery Project (KLGSDP) with a vision to boost, institutionalize and raise the level of service deliveries of Local Self Government Institutions (LSGIs) using modern tools of planning, development, project implementation and transparency in administration. The project commenced in the year 2011 and is getting completed by December, 2017.

Direct beneficiaries of the project are the 978 Grama Panchayats (GPs) and 60 Municipalities (MNs) in the State of Kerala (after delimitation in 2016, the number of GPs is 941 and MNs are 87). KLGSDP consisted of mainly four components viz., (a) an annual, performance-based untied grant to all GPs and Municipalities in Kerala to be spent on creation and / or maintenance of capital assets used in service delivery; (b) capacity building inputs to strengthen and supplement the existing systems and human resource of GPs and MNs to enhance their institutional performance; (c) support for strengthening the system of performance monitoring of GPs and Municipalities; and(d) support for a Project Management Unit (PMU) that would handle overall coordination, implementation, monitoring and evaluation of the project. B. Environment and Social Management Framework (ESMF)

The subprojects for service delivery funded by KLGSDP falls under environmental category ‘B’ as per World Bank’s safeguard policies laid down in OP 4.01 on Environmental Assessment (EA) and hence it required KLGSDP to screen projects upstream in the project cycle for potential impacts and mitigate the adverse impacts. The Environmental and Social Management Framework (ESMF) had been developed by KLGSDP in this context and made mandatory from the beginning of its subproject implementation to address the potential environmental and social issues. KLGSDP strictly followed the existing decentralized planning process for the implementation of ESMF. C. End of Term Environment Audit The End of Term Environmental Audit (ET Audit) aimed at understanding many a fact which was instrumental in achieving satisfactory or unsatisfactory level of ESMF implementation in the subprojects of KLGSDP. The audit further looked into areas of concern which reduced further effectiveness of ESMF benefits in the subproject implementation. D. Remarkable findings of the ET Audit

KLGSDP was the first project under Local Self Government Department to implement an operational ESMF mandatorily and systematically. This was a piloting method for mainstreaming the ESMF integration in whole LSG system.

 Integration of ESMF compliance Proformas in the IKM software as Annexure-6 helped the local bodies (LBs) a lot in ensuring verification and compliance process enumerated in the ESMF.

x

 Able guidance provided by KLGSDP mentors and extensive awareness training programmes at state and district level helped effectively in conveying to support staff of LSGs the importance of ESMF integration with overall planning and implementation of KLGSDP projects  Although general understanding of ESMF compliance requirement through Annexure-6 in the IKM software is good, yet understanding of project specific requirements vis-a-vis environmental mitigation measures lacked clarity in many of the Block Engineers and Implementing Officers(Assistant/Municipal Engineers, Municipal/Panchayat Secretaries, Agricultural Officers etc)  Despite notable capacity building training and monitoring efforts by PMU, training and monitoring was still found insufficient in sensitizing the entire stakeholder vis-a-vis importance of ESMF document.  The responsibility for all ESMF related processes at the GP and MN level, such as screening and verification, lies with the IOs( usually Assistant Engineers) and approval lies with Block Engineers(usually Assistant Executive Engineers). Same officers are also supposed to ensure compliance and hence an issue of conflict of interest arises many times, which goes against the spirit of fair implementation of ESMF provisions.  Mid-Term Environmental Audit (MT Audit) conducted in the year 2014 and its dissemination of findings to the LBs enhanced quality of ESMF implementation at large. E. The way forward For each project, the way forward would entail short- and medium-run interventions with complementary and mutually reinforcing objectives. In the short run, the GPs and MNs which are already familiar with the ESMF procedures can start demonstrating better results using existing ESMF provisions by introducing it to other subprojects implemented using other funds. In the medium run, the focus can shift to subprojects at a bigger scale such as the projects taken up by the Block and District Panchayats. Engaging a broad spectrum of stakeholders such as the elected local body members and the direct beneficiaries of the projects can facilitate the envisioned guidelines in ESMF to be achieved in its true sense. In light of the specific challenges faced in the implementation of ESMF, the path toward more effective and innovative implementation of ESMF calls for action on several fronts. While there is no single solution, better results can be achieved through action on the following five items  Further simplification and trimming of ESMF formats which could help in better compliance of ESMF provisions  A State Level Environmental Cell, under the Department of Environment and Climate Change, Government of Kerala, is advised, where the Environmental and Social (E&S) mandatory clearance procedures could be facilitated and monitored on behalf of LSGIs. This will also bring in more knowledge base on ESMF issues and help in holistic implementation of ESMF procedures  Frequent refresher and orientation training is important for implementing officers and other engineering staff of LSGIs.  Effective Monitoring is an important aspect of long term success of environmental safeguard. Current ESMF has a robust monitoring process in place and it is suggested that existing monitoring procedures should be complied diligently without any dilution.  Elected LB members should also be sensitized to promote their involvement in ESMF screening and compliance process. Elected members should also try to involve local community through awareness generation so as to promote ownership towards the assets created and their maintenance, through citizen-centric information, education and communication (IEC) campaign xi

In conclusion, the way forward is to remedy the institutional failures that prevent the ESMF implementation in its essential spirit to ensure sustainability in the service delivery and infrastructure projects undertaken by all the LSGIs of Kerala. Moving forward, the World Bank as well as the Government of Kerala should stand ready to support this laudable agenda of sustainable and inclusive development propagated by ESMF.

xii

Executive Summary

A. Background The State of Kerala has been leading the way in decentralized local governance in our country in many facets of decentralization and has moved at good pace in transferring functions, responsibilities, authority and finances to Local Governments. In order to further strengthen and institutionalize local service delivery and for building useful public infrastructure with responsive public services, the Government of Kerala, in partnership with the World Bank conceived the Kerala Local Government Service Delivery Project (KLGSDP).

The project commenced in the year 2011 and is getting completed by December, 2017. Direct beneficiaries of the project are the Grama Panchayats (GPs) and Municipalities (MNs) in the State of Kerala as per the Project Implementation Manual (PIM).

KLGSDP consisted of mainly four components viz., (a) an annual, performance-based untied grant to all GPs and Municipalities in Kerala to be spent on creation and / or maintenance of capital assets used in service delivery; (b) capacity building inputs to strengthen and supplement the existing systems and human resource of Municipalities and GPs to enhance their institutional performance; (c) support for strengthening the system of performance monitoring of GPs and Municipalities; and(d) support for a Project Management Unit (PMU) that would handle overall coordination, implementation, monitoring and evaluation of the project.

B. Environmental and Social Management Framework (ESMF) for KLGSDP subproject implementation KLGSDP has been classified under category B as per World Bank norms. This mandates the preparation of an ESMF as a necessary procedural requirement for project appraisal and adherence/ compliance to the ESMF during project implementation, a vital performance criterion. Accordingly, ESMF was developed as a relevant tool placed in the hands of local governments as it will empower them to manage E&S issues arising out of their own decisions and plans.

The ESMF had been developed and made mandatory from the beginning of the KLGSDP implementation to address the potential environmental and social issues arising as a result of the infrastructure development and service delivery that were to be initiated with the help of the increased untied grant flows to the GPs and MNs. Based on the findings of the Mid Term Environmental Audit carried out during the in 2014, it has been observed that, for the due diligent compliance of ESMF, certain revisions/modifications were required in the ESMF document. A series of Consultation Workshops were carried out by KLGSDP participating Subject Experts in the field, World Bank Representatives, Elected Representatives Implementing Officers of local bodies with regard to modification of the ESMF. The outcomes of the consultation workshops and the Mid Term audit results were consolidated and integrated appropriately in the ESMF document.

xiii

C. Objectives of End of Term Environmental Audit (ET Audit) KLGSDP proposed to conduct an “End of Term” Environment Audit with following three major objectives under consideration:

 To determine the extent of compliance to the ESMF achieved over the project period and identify non-compliances, if any, with respect to applicable national / state / local regulations. Audit also envisaged finding effectiveness and deficiencies in implementing the original ESMF and extent of improvement achieved, following modifications in ESMF suggested by the mid-term environmental audit.  To study and comment on the adequacy of the systems and procedures contained in the latest version of the ESMF (post mid-term environmental audit) for suitably managing all possible environmental impacts in context of all sub-projects undertaken by the local bodies and suggest scope for further improvement, if any.  To determine the extent to which direct/indirect adverse impacts from the subprojects to various constituents of the environment such as human lives, property and natural resources, have been avoided, prevented or mitigated

D. Approach and Methodology for ET Audit The Environmental Audit followed a mix-design based approach, whereby a mix of qualitative as well as quantitative data set was used. Broadly, the audit included following procedures as major steps for achieving objectives of the environmental audit:

 Scoping and Boundary Setting It was estimated by PMU of KLGSDP that, the sample-size for this final EA could be 2,500 sub- projects covering all categories of sub-projects implemented under the KLGSDP, including community infrastructure / fixed assets created/maintained and other activities undertaken using Performance Grant and One time assistance to backward Local Bodies. Study Boundary of the audit included direct as well as indirect beneficiaries of the project and both individual as well as cumulative impacts and their mitigation.

 Desk Review Subsequent to review of relevant documents from PMU, a list of indicators and guiding questions was developed focusing on the specific objective of Environmental Audit, which led to the design of various audit specific study instruments.

 Designing Study Instruments (Quantitative & Qualitative) The audit team designed data / information collection questionnaire for both qualitative as well as quantitative data/information collection. The audit questionnaires were focused on determining the environmental aspect of whole project activities, especially around ESMF provisions. The questionnaire targeted a representative sample of the direct beneficiaries as well as other key stakeholders.

 Selection of Local Body Sampling Unit (LB-SU) through Selection Matrix (LBSM) Environmental audit was conducted within overall sample size of 2500 sub project, which included 15% of the completed projects from the 3rd Grant Cycle (FY 2014-15), 15% from the 4th Grant Cycle (FY 2015-16), 15% from 185 Government approved backward assistance projects, 15% from midterm audited projects and remaining 15% from 5th Grant Cycle (FY

xiv

2016-17). In terms of GPs and MNs, audit covered a sample of 34% of the 941 GPs i.e. 321 GPs and 34 % of the 87 MNs i.e. 30 MNs, covering all the 14 districts of Kerala. The sample selection should be such that it is representative of all geographical, agro-climatic, demographic, socio-economic and cultural variations prevailing across the state.

 Field Visits: Audit schedules were prepared which included field visits, desk reviews, actual verification of the sub-projects at site with respect to the environmental and social parameters with photo documentation. PMU was kept in loop during this process and their support was obtained from time to time for facilitating the field activity. Collected field data/information was deeply and thoroughly analyzed to arrive at audit findings and environmental audit report consisting of audit observations. Conclusions and recommendations were finally drawn based on audit findings.

 Stakeholder Consultations: The relevant stakeholders were consulted at various levels to gather information regarding sub projects. At the state level, policy level and project specific discussions were held with the KLGSDP officials and at the district, GP and MN level, sub project related discussions were held with a number of other stakeholders viz District Coordinators of KLGSDP, Implementing Officers, Elected Representatives and the Public. A consultation workshop was conducted with the PMU and all the District Co-ordinators at Thrissur. Final audit report was prepared based on field observation and input from the state and district level stakeholder consultations. The outcome of this audit report was presented through a state-level audit finding dissemination workshop, held at Trivandrum, to discuss the preliminary findings and draft EA report of the environmental audit and receive feedback on the same from a wide variety of stakeholders to fine tune the final EA Report.

E. Findings of the ET Audit Audit appreciably found that KLGSDP was successful in integrating the required Proformas for environmental & social clearance and compliance verification in their regular plan software, which helped in largely satisfactory compliance of ESMF provisions on the whole. While screening level ESMF compliance was found to be followed satisfactorily, further compliance at the level of mitigation measures was found only moderately satisfactory. The compliance verification by the IOs with facilitation from Block Engineers was found to be moderately satisfactory. Statutory compliance requirement were not given adequate attention in the process of ESMF implementation and audit too could not verify such noncompliance since relevant documentation was not practiced at the LB level. Mid-Term Environmental Audit (MT Audit) enhanced quality of ESMF implementation at large by the simplification of formats in the E&S screening tool of ESMF. Detailed outcome of the audit process is discussed in the report in the context of overall conclusive comments on the ESMF implementation and monitoring process, as well as activity- specific observations.

F. Conclusions and Recommendations of the ET Audit KLGSDP was the first project under LSGD to implement an operational ESMF mandatorily and systematically and this was a piloting method for mainstreaming the ESMF integration in whole LSG system. The following are the major recommendations

xv

 A State Level Environmental Cell, under the Department of Environment and Climate Change is recommended, where the E& S mandatory clearance procedures could be facilitated and monitored on behalf of LSGIs.

 There should be a dedicated environmental cum social specialist at block level who could be given charge of managing the ESMF verification compliance in association with block engineers.

 The ESMF formats for mitigation measures for Level 1 and Level 2 activities shall be further simplified and shall be incorporated in the planning software itself. Photodocumentation of the project implementation phases shall also be promoted through the online platform.

 The robust monitoring processes described in the ESMF should be complied diligently without any dilution.

 ESMF provisions and stipulated mitigation measures for various types of subprojects must be made part of the tender and contract awarding procedures for the contractors to make the Projects ESMF compliant.

 Frequent refresher and orientation training is important for the Implementing Officers (IOs) (Municipal/Panchayat Engineer, Municipal/Panchayat Secretary).

Learning experiences and directional recommendations have been enumerated broadly on the key areas of improvement via-a-vis implementation for the KLGSDP project as a whole in this ET Audit report. Activity-specific suggestions have been made for further strengthening of ESMF implementation process to the entire LSG system as envisaged in the ESMF.

G. One time additional financial assistance to Backward Local Bodies The ET audit evaluated 28 subprojects of Level 2 category supported under the ‘one time additional financial assistance to selected backward local bodies’. Audit revealed that these projects achieved satisfactory level in ESMF implementation and ESMF procedures were holistically followed in these projects. Annexure-6 and LESA were diligently used in all DPRs. Since DPRs of these projects were prepared by NGOs as external support to local bodies, it was relatively easier for PMU to sensitize them via-a-vis ESMF requirement & regulatory compliance requirements and include the same in DPRs. Fairly good regulatory compliance in additional backward local body support projects was therefore a highlight of ESMF implementation. Monitoring of these projects have been strengthened by appointing dedicated Overseers, who could also be given awareness training on ESMF requirements and expected to keep an eye on compliance to ESMF.

H. Capacity Building Initiatives of PMU with focus on ESMF The capacity building initiatives were largely built around the efforts taken by PMU, especially the Environmental and Social Safeguard Specialist took sincere effort in conveying the importance of ESMF through the capacity building training programmes. Role of District Coordinators in reinforcing the ESMF concept during the screening process as part of the monitoring is also worth mention as they explored and utilised all available platforms like DPC Meetings, DDP Conferences, Engineers monthly meetings etc. as avenues for disseminating the ESMF concept as per the directions they received from PMU from time to time. This was visible in the APA documents that majority of the LBs cleared the minimum mandatory conditions (MMC) and performance benchmarks in ESMF compliance documentation. The audit identified that organising refresher training on regular basis is so very important for sustained implementation of ESMF provisions. In departments where transfers and new xvi

appointments are frequent, refresher training and orientation training for new recruits is very important. This was found a weak area in the current capacity building efforts.

I. Structure of the Environmental Audit Report The environmental audit report has been structured in a manner so that it is easy to comprehend the report in line with objectives of the audit, and also provides conclusive statements facts for dissemination and recommendations for policy level decisions based on detailed analysis of data collected form varied levels. The Report contains following chapters:

Chapter 1: Conclusions and Recommendations Chapter 2: End of Term Environmental Audit for KLGSDP Chapter 3: Methodology Chapter 4: Field Survey Chapter 5: Audit Observations Chapter 6: Good and Bad Practices Chapter 7: Subprojects under one time backward assistance to Local Bodies Chapter 8: Capacity Building initiatives of PMU with focus on ESMF

xvii

List of Abbreviations

1st Grant Cycle : Financial Year 2011-12 2nd Grant Cycle : Financial Year 2012-13 3rd Grant Cycle : Financial Year 2013-14 4th Grant Cycle : Financial Year 2014-15 and Financial Year 2015-16 5th Grant Cycle : Financial Year 2016-17 CA : Chief Auditor CPCB : Central Pollution Control Board DC : District Co-ordinator ESMF : Environment and Social Management Framework ET Audit : End of Term Environmental Audit FA : Field Auditor GP : Grama Panchayat IO : Implementing Officer KLGSDP : Kerala Local Government Service Delivery Project LB-SU : Local Body Sampling Unit LESA : Limited Environmental and Social Appraisal Level 1 : Low Impact Activities Level 2 : Medium Impact Activities MN : Municipality MT Audit : Mid Term Environmental Audit PMU : Project Management Unit SP : Subproject ToR : Terms of Reference ULTRA-TECH : ULTRA-TECH Environmental Consultancy and Laboratory ZA : Zonal Auditor

xviii

Chapter 1: Conclusions and Recommendations

This chapter presents the overall observations and recommendations drawn from the environmental audit of Local Bodies under the KLGSDP, in all the fourteen districts in Kerala. The Chapter starts by presenting an overview of the activities covered during the environmental audit, in terms of the number of cases of each type of activity, as well as a district-wise distribution of the same.

1.1 Overview of the Activities The environment audit of Gram Panchayats (GPs) and Municipalities (MNs) under KLGSDP project was undertaken in all fourteen project districts, on a sample basis. Overview of the activities/subprojects whose environmental audits were undertaken during the course of the field survey are summarized in Table 1.1. A total of 2500 cases of different subprojects were surveyed, spread over 351 local bodies across the fourteen project districts. Majority of the subprojects were classified under fourteen categories (following the categorization given in Proforma B, ie, the Control List Screening Tool of EMSF), i.e. road/bridges/culverts, buildings, waiting sheds, public markets/ crematoriums, micro and minor irrigation, drinking water supply, storm water drains, agriculture, meat and fish production and marketing, ponds/tanks/ wells/ canals, purchase of electrical and electronic items, sanitation and waste management, animal husbandry& dairy farming and tiny and small industries.

Table 1.1: Brief overview of subprojects covered during the Environmental Audit (EA)

No. of SN Subproject Category cases 1. Buildings: Construction, repair, maintenance and furnishings 713 2. Roads/Bridges/Culverts: Construction, repair and maintenance 1126 Waiting sheds, Parking Yards, Bathing Ghats-Construction, operation and 3. maintenance 39 Sanitation & Waste Management : Collection and Management of Solid & 4. Liquid Waste, Electronic Waste, and Biomedical Waste 15 Public Markets, Crematoriums, Burial Grounds, Public Toilets, Slaughter Houses, Waste Management Installations, Stadiums, Play grounds, Swimming Pools- 5. Construction and Expansion or Operation, Maintenance and Repair 82 Micro and Minor Irrigation - Construction and Expansion, Maintenance, Check Dams – Construction and Maintenance, Minor Irrigation - 6. Maintenance 15 Drinking Water Supply Construction and Expansion, Operation, Maintenance and 7. Repair 114 8. Storm Water Drains – Construction, Repair and Maintenance 97 9. Agriculture / Horticulture / Social Forestry - Management and extension 10 Meat & Fish Production and Marketing - Construction and Expansion of facilities and 10. Repair and Maintenance of facilities 6 11. Ponds/Tanks/Wells/ Canals – Construction, Cleaning and De-silting 61 12. Electrical & Electronic items - Purchase, Installation, Operation and Maintenance 212 13. Animal Husbandry & Dairy Farming - Construction & Expansion of facilities 2 14. Tiny and Small Industries – Establishment and Expansion 8 TOTAL 2500

1

The purpose of End of Term Environmental Audit (ET Audit) was to find out whether the necessary measures are identified during the ESMF documentation stage to mitigate any adverse environmental impacts arising out of subproject related activities undertaken by the LBs and proper documentation of the same has been carried out or not. In order to fulfil this objective, a list of subprojects undertaken by respective LBs for holistic development of the area, were sampled in consultation with the KLGSDP PMU. Table 1.2 presents a district-wise distribution of the various categories of subprojects surveyed during the ET Audit. Table 1.2: District wise distribution of major SPs surveyed during the ET Audit

S District

Roads sheds Waiting Markets, crematoriums, pools swimming Micro and Minor Irrigation Water Drinking Drain Agriculture Meat and Market Fish Ponds/Wells Purchase Sanitation Animal Husbandry Tiny and ScaleIndustries Small No Buildings 1. Trivandrum 64 60 3 15 1 12 7 1 0 8 23 0 1 0 2. Kollam 59 87 2 7 0 6 11 2 0 2 10 2 0 0 3. Pathanamthita 45 101 5 8 0 5 5 0 0 2 12 3 0 1 4. Alappuzha 52 136 0 2 1 1 8 1 0 5 22 2 0 0 5. Kottayam 66 69 2 8 1 2 4 1 0 4 20 0 0 0 6. Idukki 39 43 3 3 2 6 5 0 0 4 11 1 0 1 7. Ernakulam 69 90 4 5 2 1 20 3 1 2 24 0 0 0 8. Thrissur 50 66 0 4 3 8 5 0 0 3 14 3 0 1 9. Palakkad 37 79 5 5 1 33 7 0 0 11 14 0 0 2 10. Malappuram 69 91 2 7 0 13 7 2 0 10 16 3 0 1 11. Kozhikode 39 119 6 5 1 18 2 0 3 2 18 0 1 0 12. Wayanad 44 42 4 4 3 1 4 0 1 6 11 1 0 1 13. Kannur 43 89 0 7 0 1 3 0 0 0 4 0 0 1 14. Kasaragode 37 54 3 2 0 7 9 0 1 2 13 0 0 0 Total 713 1,126 39 82 15 114 97 10 6 61 212 15 2 8 Grand Total 2500

2

1.2 Audit Observations and Conclusions As per the mandate provided in ToR, audit aimed at understanding many a fact which were instrumental in achieving satisfactory or unsatisfactory level of ESMF implementation in the project. The audit further looked into areas of concern which reduced further effectiveness of ESMF benefits in the subproject implementation. Since KLGSDP strictly followed the existing decentralized planning process for its implementation, the ET Audit findings (positive & negative) are also summarized to reconcile with the relevant plan procedures. The audit findings and inferences vis-a-vis audit objectives mandated in the ToR are summarized in table 1.3 below.

Table 1.3: Audit findings vis-a-vis the Audit Objectives

Audit Objective Audit Findings  KLGSDP was successful in integrating the required Proformas for environmental & social compliance verification (annexure-6 ie, the Proforma C and D of ESMF) in their regular plan software(IKM software). This has resulted in local bodies following the ESMF documentation procedure successfully.

 Integration of ESMF compliance porformas in the IKM software as Annexure-6 helped the LBs a lot in ensuring verification and compliance process enumerated in the ESMF. It is observed that the documentation of same is also reasonably good in LBs since proper documentation of compliance verification form was mandatory in Annual Performance Assessment (APA) as well.

1. Determine the extent of  Extent of compliance to the ESMF over the project period could compliance to the ESMF be interpreted in two ways. With regard to screening and (both in documentation and verification process by KLGSDP through relevant proforma in field level implementation) achieved application at the time of project formulation and approval by over the project period and District Planning Committees, ESMF compliance was found to identify non-compliances, if be highly satisfactory; however, when it came to further any, with respect to applying the provision of ESMF such as incorporation of applicable national / state / mitigation measures or diligently filling up the Limited local regulations Environmental and Social Appraisal (LESA) form, ESMF compliance was found to be moderately satisfactory.

 It was difficult to identify through audit process, non- compliances, if any, with respect to applicable national / state / local regulations since most of the project related Environmental & Social Compliance proformas (Annexure-6 in IKM Software) did not explore regulatory compliance column in detail. This is due to lack of enough knowledge on the part of Implementing Officers (Municipal/Assistant Engineers, Municipal/Panchayat Secretaries, Agricultural Officers etc) or lack of interest in further exploring the applicability of regulatory compliances necessary for the projects.

3

2. Determine how effectively  Able guidance provided by KLGSDP mentors and extensive the systems and procedures defined in the latest version awareness training programmes at state and district level of the ESMF have been helped effectively in conveying to support staff of LSGs the applied by the project importance of ESMF integration with overall planning and implementation team and implementation of KLGSDP projects. identify deficiencies therein, if any.  The level of understanding of the Implementing Officers (IOs) of projects responsible for implementing ESMF provisions were not consistent as majority of them were transferred frequently or given additional charges of other LBs also causing loss of ESMF knowledge base for the time till the new Implementing Officers were given refresher training on ESMF implementation.  In order to fill the knowledge gap, refresher training programmes need to be more frequent.  Although general understanding of ESMF compliance requirement through Annexure-6 in the IKM software is good, yet understanding of project specific requirements via-a-vis environmental mitigation measures lacked clarity in many of the Block Engineers and IOs.  There is immense scope to further improve their understanding on this aspect, through capacity building activities at different levels.  Modified ESMF suggested by the Mid-Term Environmental Audit (MT Audit) enhanced quality of ESMF implementation at large mainly for the reason that several confusing and overlapping implementation aspects of ESMF were done away with.  For example, in earlier version of ESMF all types of road projects were taken into Level 2 (medium impact) category in the Control List (Proforma B of ESMF), but in reality most of such projects were related to only surface toping or maintenance and fell in Level 1 (low impact) category and as 3. Determine the extent of such LESA applicable for Level 2 were not applicable to these improvement achieved, if projects. Revised ESMF did away with this confusion and any, after modifications pushed all these projects in Level 1 while new road suggested by the mid-term construction projects were only kept in Level 2 list. Similarly, environmental audit had been incorporated there were several maintenance activities taken up on adhoc basis in different areas, were in new ESMF these subprojects were better categorized so as to bring them under Level 1 projects and manage in systematic way via-a-vis environmental management. New proforma guiding mitigation plans for the Level 2 projects and projects involving land acquisition were also introduced in new ESMF for better screening and mitigation of impacts.  New proforma, guiding mitigation plans for the Level 2 projects and projects involving land acquisition were also introduced in new ESMF for better screening and mitigation of impacts.

4

 Following MT Audit recommendations, overall ESMF compliance increased reasonably well and many non compliant projects moved into the category of compliant projects with proper intervention of KLGSDP through dissemination workshops at district level and also through the constant follow ups of District Coordinators (DCs) and PMU of KLGSDP.  However, the Audit also observed that owing to weak maintenance at post implementation stage, some of the projects which were performing well during midterm audit failed to achieve even “satisfactory” conditions of the current audit rating. This showed lack of maintenance activities following implementation of a subproject.  Significant number of projects in L1 category(37%) were found to have performed as “good”. However, same is low in L2 4. Determine the extent to category where percentage of good projects is only 9. which possible direct or o Good projects are those which scored over 75% marks indirect adverse impacts to in audit process. various constituents of the  Good projects have been successful in avoiding any adverse environment such as human impact on environment by means of holistic application of all lives, property and nature, as ESMF provisions right from sub project planning to a consequence of project implementation and monitoring stages of the project. related activities, have been  Majority of the projects have performed satisfactorily in terms avoided, prevented or of avoiding direct or indirect adverse impact on the mitigated environment by applying ESMF provisions:  60% of the project in L1 and 80% of the projects in L2 category have performed satisfactorily o Satisfactory projects are those which scored marks between 61% to 74%  Very small (3% in L1 and 11% in L2 category) number of projects were found to have performed poorly in applying ESMF provisions, thereby causing some very low level adverse impact on environment and natural resource  Some lack of clarity was found on the approach and process of filling the ESMF formats, especially the section on mitigation measures for Level 1 and Level 2 sub projects and LESA for 5. Comment on the adequacy of Level 2 sub projects. There is good scope for bringing more the systems and procedures simplicity and clarity in these formats. contained in the latest  The responsibility for all ESMF related processes at the GP and version of the ESMF (post MN level, such as screening and verification, lies with the IOs( mid-term environmental usually Assistant Engineers) and approval lies with Block audit) and point out scope Engineers(usually Assistant Executive Engineers). Same officers for further improvement, if are also supposed to ensure compliance and hence an issue of any. conflict of interest arises many times, which goes against the spirit of fair implementation of ESMF provisions.  There is a need as well as good scope for further improving the ESMF compliance at the GP and Municipality level. However, this may also likely give rise to extra workload for already stretched Implementing Officer.  The important position of IO is on a dual-charge basis at many GPs and MNs, This affects attention of IOs to environmental mitigation measures required for subproject activity, which invariably causes unsatisfactory level of implementation and monitoring of sub projects.

1.3 Audit observations on Compliance to ESMF Audit appreciably found that KLGSDP was successful in integrating the required Proformas for environmental & social compliance verification in their regular plan software and imparting

5

information on same through a series of Capacity Building trainings and sensitizing the LBs through all available platforms through their District Units which helped in largely “Satisfactory” compliance of ESMF provisions on the whole. Screening of the projects for the ESMF compliance by PMU and District Units through their regular monitoring and reporting system is also commendable. However, despite notable capacity building training and monitoring efforts by PMU, training and monitoring was still found insufficient in sensitizing all the stakeholder vis-a-vis importance of ESMF document. A questionnaire was developed by the audit team for the implementing officers (IOs) in the local bodies as the IOs are the technical personnel in LSGIs dealing with the environment safeguard issues, procedures and practices. IOs can be Municipal/Assistant Engineers for infrastructure projects excluding the construction of agriculture related projects or Municipal/Panchayat Secretaries for purchase projects. The rationale for arriving at the auditor’s conclusion that ESMF compliance was “satisfactory” in KLGSDP is explained below: i) Whether Implementing Officers (IOs) referred to the ESMF document during project planning stage, notably the screening level compliance documentation ii) Whether mitigation measures for L1 and L2 category projects were applied by IOs as per Proforma E and F given on ESMF document iii) Whether IOs views on feasibility of applying Mitigation measures successfully iv) Feedback on training programs attended by IOS Of the 341 IOs included in the scope for EA, 62% responded that respective IOs referred to the ESMF document for screening as well as for applying mitigation measures according to type of activity. Above 60% of the IOs were also of the view that application of mitigation measures in their projects was very much feasible. Above 60% marks achieved in above three categories clearly suggests that ESMF compliance was “ Satisifactory” in KLGSDP sub projects. Training frequency, however, was not found fully satisfactory in the opinion of auditor, vis-a vis capacity building component mentioned in the ESMF Document, since only 35% IOs were either aware of training programs on ESMF or actually participated in the same. Even though the reasons for this moderate percentage was attributed to different factors such as frequent transfers, new recruitments and high work load of IOs, this was found to be an area of intervention by Government to ensure a sustained capacity building mechanism for further improvement in this area. The sections 5.1.1 to 5.1.5 in Chapter 5 of Audit findings provides more explanations and pictorial representation for these rationale and findings of the auditors. Statutory compliance requirement were not given adequate attention in the process of ESMF implementation and audit too could not verify such noncompliance since relevant documentation was not practiced. Auditors also found that, Mid-Term Environmental Audit (MT Audit) and its dissemination of findings to the LBs enhanced quality of ESMF implementation at large. There are activity-specific observations and sub project wise observations noted by auditors, and are summarized in the following sections.

6

Activity Specific General Observations  Around 40,000 subprojects have been undertaken with KLGSDP during the project period. KLGSDP has led to asset creation and better service delivery in all the LBs audited.  The building projects such as modernization or construction of cabins and front offices for GP/MN offices have rendered the LB offices more receptive and public friendly.  The Proforma E and Proforma G of the ESMF envisages the planning and adoption of solid and liquid waste management system in all the building projects. Onsite solid waste disposal system was being followed in some of the Anganwadi projects audited, through the yard composting of the food waste generated. The absence of compound walls in some of the Anganwadis audited which were having close proximity to roads, ponds etc have raised safety and security concerns of the children there.  The use of recycled material in building construction as envisaged by ESMF (mitigation guidelines) was not being undertaken in the LSGs as the current Public Works Department (PWD) manual does not have provisions for the same.  Waste was observed to be poorly managed during the construction activity in some of the ongoing projects. The construction waste such as leftover cement, wood logs, stone, steel rods, rubble, etc. were not properly disposed of and were still lying around the project site during audit. Often, there was no provision for waste bins in some of the completed buildings.  Construction of some bridges has provided connectivity to high range people who were secluded due to the absence of all weather roads.  Conducting road safety audits, provision of sign boards or pedestrian facilities for the entire stretch of road constructed etc as envisaged in the ESMF are not being practiced in any of the road projects audited, as mostly these projects are of the nature of upgradation of the existing roads or retarring of the roads.  Construction of roads without drains, in the water logged areas and construction of drains without considering the natural slope of the terrain were observed as poor practices in a few cases.  Sanitation and waste management being pressing issues in Kerala, the initiative by the LSGs under KLGSDP for solving these issues prove promising. However, a few completed projects under this category were not functional due to lack of the adequate equipment and machinery for waste treatment and have rather become a public nuisances under non-compliant categories of projects as per ESMF provisions (Any activity involving littering and burning of Municipal Solid Waste in cities, towns and in urban areas is a prohibited activity as per ESMF)  Drinking water projects were found to be highly beneficial in most of the cases by providing access to piped water supply, except for a few where, the water quality of the water source itself was not maintained. A project involving new drinking water supply without testing of water quality to ensure that it is safe for human consumption is a prohibited activity according to ESMF as well.  Digging of a bore-well for water abstraction without permission of the State Ground Water Authority in notified areas or in areas classified as Critical / Over Exploited Zones, which is a prohibited activity as per the EMSF provisions was observed in 3 cases of ET Audit.

7

 It was observed that in some cases, sewage is directed towards the storm water drains. There is also a lack of trappings for silt and waste in stormwater drains, which can lead to stagnation, mosquito breeding, growth of weeds and over-flow of waste water along the roads. Sub project specific observations:

The sub project-specific observations are summarized in the following paragraphs.

1.4.1. Buildings- Construction, Repair and Expansion Awarded scores based on the audit observations to the projects coming under this category clearly indicate that there is a noticeable percentage of projects coming under Green category having audit scores more than 75 percent. Almost all of them ensured effective service delivery, but in a few cases, there were buildings with construction completed, but were not in use, due to the lack of electric or water connection. A total of 713 cases of buildings were surveyed, whereby the major observations are:  In case of natural resource usage, locally available materials were used in majority of the projects.  Rain water harvesting integrated in building design was observed only in a very rare number of cases. Rainwater harvesting should be promoted and implemented to a larger extent, as Kerala is gifted with abundant monsoon, yet go through dry spells every year.  The recyclable wastes such as paper and plastics from office buildings are usually send to recyclers, but there were provisions for onsite treatment of biodegradable waste in a very limited number of instances.  Development and maintenance of greenery in the building premises as envisioned in the ESMF is practiced in a few buildings  Most of the buildings had system for sewage treatment through septic tank followed by soak pit.  Provision for health, hygiene & safety was average in completed and as well as in ongoing projects. Only a very few projects had access to first aid, fire-fighting measures, etc.

1.4.2. Roads/Bridges/Culverts: Construction, Repair and Maintenance

A total of 1126 cases of projects were surveyed and most of the projects revealed a satisfactory way of execution according to the provisions of ESMF. Road and bridges which provide all weather connectivity to high range people/tribals, who are otherwise secluded stands out as classic examples of service delivery. Other observations are summarized below.  Quality of roads was found above average and highly beneficial to the local residents. There is a scope of improvement in areas like road safety, by provision of sign boards. In majority of the projects, roadside drains were not constructed due to lack of space.  Though the quality of the project implementation is good, most of the roads are constructed /maintained for small stretches. There were projects involving the retarring or concreting of only a 100 m stretch of road, while the rest of the portion in the road remains unmaintained due to lack proper planning of the funds.  Metalling is not enough for severe monsoon in the region like Kerala, concreting or tarring of road may be considered in future. If tarring is considered, use of plastic waste along with bitumen (plastic roads) shall be considered which will help in tackling the plastic waste management issue as well.  Lack of maintenance has resulted in blockage in some culverts.

8

1.4.3. Waiting Sheds, Parking Yards, Bathing Ghats - Construction, Operation and Maintenance

A total of 39 projects under this category were surveyed – both new constructions and maintenance. Apparently audit reflects a good deal of satisfaction among locals via-a-vis built quality of these infrastructure and in terms of service delivery.

1.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste

The total number of projects audited under this category was 15. The audit observations for this category of projects is summarized below  Provision of better sanitation facilities for the government schools is creates an enabling environment which secures children’s dignity, safety, health and attendance in classes. Maintenance was also properly done for the toilets constructed under KLGSDP funds in schools, whereas the maintenance of toilets in public places remains unsatisfactory. The toilets constructed were provided with septic tanks.  E-Toilets, which are self cleaning with very limited water consumption and in built STP, remain public abandoned projects mainly due to the lack of awareness about their usage  Solid waste management projects lacked the adequate machinery and equipment for treatment of waste such as shredders, gas collection or flaring systems etc. Mechanisms for segregation of biodegradable and non-biodegradable waste was absent in all such facilities audited. Provision of technical support and adequate funds can drastically improve these projects and can make them model projects in solving the never ending solid waste management issues Kerala is facing these days.  Subprojects involving the collection and management of electronic waste and biomedical waste were not observed during the audit. This may be because, the e-waste or biomedical waste collection in Kerala are done by big players such as the Clean Kerala Company Limited or IMAGE respectively which are authorized by Central Pollution Control Board (CPCB) for the management of these types of waste. Management of these wastes by decentralized systems is still in a nascent stage only.

1.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Waste Management Installations, Stadiums, Play grounds, Swimming Pools: Construction/ Repair and Maintenance

A total 82 cases of such projects were audited, whereby the major observations are:  The public markets constructed proved to be a boon to the local people in selling their produce, but in one instance, the market was not functional due to lack of access road.  The LBs have provided waste collection system at some of the markets audited.  First aid and firefighting equipment shall be compulsorily made available in all such projects  Slaughter house projects, burial grounds etc were not undertaken under KLGSDP.

1.4.6. Minor and micro Irrigation and Check Dams - Construction and Maintenance

 There were 15 projects audited under this category and it was observed that the projects were meticulously implemented. 9

 Canals constructed for irrigation have proved to be real blessing for the small scale farmers in many regions by providing regular water supply even during summer, whereas the water source was observed to be inadequate in one of the audited cases.  Periodic desiltation as envisioned in the ESMF was not being done in any of the cases audited, however, this was not observed to be hampering the performance of the irrigation projects

1.4.7. Drinking water supply- Construction, expansion, operation, maintenance and repair

Drinking water projects were found to be highly beneficial in most of the cases by providing access to piped water supply, except for a few where, the water quality of the water source itself was not maintained. A project involving new drinking water supply without testing of water quality to ensure that it is safe for human consumption is a prohibited activity according to ESMF as well. Water treatment methods were not adopted for the water sources such as borewells or ponds. A total of 114 cases were surveyed, findings are listed below:  Water supply scheme projects were implemented successfully and now water is easily accessible to nearby locals. While doing so, enough attention was not given to water treatment and water quality testing.  Some of the projects audited were observed to be non-functional due to lack of adequate quantity of water in the water source.  Water testing is not undertaken in many cases for overall water quality and microbial contamination.

1.4.8. Storm water Drains- Construction, repair and maintenance A total of 97 cases of drains were surveyed with following observations:  The drains were mostly constructed with cover slabs, but in some cases there were open drains constructed in which littering were observed.  Although quality of the construction was found good, there was lack of trappings for silt and waste in storm drains. Periodic cleaning to remove any sedimented silt/sand/debris shall be done. Otherwise, the accumulated silt over time will reduce the drain capacity considerably. But desilting work must be monitored and done from end to end.  In some of the roadside drain projects audited, the slope of the terrain was not given due consideration in the design of the drain and hence water was not draining to the drains and rather remaining stagnant on the road itself.

1.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension

These projects mostly included the training centres for agriculture. In two of the cases audited, a marketing centre for agriculture was being used as a fire station.

1.4.10. Meat & Fish Production and Marketing - Repair and Maintenance of facilities A total of 6 cases of such projects were surveyed. Following are the notable observations:  In the fish markets, there was no treatment facility for disposal of liquid & solid wastes generated. There was littering in the some fish markets.  Provision for health, hygiene & safety was poor, since site is not regularly cleaned and proper hygiene is not maintained.

10

1.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning These projects were constructed for small drinking water/irrigation projects. A total of 61 such projects were surveyed in this audit and major observations are outlined here under.  In a few instances. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District, Ozhukkuneettil Thodu at Kayamkulam MN, Alapuzha District), waste was seen dumped in nearby water body, ditch etc. causing pollution, mosquito breeding, stagnation etc  Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified areas, no individual and/or agency, is expected to undertake any ground water based activity, which will entail additional ground water draft. In one of these blocks (Chittoor in Palakkad), a project for renovation and recharge of well was undertaken which can be considered as one of the best practices.

1.4.12. Electrical & Electronic items - Purchase, Installation, Operation and Maintenance A total of 212 such projects were audited. These project were found to be beneficial to the LB officials. The environmental impacts of such projects are very limited during the operation phase, but after the end of life, such projects are a real threat to the environment as they become e-waste. E-waste management shall be carefully planned and implemented in the LBs. 1.4.13. Tiny and Small Industries – Establishment and Expansion Only 8 such projects were surveyed during ET Audit. These projects were mostly meant for tiny and small scale women centric industries. Most of them are under construction or construction might have just completed, but the buildings are not yet operational due to lack of water/electricity connection. 1.4.14. Animal Husbandry and dairy farming-construction and expansion facilities

Two such projects were audited and found satisfactory from ESMF point of view. However, one of the projects was not operational while other one was found lacking in suitable infrastructure.

1.4 Recommendations It was clear from the audit findings that, the ESMF implementation experience throughout the project cycle has given a number of learnings and lessons for way forward. KLGSDP was the first project under Local Self Government Department to implement an operational ESMF mandatorily and systematically. It is understood that, this was a piloting method for mainstreaming the ESMF integration in whole LSG system. The lessons learnt will pave the way for opportunities for further strengthening of the current ESMF. Given below are the key recommendations:  Design related environmental safeguards built in the sub projects through ESMF need to be integrated at the sub project planning stage by suitable institutional mechanism, because some of the design based environmental mitigation measures listed in the ESMF at present become redundant if not looked at during sub project planning. There is also a need for proper budget allocation at the time of planning itself for meeting environmental mitigation cost.  In the current system, IOs are looking after most of the ESMF implementation aspects and block engineers are responsible for verification and supervision of ESMF compliance. This not only raises conflict of interest issue but also stretches their work load. It is recommended that there should be a dedicated environmental cum social specialist at block level who could be

11

given charge of managing the ESMF verification compliance in association with block engineers. A State Level Environmental Cell is advised, where the E& S mandatory clearance procedures could be facilitated and monitored on behalf of LSGIs. This will also bring in more knowledge base on ESMF issues and help in holistic implementation of ESMF procedures.  IOs are transferred regularly. Newly appointed IO should be able to at least know all the project sites. This was one of the problems frequently observed by the ET auditors. Frequent refresher and orientation training is important for IOs.  A capacity building plan was conceptualized and made part of ESMF implementation framework. Kerala Institute of Local administration(KILA) and State Institute of Rural Development(SIRD) are the two nodal agencies which have been given mandate for planning and imparting training under local government projects . However, both the agencies could not deliver on training needs of the KLGSDP project owing to their inherent internal issues, especially lack of faculty on the expected training areas. It is recommended that these agencies should have a provision for hiring faculties from outside, if required and compulsorily complete the training mandate given to them under LSG projects since training goes a long way in successful implementation of ESMF provisions.  Effective Monitoring is an important aspect of long term success of environmental safeguard. Current ESMF has a robust monitoring process in place and it is suggested that existing monitoring procedures should be complied diligently without any dilution.  Elected LB members should also be sensitized to promote their involvement in ESMF screening and compliance process. Elected members should also try to involve local community through awareness generation so as to promote ownership towards the assets created and their maintenance, through citizen-centric information, education and communication (IEC) campaign.  ESMF formats have been simplified in the new version of ESMF. There is still scope for further simplification and trimming of ESMF formats which could help in better compliance of ESMF provisions.  Mitigation measures, identified at initial stage and implemented subsequently, should be documented. The compliance must be recorded with photographic evidence. Further, provision for photographic evidence at various stages of project implementation should be kept for a systematic recording and follow –up of activities undertaken in environmentally safe manner at GP and MN level.  Monitoring of ESMF activities should also be integrated with other monitoring activities through MIS.  Requirement of permissions and NOCs towards the concerned project (e.g. land acquisition, NA certificate, NOC etc.) should be acquired by IOs in advance. Proper procedure needs to be followed in such circumstances and records must be maintained.  Project files along with all the documents should also be stored in soft copy, so that, in case of hardcopy of the file being misplaced, it will be easier to regenerate the file.  In case of execution of sub projects falling under prohibited/restricted activities as per proforma A of ESMF document, permission from appropriate authority should be compulsorily obtained and properly documented. There were cases found during audit where Implementing Officers are unaware of such stipulations. As an example, maximum of 5 HP pump is permitted for ground water extraction as per the earlier version of ESMF, however, pumps up to 20 HP were found during audit in certain Local Bodies.

12

 ESMF provisions and stipulated mitigation measures for various type of subprojects must be made part of the tender and contract awarding procedures for the contractors to make the Projects ESMF compliant. Apart from the policy level recommendations and suggestions mentioned above, some of the activity-specific recommendations are also summarised below:  Photographs of the project site before, during and after completion of the project should be kept in the records.  There should be regular inspection of the project, especially before and after the monsoon season. During auditing, issues like cracks, leakage, etc. were observed in some buildings, roads, drains etc. In many cases, projects were incomplete, resulting in deterioration of unfinished project.  There is a need to focus on an integrated solid waste management approach for the LBs. Although the provision for SWM exists in the project, it has not been taken up yet at most places.  Environment-friendly activities such as installation of solar lights, plantation drives etc should be promoted.  More plantation measures need to be taken up by the LBs for prevention of soil erosion.  For projects related to water, quality of water must be checked periodically (for drinking water, at least once a week and for other uses, once a month) and classify as per Central Pollution Control Board norms and inform beneficiaries accordingly.  Wherever applicable, silt traps should be provided to trap silt. Such traps will not allow silt to flow in drains, thereby occupying useful volume. This will reduce de- silting requirements.  Ground water abstraction should be avoided for the project work, wherever possible. The height of guard walls for the ponds should be higher than the ground level.  There should be provision for non-conventional energy sources (solar and biogas), energy efficient electric fixtures (LED lights, energy star rated devices etc.), rain water harvesting and recycling of waste. Wastage of paper, water, electricity, etc. should be minimized in offices. Use of materials like wood, glass and agricultural soil should be minimized, while asbestos must be prohibited for regular use.  When roofing sheets are laid for buildings, transparent sheets, which can act as skylights can be provided.  Buildings must have suitable fire-fighting measures installed, and staff should be trained to use fire extinguishers and these should be checked regularly towards working condition and expiry date.  The Anganwadi projects are mostly constructed in small land parcels obtained through land donation. Hence provision of open space as play area for children is lacking in most of the projects audited. If possible, a nearby alternate open space as play area shall also be identified for the children  Regular maintenance is required for tarred roads because of wear or deterioration and hence fund allocation in the project planning stage should consider this aspect. When retarring is being done, use of plastic waste along with bitumen (plastic roads) shall be considered, which will improve the longevity of the roads.  Concrete roads require lesser maintenance compared to tarred roads and hence can be preferred in water logged areas depending on the budget  The wastewater should not be discharged in the water bodies and be treated properly as per the existing rules.

13

 The streetlights (tube lights), after end of life become hazardous waste. This shall be disposed off through authorized hazardous waste recyclers. Similarly, the waste oil/lube oil from the diesel generator is a hazardous waste. Care must be taken to store it separately in drums etc and dispose it through Kerala Pollution Control Board approved vendors.  E-waste management shall be carefully planned. Clean Kerala Company Limited collects e- waste in bulk. Hence any e-waste generated can be stored separately and shall be handed over to them.

14

Chapter 2: End of Term Environmental Audit for KLGSDP

This chapter gives a brief overview of the Kerala Local Government Service Delivery Project (KLGSDP), and the need for conducting an End of Term Environmental Audit (ET Audit). The objective and scope of the ET Audit are also detailed here.

2.1 Background Since independence, Kerala has been leading the way in decentralized local governance in the country. After the new Panchayati Raj Act came into force in 1994, the State has moved at good pace in transferring functions, responsibilities, authority and finances to Local Governments. Government of Kerala also realized that strengthening of Local Governments can play an instrumental role in delivering effective governance, building useful public infrastructure, responsive public services and effective poverty alleviation efforts. In order to further boost local service delivery projects, The Government of Kerala, in partnership with The World Bank conceived the Kerala Local Government Service Delivery Project (KLGSDP).The project strived to raise the level of service deliveries of Local Self Government Institutions (LSGIs) using modern tools of planning, development, project implementation and transparency in administration. Direct beneficiaries of the project are the 978 GPs and 60 Municipalities in the State of Kerala as per the project implementation manual(PIM)(after delimitation in 2016,the number of GPs are 941 and MNs are 87). Several interventions proposed in this project consisted of (a) an annual, performance-based untied grant to all GPs and Municipalities in Kerala to be spent on creation and / or maintenance of capital assets used in service delivery; (b) capacity building inputs to strengthen and supplement the existing systems and human resource of Municipalities and GPs to enhance their institutional performance; (c) support for strengthening the system of performance monitoring of GPs and Municipalities; and(d) support for a Project Management Unit (PMU) that would handle overall coordination, implementation, monitoring and evaluation of the project.

2.2 Environmental and Social Management Framework (ESMF) It is mandatory requirement under World Bank appraisal procedures to undertake environmental and social assessment of projects. Community driven development projects such as the KLGSDP having several sub projects of various nature and widely spread in the state required environmental and social assessment within an Environmental and Social Management Framework (ESMF), which identifies possible impacts on various environmental and social aspects and suggests ways to prevent and or mitigate them. Accordingly, an ESMF was prepared for the KLGSDP, which describes specific safeguard measures to be undertaken at various stages of the project planning and implementation process – formulation, approval, implementation & post-implementation. Application of the ESMF has been closely monitored and evaluated during the project period. The responsibility for application of the ESMF rests with the Environment Specialist in the PMU set up at the state level. For ensuring compliance of ESMF, capacity building of different project stakeholders has been undertaken. Adherence to ESMF has been monitored on a regular basis by the PMU through District Units. The MT Audit was conducted to assess the extent of compliance to the ESMF achieved midway through the project implementation phase. 15

The MT Audit suggested specific revisions and modifications in the existing screening procedures that could significantly improve its effectiveness. Suggested revisions have since been incorporated and the revised document finalized. The revised ESMF document has been published in the LSGD website and KLGSDP website for ready reference of LSG functionaries as well as the public and other stakeholders.

2.3 E&S Clearance Toolkit of the ESMF and the stages of application in project implementation The ESMF presents certain screening tools and guidelines which were developed for use of concerned LB functionaries / officials for according Environmental and Social Clearance to proposed activities and subsequently verifying compliances. This is referred to as the E&S Clearance toolkit of the ESMF. This includes the following

1. The Regulatory List Screening Tool (Proforma A) 2. The Control List Screening Tool (Proforma B) 3. E&S Clearance and Compliance Format for GPs (Proforma C) 4. E&S Clearance and Compliance Format for Municipalities (Proforma D) 5. E&S Mitigation Guidelines for Level-1 activities (Proforma E) 6. Format for Conduction of LESA for Level-2 activities (Proforma F) 7. E&S Mitigation Guidelines for Level-2 activities (Proforma G) 8. Social Screening Compliance Format for Subprojects involving Land Acquisition (Proforma H)

The ‘Regulatory List’ has been prepared for use in the first stage of screening and is intended for weeding out activities that are prohibited by prevailing applicable regulations or allowed in only very special circumstances. The second stage of screening known as the ‘Control List’ is meant for proposals which have cleared the first stage. The Control List consists of two separate components: that of activities classified as Level 1 and that of activities classified as Level 2. Level 1 activities are expected to have relatively low magnitude E&S impacts while Level 2 activities could lead to slightly higher, i.e., medium level E&S impacts. The mitigation measures for Level 1 activities are given in Proforma E and the mitigation measures for Level 2 activities are given in Proforma G.

2.4 Institutional Framework for EMSF implementation The actual implementation of the ESMF is to be affected through the existing organizational structure in the LSG system. The few marginal changes that have been made have more to do with providing facilitation and mentoring support as well capacity building. Overall coordination and monitoring support will be provided through the Project Management Unit (PMU). The Environment and Social Management Specialist of PMU has the mandate is to ensure correct and effective implementation of the ESMF.

Table 2.1: Institutional Structure for ESMF Implementation for GPs

Institution Current roles in development Responsibilities with respect planning to EMF KLGSDP State PMU having 1  Project Implementation  Provide technical support to Environmental and Social Expert  Overall Management development of capacity (On institutionalization at later  Monitoring  building modules stage, for ESMF to be made  Reporting and  Coordinate Capacity building applicable to all LB activities, 16

this documentation activities on ESMF would appropriately be replaced  Institutionalize ESMF with designated Environmental process Engineer/Environmental  Ensure correct Specialist placed at implementation of ESMF Block/District level  Review & update ESMF procedures, if required  Compile annual report on ESMF implementation and compliance with highlights of environmental gains Ward/Grama Sabha  Conceive & raise the local  Raise E&S issues with needs & issues respect to proposed project,  Review earlier development if any pursuits.  Prioritizes subproject proposals  Prepares project proposals  Raise E&S issues with Working Group based on inputs from respect to proposed project, Ward/Grama Sabha if any  Prepares DPR  Undertakes screening and mitigation plan preparation  Conducts Development  Cross-verifies ESMF GP Committee Seminar and prepares final implementation subproject plan GP Engineer /Implementation  Oversees all technical work  Prepares DPR Officer and works execution  Screens project and prepares  Provides technical guidance mitigation plan to GP  Forwards DPR to GP  Prepares DPRs Committee for onward processing  Oversees and supervises work in progress including  ESMF compliance and manages contractors  Verifies ESMF compliance Block Level Officer in the next  Ensures compliance to  Ensures ESMF compliance higher tier of Implementing mandatory guidelines  Examines the accuracy of Officer  Ensures compliance to impact assessment & technical guidelines and adequacy of mitigation ESMF measures  Verifies costing & phasing of  Addresses inter-sectoral projects environmental conflicts, if  Suggests innovation & any integration possibilities  Recommend E&S clearance  Sub-group Gives technical to the project sanction to projects  Extend support as resource persons for capacity building on ESMF District Planning Committee  Project approval  Issue E&S clearance along (DPC)  Plan integration with Project approval  Conduct annual review  Suggest modifications, if any, in EMP

17

Table 2.2: Institutional Structure for ESMF Implementation for MNs

Institution Current roles in development Responsibilities with respect planning to EMF KLGSDP State PMU having 1  Project Implementation  Provide technical support to Environmental and Social Expert  Overall Management development of capacity (On institutionalization at later  Monitoring  building modules stage, for ESMF to be made  Reporting and  Coordinate Capacity building applicable to all LB activities, documentation activities on ESMF this  Institutionalize ESMF would appropriately be replaced process with designated Environmental  Ensure correct Engineer/Environmental implementation of ESMF Specialist placed at  Review & update ESMF Block/District level procedures, if required  Compile annual report on ESMF implementation and compliance with highlights of environmental gains Ward Sabha  Conceive & raise the local  Raise E&S issues with needs & issues respect to proposed project,  Review earlier development if any pursuits.  Prioritizes subproject proposals  Prepares project proposals  Raise E&S issues with Ward Committee based on inputs from Ward respect to proposed project, if any  Conducts Development  Cross-verifies ESMF Standing Committee Seminar and prepares final implementation subproject plan  Conducts Development  Cross-verifies ESMF Municipal Council Seminar and prepares final implementation subproject plan Municipal Engineer  Ensures compliance to  Ensures ESMF compliance /Implementation Officer mandatory guidelines  Examines the accuracy of  Ensures compliance to impact assessment & technical guidelines and adequacy of mitigation ESMF measures  Verifies costing & phasing of  Addresses inter-sectoral projects environmental conflicts, if  Suggests innovation & any integration possibilities  Recommend E&S clearance  Sub-group gives technical to the project sanction to projects  Extend support as resource persons for capacity building on ESMF Assistant Executive Engineer/  Oversees all technical work  Prepares DPR including Executive Engineer / Chief and works execution mitigation plan if applicable Engineer  Provides technical guidance  Forwards DPR to Standing to the SC/MC/DPC Committee for onward  Prepares DPRs processing  Oversees and supervises work in progress including ESMF compliance and manages contractors  Verifies ESMF compliance District Planning Committee  Project approval  Issue E&S clearance along (DPC)  Plan integration with Project approval

18

 Conduct annual review with respect to environmental gains, in general, District level ESMF Compliance Report, in particular  Suggest modifications, if any, in EMP

2.5 Revisions in ESMF after the Mid Term Audit

The E&S Clearance toolkit of ESMF developed at the commencement of KLGSDP implementation, especially the Control List (Proforma B of ESMF) was thoroughly revised following the recommendations from the Mid Term Environmental Audit. Revisions were done in the regulatory list (Proforma A) and the control list (Proforma B) and 2 new formats, Proforma G and Proforma H were added. There was a revision in the institutional framework also. The duties of Block Engineer and Technical Advisory Group were merged and given to the block Engineer. The major revisions done in the regulatory list (Proforma A) of the ESMF are as follows:  As per the earlier version: “Any subproject involving construction within 200 meter to historical monuments and within 100 meter to railways, highways, etc was a prohibited activity”. In the modified version, this was changed to “Any subproject involving construction adjacent to historical monuments, railways, highways etc. infringing the distance prescribed by the Town Planning Department of Government of Kerala” is a prohibited activity  As per the earlier version: “Activities involving abstraction of water from a water course by a mechanical device of more than five horse power” is a prohibited activity. In the modified version, this has become, “Abstraction and pumping should be restricted to the safe yield of the source of water as per the certification of the Ground Water” is a prohibited activity  As per the earlier version: “Any construction activity involving locating of the leach pit, soak pit, earth closet or septic tank within a distance of 7.5 m radius from existing well or 1.2 m from the plot boundary is a prohibited activity, whereas in the new version: “Any construction activity involving locating of the leach pit, soak pit, earth closet or septic tank as per the existing guidelines of Kerala Municipal Building Rule (KMBR) & Kerala Panchayat Building Rule (KPBR)” is a prohibited activity.

The major revisions in the Control List are outlined below

 All the building construction projects, irrespective of whether new construction or repair/maintenance was considered as Level 1 in the earlier version of ESMF. Considering even the new constructions as Level 1, led to lower levels of implementation of mitigation measures. In the modified version of ESMF, all the new constructions were categorized as Level 2, requiring LESA (Limited Environmental and Social Appraisal, as per Proforma F of ESMF) and all the repair maintenance of building projects are categorized as Level 1.  All the road construction projects, irrespective of whether new construction or repair/maintenance was considered as Level 2 in the earlier version of ESMF. Considering even the repair/maintenance as Level 2, led to the requirement of doing LESA for appraisal. This resulted in lengthier documentation process for even small maintenance works. This was revised in the modified version of ESMF. Only new roads were considered as Level 2 in the new version.

19

 Similar revisions in re-categorization for better clarity were applied to the projects related to (1) ponds/tanks/wells/canals, (2)irrigation channels (3) storm water drains and (4)drinking water supply projects  Health Institutions: management of sanitation and hygiene: this category was removed and biomedical waste was included under the sanitation and waste management projects in the new version of ESMF.  A new category, Public Markets, Crematoriums, Burial Grounds, Public Toilets, Slaughter Houses, Waste Management Installations, Stadiums, Play grounds, Swimming Pools – Operation added. A new format for the mitigation measures for Level 2 activities (Proforma G) was incorporated. A new format for Social Screening Compliance for Subprojects involving Land Acquisition (Proforma H) was incorporated in the modified version of ESMF.

2.6 Objectives of Environmental Audit The Project is expected to end by June, 2017. At this juncture, End of Term Environment Audit (ET Audit) has been conducted to assess and determine the extent of success achieved in applying the ESMF, thereby suitably preventing / mitigating any likely adverse impacts on the environment infrastructure created / other expenses made using the performance grant during the project implementation period. ET audit has been conducted with following specific objectives:  Determination of the extent of compliance to the ESMF achieved over the project period and identify non-compliances, if any, with respect to applicable national / state / local regulations  Determination of how effectively the systems and procedures defined in the latest version of the ESMF have been applied by the project implementation team and identify deficiencies therein, if any. Also determine the extent of improvement achieved, if any, after modifications suggested by the mid-term environmental audit had been incorporated  Determination of the extent to which possible direct or indirect adverse impacts to various constituents of the environment such as human lives, property and nature, as a consequence of project related activities, have been avoided, prevented or mitigated  Comment on the adequacy of the systems and procedures contained in the latest version of the ESMF (post MT Audit) for suitably managing all possible environmental impacts in context of all sub-projects undertaken by the local bodies in the project and point out scope for further improvement, if any.

2.7 Scope of Work The scope of the ET Audit included all sub-projects implemented under the KLGSDP, including the projects coming under the onetime assistance to backward LBs. Compliance requirement laid out in all relevant legal documents pertaining to this project were required to be assessed. Scope of the audit assignment involved discussions at length with all officials / staff involved in project implementation including officials from the PMU, Project staff at the district level, relevant government officials at state and district levels and respective line department staff. Findings, observations and recommendations of the MT Audit were to be revisited during ET audit. Some of the major aspects that the audit exercise dwelt upon are summarized below:

20

 Assessment of strengths and weakness of internal controls which shall include but not limited to awareness, knowledge and competence of personnel (including elected members)in LSGs on environment safeguard issues, procedures and practices, maintenance of appropriate documentation/records pertaining to testing, other technical analysis, conclusions based on site conditions, reports on inspection and maintenance programs practiced, definition  Strengths / weaknesses of capacity building activities on environment;  Usefulness of including environmental performance in the Annual Performance Assessment (APA) criteria  Effectiveness and correctness of screening procedure (including LESA, if applicable) deployed  Correctness or aptness of the mitigation measures recommended. Deficiencies, if any, in screening or mitigation planning.  Correctness of implementation of compliance verification procedures  Documentation of (including photographic evidence) of good and bad practices  Issues on health and safety aspects.  Knowledge, capacity and skill levels of concerned LSG functionaries, officials and technical personnel with respect to ESMF  Effectiveness of the monitoring, reporting and feedback system between the Local Self Government Institutions and the PMU with respect to ESMF  Recommendations on strengthening the implementation of environmental and social safeguards  Recommendations on improving effectiveness of ESMF and its implementation for future LSGD activities. The approach for the study was to undertake a situation analysis of the environmental practice on a sample basis. Based on the audit of present situation, audit team examined the existing practices for ensuring environmental safeguards and has recommended measures to be included in the present framework and operational guidelines for ESMF. The next chapters describe the approach and methodology for the environmental audit study in detail.

21

Chapter 3: Methodology

This chapter presents the approach followed for the ET Audit. The detailed methodology along with the data analysis plan and measures for quality control and management are depicted in this chapter

3.1 Study Approach The ET Audit of the KLGSDP was based on the Logical Framework Approach consisting of survey tools, sample design, survey design and field survey with over all purpose of satisfying audit objective in robust manner. The boundary of ET audit or inclusions was defined in line with the scope of work as discussed in the previous chapter.

3.2 Audit Design A dual, Quantitative and Qualitative based audit design was adopted for the ET Audit. The specific objectives of the audit clearly sought out the need for collection and collation of data/information at different levels to gauge effectiveness as well as efficiency of various processes of implementation of Environmental and Social Management Framework (ESMF) developed for the KLGSDP.

3.3 Sampling Design The sample design and distribution adopted along with the sampling methodology was discussed and agreed upon, in consultation with the KLGSDP officials. Audit team referred the project MIS data of KLGSDP, considering detailed criteria to identify the representative sample of districts, sub divisions, GPs and MNs for this assignment. Environmental audit was conducted within overall sample size of 2500 sub project, which included 15% of the completed projects from the years 2014-15, 15% from the year 2015-16, 15% from backward support projects, 15% from midterm audited projects and remaining 15% from 2016-17 projects. In terms of GPs and MNs, audit covered a sample of 34% of the 941 GPs i.e. 321 GPs and 34 % of the 87 MNs i.e. 30 MNs, covering all the 14 districts of Kerala. Each district was given fair representation in the audit by means of an index calculated for each district depending on (a) the number of GPs in the district (b) number of MNs in the district (c) population density of the district (d) ranking of the district in the 1st Grant Cycle and 2nd Grant Cycle, based on the MT Audit. The LB-SUs in each district were selected randomly based on above mentioned index, at the same time; purposive sampling too was adopted to select some LBSUs in each district to satisfy two other significant criteria. The first criterion was to ensure that the best performed as well as the worst performed LB-SUs in all the districts during MT audit are represented in the ET audit as well. In this regard, three LB- SUs with the highest and lowest ranking each were selected for ET Audit. The second criterion was to ensure a fair representation of the economically weaker and marginalized communities such as the fishermen communities or economically weaker purely agronomic areas or very low income areas, minority and marginalized communities such as Scheduled castes and Scheduled tribes and regions with language minorities.

22

3.4 Local Body Sampling Units (LB-SUs) The Local Body Sampling Units (LB-SUs) refer to the specific place or location which can be used for the sampling process. The LB-SUs are selected from the sampling frame. Hence the LB-SUs are selected from the 941 GPs and 87 MNs. Selection of LB-SUs For the identification of number of LB-SUs, stratified sampling is adopted. In stratified sampling, members of the sample are selected proportionally from each stratum. All the strata should be mutually exclusive also. In this EA, the 14 districts of Kerala represent 14 different strata. This method of sampling improves the representativeness of the sample by reducing sampling error. Comparison between findings of the ET audit and the MT audit is an essential objective of the ET audit. Accordingly, for the selection of LB-SUs the results of MT audit were utilized. The LB-SUs (GP/MN) from each district is selected proportional to the aspects mentioned below.  Number of GPs in the district  Number of MNs in the district  Population density of the district (Obtained from 2011 Census data)  Ranking of the district in MT audit for the 1st Grant Cycle of KLGSDP  Ranking of the district in MT audit for the 2nd Grant Cycle of KLGSDP All the above criteria are given equal weightage. The details regarding the GPs/MNs for the districts were obtained from the website of Government of Kerala, Local Self Government Department. The population density is obtained from the Census 2011 data. The ranking for the MT audit was obtained from the MT audit report. The Index of each district for the above five criteria are determined, based on following formula: Number of entities in the given district belonging to the given category SCategory = Maximum number of entities in the given category in a district of Kerala State For .e g., Index for Trivandrum is obtained as follows. Number of GPs in Trivandrum = 73 GP s Maximum number of GPs in Kerala State is in Malappuram district, 94 GPs Therefore, Index for Trivandrum for first criteria = 73/94 = 0.78 Indices are calculated for all above five criteria, where each criterion has been given same weightage. Further criteria for selection of LB-SU and selection of activities, etc have been elaborated in detail in Voume-II document as part of this report

3.5 Detailed Survey Methodology The ET Audit of GPs and MNs followed following steps for undertaking field surveys: Step 1: Scoping and Boundary setting: In terms of Audit scope, the study covered all sub-projects implemented under the KLGSDP, including community infrastructure / fixed assets created and other activities undertaken using Performance Grant and Onetime assistance to backward Local Bodies. Study Boundary of the audit included direct as well as indirect beneficiaries of the project and both individual as

23

well as cumulative impacts and their mitigation. Compliance requirements laid out in all relevant legal documents pertaining to this project were thoroughly analysed such as the Contract Agreement with the World Bank, the PAD, the PIM, the ESMF and other applicable National, State and Local regulations. The Framework for the Environmental Audit was presented to the client and finalised in consultation with the client. Step 2: Meeting officials and Desk Review: In order to understand their perspective of implementing environment management in projects, all officials / staff involved in project implementation including officials from the PMU, Project staff at the district level, relevant Government officials at state and district levels and respective line department staff were visited by audit tem from time to time during audit process. Further, In order to familiarize themselves with project objectives, procedures and implementation framework, the audit team carried out a detailed and thorough review of relevant KLGSDP documents and other relevant documents pertaining to assessment of ESMF implementation such as PAD, ISDS, ESMF, MTR report, Mid-term Environmental Audit report, screening documentation, progress reports and ACRs. Further, the team also identified additional secondary data sources and literature useful in the context of the proposed study and reviewed the same. The team conducted an exhaustive review if the monitoring data as well as filled environmental and social review formats related to KLGSDP sub projects.. Following the review of relevant secondary documents, a list of indicators and guiding questions was developed focusing on the specific objective of Environmental Audit, which led to the design of various study instruments. A distinct set of indicators and guiding questions were developed for each of the environmental concerns identified for review, followed by development of distinct sets of study instruments for each of the identified process. These study instruments are discussed in Volume-II document of this report Also, while conducting desk reviews, the study team sought to identify key / critical areas, capacity needs, institutional aspects and building blocks for the environmental concerns and implementation, as per the environmental safeguards. The study team also sought to identify any areas for adaptation or modification, thereby enabling the project management to learn how to better shape and implement the environment aspect related to various activities. Step 3: Designing Study instruments (Qualitative and Quantitative) The study team designed data/information collection questionnaire for both qualitative as well as quantitative data collection. The survey questions were largely open ended, focused on determining the environment aspect of whole project activities, especially around ESMF provisions. Survey tools targeted a representative sample of the direct beneficiaries as well as other key stakeholders. All tools were used in English language. Based on past experience in the area of environmental audits, quantitative data collection was set up to form the main-stay of this study, and was ably supported by qualitative data (as required to substantiate tracking events and targets). A participatory approach was adopted for qualitative data collection. The qualitative data was collected through Focus group discussions (FGDs), Shared learning dialogues (SLDs), In-depth interviews and In-depth discussions with various stakeholders. Volume –II appended with this report explains more on this aspect.

24

Step 4: Field Visits The audit team undertook field visits to all the selected districts under the project, as per the sampling design proposed and finalized in consultation with the KLGSDP for specific site- based assessments. The field visits focused on collection of specific data to facilitate the determination of environment status, extent and impact of the various project activities under review as well as undertaking discussions with the relevant stakeholders. Field Visit Guide A field visit guide was developed to maintain consistency in all the field visits and to collect data in a structured manner. Based on the desk review and stakeholder consultation, activity- wise survey instruments (based on ESMF) were prepared to facilitate the experts to focus on the key information and collect data in an effective and efficient manner. Based on the finalized methodology and instruments, audit team visited each of the LBs selected through robust sampling for ensuring quality. The activities included the following tasks as per the RFP: . Comparison between findings of this audit and the earlier one . Assessment of strengths and weakness of internal controls which shall include but not limited to awareness, knowledge and competence of personnel (including elected members)in LSGs on environment safeguard issues, procedures and practices, maintenance of appropriate documentation/records pertaining to testing, other technical analysis, conclusions based on site conditions, reports on inspection and maintenance programs practiced, definition . Strengths / weaknesses of capacity building activities on environment; . Usefulness of including environmental performance in the Annual Performance Assessment criteria . Effectiveness and correctness of screening procedure (including LESA, if applicable) deployed . Correctness or aptness of the mitigation measures recommended. Deficiencies, if any, in screening or mitigation planning. . Correctness of implementation of compliance verification procedures . Documentation of (including photographic evidence) of good and bad practices . Issues on health and safety aspects. . Knowledge, capacity and skill levels of concerned LSG functionaries, officials and technical personnel with respect to ESMF . Effectiveness of the monitoring, reporting and feedback system between the Local Self Government Institutions and the PMU with respect to ESMF Recommendations on strengthening the implementation of environmental and social safeguards . Recommendations on improving effectiveness of ESMF and its implementation for future LSGD activities. Step 5: Success Stories Framework Success stories were documented to showcase and highlight a very positive experience of a particular environment focused execution that is worth narrating. By nature, these case studies are very short. Step 6: Workshop for sharing draft findings and Report Finalization The outcome of this audit report was presented through a state-level audit finding dissemination workshop, held at Trivandrum on June 28th 2017, to discuss the draft findings of the ET Audit and receive feedback on the same from a wide variety of stakeholders. The Audit

25

team has gathered and incorporated all the relevant comments and feedback into the final report.

3.6 Training of field staff for Environmental Audit Selection of Audit Personnel The ULTRA-TECH team selected and engaged experienced personnel as field auditors for the ET Audit. The field auditors were able to undertake data collection and interviews. Also, selected personnel had experience of interacting with elected representatives and employees at the GP and MN level. They were skilled at building rapport and experienced at gathering and interpretation of quantitative and qualitative data. Training programme for the field auditors was organized. Training was planned and organized prior to commencement of the audit at the field level. Training of field staff The field auditors underwent a training program (both qualitative and quantitative study instruments) of two days (April 11 and April 12th/17th , 2017), which included one day classroom training and one day field training in four batches on April 12 and 17. The training also included practice fieldwork and write-ups. In addition, the teams were made clear about the schedule for the field work, who will be responsible for which parts of the field work, and other such aspects.

3.7 Data Analysis Plan After the survey instruments were finalised, a data entry format was prepared in MS Excel. The data collected from the field was entered using this format, on which analysis was undertaken. Data analysis was conducted and presented activity-wise, followed by an overarching analysis of the entire project and feedback on the modifications or additions required in KLGSDP implementation from the environmental perspective.

3.8 Quality Control and Management Quality control protocols were followed as per standard practices for both qualitative and quantitative survey in the audit. During the mid of field auditing, a review meeting was organized by KLGSDP with the field auditors to review the progress of the audit and also to take recourse measures for the field level issues experienced during the audit.

26

Chapter 4: Field Training

This chapter describes briefly the process followed for the field survey. The same has been explained in detail in Volume-II document of this report in form of Annexure-2.

4.1 Training for Field Auditors A two-day training programme for the Environmental Audit field team was conducted, as per the following schedule, which included one day class room training and one day field training. The field trainings were conducted zone wise, details of which are tabulated in Table 4.1. Table 4.1: Details of training for the Field Auditors

Day 1 April 11, 2017 Class-room training at Thrissur District

Field level training at Kottuvally GP in Ernakulam District for the Field April 12, 2017 Auditors from Ernakulam, Idukki and Kottayam Districts

Field level training at Wadakkanchery MN in Thrissur District for the Field Day 2 April 18, 2017 Auditors from Malappuram, Palakkad and Thrissur

Field level training at Dharmadom GP in Kannur District for the Field April 18, 2017 Auditors from Kannur, Kasaragod, Wayanad and Kozhikode Districts

Field level training at Chavara GP in Kollam District for the Field Auditors April 18, 2017 from Alapuzha, Pathanamthitta, Kollam and Trivandrum Districts

The field trainings of sub project specific questionnaires were conducted in four local bodies coming under four different zones. Details of the same is summarised in Table 4.2.

Table 4.2: Subprojects covered during the field training of the Auditors

S No District GP Sub Projects Covered  Road metalling and tarring Ernakulam Kottuvally 1  Building Maintenance and Repair  Drainage construction  Drainage maintenance and repair

 Construction of footpath Kannur Dharmadom 2  Road tarring  Building Maintenance and Repair  Maintenance of solid waste treatment plant Thrissur Wadakkanchery  Drinking water project 3  Computerization  Drainage construction  Building Construction 4 Kollam Chavara  E Toilet  Foot path concrete

27

4.2 Sample Coverage by Field Survey The field survey for this study was undertaken at GP and MN level, with a review of a variety of activities implemented under the KLGSDP project. Sector specific questionnaires were used for the field data collection. Details of the survey are provided in the following paragraphs. The questionnaires developed for each of the sub projects are appended as Annexure 2 in Volume- II. The actual field survey for the ET Audit was undertaken from 12th April 2017 to 1st June 2017. As per the sample distribution provided in the previous chapter, the field survey was carried out in all 14 districts of KLGSDP implementation. In each of the districts, minimum 15 LBs were sampled (proportionate to the total no. of local bodies in the district, its population density, its ranking in the 1st Grant Cycle and 2nd Grant Cycle in the MT audit), in which 6 LBs (3 highest ranking and 3 lowest ranking LBs as per the MT audit) sampled were from the list of LBs covered under the MT Audit in 2013-14. Further, in each LB, at least five sub projects were sampled. In each of the sample LBs, discussions were held with the elected members of LB, employed members of LB, the District Co-ordinators of KLGSDP and the immediate beneficiaries of the sub projects, ie the local community, etc., along with site visits to all the sampled activities. Further details with photographic presentation are explained in Annexure-2 of Volume-II document as part of this ET audit report.

4.3 Stakeholder Consultations

As part of the environmental audit of KLGSDP supported Sub Projects implementation, a wide variety of stakeholder consultations were key to forming an opinion on the audit process and field level audit findings. Several stakeholders were consulted at various levels to gather information regarding sub projects. At the state level, policy level discussions were held with the KLGSDP officials and at the district, GP and MN level, sub project related discussions were held with a number of other stakeholders viz district coordinators of KLGSDP, implementing officers, elected representatives and the public. Final audit report was prepared based on field observation and input from the state and district level stakeholder consultations. The outcome of this audit report was presented through a state- level audit finding dissemination workshop, held at Trivandrum, to discuss the draft findings of the environmental audit study and receive feedback on the same from a wide variety of stakeholders.

28

Chapter 5: Audit Observations [

This chapter covers the audit observations including the awareness of the Implementing Officers on the various aspects in ESMF along with the field level observations for the 14 different categories of subprojects implemented under KLGSDP spread across the 14 districts of Kerala. The observations are detailed subproject wise.

5.1 Findings on ESMF Documentation and Implementation

The prime objectives of the ET Environmental Audit are associated with the implementation aspects including the adequacy of knowledge levels of the implementing officers with respect to ESMF and how are they getting equipped (capacity building) for better implementation of the ESMF guidelines. These objectives of the EA are depicted below:  Assessment of strengths and weakness of internal controls which shall include but not limited to awareness, knowledge and competence of personnel (including elected members)in LSGs on environment safeguard issues, procedures and practices, maintenance of appropriate documentation/records pertaining to testing, other technical analysis, conclusions based on site conditions, reports on inspection and maintenance programs practiced.  Assessment of the strengths / weaknesses of capacity building activities on environment.  Evaluation of the correctness or aptness of the mitigation measures recommended and to identify, the deficiencies, if any, in screening or mitigation planning.  Evaluation of the knowledge, capacity and skill levels of concerned LSG functionaries, officials and technical personnel with respect to ESMF. Towards achieving these four prime objectives, a questionnaire was developed for the implementing officers (IOs) in the local bodies as the IOs are the technical personnel in LSGIs dealing with the environment safeguard issues, procedures and practices. Maintenance of appropriate documentation is the responsibility of the IOs. The capacity building activities are aimed at the IOs mostly. The IOs are the ones responsible for the implementation of the projects as well as the planning and implementation of mitigation measures for easing the environmental impacts of the projects. The questionnaire developed for the IOs assessed the various aspects involved in project implementation starting from the project planning and formulation to the adoption of mitigation measures and their adequacy. This questionnaire also assessed the adequacy of the training programs that the IOs had undergone and how equipped are they to implement the ESMF guidelines. Distribution of the IOs participated/responded in the ET Environmental Audit A total of 341 IOs responded to the assessment questionnaire for IOs which included 65 Panchayat/Municipal Secretaries and 276 AEs. The distribution of the IOs is depicted in Figure 5.1.

19% Muncipal Engineer/Assistant Engineer 81% Panchayat/Municipal Secretary

Figure 5.1: Distribution of IOS responded to the questionnaire for IOs in the ET Audit 29

Experience of IOs in implementing KLGSDP subprojects The knowledge, capacity and skill levels of concerned IOs with respect to ESMF and their familiarity with the environment safeguard issues, procedures and practices, maintenance of appropriate documentation/records with respect to ESMF is directly linked to the number of KLGSDP subprojects they have implemented in their tenure as well as the number of years of experience they have in the project implementation field. These aspects were covered in the assessment tool for IOs. The result of the assessment is depicted in Figure 5.2.

8% >30 11% 20 - 30 46% 14% 10 - 20 11% 5 - 10 10% < 5 No response

Figure 5.2: Experience of the IOs in implementing KLGSDP subprojects

8% of the 341 IOs responded have implemented more than 30 KLGSDP subprojects, while 10% have implemented less than 5 KLGSDP subprojects. There was no response from a whopping 46% of the IOs regarding the number of KLGSDP subprojects they have implemented.

5.1.1. EMSF in the project planning stage The Environmental and Social (E & S) clearance procedures detailed in ESMF document are simple, non-expert based and user friendly, but these are new and relatively unfamiliar to various stakeholders who are expected to make use of these procedures while discharging their respective roles and responsibilities. The E&S clearance and compliance verification procedure as envisaged by ESMF enables LSGIs to integrate appropriate mitigation measures into the activity implementation plan itself and subsequently verify whether these were adequately complied with during work execution. For understanding and analyzing the use of ESMF guidelines by the Implementing Officers during the project planning phase, 341 Implementing Officers (IOs) who participated in the EA were asked whether they referred to ESMF document before commencing any Sub Project (SPs) related activities. The response from the IOs in this regard is depicted in Figure 5.3.

24% Refer ESMF document 14% Don't refer ESMF document 62% No response

Figure 5.3: Whether ESMF document is referred in the subproject planning stage: response from IOs

30

5.1.2. Adoption of Mitigation Measures as per EMSF Mitigation measures for L1 (Low Impact) activities are given in the Proforma E of the ESMF document and the mitigation measures for the L2 (Medium Impact) activities are given in the Proforma G of the ESMF document. The response to the IOs regarding adoption of mitigation measures as per ESMF is given in Figure 5.4.

Adopted mitigation measures as per 34% ESMF Didn’t adopt mitigation measures as per 62% ESMF No response 4%

Figure 5.4: Adoption of Mitigation Measures as per EMSF

62% of the 341 IOs responded stated that they adopt the mitigation measures for the environmental impacts of the subprojects, as per the ESMF document, while 4% responded that they don’t adopt the mitigation measures as per the ESMF citing reasons such as lack of expertise, time and budget constraints. However, it was noticed during the audit that the environmental impact identified in the Proforma C/D for the subprojects was only air pollution from fugitive dust emissions and the mitigation measure identified for this impact was water sprinkling or fencing. Other environmental impacts and mitigation measures detailed in the Proforma E/G are not being adopted in the LBs.

5.1.3. Feasibility of the Mitigation Measures in ESMF according to the IOs The IOs’ feedback on the feasibility of the mitigation measures mentioned in the ESMF document is depicted in Figure 5.5.

33% Mitigation measures in ESMF are feasible

60% Mitigation measures in ESMF are not feasible 7%

No response

Figure 5.5: IOs feedback regarding the feasibility of mitigation measures mentioned in ESMF document

60% of the 341 IOs responded that the mitigation measures adopted in the ESMF are feasible while 7% say these are not feasible citing reasons such as there can’t be universally applicable mitigation measures, as most of the mitigation measures are site and project specific. As cited earlier, even though the IOs have opined that the mitigation measures mentioned in the ESMF document are feasible, it was noted that the only environmental impact identified for

31

all the subprojects was air pollution from fugitive dust emissions and the mitigation measures adopted for this included water sprinkling or fencing around the project site.

5.1.4. Feedback on any training programmes attended by IOs related to ESMF Several capacity building training programmes were conducted by KLGSDP for the various stakeholders such as the IOs and other implementing staff such as the plan clerks, the KLGSDP district co-ordinators, the various other LB officials such as the Panchayat Presidents etc. Since ESMF is unique to only KLGSDP subproject implementation and this is a first of its kind in subproject implementation, knowledge dissemination to ensure ESMF implementation is possible only through training programmes. The response of the 341 IOs on whether they have attended any training program or not is depicted in

Figure 5.6.

12% 35% Attended training for ESMF

53% Have not attended any trainings for ESMF

No response

Figure 5.6: IOs feedback on whether they have attended any training programs with respect to ESMF

The capacity building of the IOs is possible mainly through trainings. While 53% of the IOs have not attended any training programs with respect to ESMF, only 35% have attended training programs. This show that the effectiveness of the capacity building programs in terms of coverage was less, as the capacity building programs could not even cover 60% of the IOs in the LBs audited.

5.1.5. Feedback of the IOs on the adequacy of the training programs The prime objective of the training programs shall be to provide enough knowledge dissemination so that IOs shall be capable to identify the environmental impacts due to subproject related activities and identify mitigation measures for these impacts and implement the mitigation measures. The response of the 341 IOs in this regard is depicted in Figure 5.7.

The training programs have equipped me to identify the environmental impacts and implement the 43% 35% mitigation measures The trainings are not adequate

22% No response

Figure 5.7: Feedback of IOs on the adequacy of training programs

32

35% of the 341 IOs felt that the capacity building programs are adequate and have equipped them to identify the environmental impacts of subprojects and implement the mitigation measures for them, while 22% opined that the training programs are not adequate. There was no response from a whopping 43% of the IOs.

5.1.6. LESA for L2 (medium Impact) Activities In case of L2 (medium impact) activities, the ESMF recommend that Limited Environmental and Social Appraisal (LESA) should be carried out. However, it was observed during the audit that, though LESA form was attached in the file, the identification of impacts and corresponding mitigation measures were not identified properly. The Block Engineer (BE) and the Implementing Officers need to ensure that these mitigation measures are included and integrated with the overall activity proposal and the associated cost figures were suitably updated to reflect the additional cost, if any, to implement the mitigation measures. Surprisingly, this aspect was missing in many Local Self Government Institutions audited.

5.2 Field Level Observations

Detailed observations from the field audits are presented in following sections.

5.2.1. Buildings- New Construction and Expansion, Repair and Furnishings This category includes the construction/maintenance/repair or furnishing of GP/MN offices, community halls, PHCs, Homeo/Ayurveda dispensary, Family Welfare Centres, Anganwadis, Pakalveedu, Libraries, School buildings, auditoriums etc. Plate 5.1 and Plate 5.2 represent 2 typical examples of this category of subprojects.

Plate 5.1: Renovation of Panchayat Plate 5.2: Anganwadi at Irikkur GP in Office, Pananchry, Thrissur Kannur District

Awarded scores based on the audit observations to the projects coming under this category clearly indicate that there is a noticeable percentage of projects coming under Green category having audit scores more than 75 percent. Almost all of them ensured effective service delivery, but in a few cases, there were buildings with construction completed, but were not in use, due to the lack of electric or water connection. A total of 713 cases of buildings were surveyed, whereby the major observations are:  The building projects such as modernization or construction of cabins and front offices for GP/MN offices have rendered the LB offices more receptive and public friendly.  The Anganwadi projects constructed at the remote sites are a boon to the economically and socially weaker locals belonging there by providing basic healthcare facilities to their children including immunizations and nutritious food along with providing them easier access to preschool activities. ESMF envisages the planning and adoption of solid and liquid waste

33

management system. Onsite solid waste disposal system was being followed in some of them through the yard composting of the food waste generated.  The absence of compound walls in some of the Anganwadis audited which were having close proximity to roads, ponds etc have raised safety and security concerns of the children there.  In case of natural resource usage, locally available materials were used in majority of the projects.  The use of recycled material in building construction as envisaged by ESMF (mitigation guidelines) was not being undertaken in the LSGs as the current Public Works Department (PWD) manual does not have provisions for the same.  Waste was observed to be poorly managed during the construction activity in some of the ongoing projects. The construction waste such as leftover cement, wood logs, stone, steel rods, rubble, etc. were not properly disposed of and were still lying around the project site during audit. Often, there was no provision for waste bins in some of the completed buildings.  Rain water harvesting integrated in building design was observed only in a very rare number of cases. An appreciable example for rainwater harvesting is Mannanchery GP office building in Alapuzha district. Rainwater harvesting should be promoted and implemented to a larger extent, as Kerala is gifted with abundant monsoon, yet go through dry spells every year.  The recyclable wastes such as paper and plastics from office buildings are usually send to recyclers, but there were provisions for onsite treatment of biodegradable waste in a very limited number of instances.  Development and maintenance of greenery in the building premises as envisioned in the ESMF is practiced in a few buildings only.  Most of the buildings had system for sewage treatment through septic tank followed by soak pit.  Provision for health, hygiene & safety was average in completed and as well as in ongoing projects. Only a very few projects had access to first aid, fire-fighting measures, etc.

5.2.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance Road construction and repair is one of the fundamental activities under the KLGSDP project. A total of 1126 roads were included in the ET Audit. This category of subproject includes gravelling, soling, tarring, concreting of roads, or construction of footpaths, bridges and culverts These projects provide a thrust for multifaceted growth in transport infrastructure of Kerala. Plate 5.3 to Plate 5.6 represent typical examples of such projects.

Plate 5.3: Keezhallur Ayithara Road Plate 5.4: Culvert construction in Narbona tarring at Dharmadam GP in Kannur Church road at Punnpra South, Alapuzha District District

34

Plate 5.5: Improvement of Plate 5.6: Kochuveli Foot Bridge at Thachakalipadi road in Kallooppara Muhamma GP in Alapuzha District GP in Pathanamthitta District

Though there were roads constructed under KLGSDP with very high social benefits such as providing connectivity to tribals or replacing the existing wooden bridge with new concrete bridge etc, one of the roads was observed to be constructed by obstructing natural drainage channel (Kurikkachira - Kattuchira road at Cherthala MN in Alapuzha District) The audit observations for this category of subprojects are detailed below:  Most of the projects under this type belong to ‘Yellow’ category, which indicates satisfactory way of execution, as yellow category indicates audit scores more than 60 percent. Quality of roads was found above average and highly beneficial to the local residents as most of the roads constructed/maintained provided connectivity to the main roads.  Though the quality of the project implementation is good, most of the roads are constructed /maintained for small stretches. There were projects involving the retarring or concreting of only a 100 m stretch of road, while the rest of the portion in the road remains unmaintained due to lack proper planning of the funds.  Since most of the road projects involved the upgradation of existing roads no land acquisition was required for construction of any road in any of the LBs visited as part of the ET Audit.  Many roads tarred in the water logged areas 3-4 years ago, are now in poor condition, with potholes and gutters.  Most of the roads are constructed without drain mainly due to lack of space or adequate funds. Construction of roadside drains shall be included in the project budgeting in the case of roads proposed/constructed in water logged areas.  In some of the roads with roadside drains, it was observed that the drains were not constructed without considering the slope of the road. Hence storm water remained stagnant on the road itself rather than entering the drain.  There is a scope of improvement in areas like road safety, by provision of sign boards. Some roads in the hilly areas were provided with safety rails along the bends on slopes. Similarly, most of the foot bridges constructed are also provided with safety handrails.  Conducting road safety audits, provision of sign boards or pedestrian facilities for the entire stretch of road constructed etc as envisaged in the ESMF are not being done in any of the road projects audited, as mostly, these included the upgradation of the existing roads or retarring.  The demands for construction of PCC road, from the communities, are highest under the KLGSDP activities since these roads are more durable. 35

 Most of the footpaths are constructed with covered drains.  Lack of maintenance has resulted in blockage in some of the culverts.  A display board containing the activity name, project name and the cost of the activity has been kept in most of the projects audited.  Regular maintenance is required for tarred roads because of wear or deterioration. Road maintenance also shall be given due consideration in project planning stage itself to ensure that the road is maintained in good condition.

5.2.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance This category of projects includes Construction, Operation and Maintenance of Waiting Sheds Parking Yards, Bathing Ghats etc. A total of 39 projects under this category were surveyed – both new constructions and maintenance. Apparently audit reflects a good deal of satisfaction among locals via-a-vis built quality of these infrastructure and in terms of service delivery. Most of the parking yards have been constructed in the GP/MN offices, which have proved beneficial to both the LSGI officials as well as the people visiting such offices. Plate 5.7 to Plate 5.10 are a few examples of this category of subprojects.

Plate 5.7: Bus waiting shed at Plate 5.8: Bus waiting shed at Kummil Karunapuram GP in Idukki GP in Kollam District District

Plate 5.9: Parking yard at Plate 5.10: Parking Yard at MN office at Vazhathope GP in Idukki District Malappuram MN in Malappuram District

Some of the audit observations for this category of subprojects are as follows:  The provision of waste bins as depicted in the ESMF was not observed in any of the audited projects. Consequently, the timely and regular collection and appropriate disposal of waste as envisioned in the ESMF was not practiced anywhere.  Faulty design features such as poor visibility, no seating arrangement etc, has resulted in public abandoning some of the bus waiting sheds.

36

5.2.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste Sanitation and waste management being pressing issues in Kerala, the initiative by the LSGs under KLGSDP for solving these issues prove promising. The total number of projects audited under this category was 15. The projects included the construction of solid waste management facilities such as biogas plants, vermi-composting units, dumping yards, e- toilets, public toilet/comfort stations, plastic shredding units etc. Typical examples of subprojects coming under this category are given in Plate 5.11 to Plate 5.14. One incinerator unit for was also audited, but was found non-operational (Ponnani Govt Taluk Hospital in Ponnani MN, Malappuram District). A ring was constructed for solid waste disposal at Kulathoor GP in Trivandrum District, which has resulted in unmindful dumping of waste all around the ring.

Plate 5.11: Biogas Plant at Kallooppara Plate 5.12: E-Toilet at Chavara GP in GP in Pathanamthitta District Kollam District

Plate 5.13: Shed for waste dumping Plate 5.14: Vermicompost Shed at yard at Wadakkanchery MN in Kaduthuruthy GP in Kottayam District Thrissur District

The audit observations for this category of projects are summarized below:  Provision of better sanitation facilities for the government schools creates an enabling environment which secures children’s dignity, safety, health and attendance in classes. Maintenance was also properly done for the toilets constructed under KLGSDP funds in schools, whereas the maintenance of public toilets/comfort stations remains unsatisfactory. Sewage disposal of the toilets were through septic tanks followed by soak pit.  E-Toilets, which are self cleaning with very limited water consumption and in built STP, remain public abandoned projects mainly due to the lack of awareness about their usage

37

 The sites for solid waste management projects were not having compound walls, which has resulted in easy access for stray animals.  Solid waste management projects lacked the adequate machinery and equipment for treatment of waste such as shredders, gas collection or flaring systems etc. Mechanisms for segregation of biodegradable and non-biodegradable waste was absent in all such facilities audited. Provision of technical support and adequate funds can drastically improve these projects and can make them model projects in solving the never ending solid waste management issues Kerala is facing these days.  The non-functional projects due to the lack of the adequate equipment and machinery for waste treatment and have become public nuisances and non-compliant projects as per ESMF provisions (Any activity involving littering and burning of Municipal Solid Waste in cities, towns and in urban areas is a prohibited activity as per ESMF).  Subprojects involving the collection and management of electronic waste and biomedical waste were not observed during the audit. This may be because, the e-waste or biomedical waste collection in Kerala are done by big players such as the Clean Kerala Company Limited or IMAGE respectively which are authorized by Central Pollution Control Board (CPCB) for the management of these types of waste. Management of these wastes by decentralized systems is still in a nascent stage only.

5.2.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools A total 82 cases of such projects were audited including public markets, crematoriums, stadiums (indoor as well as outdoor), playgrounds and swimming pools. Typical examples of these projects are shown in Plate 5.15 to Plate 5.20. Slaughter house projects, burial grounds etc were not undertaken under KLGSDP.

Plate 5.15: Public Market at Plate 5.16: Chennalode Mini Stadium at Kulathupzha GP in Kollam District Thariyode GP in Wayanad District

Plate 5.17: Gas crematorium at Thodupuzha MN in Idukki District 38

Plate 5.18: Smoke room for Kannur District Crematorium at Chenglai GP in

Plate 5.19: Swimming pool Plate 5.20: Park for Children, construction at Kaduthuruthy GP in Thiruvalla MN in Pathanamthitta Kottayam District District

The major audit observations are:  The public markets constructed proved to be a boon to the local people in selling their produce.  In some of the public markets, the LB has provided solid waste collection system.  The LBs have provided waste collection system at some of the markets audited.  The gas crematorium projects are environmental friendly. It saves a lot of land space and prevents toxins from directly leaching into soil or underground water sources. Compared to a conventional crematorium, a gas-fired crematorium consumes lesser amount of fuel and the burning process is also quicker. Care shall be taken to ensure that air pollution control equipment such as scrubbers or cyclone separators are maintained properly. The ash disposal shall also be taken care of.  In one of the crematorium projects audited (Elamkulam GP in Malappuram District), the GP has taken special interest in developing a green belt around the crematorium, as envisaged in the Proforma E and G of ESMF.  First aid and firefighting equipment shall be compulsorily made available in all such projects

5.2.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance There were 15 projects audited under this category and it was observed that the projects were meticulously implemented. Typical examples are given in Plate 5.21and Plate 5.22.

Plate 5.21: Thevarakkadavu Check Plate 5.22: Venchakulam Lift Irrigation dam renovation at Kannambra GP Project Chenkal GP in Trivandrum in Palakkad District District

The major audit observations are as follows: 39

 Canals constructed for irrigation have proved to be real blessing for the small scale farmers in many regions by providing regular water supply even during summer, whereas the water source was observed to be inadequate in one of the audited cases (Venchakulam lift irrigation, water reservoir renovation, in Chenkal GP in Trivandrum District).  Periodic desiltation as envisioned in the Proforma E and G of ESMF was not being done in any of the cases audited, however, this was not observed to be hampering the performance of the irrigation projects

5.2.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair Drinking water projects were found to be highly beneficial in most of the cases by providing access to piped water supply, except for a few where, the water quality of the water source itself was not maintained. A project involving new drinking water supply without testing of water quality to ensure that it is safe for human consumption is a prohibited activity according to Proforma A of ESMF as well. Water treatment methods were not adopted for the water sources such as borewells or ponds. Typical examples of this category of subprojects are shown in Plate 5.23 to Plate 5.26.

Plate 5.23: Pampa valley community Plate 5.24: Completion of Pulikuzhi Irrigation project at Ward 12 at drinking water scheme at Kallikadu GP in Kavalam GP in Alapuzha District Trivandrum District

Plate 5.25: Plumbing and Pump set to Plate 5.26: Pipeline extension to GP Office, Thopilavi Drinking water scheme at Veterinary Hospital at Nedumudi GP in

Chenglai GP in Kannur District Alapuzha District

A total of 114 cases were surveyed, findings are listed below:  Water supply scheme projects were implemented successfully and now water is easily accessible to nearby locals. While doing so, enough attention was not given to water treatment and water quality testing.  Some of the projects audited were observed to be non-functional due to lack of adequate quantity of water in the water source.

40

 Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified areas, no individual and/or agency, is expected to undertake any ground water based activity, which will entail additional ground water draft. In one of these blocks, a project for renovation and recharge of well was undertaken which can be considered as one of the best practices.  One of the projects audited(Pampa Valley Community Irrigation at Kavalam GP in Alapuzha District, Plate 5.23) is a good example for community managed drinking water supply scheme. The project has water intake from river Pampa, the water is brought through underground pipelines to the water treatment unit. The water treatment unit has an RO plant. The treated water is distributed to the nearby residents at the rate of 50 paise/litre. The disadvantages of this scheme are, water quality testing is not being conducted regularly and the water storage tanks are also not cleaned regularly.

5.2.8. Storm Water Drains- Construction, repair and maintenance A total of 97 cases of drains were surveyed under this category and typical example of a drain constructed with cover slab is given in Plate 5.27and a recently constructed open drain is shown in Plate 5.28 .

Plate 5.27: Construction of drain with Plate 5.28: Kattusheri Drainage cover slab at Ward 2 in Chellanam GP Construction at Alathur GP in Palakkad in Ernakulam District District

 The drains were mostly constructed with cover slabs, but in some cases there were open drains constructed in which littering were observed.  Although quality of the construction was found good, there was lack of trappings for silt and waste in storm drains. Periodic cleaning to remove any sedimented silt/sand/debris shall be done. Otherwise, the accumulated silt over time will reduce the drain capacity considerably. But desilting work must be monitored and done from end to end.  In some of the roadside drain projects audited, the slope of the terrain was not given due consideration in the design of the drain and hence water was not draining to the drains and rather remaining stagnant on the road itself.

5.2.9. Agriculture/ Horticulture / Social Forestry - Management and extension

These projects mostly include the asset creations for agriculture such as the protection for paddy fields (Plate 5.29)or training centres for agriculture. In one of the cases audited, a marketing centre for agriculture was being used as a fire station (Nilambur MN in Malappuram District). In another project involving a training centre for Agriculture, the building was used currently for fire station (Kallikadu GP in Trivandrum District)

41

Plate 5.29: Protection wall to Mudakkuzha padam at Mudakuzha GP in Ernakulam District

5.2.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities A total of 6 cases of such projects were surveyed.

Plate 5.30: Fish Market at Muvattupuzha MN in Ernakulam District

Following are the notable observations:  In the fish markets, there was no treatment facility for disposal of liquid & solid wastes generated. There was littering in the some fish markets.  In one of the markets audited, which was a new market construction, the new market was not operational due to the lack of a proper access road (Fish market at Muvattupuzha MN, in Ernakulam District, Plate 5.30)Provision for health, hygiene & safety was poor, since site is not regularly cleaned and proper hygiene is not maintained.  One of the projects audited, the biogas plant for a fish market (at Nilambur MN in Malappuram District) though had adopted robust technology (BARC model biogas plant), but was not operational due to public protest. Those who are working in the fish market registered a complaint of unbearable smell when the plant was operational and the plant was shut down. The smell might be due to the overloading of the biogas plant. In addition, there were no provisions for using/flaring the biogas produced as well.

5.2.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning These projects such as ponds/tanks/ wells/canals were constructed/repaired/maintained for small drinking water/irrigation projects. Plate 5.31 and Plate 5.32 show 2 examples of such subprojects.

42

Plate 5.31: Side protection wall for Plate 5.32: Construction of Borewell at Kuttikulangara Pond at Madavur GP in Trivandrum District Kayamkulam MN in Alapuzha District

A total of 61 such projects were surveyed in this audit and major observations are outlined here under.

 In the case of pond protection, deepening of the ponds were not done, only side walls for protection were constructed. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District, pond at Thumpamon GP in Pathanamthitta District)  In a few instances. (Eg. Kuttikulangara pond at Kayamkulam MN, Alapuzha District, Ozhukkuneettil Thodu at Kayamkulam MN, Alapuzha District), waste was seen dumped in nearby water body, ditch etc. causing pollution, mosquito breeding, stagnation etc  Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. In the the Notified areas, no individual and/or agency, is expected to undertake any ground water based activity, which will entail additional ground water draft. In one of these blocks (Chittoor Thathamangalam MN in Palakkad District), a project for renovation and recharge of well was undertaken which can be considered as one of the best practices.

5.2.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance A total of 212 such projects were audited which included the purchase of computers, printers, scanner, air conditioners, DG sets etc for LB offices. These projects were found to be highly beneficial to the LB officials. The purchase of streetlights and electric line extensions were also included in this category. The environmental impacts of such projects are very limited during the operation phase, but after the end of life, such projects are a real threat to the environment as they become e-waste. E-waste management shall be carefully planned and implemented in the LBs. Clean Kerala Company Limited collects e-waste in bulk. Hence any e-waste generated can be stored separately and shall be handed over to them. Plate 5.33 and Plate 5.34 show 2 typical examples of this category of subprojects.

43

Plate 5.33: Purchase of Generator Plate 5.34: Purchase of Touch Screen for GP for GP office at Velukkara GP , office at Veeyapuram GP in Alapuzha Thrissur District District

The following aspects shall be taken care of in such projects  The streetlights (tube lights), after end of life become hazardous waste. This shall be disposed off through authorized hazardous waste recyclers.  The AC filters shall be periodically maintained to ensure that the indoor air quality is maintained.  The waste oil/lube oil from the diesel generator is a hazardous waste. Care must be taken to store it separately in drums etc and dispose it through Kerala Pollution Control Board approved vendors.

5.2.13. Tiny and Small Industries – Establishment and Expansion Only 8 such projects were surveyed during ET Audit. These projects were mostly meant for tiny and small scale industries, majority of them are women centric. Most of them are under construction or construction might have just completed, but the buildings are not yet operational due to lack of water/electricity connection. Plate 5.35 to Plate 5.37 show typical examples of such projects

Plate 5.35: Maniyarankudi Khadi Plate 5.36: Construction of building to industrial centre at Vazhathopu GP Kolkkalam Vanitha Thozhil Pariseelana in Idukki District Kendram at Ponmala GP in Malappuram District

44

Plate 5.37: Building for Vanitha Vyayasaya Estate at Kannambra GP in Palakkad District

5.2.14. Animal Husbandry dairy farming-construction and expansion facilities Two such projects were audited and found satisfactory from ESMF documentation (Proforma C) point of view. However, one of the projects was not operational while other one was found lacking in suitable infrastructure. One typical example for this category of subprojects is given in Plate 5.38.

Plate 5.38: Cattle feed godown at Karode GP in Trivandrum District

5.3 Comparison of Projects evaluated during the MT Audit and ET Audit

A brief comparison of some of the projects evaluated during the MT Audit and the ET Audit is given in this section.

During ET Audit During MT Audit

Comparative Status of Waiting Shed at Kallooppara GP in Pathanamthitta during MT and ET Audits Waiting shed maintenance at Kallooppara GP in Pathanamthitta District (Project No SO 0093/13, KLGSDP

45

fund Rs 25,000/-). No change in the condition of the Waiting Shed

During MT Audit During ET Audit

Comparative Status of Ayyappankulam Renovation at Kollenkode GP in Palakkad during MT and ET Audits

Ayyappankulam Renovation at Kollenkode GP in Palakkad District (Project No. 115, KLGSDP fund Rs 65,000) The pond has been renovated and maintained and fencing has been provided to avoid trespassing or disposal of waste

During ET Audit During MT Audit

Comparative Status of Storm water drain at Pandakashala at Karumkulam GP in Trivandrum during MT and ET Audits

During ET Audit During MT Audit

46

Comparative Status of Construction of ring for waste management at poipallivilakom at Kulathoor GP in Trivandrum during MT and ET Audits

During ET Audit During MT Audit

Comparative Status of Construction of Open Air Auditorium to Govt Girls’Higher Secondary School Mavelikkara MN, in Alapuzha during MT and ET Audits Construction of Open Air Auditorium to Govt Girls’Higher Secondary School Mavelikkara MN, in Alapuzha District

During MT Audit During ET Audit

Comparative Status of Construction of GP office in Chettikulangara GP in Alapuzha during MT and ET Audits

During ET Audit During MT Audit

Comparative Status of Construction of Anganwadi No.15 at Eraviperoor GP in Pathanamthitta during MT and ET Audits This was a non-compliance project during the Annual Performance Assessment (APA) in 2011-12 due

47

to the absence of a compound wall. This problem was rectified and compound wall was constructed during the MT audit. During the ET audit, it was observed that water is still not available at the Anganwadi, though water connection is present. Water is brought from the neighbouring houses.

During ET Audit During MT Audit

Comparative Status of E-Toilet at Mavelikkara MN in Alapuzha during MT and ET Audits

5.4 Application of Index of Environmental and Social Integrity (IESI) The Index of Environmental & Social Integrity (IESI) has been conceived to provide a broad based tool to evaluate environmental & social conditions in sample project locations. The mode of deriving IESI from the scores of attributes has been demonstrated in Annexure 2.4. The questionnaires of all the 21 types of projects audited for Level 1 and Level 2 combined were comprised of attributes under different metrics, and marks were allocated individually (Annexure 2.4.1 and 2.4.2). Each attribute carried pre-determined maximum marks, and subsequent to field auditing, 4 Zonal auditors evaluated critically and awarded deserving scores leading to Index of Environmental & Social Integrity (IESI). Mean values of IESI under different categories for all types of projects, implemented in Mid –Term Audit (MT), 2013-14 (Y3), 2014-15 & 2015-16 (Y4) and 2016-17 (Y5) in 14 districts of the State are presented in Annexure 3.1.The application of this index to the evaluation of the subprojects, and the ranking obtained for the LBs for the various Grant Cycles are described in detail in Annexure 3, of this report. In order to point out the reasons for ‘red’ category projects (alarm), each attribute under different groups was analysed critically. Accordingly, per cent IESI of each group (ESMF Documentation; Natural Resources; Waste Management; Health, Hygiene & Safety; Ecology & Biodiversity; Socio-economic; General etc.), denoted as Percent Causative Factors, was worked out. This exercise clearly indicates weak groups that need special attention for improvement in near future. The application of IESI to various categories of subprojects is depicted in the following sections.

5.4.1. Buildings- New Construction and Expansion, Repair and Furnishings

The percentages of building repair and furnishing projects coming under red, green and yellow categories are depicted in the pie chart in Figure 5.8. The histogram in Figure 5.8 the shows the contributing factors for the lesser scores for the red category projects. Attention on these

48

contributing factors indicated as red in the histogram can improve the performance of the subprojects in the IESI scale.

Red 80.00 3% 60.00 Green 36% 40.00 20.00

Yellow 0.00 61% ESMF NR Waste HHS SE Gen

Figure 5.8: Percentage of building repair/furnishing projects under green/yellow/red categories as per IESI Scores and factors causing low scores for Red category projects

From the above presented histogram and pie chart, it is clear that, in building repair/furnishings category, very few (3%) projects are coming under Red category. Health, hygiene & Safety, Natural resource depletion and waste management are the aspects which need immediate attention. The percentages of building construction projects coming under red, green and yellow categories are depicted in the pie chart in Figure 5.9. The histogram in Figure 5.9 shows the contributing factors for the lesser scores for the red category projects. Attention on these contributing factors indicated as red in the histogram can improve the performance of the subprojects in the IESI scale.

Green Red 80.00 6% 12% 60.00 40.00 20.00 0.00 Yellow ESMF NR Waste HHS EB SE Gen 82%

Figure 5.9: Percentage of building construction projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

In this category of projects, 12% are Red category projects and 82% are under Yellow category, showing that there is a possibility that these projects may come under Green category, if attention is given to Natural Resources, Waste Management, Health, Hygiene & Safety and Ecology and Biodiversity.

5.4.2. Roads/ Bridges/Culverts: - New Construction, Repair and Maintenance

49

Red 80.00 Green ESMF 40% 2% 60.00 40.00 NR 20.00 Waste Yellow 0.00 58% HHS SE

Figure 5.10: Percentage of road repair and maintenance projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

Figure 5.10 depicts that; very few (2%) projects are coming under Red category. Health, hygiene & Safety, Natural resource depletion and waste management are the aspects which need immediate attention to improve overall project quality to good level. Green projects also are around 40%.

Green Red 100.00 11% 12% 80.00 60.00 Yellow 40.00 77% 20.00 0.00 ESMF NR Waste HHS EB SE Gen

Figure 5.11: Percentage of road construction projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

Percentage of Red and Green projects is almost comparable (12% and 11% respectively) (Figure 5.11) for road construction projects. Immediate attention is required for the sectors Health, Hygiene and Safety, Ecology – Biodiversity and General Impression of the projects.

5.4.3. Waiting Sheds, Parking Yards, Bathing Ghats: Construction, Operation and Repair/ Maintenance

Figure 5.12: Percentage of operation/repair and maintenance of waiting sheds and parking yards projects under green/yellow/red categories as per IESI Scores

The pie chart (Figure 5.12) shows that there are no Red category projects in this category. Hence the histogram for causative factors for the red category projects is also absent for this category of projects. 39% of the projects are coming under Green category.

50

5.4.4. Sanitation and Waste Management: Collection and Management of Solid & Liquid Wastes, Electronic Waste and Biomedical Waste

100.00 80.00 60.00 40.00 20.00 0.00 ESMF NR Waste HHS EB SE Gen

Figure 5.13: Percentage of sanitation and waste management projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

50% of the projects in this category (Figure 5.13) are in Red category, showing immense scope for improvement in Natural Resources, waste Management, Health, Hygiene & safety.

5.4.5. Public Markets, Crematoriums, Burial Grounds, Slaughter Houses, Stadiums, Play grounds, Swimming Pools Red 80.00 ESMF Green 4% 60.00 29% NR 40.00 SE 20.00 Gen Yellow 0.00 PS 67% ESMF NR SE Gen PS

Figure 5.14: Percentage of repair and maintenance of public markets, crematorium, playgrounds and swimming pool projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

For projects involving the repair/maintenance of public markets, stadiums, play grounds and swimming pools, 4% of Red Category projects (Figure 5.14) while 29% are Good category projects. Areas for improvement are Natural Resources and Project Specific arrangements including Health & Safety and Waste Management

Green Red 100.00 10% 15% 80.00 60.00 40.00 20.00 0.00 ESMF NR EB SE Gen Project Yellow Sp. (for 75% D)

Figure 5.15: Percentage of construction of public markets, crematorium, playgrounds and swimming pool projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

51

The projects involving the construction of public markets, play grounds, stadiums and swimming pools have 15% Red and 10% Green category projects (Figure 5.15). Areas for improvement are Natural Resources and Project Specific arrangements including Health & Safety and Waste Management and overall impression.

5.4.6. Minor and Micro Irrigation and Check Dams - Construction and Maintenance

Yellow 42% Green 58%

Figure 5.16: Percentage of construction and maintenance of minor and micro irrigation projects and check dams under green/yellow/red categories as per IESI Scores

As depicted in Figure 5.16, this category has no Red category projects. It consists of 58% Green category projects, which is the only case, where Green Category projects outnumber the Yellow Category projects. This shows good implementation and proper maintenance.

5.4.7. Drinking Water Supply- Construction expansion, operation, maintenance and repair 100.00 Green Red 38% 24% 80.00 60.00 Yellow 40.00 38% 20.00 0.00 ESMF NR Waste HHS SE Gen

Figure 5.17: Percentage of maintenance and repair of drinking water supply projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

From Figure 5.17, it can be inferred that 24% projects are in Red category and 38% in Green and Yellow category. This is the only case where Green projects are equal in number with Yellow category. This number can be improved by taking care of Waste management and Health, Hygiene & Safety issues. This type of projects has good record in Socio economic area as they have good social benefits and people satisfaction.

52

Green Red 80.00 21% 6% 60.00

40.00

20.00

Yellow 0.00 73% ESMF NR Waste HHS EB SE Gen

Figure 5.18: Percentage of construction and expansion of drinking water supply projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

For the construction and expansion of drinking water supply projects, only 6% projects are in Red category (Figure 5.18), with attention required for Waste, HHS, Ecology – biodiversity and overall impression.

5.4.8. Storm Water Drains- Construction, repair and maintenance

Green Red 100.00 31% 9% 80.00 60.00 40.00 20.00 Yellow 0.00 60% ESMF NR Waste HHS SE Gen

Figure 5.19: Percentage of repair and maintenance of storm water drain projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

Figure 5.19 demonstrates that in this category, only 9% projects are in Red and 31% in Green category. The number of Red category projects can be reduced by giving additional attention to Natural resources, Waste management, HHS and overall impression.

Green Red 80.00 5% 13% 60.00 40.00 20.00

Yellow 0.00 82% ESMF NR Waste HHS EB SE Gen

Figure 5.20: Percentage of construction of storm water drain projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

In case of construction of new drains, attributes resulting in poor scores are waste management, HHS and EB (Figure 5.20). This type has more red Category projects (13%) than Green category projects (5%).

53

5.4.9. Agriculture/ Horticulture / Social Forestry - Management and extension Red 80.00 Green 10% 60.00 40% 40.00 Yellow 20.00 50% 0.00 ESMF NR Waste HHS SE Gen

Figure 5.21: Percentage of agriculture/horticulture and social forestry projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

Figure 5.21 shows that this category has 40% Green and 10 % Red category projects. This percentage can be further improved by taking additional care for Natural resources, Waste management and HHS.

5.4.10. Meat and Fish Production and Marketing - Repair and Maintenance of facilities

Red 100.00 17% 80.00 Green 33% 60.00 40.00 Yellow 50% 20.00 0.00 ESMF Waste HHS SE Gen

Figure 5.22: Percentage of repair and maintenance of facilities for meat and fish production and marketing projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

This category has 33% Green, 50% Yellow and 17% Green category projects. Waste management. HHS and socioeconomic are three areas where improvement is desired (Figure 5.22).

5.4.11. Ponds/Tanks/Wells/Canals: Construction, De-silting & Cleaning

54

Red 80.00 Green 6% 26% 70.00 60.00 50.00 Yellow 40.00 68% 30.00 20.00 10.00 0.00 ESMF NR Waste HHS EB SE Gen

Figure 5.23: Percentage of repair and maintenance of ponds/tanks/well/canals projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

This category has only 6% red projects, it needs special attention for Ecology-biodiversity along with Waste management and HHS (Figure 5.23).

5.4.12. Electrical& Electronic items - Purchase, Installation, Operation and Maintenance

Green Red 120 27% 4% 100 80

Yellow 60 69% 40 20 0 ESMF Waste HHS SE Gen Cert

Figure 5.24: Percentage of electrical and electronic items purchase, installation, operation and maintenance projects under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

Even though number of Red category projects in L1M is meager (4%), it is because of unawareness of E-waste management, Safety and overall impression of project (Figure 5.24). Other than that, other attributes of L1M are quite good.

5.4.13. Tiny and Small Industries – Establishment and Expansion

55

Green Red 80.00 0% 14% 60.00

40.00

20.00 Yellow 86% 0.00 ESMF NR Waste HHS EB SE Gen

Figure 5.25: Percentage of tiny and small industries-establishment and expansion under green/yellow/red categories as per IESI Scores and factors causing low scores Red category projects

This category has 14% Red and 86% Yellow category projects (Figure 5.25). There are no Green category projects. Areas to be improved for Red category projects are Natural Resources, Waste management, HHS and Ecology – biodiversity. Socio-economic attribute has good score.

56

Chapter 6: Good and Bad practices

This chapter depicts the good and bad practices in subproject implementation, observed during the ET Audit

One of the mandates of the ET Audit was to identify good as well as bad practices observed in KLGSDP project vis-à-vis environmental and social safeguard and document them for further reference or learning opportunities. ULTRA-TECH audit team took utmost diligence in understanding such projects and documenting the same under the title Good Practice and Bad Practice. These practices are explained below under different categories of the projects.

6.1 GP/MN Office Building

6.1.1 Good Practices One of the notable and replicable good practices is the GP office construction at Mannanchery GP in Alapuzha District (Plate 6.1). The building had rain water harvesting system, a vegetable garden, a baby feeding room and the access to the GP office was made disabled friendly with a ramp.

Highlight: Rain water harvesting system, vegetable garden, baby feeding room and ramp constructed for providing easy access to the disabled.

Plate 6.1: GP office at Mannanchery GP in Alapuzha District

6.1.2 Bad Practice

Some of the buildings were constructed without proper safety features for the users. One typical example is the truss work and maintenance of PHC building at Chettikulangara GP in Alapuzha District (Plate 6.2). A staircase in the rear side of PHC building and tile works was done using KLGSDP funds in this project.

Highlight: The stair is not provided with any safety hand rail.

Plate 6.2: PHC building at Chettikulangara GP in Alapuzha District

57

6.2 Anganwadi Centres Anganwadi Centres were started by the Indian government in 1975 as part of the Integrated Child Development Services program to combat child hunger and malnutrition. These centres provide supplementary nutrition, non-formal pre-school education, nutrition and health education, immunization, health check-up and referral services of which latter three services are provided in convergence with public health systems. About 80 Anganwadi Centres were including the ET audit. Four Anganwadi centres are presented here as case study for good practices and two for bad practice.

6.2.1 Good practices Vazhathopu Anganwadi at Vazhathope GP in Idukki District (Plate 6.3) can be projected as one of the well implemented and model Anganwadi Centres. It has a well-furnished room for pre- school activities, an open space for play area, outdoor play equipment, a separate room for kitchen, adequate space for veranda, provision for drinking water, child friendly wash basin and child friendly separate toilets for girls and boys.

Highlight: Well furnished room, open area, outdoor play equipment, separate kitchen, drinking water facility, child friendly wash basin, child friendly toilets for boys and girls

Plate 6.3: Vazhathoppe Anganwadi at Vazhathope GP, Idukki District

Kuttooli Anganwadi in Keezhuparamba GP in Malappuram district (Plate 6.4)is another well implemented project. It is an air conditioned Anganwadi. Well maintained and spacious front yard and a neat, clean and spacious kitchen. It is also used as a meeting place for different local groups of the GP. Air-conditioning is aimed at attracting more children to the Anganwadi. Children are found to be in extreme distress during the peak summer months of March, April and May prompting the GP to implement such a project.

58

Highlights: The only air conditioned Anganwadi audited. It is also used as a meeting hall for the various local meetings during the off hours of the Anganwadi

Plate 6.4: Kuttooli Anganwadi at Keezhuparamba GP in Malappuram District

Madathinkadavu Anganwadi at Mariyapuram GP in Idukki district (Plate 6.5) and Kavana Angawadi at Avoli GP in Ernakulam district (Plate 6.5) are another set of good practices. At these places, the food waste is composted within premises and the children are encouraged to actively participate in gardening. By deepening children's sense of connection with nature, school gardening is inspiring environmental stewardship and evokes in them a greater awareness of sustainable living and help them in achieving insight into the long-term human impact on the natural environment. From the water shortage to the over-use of pesticides, children who engage in gardening have first-hand opportunities to observe the importance of conservation and intelligent allocation of resources.

Highlights: Food waste is yard composted and used for gardening. Children are encouraged for gardening which imprints in them the first lessons of sustainable living.

Plate 6.5: Kavana Anganwadi at Avoli GP in Ernakulam District Plate 6.6: Madathinkadavu Anganwadi at Mariyapuram GP in Idukki District

59

6.2.2 Bad practices The Anganwadi at Manjappara at Nedumkandom GP in Idukki District and the Mugu Anganwadi at Puthige GP in Kasaragod District were found with negligence in safety aspects. Compound walls, which are necessary for children safety was found missing in these Anganwadis. These Anganwadi centres are located on the main road with poor access to the building.

Highlight: The Anganwadi is on the side of Highlight: Anganwadi on the top of an elevated main road but compound wall is not provided. land parcel, without any compound wall or access No proper access way provided. road.

Plate 6.7: Manjappara Anganwadi at Plate 6.8: Mugu Anganwadi at Puthige Nedumkandom GP in Idukki District GP in Kasaragode District

6.3 Family Welfare Centres

6.3.1 Good Practice Family Welfare Centre (FWC) is aimed at extending the family planning and welfare services and three FWCs were included in the ET audit. Nirappukala FWC at Kallikad GP in Thiruvananthapuram District (Plate 6.9) follows certain good practices which can be replicated in other FWCs. At Nirappukala FWC awareness classes are conducted for adolescents, women and old people. Non Communicable Disease checkups and medical camps are conducted once in 2 months. Child immunization programmes are also conducted through this FWC, besides there is a small library facility for the women in the locality.

Highlights: A small library is maintained in the FWC for women in the locality

Plate 6.9: Family Welfare Centre at Kallikadu GP in Trivandrum District

60

6.4 Foot Bridges

6.4.1 Bad Practice The Hosabettu Koppala Foot Bridge constructed at Manjeshwaram MN in Kasaragod District had access steps in a very dilapidated state (Plate 6.10) . Kallur Koppala Foot Bridge, in Vorkady GP in Kasaragod District had no proper access way(Plate 6.11).

Highlight: Safety Handrails are provided Highlight: Safety Handrails are not provided to to the foot bridge, but the access steps the foot bridge, and no proper access way to the are in a dilapidated state bridge

Plate 6.10: Hosabettu Koppala Foot Plate 6.11: Kallur Koppala Foot Bridge in Bridge at Manjeshwaram MN in Vorkady GP in Kasaragod District Kasaragod District

6.5 Bus Waiting Sheds Bus waiting sheds provide a proper waiting area for pedestrians/commuters waiting to get a ride from the various bus services. A good bus waiting shed is one that allows visibility and easy access to the bus, is comfortable, safe and convenient, provides clear information, has low maintenance requirements and is vandal-resistant. An unused waiting shed is a waste of money and an unnecessary maintenance problem. Waiting sheds are expected to provide a place to sit, protection from weather, and a feeling of safety and security. The size of a bus waiting shed depends on the climate as well as the number of people who are expected to use it. Given below are good (Plate 6.12 and Plate 6.13) and bad practice (Plate 6.14) case studies under this category project.

6.5.1 Good Practice

Highlights: Allows visibility and easy access to bus, provides place to sit and provides protection from the sun and rain.

Plate 6.12: Bus Waiting Shed at Chakkittapara GP in Kozhikode District

61

Highlights: Sleek design with minimum requirement of construction material. Hence a low cost and effective design.

Plate 6.13: Bus waiting shed at Ayavana GP in Ernakulam District

6.5.2 Bad Practice

Highlights: Not used by public and seems abandoned.

Plate 6.14: Bus waiting shed at Kalloorkad GP in Ernakulam District

6.6 Waste management Projects

6.6.1 Good Practices i Waste Dumping Yard at Division 19 at Karunagappally MN in Kollam District (Plate 6.15) currently does not have a leak proof roof causing leachate generation and pollution. Karunagappally MN has realised the significance of the dump yard site reclamation and proposed to transform this dump yard to a sophisticated waste management facility with a plastic shredding unit, crematorium etc. KLGSDP fund has been allocated in the year 2016- 17 for renovating the dilapidated roofs of the existing dump yard to make it a leak proof trussed roof. This is likely to eliminate the risk of leachate generation. The construction of trussed roof will commence by July 2017. The dump yard site reclamation is a very promising step towards achieving compliance with Solid Waste Management Rules ,2016.

62

Highlights: KLGSDP fund of Rs 1,75,000/- has been allocated to replace the existing ramshackle roofing of the dump yard with a leak proof trussed roof. The MN further aims at a reclamation of the dump yard and convert it to a sophisticated waste processing facility with a plastic shredding unit, crematorium etc.

Plate 6.15: Dumping Yard at Division 19 in Karunagappally MN of Kollam District ii For installing a waste Incinerator at Kollenkode GP in Palakkad district, Rs 50,000/ was allocated from KLGSDP funds. “Incineration” means an engineered process involving burning or combustion of solid waste to thermally degrade waste materials at high temperatures. The GP governing body during the procurement stage felt that, incinerators can be environmentally degrading and the project was cancelled and a refund of Rs 50,000/- was made to KLGSDP.

Highlight: An incinerator project earlier planned and formulated was dropped and a total refund was made to KLGSDP funds as the GP governing body of Kollengode GP in Palakkad District felt that the incinerator can be environmentally degrading.

For running a waste incinerator, volume of waste produced daily should be adequate to continuously run an incinerator. Moreover, the type of waste generated in Kerala household is not suited to incineration i.e. it is very wet. The local environmental conditions (e.g. high humidity) and wet waste would cause corrosion of the incinerator and shorten its life span. Moreover, the capital cost of incineration and ongoing equipment maintenance are very high. There is no opportunity for promoting material recovery from incinerator. If an incinerator planned to be installed in any local body, it should have suitably designed pollution control devices to achieve the emission limits prescribed by the Solid Waste Management Rules 2016.

63

6.6.2 Bad Practices i Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta District (Plate 6.16) is one of the worst waste management projects. Plastic rejections are considered to be the major contributor towards the irreparable damage caused to the environment due to pollution, world over. Converting these rejects into recyclable products will enable the LSGIs to sell off the value added products to generate revenue. Plastic rejects are used in many local bodies for road tarring. As per the G.O (RT) No. 3119/2016/LSGD dated 17.11.2016, instructions for the construction of road using non-recyclable plastics has been issued. Besides, in the plan formulation guidelines for Urban local bodies and 3 tier GPs for the year 2017-18 this has been emphasised [GO (MS)No.79/2017/LSGD Dt.3.4.2017 and GO(MS)No.72/2017/LSGD Dt.29.3.2017]. Clean Kerala Company Ltd under LSGD has been entrusted to facilitate this activity. In a well designed and implemented plastic shredding unit, clean plastic rejects can be converted into utility material for recycling. The required infrastructure for a plastic shredding unit are (a) Plastic scrap shredder - for shredding low grade plastics (b) Blade grinding machine and (c) Hydraulic baling machine along with the allied equipment. At Ranni Pazhavangandi GP in Pathanamthitta District, the plastic shredding unit is defunct. The project was implemented in 2014-15. The project consists of a shed without any machinery. The plastic waste, cardboard waste etc are collected by the GP appointed staff and dumped at the shed and outside it. Hazardous waste such as tube lights (fluorescent light tubes) were also found in the piled up waste dump.

Highlights: Not a secured facility. Consists of a shed without any walls or compound wall. No machinery to shred the waste. All sorts of recyclable and non-recyclable waste such as plastic bottles, cardboard boxes and hazardous waste such as tube lights are being dumped at the site and outside. Chances of leachate generation, as waste are dumped on the earth without any cover. Easy access to rodents and stray animals.

Plate 6.16: Plastic shredding unit at Ranni Pazhavangandi GP in Pathanamthitta District

ii Biogas plant at the Taluk hospital in Thodupuzha MN in Idukki District (Plate 6.17)was implemented in 2012-13 for treating the organic waste from the Taluk hospital. The project is currently not in use and is in a dilapidated condition. An underground tank has been constructed with an opening to throw the organic waste into it. The project does not even qualify to be called a biogas plant as the components required for carrying out biomethanation are not there for this project. 64

Highlights: Abandoned asset with inadequate infrastructure. No eqipment to pulverise the waste or to collect the gas produced. Easy access to rodents and stray animals.

Plate 6.17: Biogas Plant at Taluk Hospital at Thodupuzha MN in Idukki District iii The eToilets can be an integral part of urban as well as rural sanitation infrastructure. The eToilets are electronic public toilets. E-Toilets can be considered as one of the innovative sanitation solution for the public spaces around as such as the premises of (1) local body offices, (2) court buildings (3)bus stands (4) railway stations etc. The e-toilets are usually provided at public places or in schools etc. Project Features The insertion of a coin opens the door of the eToilet for the user, switches on a light—thus saving energy. The toilets are programmed to flush automatically. These are modular, sleek and have appealing aesthetics. The features of the e-toilets are (1) they are very compact and (2)easy to install. The STP (Sewage Treatment Plant) of the e-toilets has 2 kLD capacity which means more than two hundred people can make use of this facility in a day. Other features of the e-toilets are, they have automatic doors which open only when the intended user inserts coin in the designated slit. Another important feature is that, the doors won’t open, if there is not enough water in the storage tank for flushing. It has automatic flushing mechanism as well. The model DB 9007K from Keltron was used by Mavelikkara MN in Alapuzha District (Plate 6.18). This project was audited during the MT audit and it was observed that the social acceptance of the e-Toilets is very less and the public are very reluctant to use this facility. With all its obvious features for ensuring public utility, the e-toilets, become a nuisance, if not maintained well. In the ET audit, it was discovered that the project is maintained well. The AMC has been awarded to Eram Scientific and they offered an SMS based system for redressing any operational issues. The social benefits from the project remains very poor, as the number of persons utilizing this facility remain very limited despite the efforts being made to maintain it properly.

65

Highlights: The projects are not used by public, despite the efforts made in maintaining them. All the 3 e-Toilets audited remain public abandoned projects, though efforts are being made at Mavelikkara MN to ensure regular maintenance of the project

Plate 6.18: E-Toilet at Mavelikkara MN in Alapuzha District

6.7 Drinking Water Supply projects Drinking water supply projects have largely been well executed. However, a few cases of bad practices too were observed and listed here (Plate 6.19 to Plate 6.21).

6.7.1. Bad Practices

Highlight: The bore well is not given any safeguard or protection.

Plate 6.19: Kavilppadi Irrigation Project in Mariyapuram GP in Idukki District

Highlight: The exposed pipeline along the foot of the hill can result in pipe breakage at any time

Plate 6.20: Mulamthandu Water Supply Scheme in Santhanpara GP in Idukki District 66

Highlights: Not functional. Water quality is not maintained, as the water source itself is highly unhygienic Plate 6.21:Keezhur Pipeline extension in Chemnad GP in Kasargod district

6.8 Storm water Drains

6.8.1 Bad Practices In a typical drainage system, storm water is collected by drains which then convey it and discharge it through an outfall to a natural water body such as a creek, river, lake or pond. A storm water drain designed without a discharge system will reverse its very purpose of protection from flooding and can result in maximising the floods along the region near it. The storm water drain at Kadappuram GP in Thrissur District (Plate 6.22) was constructed without providing any outfall or discharge system. Another bad practice is the construction of open drains without regular cleaning/desilting/maintenance (Plate 6.23)

Highlight: A storm water drain constructed without any outfall or discharge system or any receiving water body/drain/sewer system

Plate 6.22: Construction of drainage at 4 cent Colony road Kadapuram GP in Thrissur District

Highlight: The drain is not cleaned regularly. Filled with debris and mud, as there is no covering slab and hence unable to allow proper water drainage

Plate 6.23:Construction of Drain at Kulanmavu Ambalabhagom Road at Arakkulam GP in Idukki District 67

6.9 Public Markets New market construction at Nedumkandom GP in Idukki district was found to be a bad case of construction while the same facility in Kulathupuzha GP in Kollam District was found under good case.

6.9.1. Good Practices

The public market at Kulathupuzha GP in Kollam District (Plate 6.24) is a good market construction project.

Highlights: Facility used by local people for selling the goods they produce. Storm water drains are present. Solid waste from the market is being collected by the Panchayat for disposal

Plate 6.24:Renovation of town market at Kulathupuzha GP in Kollam District

6.9.2. Bad Practice

The public market at Nedumkandom GP in Idukki District (Plate 6.25) doesn’t have provision for solid waste management. All the market stall are not occupied by vendors

Highlights: Facility is electrified but not utilized much. No provision for solid waste management exists in this facility. Plate 6.25: New market construction at Nedumkandom GP in Idukki District

6.10 Open Well construction/ Renovation Protection to well structure is important for long term use of constructed wells. During audit it was found that some of the wells are not usable currently owing to contamination of water since such wells were not provided with compound wall etc. Given below are two good practices and one bad practice.

68

6.10.1. Good Practices One of the best and replicable examples of open well renovation was undertaken at Chittoor- Thathamangalam MN in Palakkad District. Out of the 151 blocks in Kerala, 5 blocks have been notified by the State Ground Water Authority vide its Extra Ordinary Gazette Notification as ‘Notified Areas’. These areas are ‘over exploited’ in terms of ground water. In the Notified areas, no individual and/or agency, is expected to undertake any ground water based activity, which will entail additional ground water draft. In Chittoor Thathamangalam MN, which is coming under Chittoor block, a project for renovation and recharge of open well was undertaken at the MN office compound. The rainwater collected from the rooftop of the MN office was filtered through a filter unit and the filtered water was flowing to the ground to recharge the well. The MN has gone an extra mile, by beautifully decorating the open well parapet wall, so as to easily grab the public attention to the project and create awareness among the public regarding the significance of ground water recharge (Plate 6.26). Another good practice is shown in Plate 6.27.

Highlights: Rainwater from the rooftop of the MN office is directed to a filter and the filtered water is fed to the well, resulting in recharge of the well. The parapet wall of the well has been beautified to grab public attention to create awareness regarding ground water recharge. The filtering process is depicted through pictures on the filtration unit.

Plate 6.26: Renovation and recharge of open well was undertaken at the MN office at Chittoor MN in Palakkad District

Highlight: Open well maintenance done by constructing compound wall and gates, covering nets are also provided for covering wells when not in use..

Plate 6.27:Open well maintenance at Baison Valley GP in Idukki District

6.10.2. Bad Practice Well water was contaminated and cannot be used at Vallapuzha GP in Palakkad District (Plate 6.28) 69

Highlight: The well has contaminated water and not in use because this well is unprotected.

Plate 6.28: Open well near Vallapuzha Railway Station at Vallapuzha GP in Palakkad District

6.11 Road concreting

6.11.1. Bad Practice Some of the road concreting/tarring was found abruptly terminated (Plate 6.29) and without drain provisions causing frequent damage due to rain.

Highlight: Road concreting ending abruptly and constructed without any drainage provision.

Plate 6.29: Concreting of Pathichiripadi road at Mankulam GP in Idukki district.

6.12 Pond Maintenance

6.12.1. Good Practices Two good practices in pond maintenance (Plate 6.30 and Plate 6.31) and a bad practice (Plate 6.32)in the same category are presented here.

Highlight: During the MT Audit, the pond was observed to be dumped with waste. But during the ET Audit, it was observed that the pond has been renovated and maintained and fencing has been provided to avoid trespassing or disposal of waste.

Plate 6.30: Ayyappankulam Renovation at Kollenkode GP in Palakkad District

70

Highlight: It is a very large pond and is well maintained. The walls of the pond are well maintained and in some portions new walls constructed. Interlocks paved, cement benches constructed. Some garden trees are also planted. Steel handrails for the stairs to the pond are the pending work (going on). Currently local people wash and take bath in the pond and in future it will be used for drinking water supply after necessary modifications.

Plate 6.31: Renovation of Odangattkulam at Edayur GP in Malappuram District

6.12.2. Bad Practices

Highlight: The pond maintenance is not at all effective. The pond is filled with aquatic weeds such as Azolla. The protection mesh is not serving any purpose.

Plate 6.32: Maintenance of Panchayat pond at ward 3 at Kavalam GP in Alapuzha District

71

Chapter 7: Projects under onetime financial assistance to Backward LSGIs

This chapter presents the observations on subprojects which were implemented using the onetime financial assistance to Backward LSGIs and elaborates how sustained effort from PMU Environmental and Social Specialist through numerous capacity building programmes helped in convincing the Backward LSGIs that environment friendly projects will give them benefit over and above just service delivery .

7.1 One time financial assistance A provision was made in the final phase of KLGSDP to provide grants up to Rs. 2 crores to 60 backward LBs (40 backward GPs, 10 tribal GPs and 10 revenue deficit MNs). Till now, the PMU has focused expressly on getting DPRs prepared, obtaining Technical Sanctions and getting the work contracted as early as possible. Consequently, about 182 sub-projects have been contracted before the deadline of 31 March 2017, out of which, work on 165(90%) has begun. Since grant is coming to a close, the thrust quickly shifted to ensuring timely execution and completion of implementation activities in the field with respect to these backward local governments. The PMU facilitated the appointment of around 58 Overseers at LSGI level exclusively for the 182 sub-projects contracted under this arrangement. The monitoring, supervision and administrative measures were enhanced in such projects to positively ensure completion of all civil / other works. At the LSGI level the Overseers appointed exclusively for the purposes of monitoring progress of these activities were integrated with this monitoring mechanism. They were supposed to be providing real time updates on physical and financial progress of the sub projects on a daily basis. The Project Director periodically (preferably on a bi-monthly basis) holds a review meeting wherein all concerned Executive Engineers / Assistant Engineers are be invited to present the progress on activities pertaining to this component. Simultaneously the present system of Deputy Project Director level review also continues. The PMU held refresher trainings at KILA on 10th April 2017 to introduce the enhanced monitoring mechanism to all the District Coordinators and Overseers. This training will be repeated multiple times if and whenever required during the period till project completion.

72

During ET audit 28 such projects were included in the scope of audit. List of these projects along with their features are tabulated in Table 7.1.

Table 7.1: Projects funded under the onetime financial assistance to Backward LSGIs covered in the ET Audit

No. District Name of LB Name of Project Auditor Observations Participatory Rural Appraisal (PRA) and Focus Ground Discussion (FGD) conducted 1. Construction of PHC with respect to development plan of Ottoor GP. Nursing station, wards, a mini building at Njakkad operation theatre and a fitness centre will be constructed as part of this work. The work is ongoing. Just finished the concreting. PRA and FGD were conducted. Total 256 students are studying here. Construction 2. Construction of of 2 classrooms and 2 toilets, as part of this project. Now the concreting work has Ottoor Mullarancode LPS finished. They demolished half portion of toilet. So they are planning to a construct 1. Trivandrum building a new toilet block also. Site was a barren land used by students for playing before the project. PRA and FGD were conducted. 224 students studying here. 2 additional classrooms, 3. Construction of class one office room and 2 toilets are being constructing now. Before the project the room in Njekkad LPS land was barren. Now the concreting work has finished. 4. Vekkamkulam Drinking Ongoing work and hence water supply has not yet started. After the completion Anchuthengu water project many houses will get drinking water continuously 5. Construction of The work is under construction. Coconut trees are cut down for construction Ayurveda Hospital purpose. Coconut trunks are used in pilling as the ground water level is high. building The works in under construction and has some disputes with the nearby 2. Kollam Mundrothuruth communities. Coconut trunks are used in pilling as the ground water level is high. 6. Construction of LPS and During the pilling process, the local people are facing many problems. The walls of Buds school the neighbourhood households found to have some cracks and breakage and they claim it is due to the piling process. The work disturbs the water supply of nearby families. 7. Muzhangottuchal Natural village (model Anganawadi, Pakal Since the total fund to be allotted from KLGSDP was modified, the project is veedu, Buds school, modified to a natural pool with pedestrian track. These constructions are Women/ Kudumbasree completed. Important project as it’s a major step to conserving water sources. 3. facilitation Centre, Open auditorium, Library& Pathanamthitta Thumpamon Park) 8. Construction of model Anganavadi building Construction almost completed. Wiring is to be done. with compound wall no.

73

69 9. Construction of model Anganavadi building Work ongoing. Construction nearing completion with compound wall no. 70 10. Construction of model Work ongoing. Construction nearing completion Anganavadi building

with compound wall no.

71 11. Construction of Road in Work completed. Beneficial to SC Colony. Malappuram Colony 12. Construction of The work is just started, piling work is going on. It is a wet area, hence strong Ayurveda Hospital foundation is needed. Soil tests were carried out 4. Alappuzha Veeyapuram 13. Renovation and PHC Building extension work, where piling work and foundation work started. 2 extension of PHC trees were cut down, but no replanting/ compensatory planning done. building 14. Koduthuruth-Mattom- SNDP-Valachakari- Road gravelling and metalling work has completed bridge work going on. Vechoor road and bridges 5. Kottayam Vechoor 15. Kaipuzhamuttu- Valyavelicham- New road construction provides access to main road easier. Manjadikari road and bridge 16. Peruvanthanam Drinking water supply Total of 8 tanks and their pipelines are planned in the project. The work is in 6. Idukki Peruvanthanam project including Check progress. The base of tank is completed. Installation of pipeline is not yet started dam & Pond construction 17. Renovation and Muvattupuzha The construction is good. The debris is properly disposed. But not working yet, 7. Ernakulam Modernisation of Fish MN because the road to the market is under construction. market 18. Construction of Construction of gas crematorium undertaken by COSFORD. Hence local people not Crematorium engaged for construction. 19. Improvement of basic

8. infrastructure and Thrissur Kadappuram Beneficial to the children in the colony as currently, they have to walk up to 1.5 km construction of an to reach the nearest Anganwadi. Work is ongoing. Spacious building. Anganwadi in Tsunami Rehabilitation colony

74

20. Tribal Agro marketing, It is an ongoing and big project. It will be a great platform for the tribal’s to sell their Muthalamada service and facilitation agricultural products. centre 21. Construction of Construction is going on as per the rules. The foundation & pillar work is Chittoor Thathamangalam completed. The local people are engaged in the project work. The raw materials Community hall using for this project is local items 22. Construction of The construction work is in process. It is double store building. It will benefit to the Peringottukurris Community hall in people more. It is situated in a junction, so the people can reach this place easily and si Parithipully very accessible. 9. The construction work is going on. 8%of this project is used for environmental 23. Construction of Gas management. After this implementation external flow of cash will become and Crematorium Palakkad income to the GP. It increases the welfare of the society. 24. Construction of Construction work is on process. They are taking mitigation measures. The Anganwadi building at beneficiaries of the project are children, women and adolescents. It will help to Kuthannur Karakode improve skills. 25. Construction of Construction work is on process. They are taking mitigation measures. The Anganwadi building at beneficiaries of the project are children, women and adolescents. It will help to Lakshamveedu improve skills and help in health inequalities that’s the benefits gained from growth (Kothamangalam) can be enjoyed by everyone. Construction of additional classrooms including one smart class room and toilet. Work is going on. Construction materials are carefully dumped. One compound wall 26. Renovation of may be needed behind the building because of a natural canal which is fed only in 10. Malappuram Urangattiri Odakkayam tribal school rainy season. But not seriously dangerous. Socially very important since the school belongs to a rural and tribal area. The project has enhanced people’s attention towards school. 27. Construction of model Anganwadi building- ICDS Self Delivery Centre, model building and facility. Good construction, no cracks, 11. Kozhik ode Koothali Koothali Theru side wall, water and electricity available. Anganwadi 28. Construction and maintenance of Good construction but not completed due to the non availability of labourers. Need Mullankolli Anganwadi building to plant much trees near the building. Seethamoodu. 12. 29. Construction of model Wayanad Anganavadi building Construction ongoing. Since the fund allotted was modified, the recreation hall for Kottathara with compound wall and old and deprived people not planned in the present construction. recreation hall for old & derived people

75

All 28 projects achieved satisfactory level in ESMF implementation, although it was found that there still exists a great scope for further improving ESMF implementation in such projects in future. As mentioned above, monitoring of these projects have been strengthened by appointing dedicated Overseers, who could also be given awareness training on ESMF requirements and expected to keep an eye on compliance to ESMF. A notable achievement in terms of environmental safeguard in these projects took place when LBs took greater interest in deciding the nature of subprojects. Sustained effort from PMU environmental and social specialist through numerous capacity building programmes helped in convincing these bodies that environment friendly projects will give them benefit over and above just service delivery. ET audit found that satisfaction level of LBs is quite high in backward local body support projects. Out of the 28 projects, 6 projects require clearances from Statutory/ Regulatory agencies. The list of the projects requiring the clearances are given in Table 7.2.

Table 7.2: Backward Assistance Subprojects requiring Statutory Clearances

Type of Sl Project District Local Body Name of Sub- Project statutory/regulatory No Cost clearance required Koduthuruth-Mattom- Irrigation 1. Kottayam Vechoor SNDP-Vechoor road 13000000 Department, State and bridges Wetland Authority Peruvanthanam Drinking water supply 2. Idukki Peruvanthanam project including 20000000 Forest Department Check dam & Pond construction Improvement of Basic Infrastructure Revenue Department, 3. Thrissur Kadappuram 12000000 facilities at Tsunami CRZ Clearance Rehabilitation Colony Pollution Control Construction of a gas Board, DMO & District 4. Thrissur Kadappuram 8000000 crematorium Collector

Construction of community hall in 18064173 PWD 5. Palakkad Peringottukurrissi Parithipully

Pollution Control Construction of gas 6594601 Board, DMO & District 6. Palakkad Kuthannur crematorium Collector

76

Chapter 8: Capacity Building Programme

An effort was made as part of ET audit to understand and analyse the capacity building initiatives taken up by PMU with specified focus on ESMF right since the project inception. Audit team also looked into various aspects of strength and weakness in current capacity building measures of KLGSDP, especially focussing around ESMF. Both these aspects have been explained in this chapter.

8.1 Capacity Building Initiatives A capacity building plan was conceptualized and made part of ESMF implementation framework itself with the objective of inculcating the concept and essentiality of integrating environmental & social concerns in Performance based Grant. For the benefit of beneficiaries and for the effective project implementation, PMU took up the decision to involve itself proactively in arranging and imparting capacity building training in big way. Result of this effort can be best understood by the fact that the word “ESMF’ is now known and familiar to majority of the LB functionaries including Implementing Officers and Elected Representatives at GP or MN level. During stakeholder consultations, it was observed that, the majority of the functionaries are aware of the green concept projects after the effort of dissemination trainings of MT audit findings at district levels. Although it is likely to take more time by the LBs to make ESMF practical and implementable in its true effect, yet it is appreciable that the sense of ESMF is currently accepted by the LBs to a great extent. It is understood that this sensitisation is the result of various types of capacity building programmes adopted and implemented by PMU in team effort with its District Units. Various Capacity Buildings initiated by KLGSDP are discussed in detail in following subsections. 8.1.1. State Level Trainings State level trainings conducted by PMU are depicted in Table 8.1.

Table 8.1: State Level Capacity Building Programmes

Sl No Training Event Category of Duration Date of No. of Participants of training training participants

1 Orientation training for KLGSDP District 2 day 12-13 July 35 District Co-ordinators and Co-ordinators / 2012 Execution Support Agencies Specialists of ESAs / District Planning Officers

th 2 Orientation Training on LSGI Block 1 day 12 70 ESMF and procurement for Engineers September Block Engineers 2012

th 3 Orientation Training in Municipal 1 day 13 65 ESMF and procurement for Engineers September Municipal Engineers 2012 i Project Orientation Training for the KLGSDP District Co-ordinators and Execution Support Agencies

77

For the effective implementation of the Project, 14 District Co-ordinators were recruited during July 2012. To make them aware about various components and activities of the Project, a two day Project Orientation Workshop was conducted on 12th and 13th July 2012 at Institute of Management in Government (IMG) Trivandrum. . The following participants attended the programme. . 14 newly recruited KLGSDP District Co-ordinators . 14 District Planning Offices . Specialists from DAC and SIRD

ii Orientation Training on ESMF & Procurement for the LSGI Block Engineers: As part of project implementation, the Assistant Executive Engineers at Block level are assigned to provide technical assistance (engineering design, ESMF, procurement, contract supervision, quality assurance) to individual GPs and Municipalities during preparation of DPRs. In order to make them aware about the project, a one day Orientation training with special focus on ESMF and Procurement procedures was organised by PMU on 12th September, 2012. The sessions were handled by PMU Specialists in association with World Bank Senior Environment Specialist. The training was attended by 70 Block Engineers. iii Orientation Training on ESMF & Procurement Procedures for the Municipal Engineers: Similar to LSGI Block Engineers, a one day Orientation training on ESMF & Procurement procedures was imparted to the Municipal engineers of all Urban Local Bodies by PMU on 13th September, 2012. Sixty five Municipal Engineers attended in the training programme. 8.1.2. District level Orientation Training on ESMF & Procurement Procedures for the Support Staff of LSGs: During the inception of the project, orientation training was imparted only to the Presidents and Secretaries of Local Self Governments by KILA during 2011. However, the grass root level officials viz. Plan Clerks (Clerks dealing with KLGSDP Performance Grant Projects) and Overseers directly involved in various stages of project formulation and field level implementation, were left out from the first phase of capacity building programmes. As the knowledge of KLGSDP activities is a pre requisite for the successful implementation of Performance grant projects under KLGSDP, it has been proposed to impart training to the support staff (Plan clerks & Overseers) of all 978 GPs and 60 Municipalities. The training were planned to organise at District level. 14 District level Orientation training programmes were conducted on a war foot basis spanning over a period of two months (September 10 - November 15, 2012). Perhaps this was one of the major initiatives taken up by the PMU to disseminate the idea of ESMF in the Performance Grant bringing all the LB functionaries (LB Presidents / Chairmen, Secretaries, AEs & Plan Clerks who are the real stakeholders in

78

project formulation, approval & implementation) in a common platform to spread the idea of ESMF in a unified manner, so that during the process the spirit of ESMF integration is kept intact mandatorily. Details of these programmes are summarised in Table 8.2.

Table 8.2: District Level Capacity Building Initiatives

Sl Training Event Category of Duration Date of No. of No participants of training training participants

1 Orientation Training on Plan Clerk 1 day September 2637 ESMF and procurement Overseers (14 10-15th procedures for the Asst. Engineers batches) November support staff of LSGs 2012

2 Orientation training on Elected 1 day 16th August 4934 Annual Performance representatives, (14 to 8th Assessment (APA) for Secretaries, batches) September LSGI functionaries Assistant 2013 Engineers, Plan Clerks, Accountants

8.1.3. Capacity of environmental auditors, LSGI functionaries and Implementing Officers In addition to capacity building training programmes, workshops were held during MT Audit and ET Audit. The Consultation Workshop on Environmental Audit was organised in association with M/s. ULTRA-TECH. The participants include selected Block Engineers, Implementing officials namely Secretaries, Municipal Engineers, Assistant Engineers and Agriculture Officers of selected LSGIs covering all Districts, representatives of EA firm, District Coordinators of KLGSDP and officials from KLGSDP Project Management Unit. State and district level dissemination workshop on environmental audit findings were organised at both MT and ET audit which helped in understanding stakeholders perspective on audit finding and fine tuning the same. 8.1.4. Orientation Training for the newly elected LSG functionaries & Refresher Training for the Implementation Officials: An important initiative of PMU was the conduct of Orientation training to the newly elected LSG functionaries and Refresher training for project Implementation Officials (Secretaries and Engineers). Programs were conducted at District level. GP Presidents/Municipal Chairpersons, LSG Secretaries and LSG Engineers were the participants. 12 such District level programs were conducted .The sessions covered in the training are i) KLGSP an overview, ii) Procurement procedures, iii) Environmental and Social Management Framework (ESMF) and iv) Vulnerable Group Development Framework (VGDF) and Gender action plan. Various sessions were handled by Specialists from PMU. Altogether 1948 LSG functionaries were trained in 12 programs. Out of this, 611 were elected representatives, 792 Secretaries and 545 Engineers. 8.1.5. Orientation training to the newly recruited District Coordinators of KLGSDP under backward support grant As part of implementation of sub projects under backward support grant, 11 new District Coordinators were recruited by PMU. In order to orient them a two day Orientation training was organised for the newly recruited District Coordinators during 14th – 15th October, 2016 at Maria Rani Centre, Trivandrum. The objective of the training was to orient the new District Co-ordinators about the various components of KLGSDP with focus on Performance Grant and

79

Backward LG support Grant. Besides, awareness was given on Procurement procedures and ESMF guidelines – its rationale, protocols and procedures.

8.2 Comments on the strength and weakness found in the existing capacity building initiatives Current capacity building initiatives were largely built around the efforts taken by PMU. PMU, especially Environmental and Social Safeguard Specialist took sincere effort in conveying the importance of ESMF to all, irrespective of position or designation. Role of District Coordinators in reinforcing the ESMF concept during the screening process that they were doing as part of the monitoring is also worth mention as they explored and utilised all available platforms like DPC Meetings, DDP Conferences, Engineers monthly meetings etc. as avenues for disseminating the ESMF concept as per the directions they received from PMU, time to time. This was visible in the APA documents that majority of the LBs cleared the minimum mandatory conditions (MMC) and performance benchmarks in ESMF compliance documentation. Training became a much sought after programme in KLGSDP’s events. This was well noted during audit when it was found that the word ESMF is so very well known to all the stakeholders audit team met with. Nevertheless, it was also observed by the audit team that support from KILA must be there in organising refresher training on regular basis which is so very important for sustained implementation of ESMF provisions. In departments where transfers are frequent, refresher training and orientation training for new recruits were very important. This was found a weak area in the current capacity building efforts. Project authorities must make sure that whatever strengthening requires at KILA for training and capacity building is provided to it. A notable suggestion in this regard is provision for hiring of external/permanent faculty, as environmental compliance is most sought after theme in the current scenario.

80

81