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Updated Environmental Management Plan

This environmental management plan is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

TA 7644 September 2016

Regional: Greater Mekong Subregion: Preparing the Corridor Towns Development Project

Moc Bai Subproject

Updated Environmental Management Plan

for

Moc Bai Sub-project, Water Supply Improvement Component,

Viet Nam

of

TA - 7644 (REG): Greater Mekong Sub-region: Preparing the Corridor Towns Development Project

September 2016

TA-7644 (REG): Corridor Towns Development Project 1

ABBREVIATIONS ADB - Asian Development Bank AH - Affected Household BOD - Biological Oxygen Demand COD - Chemical Oxygen Demand CSC - Construction Supervision Consultant CTDP - Corridor Towns Development Project DoC - Department of Construction DoF - Department of Finance DoH - Department of Health DoNRE - Department of Environment and Natural Resources DoT - Department of Transport DPI - Department of Planning and Investment EA - Executing Agency EIA - Environmental Impact Assessment EMC - Environmental Monitoring Consultant EMP - Environment Management Plan EMO - Environmental Monitoring Officer FGD - Focus Group Discussion GMS - Greater Mekong Sub-Region IA - Implementing Agency IEE - Initial Environmental Examination NGOs - Non Government Organization O&M - Operation and Maintenance PMSCD - Project Management Support & Capacity Development PMU - Project Management Unit WTP - Water Treatment Plant UXO - Unexploded Ordnance - WEIGHTS AND MEASURES km Kilometre kg Kilogram ha Hectare mm Millimeter


Table of Contents

I. INTRODUCTION 3

A. Purpose of EMP Update 3

B. Component Investment: Water Supply Improvement 3

II. SUMMARY OF POTENTIAL IMPACTS 5

III. MITIGATION PLAN 13

IV. MONITORING PLAN 23

A. Environmental Policy and Standards 23

B. Performance Monitoring 26

V. PUBLIC CONSULTATION 31

VI. GRIEVANCE REDRESS MECHANISM 33

VII. INSTITUTIONAL ARRANGEMENTS & RESPONSIBILITIES 35

A. Institutional Capacity Review and Needs 37

VIII. REPORTING 37

A. Mechanisms for Feedback and Adjustment 38

IX. ESTIMATED COST OF EMP 38

X. EMERGENCY RESPONSE PLAN 38

XI. CONCLUSION 38

APPENDIX A: EIA APPROVAL 40

APPENDIX B: RECORD OF CONSULTATIONS AND DISCLOSURE 41

APPENDIX C: GRM COMPLAINT FORM 53

APPENDIX D: PARTICULAR CONDITIONS (FOR BIDDING DOCUMENTS) 54

Table 1. Component Borehole Details ................................................................................... 4

Table 2. Potential Receptors ................................................................................................. 6

Table 3. Surface Water Analysis - Dia Xu Canal, 2016 (DoNRE) ........................................ 10

Table 4. Surface Water Analysis - Vam Co Dong River, 2016 (DoNRE)............................. 11

Table 5. Groundwater Data Borehole G4 12/01/15 ............................................................. 12

Table 6. Summary of Potential Environmental Impacts ....................................................... 13

Table 7. Environmental Impact Mitigation Plan.................................................................... 14

Table 8: Applicable Laws, Policy and Environmental Standards ......................................... 23

Table 9: National technical regulation on ambient air quality ............................................... 24

Table 10: National technical regulation on hazardous substances in ambient air ................ 24

Table 11: National technical regulation on drinking water quality ........................................ 25

Table 12: National technical regulation on noise ................................................................. 25

Table 13. Environmental Monitoring Plan ............................................................................ 27

Table 14. Performance Monitoring Indicators ...................................................................... 31

Table 15. Reporting Requirements...................................................................................... 37

Table 16: Stages of Consultation during PPTA ................................................................... 46


I. INTRODUCTION

1. This document is the environmental management plan (EMP) for the water supply improvements component for the Moc Bai sub-project for the Corridor Towns Development Project (CTDP). The EMP for the component defines mitigation and monitoring measures and describes the institutions, responsibilities and mechanisms to monitor and ensure compliance. Such institutions and mechanisms will seek to ensure continuous improvement of environmental protection activities during preconstruction, construction, and operation of the project in order to prevent, reduce, or mitigate adverse impacts. 2. This EMP for water supply improvements in Moc Bai is one of four EMPs that have been prepared for the project components in Moc Bai. The Corridor Towns Development Project also includes infrastructure components in the sub-project locations of Dong Ha and Lao Bao in Quang Tri province, together with Moc Bai in Tay Ninh. The parent Initial Environmental Examination (IEE) of the three sub-projects areas is found under separate cover. 3. A national Environmental Impact Assessment (EIA) for the three sub-projects has been approved as required under Vietnamese law. A copy of the approval letter is provided in Appendix A.

A. Purpose of EMP Update

4. The Project Management Support and Capacity Development team (PMSCD) are engaged to provide support to the PMU throughout the design phase of the component. The PMSCD team is able to comment on the detailed designs and as a result, improvements can be made. 5. The purpose of this EMP update is to ensure that the final EMP reflects the detailed designs for the component and ensures that the mitigation measures set out are appropriate for the design implementation. The EMP revision takes into consideration environmental impacts and where appropriate, measures taken to change the design so as to allow improved environmental outcomes for the component.

B. Component Investment: Water Supply Improvement

6. The component to which this EMP relates comprises the following:

(i) Rehabilitation of existing wells and pumping station;

(ii) Construction of new pumping station and drilling new wells with each capacity of 60-70m3/h and a Pipeline system, diameter of 150-500mm, total length approximately 5,200m;

(iii) Water treatment plant (WTP): A new water plant (capacity 7000m3/day) will be established near the current Ben Cau water treatment plant;

(iv) Water distribution network (approximately 51km): The distribution network includes pipeline system with size from 100mm to 400mm;

(v) Service pipeline (approximately 45km) with size from 63mm to 90mm; and

(vi) Installation of about 3,000 flow meters.


7. Table 1 provides detail on the boreholes required: Table 1. Component Borehole Details

No Borehole Old name

(in Scheme 2003)

Requirement

New Recovery Pump

installation Build utility

house

1 G2

2 G3

3 G4 M7 if necessary if necessary

4 G5 M17

5 G6

6 G7

7 G8 M20

8 G9 M10 Source: DED Team; Technical Design Description

8. In addition to the water supply improvements, the components in Moc Bai include i) wastewater treatment plant development; ii) urban road improvements; and iii) a Material Recovery Facility. These components have separate EMPs. 9. Moc Bai border town is located approximately 80km north west of Ho Chi Minh City on the border with Cambodia. The location of the water supply improvement component is in Figure 1.

Figure 1: Component Location of Water Supply Pipeline


Source: Detailed Engineering Design Report

Figure 2: Component Location of Water Supply Boreholes

Source: PMSCD Team

II. SUMMARY OF POTENTIAL IMPACTS

10. Environmental context: The water supply improvement project includes boreholes and pipelines. The pipelines to be laid along the side of existing roads, which pass through a mix of residential areas and agricultural areas. The residential areas are low density low rise areas. The agricultural land is dominated by paddy. The key receptors are noted in Table 2 below.


11. Area of Influence. The area of influence for the component depends on the environmental impact being considered. Local impacts with a narrow area of influence are those impacts arising from noise, dust and amenity issues. A larger area of influence results from impacts which contribute to global issues such as the embodied carbon associated with the manufacture, supply and use of concrete products, and the carbon emissions associated with material transport. For the purposes of this EMP, the area of influence for amenity issues is taken to be 300 m, based on noise levels, as follows:

WHO Community Noise Limits: One Hour LAeq 55 dBA (Outside; residential receptor, day time limit)

Construction Noise: Backhole excavator 80dBA at 15m and concrete mixer 79dBA. Source: Construction Noise Handbook (www.fhwa.dot.gov), US Department of Transport.

Noise attenuation factor: a conservative 6 dBA each time the distance from the point source. Source: US Occupational Safety and Health Administration (www.osha.gov/dts/osta/otm/new_noise/). Note that in soft vegetated environments such as at a vegetated river bank, the noise attenuation will be significantly increased meaning the area of influence could be narrowed. However this would not be the case where vegetation is removed.

Calculation: At 320m noise at receptor approximately 55 dBA 12. Potential Receptors: In addition to the baseline environmental data provided in the IEE for this component, the site specific receptors and environmental context is presented in Table 2 below. Table 2. Potential Receptors

Environmental Receptor Receptor Detail

Aquatic Receptors

Surface water: Surface water in the area is dominated by Vam Co Dong river to the east, running north to south. There are several canals used for fishing and irrigation in including:

Canal Dia Xu crossing the pipeline at 11°06'09.7"N 106°10'54.2"E and running adjacent to the road for 1.7km from borehole G8 to the main road

Canal Ra Bit crosses at 11°05'23.0"N 106°11'05.6"E. Unnamed canal at 1°03'56.2"N 106°11'46.4"E Canal Kenh Xang at 11°03'36.7"N 106°12'02.1"E Canal Tra Co at 11°00'54.5"N 106°13'57.5"E; Canal which crosses the road at 10°59'47.7"N 106°13'54.6"E

and 10°59'31.8"N 106°13'00.8"E and runs adjacent to the northern edge of the road for 1.6km.

A canal runs adjacent to the southern edge of the road for 1.6km from 11°04'54.1"N 106°14'23.6"E (main road QL22, south of An Thanh commune market) east to Vam Co Dong River.

Aquatic Resources: Discussions with DoNRE1 has confirmed that no

protected species of fish are known to be present in the river or canal system.

Groundwater: Groundwater analysis is provided in

Table 5. This shows raw water from borehole 4. Of particular note is high irons levels.

1 Meeting 07/09/16 PMU Moc Bai, with Mr Phuc, Director of Environmental Monitoring Centre, DoNRE

http://www.fhwa.dot.gov/

http://www.osha.gov/dts/osta/otm/new_noise/


Ecological Receptors

Flora: Discussions with DoNRE2 confirmed there are no protected

species in the project area. Observations on species show that along the pipeline route there are sections which contain a mix of common species such as bamboo (Bambusa blumeana), eucaplyptus (Eucalyptus urophylla) and melia azedazach. None of these are protected species. Boreholes G3, G7 and G6 are new and in areas currently used for agriculture, dominated by rice; borehole G8 is also adjacent to a rice field without other significant flora. Borehole G9 is in an area of low (approx 1m) scrub vegetation. Borehole G5 is in an overgrown area of vegetation and has a number of trees within 10m including those listed above and Dipterocarpus alatus

3and Ficus microcarpa.

At a number of locations trees are present at the edge of the current road such as the approach to An Thanh commune market and adjacent to the southern loop of water supply pipe. The Moc Bai master plan was developed in consultation with commune leaders and it is understood that the communes intend to widen roads as the trees are in the right of way.

Fauna: No fauna species were observed. The pipeline is to be sited along current roads which do not provide preferable habitats for natural fauna.

Soil: The soil is sandy.

Protected Areas: DoNRE confirmed there are no protected areas in the component area.

Borehole G5

Borehole G9

Trees adjacent to road & canal

Cultural Receptors

Graves near road (pipeline)

In Binh Tanh commune (southern end of pipe network) on the eastern alignment, a number of family graves are observed within 10m of the road on both sides of the road.

There are five temples observed within the project area. All but one are from the Cao Dai religion, the other being Buddhist.

The temples are all accessed from roads which are to be affected by the installation of pipelines.

2 Meeting 07/09/16 PMU Moc Bai, with Mr Phuc, Director of Environmental Monitoring Centre, DoNRE

3 This is an IUCN listed endangered species when within its natural habitat. However it is regularly used for

replanting areas within Viet Nam and in this location is not in a natural state.


Temple 11° 1'15.82"N 106°13'44.19"E

Infrastructure/Utilities

Between Borehole 6 -8

Power supply cables and street lighting is present at many places along the network. Example includes the road between boreholes 6 and 8 which will have a water supply pipeline installed.

The road network itself is also a receptor. It crosses four bridges in the southern end of the network and Dia Xu bridge near Borehole G3; all bridges are required for traffic and access and cross irrigation canals.

Businesses/Livelihoods

An Thanh market

Phuoc Chi Commune

There are several concentrations of businesses which are operating adjacent to the roads along which the pipeline will run. Key areas include the market area 11° 5'7.00"N, 106°13'54.57"E (An Thanh commune), the business and residential area of Binh Hoa commune 11° 1'23.47"N, 106°13'35.89"E

Additionally at intermittent locations along the pipeline network, small businesses operate such as that outside the school at 10°59'46.26"N, 106°13'54.71"E (south east corner of pipeline network at Phuoc Chi commune)

Businesses along the road include restaurants/coffee shops where customers sit at the edge of the road.

Health Facilities The District Hospital is at 11° 6'35.73"N, 106° 9'44.61"E. It is


accessed from the road along which the pipeline will be installed and the building is approximately 170m from the road.

Schools A secondary school is at 10°59'46.26"N, 106°13'54.71"E (south east corner of pipeline network at Phuoc Chi commune). A kindergarten is at 11° 5'45.29"N 106°11'1.33"E

Residential Areas

There are three key areas of concentrated housing, located at An Thanh commune, centred around the market area to the east of the pipeline, Binh Hoa to the south and Ben Cau to the north east at borehole G5.

13. The location of key receptors is shown in Figure 3. Figure 3: Key Receptors (northern, central and southern sections of network)


Source: PMSCD Team

14. Updated surface water quality analysis is provided by DoNRE as part of their regular sampling program and includes Dia Xu canal, which enters Vam Con Dong River and Vam Co Dong river itself. See Table 3 and Table 4; groundwater data are presented in


Table 5. Table 3. Surface Water Analysis - Dia Xu Canal, 2016 (DoNRE)

Date of sampling

16-Mar 13-Apr 10-May 06-Aug 12-Jul 12-Aug QCVN 08-MT:2015 /BTNMT, Cat. B1

Time of sampling

15h20p 11h45p 11h00p 13h00p 13h45p 08h00p

Temperature 31 31,4 31,5 31,1 31,2 27,3 No requirement

pH 7,11 6,75 7,01 7,01 6,78 6,53 5,5 - 9

Conductivity 124 164 211 129,1 126 78,2 No requirement

DO 1,88 2,42 2,61 2,15 2,72 1,53 >=4

Turbidity 239 198 116 249 138 71,8 No requirement

TSS 108 89 47 115 75 60 50

COD 19 28 22 44 33 35 30

BOD5 13 19 13 29 19 19 15

N-NH4+ 1,01 0,98 0,63 1,2 1,17 1,47 0,9

Cl- 5,4 5,66 19,77 12,4 18,76 17,49 350

N-NO2- 0,026 0,003 0,006 0,011 0,004 0,009 0,05

N-NO3- 0,5 0,69 0,48 0,83 0,451 0,26 10

P-PO43-

0,013 0,04 0,059 0,081 0,084 0,6 0,3

Coliform 24000 4600 11000 15000 9300 4600 7500

CN- UD UD UD UD UD 0,002 0,05

TDS 90 95,6 121 74,7 72,6 46,1 No requirement

Total Phosphor

0,196 0,2 0,19 0,45 0,42 0,88 No requirement

*UD = Undetectable Table 4. Surface Water Analysis - Vam Co Dong River, 2016 (DoNRE)

Sample Date 03-Feb 03-Mar 13-Apr

12-May 28-Jun 11-Jul 11-Aug

QCVN 08-MT:2015 /BTNMT, Cat. B1

Temperature 30,1 28,5 31,9 31,5 28 29 30,3 No requirement

pH 7,62 6,68 6,33 6,49 6,07 6,73 6,36 5,5 - 9

Conductivity 125,8 124,9 268 323 102,1 137,1 90,2 No requirement

DO 3,16 2,2 3,15 2,01 3,74 2,54 2,88 >=4

Turbidity 70,9 77,9 101 104 38,4 35,3 85,6 No requirement

TSS 18 25 30 36 24 26 33 50

COD 15 17 31 27 28 13 17 30

BOD5 8 9 16 15 16 8 8 15

N-NH4+ 0,67 0,84 0,8 0,89 0,34 0,71 0,63 0,9

Cl- 6,55 6,55 21,98 42,21 7,71 11,05 6,6 350

N-NO2- 0,011 0,011 0,003 UD UD 0,004 0,004 0,05


N-NO3- 0,51 0,52 1,07 0,91 0,84 1,034 0,88 10

P-PO43-

0,049 0,055 0,022 0,052 0,13 0,012 0,12 0,3

Fe 1,96 1,82 + + 0,96 + + 1,5

Coliform 93000 2400000 1500 4600 1100 460 24000 7500

E.Coli 240 240 + + 23 + + 100

Oil & Grease 0,11 0,12 + + 0,13 + + 1


Table 5. Groundwater Data Borehole G4 12/01/15

Source: DED Team

Figure 4: Location of surface and groundwater sampling points

Source: PMSCD Team


15. The IEE indicates that potential impacts of the development are primarily construction-related and can be mitigated. Specifically, these potential impacts are essentially disturbances and nuisances to local community and businesses in Moc Bai such as noise, dust, solid & liquid waste, traffic, and reduced community and commercial access arising from construction activities. During the operation of completed water supply system and WTP the potential environmental issues are: 1) the sustainability of the required quality and quantity of raw groundwater source; 2) disposal of treatment sludge; 3) the ability of future wastewater management of the community to accommodate the increased wastewater as a result of the enhanced water supply system; and 4) risk of spills of hazardous chemicals such as chlorine. 16. The impacts are summarized in Table 6. Note all land acquisition and resettlement to be addressed by Resettlement Action Plan as appropriate for the Moc Bai sub-components. Table 6. Summary of Potential Environmental Impacts

Pre-construction Phase 1) Land clearing 2) Resettlement issues – to be managed in resettlement action plan Construction Phase

1) Environmental impacts of civil works (e.g., dust, air pollution, solid & liquid waste, erosion, local flooding, pollution of land, and sedimentation and pollution of surface waters. 2) Potential unforeseen impacts on ecological habitats and pollution of surface waters through accidental spillages. 3) Civil nuisance (e.g., noise, vibration, increased traffic, reduced access, disrupted business & community activity, social issues from migrant workers, worker & public accidents). 4) Impaired use of roads to be upgraded and use of roads which may be used by construction traffic and disturbance to adjacent households, businesses, and public places.

Operation Phase

1) Unsustainable quantity & quality of groundwater supply, 2) insufficient capacity to manage increased wastewater production by community, 3) Potential pollution from spills of hazardous materials such as chlorine, and 4) Ability to manage treatment sludge

III. MITIGATION PLAN

17. The mitigation measures of the EMP are presented in a comprehensive mitigation plan for the subproject presented in Table 2. The plan includes the environmental issues and concerns raised at the stakeholder meetings. The plan identifies responsible parties, location, and timing.


Table 7. Environmental Impact Mitigation Plan

Component Activity Potential

Environmental Impacts

Proposed Mitigation Measures Cost Institutional Responsibilities

Supervision Implementation

Pre-Construction, Detailed Design Phase

All All

1. Develop Site-Specific EMP with individual management sub-plans for: a) Construction worker camp management (if a camp is planned) b) Construction drainage; c) Erosion; d) Noise and Dust; e) Borrow Site & Spoil Disposal; f) Solid and Liquid Waste Disposal; g) Construction & Urban Traffic; h) Utility and Power Disruption; i) Community and Occupational Health and Safety; j) Tree and Vegetation Removal and Site Restoration; k) Construction Materials Acquisition, Transport, & Storage, l) Cultural Sites and Chance finds; m) Surface Water Protection; n) Emergency Response Procedures; and o) Site clean up

Included in bid price

PMU/PMSCD Contractor

Borehole construction & rehabilitation

Groundwater Contamination

2. The contractor will provide a method statement for all borehole related work which will be carried out either by the contractor or a specialist sub-contractor.


PMU/PMSCD Contractor

UXO survey, & removal

Injured worker or public

3. Ensure national military is consulted and sweeps & clears areas where necessary To be confirmed as required

EA/National Government

National Government

Grievance Redress Mechanism

None 4. Erect sign boards with project details and GRM procedures/contact details at each road location. Included in bid price

PMU Contractor

Construction Phase






Implement Management Sub-Plan a) Workers’ Camp

Pollution and social problems

Measures to be included in the management sub-plan will include: 5. Locate worker camps away from human settlements. 6. Ensure adequate housing and waste disposal facilities including pit latrines and garbage cans 7. All waste stored under a roof 8. A solid waste collection program must be established and implemented that maintains a clean worker camps 9. Locate separate pit latrines for male and female workers away from worker living and eating areas, and also in

areas of suitable soil and above the local groundwater table. 10. A clean-out or infill schedule for pit latrines must be established and implemented to ensure working latrines

are available at all times. 11. Worker camps must have adequate drainage. 12. Local food should be provided to worker camps. Guns and weapons not allowed in camps. 13. Transient workers should not be allowed to interact with the local community. HIV Aids education should be

given to workers. 14. Camp areas must be restored to original condition after construction completed.


PMSCD/PMU Contractor

Implement Management Sub-Plan b) Construction Drainage

Loss of drainage & flood storage

Measures to be included in the management sub-plan will include: 15. Provide adequate short-term drainage away from construction sites to prevent ponding and flooding. 16. The contractor will prevent borrow pits and quarries from filling with water. The sites will be pumped

periodically to a location approved by DoNRE and PMU as required. The water will not increase sediment loading in local water courses.

17. Install temporary storm drains or ditches for construction sites 18. Ensure connections among surface waters (ponds, streams) are maintained or enhanced to sustain existing

stormwater storage capacity. 19. Protect surface waters from silt and eroded soil including all irrigation canals

Included in contractor bid cost

PMSCD & PMU Contractor

Implement Management Sub-Plan c) Erosion control

Soil erosion

Measures to be included in the management sub-plan will include: 20. Berms, and plastic sheet fencing will be placed around all excavations and earthwork areas. Preference will

be given to installing a geo-textile barrier to allow the site to drain. 21. Earthworks will be conducted during dry periods. 22. Maintain a stockpile of topsoil for immediate site restoration following backfilling. 23. Protect exposed or cut slopes with planted vegetation, in accordance with a slope stabilization protocol. 24. Re-vegetate all soil exposure areas as soon as practicable and appropriate to the season using native species

as advised by DoNRE








Implement Management Sub-Plan d) Noise and dust

Air Pollution (dust) Civil nuisance (Noise)

Measures to be included in the management sub-plan will include: 25. Regularly apply wetting agents to exposed soil and construction roads. 26. Cover or keep moist all stockpiles of construction aggregates, and all truck loads of aggregates. 27. Minimize time that excavations and exposed soil are left open/exposed. Backfill within 48 hours. 28. Working time will be restricted to between 07:00 and 17:00 unless construction requires disruption of power

supplies. See Utility & Power Management Sub-Plan 29. All equipment will be properly and adequately maintained as well as regularly serviced in accordance with

manufacturer recommendations 30. Replace or repair unnecessarily noisy vehicles and machinery. 31. Vehicles and machinery will be turned off when not in use. 32. Construct temporary noise barriers around excessively noisy activity areas where required. 33. Wheel washes used for construction vehicles leaving the construction site. 34. All mud on public roads resulting from construction traffic will be removed before the end of the working day on

which it was deposited on the road.



Implement Management Sub-Plan e) Borrow Site and Spoil management

Land contamination, surface water pollution, ecology

Measures to be included in the management sub-plan will include: 35. All borrow pits and quarries will be approved by DoNRE, in accordance with Borrow Site & Spoil management

sub-plan. 36. Select pits and quarries in areas with low gradient and as close as possible to construction sites. 37. Required aggregate volumes must be carefully calculated prior to extraction to prevent wastage. 38. Pits and quarries will not be located near surface waters, forested areas, critical habitat for wildlife, or cultural

property or values. 39. All topsoil and overburden removed will be stockpiled for later restoration. 40. All borrow pits and quarries will have a fence perimeter with signage to keep public away. 41. After use pits and quarries will be dewatered and permanent fences installed with signage to keep public out,

and restored as much as possible using original overburden and topsoil. 42. Unstable slope conditions in/adjacent to the quarry or pit caused by the extractions will be rectified with tree

planting. 43. Define & schedule how materials are extracted from borrow pits and rock quarries, transported, and handled &

stored at sites. 44. Uncontaminated spoil will be disposed of in DoNRE designated sites, which must never be in or adjacent

surface waters. Designated sites must be clearly marked and identified - in accordance with Borrow Site & Spoil management sub-plan.

45. Spoil will not be disposed of on sloped land, near cultural property or values, ecologically important areas,, or on/near any other culturally or ecologically sensitive feature.

46. Where possible spoil will be used at other construction sites, or disposed in spent quarries or borrow pits. 47. A record of type, estimated volume, and source of disposed spoil will be retained. 48. Suspected contaminated soil will be tested, and disposed of in designated sites identified as per National

regulations. 49. Before treatment or disposal contaminated spoil will be covered with plastic and isolated on hard standing with

sealed drainage.


PMSCD & PMU & DoNRE

Contractor






Implement Management Sub-Plan f) Solid and liquid construction waste

Land contamination, surface water pollution, resource use

Measures to be included in the management sub-plan will include: 50. All solid and liquid waste to be managed in accordance with the approved Solid and Liquid Waste Disposal

Management Sub-Plan 51. Management of general solid and liquid waste of construction will follow National regulations, and will cover the

collection, handling, transport, recycling, and disposal of waste created from construction activities and worker force.

52. Appropriate sites for disposal of solid and liquid waste to be determined by DoNRE and adhered to by the contractor.

53. Disposed of waste will be catalogued for type, estimated weigh, and source. 54. Construction sites will have appropriate sized garbage bins. A schedule of solid and liquid waste pickup and

disposal will be established and followed to ensure construction sites are as clean as possible. 55. Solid waste will be separated and recyclables sold to buyers in community. 56. Collection, storage, transport, and disposal of hazardous waste such as used oils, gasoline, paint, and other

toxics will follow National regulations. 57. Wastes will be separated by type (e.g., hydrocarbons, batteries, paints, organic solvents) 58. Wastes will be stored above ground in closed, well labeled, ventilated plastic bins in good condition well away

from construction activity areas, all surface water, water supplies, and cultural and ecological sensitive receptors.

59. All spills will be cleaned up completely with all contaminated soil removed and handled in accordance with the contaminated spoil sub-plan .

60. Contractor will apply the waste hierarchy and will demonstrate how the following order of preference for waste management will be implemented: waste prevention at source, waste reuse, waste recycling.

61. All waste to be stored under a roof.


PMSCD & PMU & DoNRE

Contractor

Implement Management Sub-Plan g) Construction and urban traffic

Traffic disruption, Community Health & Safety

Measures to be included in the management sub-plan will include: 62. Schedule construction vehicle activity during light traffic periods. Create adequate traffic detours, and

sufficient signage & warning lights. 63. Post speed limits, and create dedicated construction vehicle roads or lanes. 64. Inform community of location of construction traffic areas, and provide them with directions on how to best co-

exist with construction vehicles on their roads. 65. The contractor will ensure temporary pedestrian crossings will be located at least 50m away from construction

areas. 66. The contractor will ensure road and walkway lighting is provided during construction and that all construction

sites are lit to prevent accidental injury to the public.



Implement Management Sub-Plan h) Utility and power disruption

Loss or disruption of utilities and services such as water supply and electricity

67. Utility Disruption sub-plan to identify where outages in utilities and services will occur, or are expected. 68. Contact local utilities and services with schedule, and identify possible contingency back-up plans for outages. 69. Contact affected community to inform them of planned outages 2 weeks in advance. 70. With prior agreement from PMU and Moc Bai utility company all outages will be scheduled over night between

24:00 and 06:00.


PMSCD & PMU & Moc Bai utility company

Contractor

Measures to be included in the management sub-plan will include: 71. Implement the Resettlement Action Plan regarding communities affected by utility disruption

Included in PMU cost

PMSCD PMU






Implement Management Sub-Plan i) Community and Occupational Health and Safety

Community and Occupational Health and Safety

Measures to be included in the management sub-plan will include:

72. A signed commitment from the Contractor to a) Understand and b) comply with IFC Environmental Health and Safety guidelines (2007)

73. Appropriate fencing, protective barriers, and buffer zones will be provided around all construction sites and excavation trenches.

74. Access across excavation trenches will be provided where no alternative is possible which will allow the safe passage of pedestrians and motorbikes.

75. Sufficient signage giving health and safety warnings and information disclosure at all sites. 76. National Worker and public safety guidelines will be followed.. 77. Speed limits will be imposed on all construction vehicles. 78. The contractor will not cause standing water suitable for disease vector breeding on any construction site or

worker camp area 79. Worker education and awareness seminars for construction hazards will be given. A construction site safety

program will be developed and distributed to workers. 80. Appropriate safety clothing and footwear will be mandatory for all construction workers. 81. Adequate medical services will be on site or within 1km of all construction sites. 82. Drinking water will be provided at all construction sites. 83. Sufficient lighting will be used during necessary night work. 84. All construction sites will be examined daily to ensure unsafe conditions are removed. 85. Provision will be made for not allowing 220 to 240V Electric Power tools and warning lights to be used on site if

the workers are likely to be working within a very wet or flooded environment. In these areas it would be preferable to use the 12V lighting systems and cordless power tools. If larger capacity units are required, then diesel powered or petrol units will be provided. Use of 220 to 240V Electric Power tools could still be allowed subject to the site safety officer confirming that all the tools have been inspected and approved for use on site and have been appropriately tagged, and there is no standing water on site. However in conditions where the workers are actually standing in ponded water, such power tool will not be allowed on site. This then also applies to any flashing or rotating warning lights which will only be battery powered (12 or 24V units) rather than 220 to 240V units.



Implement Management Sub-Plan j) Tree and vegetation removal, and site restoration

Damage or loss of trees, vegetation, and landscape

Measures to be included in the management sub-plan will include: 86. No unnecessary cutting of trees – all vegetation to be removed will be in accordance with the Tree and

Vegetation Removal and Site Restoration management sub-plan. 87. Contact local forestry department for advice on how to minimize damage to trees and vegetation. 88. Consult DoNRE to determine the most successful restoration strategy and techniques and use native

species. 89. No unnecessary cutting of trees – all vegetation to be removed will be in accordance with the Tree and

Vegetation Removal and Site Restoration management sub-plan 90. All construction areas to be re-vegetated and landscaped after construction completed. Consult DoNRE to

determine the most successful restoration strategy and techniques and use native species.








Implement Management Sub-Plan k) Construction materials acquisition, transport, and storage sub-plan

Water and air pollution, soil erosion, community health and safety, land contamination

Measures to be included in the management sub-plan will include: 91. Define and schedule how fabricated materials such as steel, wood structures, and scaffolding will

transported and handled. 92. All aggregate loads on trucks will be covered. 93. Piles of aggregates at sites will be used/or removed promptly, or covered and placed in non traffic areas. 94. Construction material acquisition will be in line with the borrow pit and spoil management sub-plan 95. Asphalt plants and concrete batching plants to be located at least 500m downwind, or as far as

practicable, from the nearest dwellings in order to reduce the impact of fumes on humans and to be fitted with necessary equipment such as bag house filters to reduce fugitive dust emissions. Bitumen production and handling areas will be isolated.

96. Contractors will be suitably trained and experienced with the production, handling, and application of bitumen.

97. All spills of concrete and bitumen will be cleaned immediately and handled as per waste management sub-plan

98. Bitumen will only be spread on designated areas when repairing roads if required following pipeline installation

99. Bitumen will not be used as fuel.


PMSCD/PMU Contractor

Implement Management Sub-Plan l) Cultural Sites and Chance finds

Cultural Heritage

Measures to be included in the management sub-plan will include: 100. Chance finds of valued relics and cultural values will be reported immediately. Contractors and site

supervisors will be trained on the action to be taken if a chance find is discovered. 101. Upon a chance find all work stops immediately, find left untouched, and PMU notified immediately. If find

deemed valuable, provincial cultural authorities must be notified. 102. Work at find site will remain stopped until authorities allow work to continue. 103. At all locations where family graves are located within 15m of the road, the Contractor will provide a highly

visible tape barrier, to ensure that workers, materials and equipment does not damage the sites.


PMSCD & PMU contractor






Implement Management Sub-Plan m) Surface Water Protection

Surface and groundwater pollution

Measures to be included in the management sub-plan will include: 104. Protective coffer dams, berms, plastic sheet fencing, or silt curtains will be placed between all earthworks

and surface waters. 105. Erosion channels will be built around aggregate stockpile areas to contain rain-induced erosion. 106. Earthworks will be conducted during dry periods. 107. All construction fluids such as oils, and fuels should be stored and handled well away from surface waters

An earthen bund will be provided around any above ground fuel storage tanks with a capacity of 110% of the largest single tank within the tank farm.

108. No waste of any kind is to be thrown in surface waters or disposed on land unless in an authorized waste disposal site in accordance with the waste management sub-plan.

109. No washing or repair of machinery within 50m of surface waters. 110. Pit latrines to be located well at least 200m from surface waters, and in areas of suitable soil profiles and

above the groundwater levels. 111. No unnecessary earthworks in or adjacent to water courses unless prior permission has been obtained

from PMU/DoNRE. 112. All irrigation canals and channels will be protected the same way as rivers, streams, and lakes 113. The contractor will ensure all wells are drilled using methods which do not allow contamination of

groundwater during construction.



Implement Management Sub-Plan n) Emergency Incident Response Plan

All environmental and human health receptors

Measures to be included in the management sub-plan will include: 114. The Contractor will set out an Emergency Response Plan. The plan will contain: 1. Roles and Responsibilities for those working on behalf of the contractor who will be involved in an

incident response; 2. Actions and Procedures which will be taken for each incident. See 115 below; 3. Measures to Prevent an Incident. See 116 below. 4. Contact details of emergency medical facilities; and 5. Corrective action procedures following in incident 115. The Contractor will develop Incident Response procedures prior to construction. The procedures will

cover actions to be taken in case of: 1. Worker injury (e.g. construction or traffic accident) 2. Spillage (e.g. fuel spillage) 3. Fire (e.g. fuel or chemicals storage area); and 4. Any other incidents anticipated by the contractor. 116. The Incident Response Plan will set out Preventative Measures for all types of incidents covered in the

Incident Response Plan. This will include: Prevention of Injury – to include Personal Protective Equipment requirements for construction workers,

training requirements Prevention of Spillage - All construction fluids such as oils, and fuels will be stored on hard standing with

sealed drainage with a capacity of 110% of the largest fuel container, will include procedures on refueling and maintaining vehicles


PMU contractor






Prevention of Fire – to include measures for Ignition Sources including prevention of smoking on construction site, management of flammable materials and liquid.

Other Incidents – prevention measures relevant to other issues considered relevant by the contractor.

Implement Management Sub-Plan o) site clean up sub-plan

Land use, nuisance, community health and safety

Measures to be included in the management sub-plan will include: 117. On completion of construction works: 118. All sites to be cleaned of mud on roads and public areas 119. All sites to be cleaned of all litter, debris and any other materials or equipment associated with

construction activities 120. All sites to be restored on completion 121. All sites to be handed over only after inspection completed by PMU


PMU contractor

Operation Use of Hypochlorite or safer alternative to Chlorine

Occupational Health and Safety

122. Given the significant health risks associated with using chlorine, the operator will commit to using a safer alternative, such as hyphochlorite, which can be used within the final design of the water treatment plant

Included in operational costs

Relevant local authority

Moc Bai Water Company

Supply of treated water

Treated water cannot meet demand

123. Regularly monitor the use (demand) of potable water, to ensure shortfalls in supply do not occur 124. Develop and implement Operation and Maintenance (O&M) manual for all equipment and operations of

water supply system which includes regular maintenance of treatment system components, and materials supply to ensure treated water production (m3/day) always meets demand and quality specifications. Incorporate contingency and back-up plans for planned and unplanned system shutdowns.




Operation of raw & treated water pipelines

Local flooding from ruptures

125. As part of implementation of O&M manual for water supply systems instate a regular inspection program of all pipeline networks starting at intakes and ending at distribution networks focusing on junctions and end-user connections.




Operation of WTP Occupational health and safety,

The contractor will develop and implement a Health and Safety Manual as part of the O&M which will include the following:

126. A signed commitment from the Operator to a) Understand and b) comply with IFC Environmental Health and Safety guidelines (2007)

127. Training Programme for workers in workplace safety of Water supply treatment plant operation according to Department of Labour, Invalids and Social Affairs regulations.

128. Provide all operational staff with appropriate personal protective equipment 129. Prevent public access to all intake areas, pipeline corridors, WTP, & distribution networks with fencing and

appropriate signage. 130. Conduct safety orientation trainings including regular safety drills for workers especially on the

use/handling of chlorine. 131. Provision of appropriate and adequate PPE for workers (including regular training and drills on the use of

these PPEs and other emergency equipment). 132. Enforce WTP truck drivers to follow speed limits on roads and highways. Provide adequate signage

informing public of WTP truck traffic routes, and pipelines service routes. 133. Ensure all WS system vehicles in good working order




Chemical land and surface 134. As part of O&M manual provide clear methods and procedures for safe handling and storage of planned Included in Relevant local Moc Bai Water






Management water pollution, health and safety, solid waste

treatment chemicals defined including spills action plan. 135. With O&M manual define and implement a formal solid and domestic waste collection and disposal

protocol for all WTP activities. 136. Chlorine supplies for three days normal use must always be maintained

operational costs

authority Company

Sludge Management Land and surface water pollution

137. Review plans for sludge disposal for WTP, and design sludge drying & disinfecting technology at WTP if feasible.

138. Review and clarify with DoNRE the appropriate landfill location to dispose of the sludge produced at the WTP.

139. Never dump or temporarily store sludge on lands outside landfill site, WTP property, or within 100m of surface water courses.

140. Ensure sludge is covered when transported to designated landfill. 141. Develop and implement regular sludge quality monitoring to document sludge quality (See Environmental

Monitoring Plan)




Production of treated water

Land and surface water pollution

142. In ability to cope with volumes of wastewater resulting from improved water supplies –regular monitoring and balancing of water use and wastewater production ensuring adequate budget to plan and implement improvements to manage increased wastewater through collaboration with wastewater undertaking.




All All

In accordance with the approved EIA, the additional mitigation measures are required: 143. Chlorine supplies (or alternative chemical such as hypochlorite) for three days normal use must always be

maintained 144. Chlorine storage area must be isolated by closed doors and separate ventilation system (or chlorine

alternative will be stored appropriately) 145. Na2CO3 or appropriate neutralizing chemical must be maintained in sufficient quantities to neutralize twice

the amount of stored chlorine (or chlorine alternative)





IV. MONITORING PLAN

18. The environmental monitoring plan for the EMP is provided in Table 13. The monitoring plan focuses on all three phases (pre-construction, construction, post-construction operation) of the component and consists of environmental indicators, the sampling locations & frequency, method of data collection, responsible parties, and estimated costs. The purpose of the monitoring plan is to determine the effectiveness of the impact mitigations, and to document any unexpected positive or negative environmental impacts of the component..

A. Environmental Policy and Standards

19. The key environmental protection laws, policy, and environmental standards that need to be followed with the implementation of the EMP are listed in Table 8. Table 9 to Table 12 list the relevant national standards for this component. Table 8: Applicable Laws, Policy and Environmental Standards

National Laws

Law on Environmental Protection (LEP) No. 55/2014/QH13 dated 23rd

June 2014

Law on Water Resources No.17/2012/QH13 dated 21st June 2012

Law on Construction (LoC) No. 50/2014/QH13 dated 18th June 2014

Cultural Heritage Law 28/2001/QH10 dated 29th June 2001

Law No. 32/2009/QH12 dated June 29, 2009 of the National Assembly amending and

supplementing a number of articles of the Law on Cultural Heritages

Biodiversity Law 20/2008/QH12 dated 13th November 2008

Land law No.45/2013/QH13 dated 29th

November 2013

National Decrees & Circulars

Decree No. 59/2015/ND-CP dated June 18, 2015 of the Government on construction

project management

Decree No. 15/2013/ND-CP dated February 6, 2013 of the Government on quality

management of construction works.

Decree No. 45/2013/ND-CP of May 10, 2013, detailing a number of articles of the

Labour Code on working time, rest time and occupational safety and health.

Decree No. 201/2013/ND-CP dated November 27, 2013 of the Government detailing

the implementation a number of articles of the Law on Water Resources.

Decree No. 38/2015/ND-CP dated April 22, 2015 of the Government on the

management of wastes and scraps

Circular No. 27/2013/TT-BLDTBXH dated October 18, 2013 of the Ministry of Labor,

Invalids and Social Affairs on providing for occupational safety and hygiene training.

Circular No. 27/2014/TT-BTNMT dated May 30, 2014 of the Ministry of Natural

Resources and Environment regulating the registration for groundwater extraction, form

of dossier for issue, extension, modification, re-issue of water resource permit.

Circular No. 12/2011/TT-BTNMT dated April 14, 2011 of the Ministry of Natural

Resources and Environment stipulating hazardous waste management

International Guidelines

World Bank Group, 2007. Environmental Health and Safety Guidelines, Washington DC. AWWA Standard Methods for Measurement & Analysis Environmental Quality

National Environmental Standards & Methods

https://luatminhkhue.vn/en/law/law-no-32-2009-qh12-dated-june-29--2009-of-the-national-assembly-amending-and-upplementing-a-number-of-articles-of-the-law-on-cultural-heritages.aspx

https://luatminhkhue.vn/en/law/law-no-32-2009-qh12-dated-june-29--2009-of-the-national-assembly-amending-and-upplementing-a-number-of-articles-of-the-law-on-cultural-heritages.aspx

http://luatvietnam.net/vbpl/56052/environment/detailing-a-number-of-articles-of-the-law-on-water-resources.vlo

https://luatminhkhue.vn/en/decree/decree-no-38-2015-nd-cp-dated-april-22--2015-of-the-government-on-the-management-of-wastes-and-scraps.aspx

https://luatminhkhue.vn/en/decree/decree-no-38-2015-nd-cp-dated-april-22--2015-of-the-government-on-the-management-of-wastes-and-scraps.aspx

http://vietlawonline.com/vbpl/60040/environment/new-regulations-on-water-resource-extraction-and-discharge-of-wastewater-permits-.vlo


Water quality:

QCVN 01:2009/BYT – National technical regulations on quality of drinking water QCVN 08-MT:2015/BTNMT – National technical regulations on quality of surface water QCVN 09-MT:2015/BTNMT – National technical regulations on quality of groundwater QCVN 24:2008/BTNMT– Industrial wastewater discharge standards QCVN 02:2009/BYT: - National standard of domestic water supply

TCVN 5502:2003 – Supplied water – Requirements for quality TCVN 6773:2000 – Water quality – Water quality for irrigational purposes TCVN / QCVN – Standard methods for analyzing environmental quality

Air Quality:

QCVN 05:2013 – Standards for ambient air quality QCVN 06:2009 – Maximum allowable concentration of hazardous substances in the

ambient air TCVN 6438:2001 – Maximum permitted emission limits of exhausted gases from

vehicles Solid Waste Management:

QCVN 07:2009– National technical regulations for classification of hazardous wastes

QCVN 03:2008/BTNMT: - National regulation heavy metals concentrations in soil

Vibration and Noise:

QCVN 26:2010/BTNMT: National technical standard for noise

QCVN 27:2010/BTNMT: National technical standard on vibration

TCVN 6962: 2001 Allowable vibration level for public and residential areas TCVN 6962:2001: - Allowable vibration and shock from construction activities

Table 9: National technical regulation on ambient air quality

QCVN 05:2013/BTNMT

No. Parameter Unit

Requirement

Average 1h

Average 8h

Average 24h

Average year

1 SO2 µg/m3 350 - 125 50

2 CO µg/m3 30.000 10.000 - -

3 NO2 µg/m3 200 - 100 40

4 TSP µg/m3 300 - 200 100

5 Pb µg/m3 - - 1.5 0.5

Table 10: National technical regulation on hazardous substances in ambient air

QCVN 06:2009/BTNMT

No. Parameter Unit Requirement

1 H2SO4 µg/m3

Average 1h 300

Average 24h 50

Average year 3

2 Mg3Si2O3(OH) µg/m3 - 1 fibre/m

3

3 Benzene µg/m3 Average 1h 22


Average year 10

4 Hydrocarbon µg/m3

Average 1h 5.000

Average 24h 1.500

5 NH3 µg/m3 Average 1h 200

6 H2S µg/m3 Average 1h 42

Table 11: National technical regulation on drinking water quality

QCVN 01:2009/BYT

No. Parameter Unit Requirement Level of

supervision

1 Color TCU 15 A

2 Smell and taste - No strange smell and

taste A

3 Turbidity NTU 2 A

4 pH - 6.5 – 8.5 A

5 Hardness by CaCO3 mg/l 300 A

6 Chloride mg/l 250 A

7 Total iron mg/l 0.3 A

8 Total manganese mg/l 0.3 A

9 Nitrate mg/l 50 A

10 Nitrite mg/l 3 A

11 Sulfate mg/l 250 A

12 Permanganate indicator

mg/l 2 A

13 Free chlorine mg/l 0.3 – 0.5 A

14 Total coliform Bacteria/100ml 0 A

15 E.Coli Bacteria/100ml 0 A

Table 12: National technical regulation on noise

QCVN 26:2010/BTNMT

No. Area

Maximum allowed noise, dB

6h - 21h 21h - 6h

1 Special area 55 45

2 Normal area 70 55


20. An independent national environmental monitoring consultant (EMC) will be required to implement the environmental monitoring program set out in Table 13. This position will be part of the Construction Supervision Contract; the Construction Supervision Company will provide a suitably qualified environmental monitoring staff member. The PMU will provide logistical support to the EMC where necessary for the implementation of environmental monitoring plan. 21. After the construction phase is completed the sustainability of potable water quality from WTP needs to be monitored starting with the quality and quantity of the raw groundwater supply for the WTP. 22. Any required monitoring related to resettlement will be included in the Resettlement Action Plan.

B. Performance Monitoring

23. Performance monitoring is required to assess the overall performance of the EMP and is presented in Table 14. This table includes the surface water and ground water monitoring requirements as set out in the domestic EIA approved for this project.


Table 13. Environmental Monitoring Plan

Environmental Indicators Location Means of Monitoring Frequency Reporting Responsibility

Estimated Costs

4 (USD) Supervision

Implementation

Pre-construction Phase – Update Baseline Conditions

Update baseline on sensitive receptors (e.g., cultural property & values, new schools or hospitals, rare/endangered species, critical habitat),

At final locations for all construction activities Original field work, and resumption of community consultations that were initiated for IEE.

Once Once EA/PMU Environmental Monitoring Consultant

$1,000

A) Air quality: dust, CO, NOx, SOx, noise, wind, temperature and vibration levels B) Surface water: TSS, heavy metals (As, Cd, Pb,) TPH, oil and grease, total & faecal coliform, COD, BOD, temperature, C) Groundwater depth and TSS, heavy metals (As, Cd, Pb,) TPH, oil and grease, total & faecal coliform, COD, BOD, NH3, NH4, other nutrient forms of N & P,

A): At all construction sites B) at all surface waters within 50m of any construction site or camp area C) At sites of water treatment plant and abstraction wells.

Using field and analytical methods approved by DoNRE.

(A & B): One day and one night measurement during rainy & dry seasons. C) Twice

One baseline supplement report before construction phase starts

PMU Environmental Monitoring Consultant

$2,000

Presence of UXO At all excavation sites throughout component area

Military to survey and sweep affected areas of UXO

Once Once PPC / PMU military tbd.

Building condition reports At buildings within 5m of well drilling site Take and store digital photographs of building and record its condition including flooring, walls and roof.

Once Once EA/PMU Environmental Monitoring Consultant

Part of contract cost

Updated, & expanded community stakeholder comments & concerns of component and ensure GRM is disseminated in all project locations

At easily accessible sites at all investment sites Following consultation format and procedures established for IEE.

At least once & in conjunction with Grievance Redress Mechanism

At each location for each event

PPC / PMU PMU $1,000

Construction Phase Analysis of soil quality (heavy metals Possible contaminated lands at all excavation Using field and analytical methods Once if Once PMU Environmental $1,000

4 Estimated field sampling and laboratory analysis costs include field and laboratory technicians. Cost for part-time national monitoring consultant to assist PMU with EMP will be part of cost estimate for

DDSC.



Estimated Costs

4 (USD) Supervision

Implementation

(As, Cd, Pb, oil & grease, hydrocarbons).

sites approved by DoNRE. needed Monitoring Consultant

Air quality: As per pre-construction Baseline sites of pre-construction phase. Method as per pre-construction

Quarterly during construction periods

Quarterly PMU Environmental Monitoring Consultant

$3,000/yr

Surface water quality: As per pre-construction

Baseline sites of pre-construction phase. Method as per pre-construction

Quarterly during construction periods


$3,000/yr

Groundwater Levels and Quality at new well sites

At new well sites Using field and analytical methods approved by DoNRE, as per pre-construction

Twice during construction period


$6,000/yr

Groundwater pollution Site of Well Drilling Method Statement Visual Observation of implemented Mitigation Measures

Weekly Monthly PMU Environmental Monitoring Consultant

Including in contract

Pollution and social problems Site of Implementation of Management Sub-Plan a) Workers’ Camp

Visual Observation of implemented Mitigation Measures



Loss of drainage & flood storage Site of Implementation of Management Sub-Plan b) Construction Drainage




Soil erosion Site of Implementation of Management Sub-Plan c) Erosion control




Air Pollution (dust) Civil nuisance (Noise)

Site of Implementation of Management Sub-Plan d) Noise and dust




Location of affected people including all human receptors identified in this EMP (residential areas, temples, school, kindergarten, businesses along pipeline network)

Consultation Monthly Monthly PMU/PMSCD PMU-EMO Included in PMU budget

Land contamination, surface water pollution, ecology

Site of Implementation of Management Sub-Plan e) Borrow Site and Spoil management




Land contamination, surface water pollution, resource use

Site of Implementation of Management Sub-Plan f) Solid and liquid construction waste






Estimated Costs

4 (USD) Supervision

Implementation

Traffic disruption, Community Health & Safety

Site of Implementation of Management Sub-Plan g) Construction and urban traffic




Loss or disruption of utilities and services such as water supply and electricity

Site of Implementation of Management Sub-Plan h) Utility and power disruption




Location of affected people Implementation of RAP Monthly Monthly PMU/PMSCD PMU-EMO Included in PMU budget

Community and Occupational Health and Safety

Site of Implementation of Management Sub-Plan i) Community and Occupational Health and Safety




Damage or loss of trees, vegetation, and landscape

Site of Implementation of Management Sub-Plan j) Tree and vegetation removal, and site restoration




Water and air pollution, soil erosion, community health and safety, land contamination

Site of Implementation of Management Sub-Plan k) Construction materials acquisition, transport, and storage




Cultural Heritage Site of Implementation of Management Sub-Plan l) Cultural Sites and Chance finds

As required As required PMU Environmental Monitoring Consultant


Surface and groundwater pollution Site of Implementation of Management Sub-Plan m) Surface Water Protection




All environmental and human health receptors

Site of Implementation of Management Sub-Plan n) Emergency Incident Response Plan




Land use, nuisance, community health and safety

Site of Implementation of Management Sub-Plan o) site clean up


Once End of Construction

PMU Environmental Monitoring Consultant


Operation Groundwater quality and yield: TSS, heavy metals (As, Cd, Pb, Al,) oil and grease, total & faecal coliform, pH, DO, COD, BOD5, temperature, TDS, NH3, NH4, other nutrient forms of N & P, and volume (m3/hr)

At abstraction sites Using field and analytical methods approved by DoNRE.

Quarterly for 5 years

Biannually DoNRE DoNRE / “Moc Bai water supply company”

$4,000.00 / yr

Treated water quality: TSS, heavy metals (As, Cd, Pb, Al,) oil and

At 10 random locations along distribution network

Using field and analytical methods approved by DoNRE.


Biannually DoNRE MoH / “Moc Bai water supply

$4,000.00 / yr



Estimated Costs

4 (USD) Supervision

Implementation

grease, total & faecal coliform, pH, DO, COD, BOD5, temperature, TDS, NH3, NH4, other nutrient forms of N & P.

Compare to: QCVN 09-MT:2015/BTNMT, category A

company”

Surface Water Quality: pH, DO, TSS, COD, BOD5, Ammonium (as N), Nitrate, Phosphate, Fe, Cd, Cu, Pb, Zn, oil and grease, E-coli, Coliform, Mn, TDS, salinity

Đìa Xù Canal, near WTP Using field and analytical methods approved by DoNRE. Compare to: QCVN 08-MT

Quarterly Biannually DoNRE MoH / “Moc Bai water supply company”

$4,000.00 / yr

Worker & public injury associated with WTP operations

On property of WTP. Regular record keeping Continuously For each event

Moc Bai water supply company

Department of Labour

None

Al, TDS, SS and turbidity At backwash discharge locations Using field and analytical methods approved by DoNRE.


Biannually Moc Bai water supply company

DoNRE/ MoH $2,000.00 / yr

Table 14. Performance Monitoring Indicators

Major Environmental Component

Key Indicator Performance Objective Data Source

Pre-construction Phase

Public Consultation & Disclosure

Affected public & stakeholders

Meetings with stakeholders contacted during IEE & new stakeholders convened for follow-up consultation & to introduce grievance mechanism

Minutes of meeting, and participants list

EMP Updated EMP EMP is updated to account for changes in baseline environment and/or project design

EMP

Bid Documents Requirements of EMP (CEMP5)

EMP appended to bidding documents with clear instructions to bidders for CEMP

Bid documents

Training of PMU/ECO Training course(s) & schedule

By end of Pre-Construction phase, required course(s) are delivered as per designed and scheduled

Course(s) outline, participants, and schedule

UXO UXO –Confirmed not present Ensure no UXO are present Military Construction Phase

All component areas Management Sub-Plans submitted and approved

Implementation and monitoring of mitigation measures

Contractor sub-plans and Monitoring by EMC6

All component areas Sensitive receptors for baseline updated

All sensitive receptors are unharmed during implementation

Monitoring by EMC

Water quality of affected surface and ground waters

Parameters set out in Environmental Monitoring plan

National environmental standards & criteria met

Monitoring by EMC

Air quality Parameters set out in Environmental Monitoring plan

Levels never exceed pre-construction baseline levels

EMC & contractor monitoring reports,

Soil quality Parameters set out in Environmental Monitoring plan

Rigorous program of procedures & rules to collect and store all waste from construction camps and sites practiced.

Contractor and EMC monitoring reports

Operation

Quality & quantity of raw groundwater for WTP

Quality & quantity requirements to sustain potable supply

Treatable to potable standards Plant operators, MoH

Treated water quality from WTP

Taste, incidence of water borne diseases

Drinking water standard of MoH Reports by MoH, public input, DoNRE

V. PUBLIC CONSULTATION

24. As indicated in the IEE, no negative issues of the subproject/component investments were raised by consulted stakeholders in Moc Bai. Detailed information on the consultations undertaken on behalf of all components for the Moc Bai sub-project are presented in Appendix B. 25. Follow up consultation and EMP Disclosure. Consultation and disclosure will be consistent with ADB’s Public Communication Policy (2011) and Safeguards Policy Statement (2009). During the update of this EMP, the stakeholder consultations that were implemented for the IEE are continued with the start of the pre-construction phase of the component.

5 Contractor Environmental Management Plan developed from EMP in contractor bidding document

6 Environmental Monitoring Consultant hired to implement Environmental Monitoring Plan


26. Planned Consultation & Disclosure. At least one (1) consultation event is planned in Moc Bai to inform key stakeholders of: (i) ADB Environmental Safeguard Requirements; (ii) Potential Environmental Impact and Mitigation Measures as described in this EMP and the EMPs for the other components for the sub-project; and (iii) the GRM process. At the event, the status of the environmental safeguard document will be discussed and PMU will fulfill the disclosure requirements by retaining a copy a summary EMP in Vietnamese language for public viewing throughout component implementation 27. In addition, an orientation on the GRM and its procedures will be included in the event – details such as persons to contact and contact details will be provided. Likewise, contact details of contractor, PMU and ADB (for submission of complaints) will be posted in signboards in all project location. Finally, follow-up consultation and public information activities will be conducted as often as may be necessary. 28. Consultation during implementation. During implementation, further consultation will take place during the project implementation period. This will be undertaken by the PMU Environmental Control Officers, who will ensure consultation with affected people and other stakeholders at least four times during the construction period. It is suggested that the consultations take the form of meetings and site based discussions and include the following:

o Environmental impacts of civil works (e.g., solid & liquid waste, erosion, local flooding, pollution).

o Any unforeseen impacts caused by accidentally e.g. through spillages’ o Civil nuisance (e.g., noise, vibration, reduced access, disrupted business &

community activity, social issues, community health and safety). o Impaired use of roads (e.g. traffic issues and access). o GRM and its procedures including details of persons to contact and contact

details 29. The contractor is required to ensure that project sign boards are erected at each road location which gives the project details including a phone number for the GRM and an address for the PMU office as well as ADB contact details. 30. Inclusion of Affected People’s Views. As a result of discussions with Affected People in September 2016 during the update to this EMP, the following mitigation measures will be included in the EMP:

o Concern: Well drilling may crack buildings. o Response: Unlikely given distance from buildings to new wells, however

disseminate GRM during project construction and contractor will undertake a condition report for all buildings within 10m of any new wells.

o Concern: Groundwater may dry up with increased abstraction o Response: Monitoring to confirm actual ground water availability for

householders. This will be undertaken by the PMU-ECO consultation householders during implementation and the water operator during operation.

o Concern: installing pipelines will disturb households and businesses o Response: Control of nuisance issues (dust, noise and fumes) and restrict

construction working hours.


VI. GRIEVANCE REDRESS MECHANISM

31. A Grievance Redress Mechanism (GRM) will be established, which will cover the water supply improvement component, as well as all other components in the sub-project. The IEE established the GRM process which is shown in Figure 2. During this EMP revision, the GRM was discussed with the PMU in Moc Bai to ensure it is still relevant to the component.

Figure 2: Grievance Redress Mechanism

Source: PMSCD Team

Level : Co u e People’s Co ittee CPC PMU is I for ed

Withi Days, is co plai t resolved? Yes

No

Level : City or District People’s Co ittee DPC PMU is I for ed

Special Missio / Judicial syste


No

Level : Provi cial People’s Co ittee PPC PMU is I for ed


No

GRM ACCESS POINT


32. The PMU will be involved at all stages of the GRM process and is responsible for recording all complaints made through the GRM and the resolutions. 33. Level 1. The GRM may be accessed thought the Commune People’s Council or directly through the PMU, as signboards with contact details (including phone number) for the component will be erected at the necessary locations. In reality, complainants may also contact the contractor directly. The PMU will have 15 days after the lodging of the complaint to resolve the grievance. The PMU may get assistance from the DoNRE in evaluating the technical basis of complaints related to environment-related impacts (e.g., vehicle emissions, dust, noise, vibration) as required. Address of Commune People’s Council: UBND Lợi Thuận Commune, Bến Cầu District Tây Ninh Province; Address of PMU Tay Ninh: Xuyên Á Road, Thuận Tây Village, Lợi Thuận Commune, Bến Cầu District, Tây Ninh Province 34. Level 2. If the complainant is not satisfied with the resolution, (s)he may bring the case, either in writing or verbally, to any member of the District People’s Committee, which will have a further 30 days following the lodging of the complaint to resolve the case. Address of Ben Cau District People’s Committee: Resident Area No 1, Go Dau Town, Ben Cau District, Tay Ninh Province 35. Level 3. If the complainant is not satisfied with the resolution, (s)he may bring the case, either in writing or verbally, to any member of the Provincial People’s Committee, which will have a further 45 days following the lodging of the complaint to resolve the case. Address of PPC Tay Ninh: No 136, Trần Hưng Đạo Str, Ward 2, Tây Ninh City, Tây Ninh Province. 36. Special Mission or Judicial System. If the complainant is still unsatisfied, the PMU/EA will inform ADB to convene a special mission to attempt a resolution prior to use of the Viet Nam judicial system. 37. A Complaint Form as set out in Appendix C will be used by PMU to record the complaints made under the GRM. PMU is responsible for retaining up to date copies of these forms. 38. Accountability Mechanism of the ADB. In addition, affected people may always contact the Complaints Receiving Officer of the ADB via the following addresses which will be included in the signboard:

Complaints Receiving Officer, Accountability Mechanism Asian Development Bank ADB Headquarters, 6 ADB Avenue, Mandaluyong City 1550, Metro Manila, Philippines (+632) 632-4444 loc. 70309 (+632) 636 2086 [email protected]

Instructions available here: http://www.adb.org/site/accountability-mechanism/how-file-complaint)

http://www.adb.org/site/accountability-mechanism/how-file-complaint

http://www.adb.org/site/accountability-mechanism/how-file-complaint


VII. INSTITUTIONAL ARRANGEMENTS & RESPONSIBILITIES

39. The primary management framework overseeing the implementation of the environmental management plan (EMP) for Moc Bai subproject will be defined by the: 1) Tay Ninh Provincial Peoples Committee (PPC) who is the executing agency (EA) of the subproject; 2) Tay Ninh PPC delegated to Tay Ninh Province Economic Zone Authority (TANIZA) as the implementing agency (IA) and project owner (PO) including selection and signing contract with construction contractors; 3) a Project Management Unit (PMU) nominated by the TANIZA who will assist the TANIZA with the overall implementation of the component investments including directing and supervising the construction contractors. 40. A Project Steering Committee (PSC) has been created to provide policy and technical guidance for subproject implementation. The PSC is chaired by the EA and a Vice chairman of PPC is working as Chairman of PSC, and is comprised of line departments such as Construction (DoC), Transport (DoT), Finance (DoF), and Environmental Management (DoNRE), as well the Tay Ninh Province Economic Zone Authority (TANIZA). The Department of Environment and Natural Resources (DoNRE) is the regulatory authority for all environmental matters of the subproject/component 41. Working within the PMU, an environmental management officer (EMO) has been assigned based on Decision No 1549/QĐ-UNND dated 07/08/2013 of PPC Tây Ninh in the PMU. The EMO will work with the construction contractors on all packages, to ensure that the EMP is implemented for all component investments and support the PMU with regards to environmental and social safeguard reporting requirements as set out in Table 15. 42. Each Contractor shall nominate an environmental control officer who will ensure the impact mitigations of the EMP are implemented and who will provide the necessary environmental reports for the Contractor, as set out in Table 15 (Reporting Requirements) 43. A Project Management Support & Capacity Development consultant (PMSCD) assist with the project and a Detailed Engineering Design team are engaged to undertake detailed designs of the component. The PMSCD team includes an environmental specialist who works with PMU-EMOs to update the EMP to ensure EMP meets the final component designs. The environmental specialist will assist the EMO at the beginning and periodically throughout the implementation of the component investment. 44. The ADB is responsible for monitoring to ensure the component meets the environmental safeguards of the SPS (2009). 45. The responsibilities of the EA in relation to environmental safeguards requirements are summarized below:

1. Overall responsibility for component/subproject implementation and establishment of the subproject Management Unit (PMU);

2. Ensure compliance of Loan Covenants; 3. Approve procurement plans, bidding documents, bid evaluation and contract awards

including EMPs; 4. Submit regular quarterly and annual subproject reports to ADB including relevant

reporting on EMP implementation; 5. Ensure compliance of subproject/component implementation with ADB’s social and

environmental policies and guidelines; 6. Approve proposed actions in the event of adverse financial audits or monitoring and

evaluation reports. 46. The EA will hold overall accountability of the subproject implementation and operation on behalf of the Government of Viet Nam and will work as national subproject agency.


47. The responsibilities of the IA in relation to environmental safeguards requirements are summarized below:

1. Coordinate and monitor subproject/component implementation activities of PMU including all environmental safeguards activities;

2. Coordinate capacity development program for PMU, 3. Obtain necessary approvals from respective departments and other institutions such

as DoNRE prior to awarding of civil works contracts, 4. Support PMU-EMO in the implementation of EMP, 5. Coordinate regular reporting of PMU to EA on EMP implementation, 6. Undertake regular quality control inspection of subproject/component facilities, 7. Manage the handover of subproject facilities to agencies responsible for operation

and maintenance 48. The PMU will oversee and coordinate the implementation of the subproject/component investments including the management of the institutional strengthening plan. It will also be responsible for coordinating subproject/component implementation with the participating agencies and institutions at the district and corridor town levels to ensure broad participation in subproject/component related activities and further enhance subproject/component ownership. 49. Responsibilities of the PMU in relation to environmental safeguards requirements are summarized below:

1. Undertake day to day management of subproject/component activities; 2. Implement approved annual rolling work and financial plans; 3. Prepare and submit regular quarterly and annual subproject/component reports

including environmental safeguard reporting; 4. Supervise civil works contractors including EMP implementation; 5. Ensure that EMPs are incorporated in the detailed designs and included in civil works

contracts; 6. Ensure EMP implementation; submit regular monitoring reports to IA and EA; and 7. Monitor implementation of resettlement activities by the respective corridor towns and

submit monitoring reports to IA and EA; 8. Dissemination of Grievance Redress Mechanism (GRM)7; and 9. Ensure EMP is initiated by the responsible parties as set out in this EMP.

50. The PMU and EMO with assistance from the PMSCD will ensure that the EMP becomes part of the construction contract, and that (i) tender documents specify requirements of EMP must be budgeted, (ii) the contractor has experience of implementing EMPs or provide staff with experience, (iii) the EMP is implemented, and that the contractor(s) abide by the EMP. The EMO should undertake regular site inspections and the results should be recorded and submitted to the relevant authorities as part of progress reporting. 51. Role of the Contractor. The contractor’s responsibilities for environmental safeguards are summarized as follows:

1. Implement the requirements of this EMP and associated reporting requirements; 2. Develop and submit for approval to the CSC a Site-specific EMP that responds to the requirements of the EMP, and that includes all sub-plans as defined in EMP Table 7, item 1. 3. Obtain and maintain all required permits and/or licenses required as to allow for the construction of the component;

7 Grievance Redress Mechanism is updated or checked it remains appropriate during the design phase.


4. Appoint one full-time qualified staff to coordinate EMP implementation, including environment, health and safety; 5. Collaborate with the PMU to address any grievances raised under the GRM.

52. Role of the Contract Supervision Consultant (CSC). The CSC has responsibility for monitoring a number of the environmental safeguards mitigation measures. An independent environmental monitoring consultant (EMC) will be engaged under the CSC contract, as set out in Section IV Monitoring plan.

A. Institutional Capacity Review and Needs

53. Currently there is little capacity for environmental assessment and management amongst subproject staff (e.g., PMU) in Moc Bai. The PMSCD with assistance from the designated PMU-EMO of the subproject will develop and deliver training courses to the PMU staff. The purpose of the courses is to strengthen the ability of the PMU to oversee implementation of the EMP by construction contractors and EMC 54. The EMO will be the only full-time person responsible for environmental issues. The EMO should attend training courses as required. Costs for training should are included with costs for implementation of the EMP. 55. Training on the implementation of an EMP is should focus on two thematic areas. i) the potential impacts of infrastructure development on the natural and social environment; and ii) environmental safeguard requirements of the ADB and National laws, with specific focus on the EMP. 56. During the design phase, PMSCD will develop and schedule a training plan for PMU (EMO) to be able to fully implement EMP, and to manage implementation of mitigation measures by contractors.

VIII. REPORTING

57. Regular reporting on the implementation of mitigation measures, and on monitoring activities during construction phase of the component is required. Reporting is the responsibility of PMU and should be conducted in conjunction with the regular meetings with stakeholders as part of the stakeholder communication strategy. 58. Environmental monitoring reports (using the integrated safeguards monitoring report format) will be prepared quarterly for the EA by the PMSCD in collaboration with PMU/EMO and sent to the DoNRE and ADB. The reports will table all indicators measured with the monitoring plan of EMP including performance monitoring indicators, and will include relevant national environmental quality standards. Table 15 gives reporting requirements.

Table 15. Reporting Requirements

Report Frequency Purpose From To

Contractor’s Progress Report

Weekly EMP Implementation

Progress Contractor PMU

EMP Progress and Compliance Report

Monthly Confirm EMP

Monitoring EMC PMU

EMP Monitoring Monthly Relevant EMP

monitoring parameters PMU-EMO PMU

Environmental Monitoring Report

(Integrated safeguards

Semi-Annual

Full EMP Implementation and

Adherence to Environmental

EA ADB/DoNRE


monitoring report format)

Covenants/Conditions

A. Mechanisms for Feedback and Adjustment

59. Based on environmental monitoring and reporting systems in place, the PMU shall assess whether further mitigation measures are required as corrective action, or improvement in environmental management practices are required. The effectiveness of mitigation measures and monitoring plans will be evaluated by a feedback reporting system. The PMU will play a critical role in the feedback and adjustment mechanism. If the PMU identifies a substantial deviation from the EMP, or if any changes are made to the project scope that may cause significant adverse environmental impacts or increase the number of affected people, then the PMU shall immediately consult DoNRE and ADB to get approval and identify EMP adjustment requirements.

IX. ESTIMATED COST OF EMP

60. The costs for implementing the EMP are primarily for environmental monitoring because the costs for implementing impact mitigation measures are included in the construction costs as contained within the contractor bid documents. 61. Estimated costs for field sampling and laboratory analyses for the Monitoring Plan during pre-construction and construction and construction phases are $17,000. This does not include UXO survey & removal by military. Monitoring costs per year from beginning of operation phase are estimated at $14,000. All estimated costs are preliminary, and based on the national cost norms for environmental sampling and analyses (Circular 83/2002/TT-BTC).. 62. An estimated budget of USD$11,000 is required for capacity building for environmental management. This budget will be incorporated as part of the overall training and capacity development budget planned until the end of the project in 2017. .

X. EMERGENCY RESPONSE PLAN

63. The contractor will set out an emergency response plan as required in the Mitigation Measures ( Emergency Incident Response Plan).

XI. CONCLUSION

64. This EMP shows that the likely environmental impacts from the component are expected to be short term and not significant during construction. The impacts during operation are associated with the water use and sludge management. It is recommended that an alternative to chlorine is used for water treatment gives its potential risks as it is hazardous to health. 65. It is concluded that these impacts can be adequately managed though the implementation of this EMP and on-going maintenance of high operational standards when the water treatment plant comes online. 66. It is expected that with the correct support and training which can be provided by PMSCD, the IA will be equipped to ensure EMP implementation and will be able to fulfill the monitoring and reporting requirements as set out in this EMP.


67. The component overall will benefit Moc Bai. It will provide a much needed supply of potable water for residents, businesses and visitors to this key border town. It will also leave a legacy for the IA staff of improved skills in environmental management.


APPENDIX A: EIA APPROVAL

*PMU TO INSERT EIA APPROVAL LETTER HERE


APPENDIX B: RECORD OF CONSULTATIONS AND DISCLOSURE

68. This Appendix gives information on consultations undertaken on behalf of all sub-projects in Moc Bai.

69. Consultations were undertaken at various stages/points throughout the PPTA. Including during the development of the IEE, and twice during the development of this updated EMP.

70. Consultations with stakeholders was undertaken in Tay Ninh as shown on 31st May 2016. The event was held at the PMU office 31st May 2016 and included Environmental and Gender issues; the agenda was:

(1) Environment: (i) ADB Environmental Safeguards; (ii) Project Environmental Risks; (iii) EMP Disclosure: Implementing Environmental Management Plans; and (iv) Consultation on EMP and GRM.

(2) Gender: (i) Gender awareness; (ii) Gender Policies of the Vietnamese Government and ADB; (iii) Gender Actions Plans (GAP) (GAP); (iv) Group Discussion on GAP.

71. The consultation on EMP and GRM included discussions on the information presented and to obtain views and concerns of the participants. Comments from participants are below:

Have gained necessary knowledge on environment and gender safeguards policies relating to this project. Need further coaching and practice on monitoring the actual implementation of EMP and GAP;

Need further clarification on gender role;

Need further coaching after this training

Training on skills on evaluating the environmental impacts and on monitoring the implementation of EMP during the construction phase;

Need further survey on environmental status and impacts at each area;

Training on knowledge and skills on communication and motivating people;

Need to involve Commune People's Council in the monitoring work because it is the powerful body at the commune level;

The Grievance Redress Mechanism (GRM) was discussed. With reference to the GRM timing, the decision from the participants was that the project GRM requires revising to be in line with the timescales in Vietnamese law. As a result, the level 2 and level 3 timescales have been changed from 15 days to 30 and 45 days respectively. These changes will be reflected in the future final versions of the EMPs.

72. Participants of 31st May 2016 meeting to discuss Environmental Safeguards for all Moc Bai sub-project components:


73. Consultation with Affected People was undertaken in Moc Bai in September 2016. The events included a meeting held at the PMU office 8th September 2016. The content and output from the consultation is as follows:

Content of consultation meeting

Presentation of PMU and PMSCD:

- Mr. An – Vice director of PMU: introduce objective of consultation meeting, including: summary

of project progress, contents of subprojects.

- Ms. Nguyet – Env. Specialist:

1. Presents impacts of the project to environment and living of people in the area:

Positive impacts: The WPT will improve water quality and number of people can use

clean water will be increased.

The potential adverse effects that activities of WTP will affect to quality and quantity of

groundwater supply, local authority will be insufficient capacity to manage increased

wastewater production by community and it is potential pollution from spills of hazardous

materials such as chlorine.

Besides, living of people will be nuisance from noise, vibration, and dust from construction

equipments, increased traffic from construction vehicles and road disruptions, disrupted

business & community activity.


2. Presents on mitigation measure and environmental management plan:

• Environmental management plan has to be enclosed with bidding document and be

implemented by contractor. Contractor must put in place Management Sub-Plans for each

key aspect of construction and each plan is approved by PMU before the project starts.

• Detail of mitigation measures and complaints procedure is introduced to affected people.

Comments of local authority and affected people:

Local Authority: Vice chairman of Loi Thuan commune agrees with contents of draft

environmental management plan of WTP project. However, it is proposed that PMU must have

supervision plan in order to be sure that EMP will be achieved.

Affected people:

- Drilling deep wells may affect exiting building construction, shake, crack houses therefore

PMU has to monitor contractor.

- Installing water pipeline along two sides of urban roads will be disrupted business &

community activity.

- Some households are using groundwater from drilled wells with depth from 28 – 30m, while

wells of WTP will be depth 150m, more deeper than wells in households, so it is considering

that whether WTP will deplete most quantity of groundwater and wells in households will be

lack of water?

Conclusion:

- PMU will provide technical specification of construction to contractor who has to conduct

mitigation measure in the construction phase, which shall ensure reducing vibration, crack

buildings, houses.

- Project designer had done hydrological and geological investigation, analysis groundwater

quality to defined depth of wells 150m because at this groundwater layer, water quality is the most

suitable for treatment with the lowest cost. Furthermore, there are many different groundwater

layers so it will not effect to exploitation groundwater of people.

- PMU commits doing construction supervision and implementing grievance redress mechanism

to resolve complaints of people on time.


List of Affected People


74. Consultations undertaken throughout the PPTA are summarized in Table 16: Stages of Consultation during PPTA (taken from original IEE of Moc Bai subproject.

Table 16: Stages of Consultation during PPTA

Project stage Purpose Tools/Process

Inception stage

Identify stakeholders; Identify key poverty reduction and

social development options; Identify work required (plans for

action/mitigation plans, frameworks, or other measures)

Incorporation of feedback on initial project concepts;

Stakeholder analysis and workshops, confirm who will be involved and how;

Screening of issues

SLEDPs Establish levels of participation of stakeholders in current planning;

Prepare socio-economic profiles; Identify existing opportunities and

constraints on urban development

Key informant interviews and focus group discussions;

Data collection - participatory rapid appraisal (PRA) techniques;

Participatory SWOT analysis

FSs

Confirm problem analysis; Assess needs, demands, and

capacities of beneficiaries; Foster maximum positive impact for

women/girls; Develop appropriate mitigation plans,

frameworks or other measures if negative effects are unavoidable

Data collection – PRA techniques, and household survey;

Willingness/ability to pay survey; Poverty and gender analysis; Stakeholder analysis; Risk reduction options; Analysis focused on affected

persons and/or communities

Draft RP/PSA preparation and reporting

Detailed identification of risks and impacts;

Ensure social concerns are addressed in designs;

Involve stakeholders in agreement on preferred design;

Maximize poverty reduction and social development impact;

Minimize negative impacts (RP)

Consultation and PRA (incl. responses to draft PSA);

Analysis; Review of action/mitigation plans

or other measures Prepare SDP and GAP

Finalisation of RP/PSA, disclosure

Facilitate stakeholder ownership of final design;

Confirm poverty reduction and social development outcomes in project design;

Agreement to measures and programs included in SDP and GAP

Confirm with government and development partner policies

Review of design elements based on responses/comments on draft RP/PSA;

Review of project compliance with requirements for action/mitigation plans, frameworks, or other measures

75. The CTDP has been prepared in a participatory manner with consultations with primary stakeholders, beneficiary communities and directly affected people/households. During the identification of priority subprojects and preparation of the SLEDPs, consultations were held with the EAs, IAs and other stakeholder agencies and organizations including representatives of the private sector (Business Associations and Chamber of Commerce), non-governmental organizations (NGOs), mass organizations (Youth Union, Women’s Union) and civil society organizations (CSOs). Consultation tools include key informant interviews (KIIs), focus group discussions (FGDs), semi structured interviews, and a household survey.

76. Consultations have also been undertaken specifically for the environmental and social impact assessments in an integrated manner, and will be reported in the various reports and plans prepared for each subproject. The purpose of the consultations undertaken for the component has been to; (i) introduce the CTDP and component; (ii) briefly identify impacts and receive feedback on the impacts and any proposed mitigation measures; (iii) disclose relevant project information (such as eligibility and entitlements for


compensation, proposed SDP and GAP measures and the IEEs); and (iv) record the response of beneficiary communities to the CTDP and anticipated impacts, both positive and negative.

77. A Stakeholder Communication Strategy (SCS) and Communication and Participation Plan (CPP) have been prepared for the CTDP. The CPP details the consultations undertaken to date and establishes the framework for ongoing consultation and participation as the Project moves into its implementation stage.

Results of Focus Group Discussions

78. For the FS and detailed subproject discussions, consultations have been held with affected/beneficiary communities through focus group discussions (FGDs) with small groups of men and women from the communities. As described in Section 3, a household survey was also undertaken to understand the characteristics of beneficiary households and their access to urban services and facilities. As shown in Table 5.2.1, meetings were held in two locations with a total of 49 participants.

Table 5.2.1 – Consultation Meetings with Beneficiary Towns/Communes

Date Location No. of male participants

No. of female participants

Total

29.08.11 Ben Cau 8 8 16

03.09.11 Loi Thuan 8 9 17

04.09.11 Loi Thuan 8 8 16

Total 24 25 49

Source: PPTA Consultations (August/September 2011)

Results of Women’s FGDs

79. The women’s groups commented that most women of the town work in trade (especially at the border gate), small business, or in the agriculture/forestry sector exploitation, there are also many women who migrate to Ho Chi Minh City and Cambodia for seasonal work. It was noted that some women work in tourism and construction, but not very many. The women noted that their unemployment levels are not as high as those of men and their work is relatively more stable (even though many women do not earn a regular income) because men are likely to be employed in seasonal, daily labor and casual work.

80. The women noted a number of challenges and issues facing the town in terms of its development including; high unemployment and lack of job stability; lack of agricultural land and limited access to extension workers and information; problems with basic infrastructure including inadequate water supply and environmental sanitation, roads are undeveloped and in poor condition; high drop-out rates from schools (especially girls); available job opportunities for women are limited there are few “careers” available to them and therefore incomes and employment are not seen as sustainable, in particular there are no funds or support for women’s development (especially for increasing skills) and lack of vocational training for changing jobs.

81. The women’s groups suggested that measures to address the problems could include (by priority) improving infrastructure and services especially roads, water supply, healthcare and wastewater treatment (and sanitation); creating jobs for people (especially women) by supporting development of industry and tourism (developing tourism activities and ventures); and provision of skills and vocational training for working-age women, especially those engaged in arduous and low-paying work such as farming.

82. Comments about the road improvement subproject included that the existing roads that provided access between the town centre and the wards/communes were in poor condition, narrow and often of only earth construction, during the rainy season (June –


October) they become flooded and very difficult to pass and in the dry season dust become a real problem. There are issues with dangerous driving, especially by bus and truck drivers which are exacerbated by narrow and poor condition roads. A number of roads that have been planned for many years have never been constructed and therefore the overall network is incomplete. Travel at night is dangerous because there are no street-lights. The women noted a number of benefits, they agreed that most people in the town would benefit from upgrading the roads and installing drainage, they also commented that the upgrading will improve accessibility and ease of travel and convenience and it will also be easier for children to get to and from school. Improved access will contribute to tourism, and in general upgrading the roads and drainage will result in an improved urban environment.

83. When discussing the wastewater treatment plant and sewerage subproject the women noted that this would improve health, particularly for those people living along the currently open channels which convey wastewater, effluent and storm-water run-off, the women also noted that the sewers get blocked with rubbish because the solid waste collection service is not frequent enough. In the rainy season wastewater backs up and floods the low-lying areas and both children and adults fall ill (fever, stomach ailments and eye infections) because the flood waters (which can contain sewage and wastewater) can take a long time to recede. Stagnating pools of water are breeding grounds for mosquitoes. The women’s groups considered that there would be general environmental improvements with this subproject, with a cleaner environment, exposure to various illnesses will be reduced.

84. The water supply expansion subproject received very high support, women from Loi Thuan noted that few households were connected to the town supply, only a few households in Ben Cau town were connected to the municipal supply and women had to collect water from wells or nearby rivers/streams. Even women from Ben Cau who lived in households that were connected to the town supply noted that the supply was insufficient and the quality of water received was very poor. The women noted that there was inadequate “clean and safe” water for daily needs and that use if unsafe water caused disease in both women and children. The women were very clear that was a need to both expand the supply system and improve the treatment and quality of the water delivered.

85. The women’s groups identified similar potential negative impacts associated with each of the component proposed in Moc Bai, these are associated with the construction works including environmental pollution, access and mobility problems (i.e. it will be difficult for people to move around during construction period, noise and dirt, creation of waste. These can be mitigated with proper implementation of the environmental management plan (EMP).

86. The women wondered if it would be possible to ensure that construction vehicles only used certain routes, the roads had been damaged by many construction trucks in the past and they wanted to avoid further any damage. Difficulties in access to the properties was raised, it was explained that, similar to the road improvement subproject, a plan would need to be devised to ensure that access was not impeded during construction.


87. The FGDs touched on climate change issues to determine whether effects had been noticed or if adaptation measures had been required. In terms of noticing changes in weather/climate, the women’s FGDs stated that heavier rains and flooding occurred more frequently and took longer to recede, the rainy season/winter was longer than usual, and the summer/dry season, although shorter was hotter and drier.

88. A number of effects associated with these changes were identified; the area affected by floods increased each year; increased pollution in rivers and lakes due to flooding and erosion; larger numbers of people got sick; and flooding and erosion affected infrastructure and land (residential and agricultural). When asked to rank these changes and impacts by their significance the women overwhelmingly noted flooding as the most significant impact followed by erosion.

Results of Men’s FGDs

89. According to information provided during the men’s FGDs the main livelihood and business activities in the town includes trade and services, industry but mostly small-scale industry, construction, and agriculture. More than half of men of the town are involved in seasonal work such as production of building materials and unloading goods. The men commented that only few men were involved in trade or marketing. The main economic activity in Loi Thuan is agricultural production, when it is not planting or harvesting time the men hire out their labor on a causal or daily basis; the men considered that unemployment was higher for males than females and a larger proportion of men were engaged in only daily/casual work.

90. The groups note a number of socio-economic issues or pressures facing the men of the town such as; unemployment and lack of jobs in higher paying sectors; migration of people to other areas (including Cambodia) for work leaving the family without a head male; constrained market access; and poverty. In each of the FGDs unemployment and job instability was ranked as the foremost development problem or issue, lack of land for agricultural production (forcing men to work in low-paying jobs in the town) was seen as the second most pressing issue, inadequate infrastructure (roads, water supply and healthcare) was considered as the third problem, and high rates of children dropping out of secondary school was seen as the fourth issue.

91. The men’s groups ranked their development priorities creating jobs and wider range of employment opportunities, improving urban infrastructure focusing on roads/drainage, water supply, improving solid waste management and health care ranked as their second priority. In Loi Thuan tackling the problems of flooding, including raising the levels of the roads, was mentioned in one of the groups. While not high on the list of priorities the men also noted lack of recreational areas and the need for a park to be created.

92. The types of interventions that could address the problems identified were very similar to those mentioned in the women’s FGDs, the men’s groups suggested that creating jobs by developing the tourism sector and building factories would help with unemployment, while provision of vocational training for new careers was also seen as important in addressing lack of job opportunities along with specialized training for farmers to help them improve production.

93. During discussions about the road improvement subproject it was noted that the traffic system in Moc Bai had not been upgraded in many years, only a few new roads had been constructed and while these assisted in helping move people and goods, they served only a small proportion of the population. Improved roads, including fulfilling the master plan for the road network was required; this would be beneficial for the people of the town and encourage visitors and traders which would boost many small businesses such as local contractors, street vendors and cafes and food sellers. Truck and bus drivers often drive too fast and dangerously, especially cross-border traffic, improving road conditions will help address this but better enforcement of traffic rules is also required.


94. The men identified some negative impacts, mostly associated with construction, including security issues, and waste and pollution (indiscriminate dumping of material), both of which can be mitigated through measures included in the EMP.

95. The water supply subproject was considered necessary to reduce the number of households that had to rely on water from wells, water tanks or rivers. Like the women, the men noted that only a few households used piped water from the town supply scheme. The supply system needed to be expanded to include Loi Thuan.

96. During discussions about the wastewater treatment plant and sewerage subproject, the men’s groups noted that treatment plants and a well-designed pipe network were necessary to make sure the sewerage was treated and disposed of properly and also get rid of the bad odor from the drains and open channels. The men considered that the subproject would not create long-term negative impacts, just temporary ones. In the long-term the subproject would benefit the whole community.

97. With regard to climate change issues, the men’s groups, like the women’s groups, noted that in recent years there had been increased and more frequent flooding in the rainy season, increased and longer droughts in summer, increased extreme weather events such as storms, erosion was more prevalent, and there were changes in temperature changed (being hotter and drier in summer and colder in winter).

98. The impacts of these changes were identified as; destruction of crops due to either flooding or drought; landslides affecting roads, access and houses; erosion damaging agricultural land and important infrastructure such as roads; more mosquito and flies; increased numbers of people getting sick; and difficulties in growing the plants traditionally cultivated in agriculture.

99. People were asked how they responded to these effects, the men stated that they had been forced to change their usual agriculture productions by changing crop season as well as growing different crops (cassava), and invest in protection measures such as raising houses or relocating to higher places, sand-banking, and increasing forest protection (including re-planting).

100. When asked to prioritize the most significant negative impacts from climate/weather pattern changes, the groups each identified flooding (and raised river levels) as the major concern, followed by erosion, and increased extreme weather events damaging crops and trees. Key Informant Interviews

101. A number of KIIs were conducted during the development of the SLEDP and further KIIs were undertaken for the PSA. The results of the KIIs are as follows.

Women’s Union

102. The KII with the VWU revealed that women in the town have relatively high levels of education compared with the women in the more rural communes, including 100% of females enrolled in school, high literacy, and over 70% of women graduated from junior and high schools. In the rural and peri-urban areas the reasons that females drop-out of school include the need to assist the family by finding jobs and contributing to household income, and people's low perception of women i.e. females are not expected to perform well at school or achieve as much as the males, they are also not encourage to “widen their horizons”. Other problems faced by women in the town include lack of capital to start small businesses, lack of skills, some women become involved in social evils such as gambling, prostitution, alcohol abuse and use of drugs.

103. There has been a lack of provision of vocational or professional training for women and a lack of funds for the VWU to become actively involved in this area even though they wish to. There have been few if any foreign funded projects and limited involvement of NGOs with local women. Annually, the VWU applies for a budget to organize small training courses for women, such as literacy classes, training in cross-border trafficking awareness,


and awareness raising about drugs, family violence, and environmental issues (including water and sanitation), and nutrition for children. However, due to limited funds, training courses cannot be held every year and even in a year when the courses/classes can be provided they have to target fewer women than intended.

104. The WVU also provides loans to support for small business run by women, loans for female students and poor women and funds for temporary settlements made available through the Bank of Social Policy and Agriculture and Rural Development Bank.

105. The WVU takes part in local economic development plans and programs and also participates in establishing the needs of women in the annual budget plan. The WVU expressed an urgent need for training to raise awareness of female staff so that they can participate in contributing their ideas, assisting in decision-making at higher and more meaningful levels, and providing inputs to urban planning and development.

Department of Labor, Invalids and Social Affairs

106. According to the Department of Labor, Invalids and Social Affairs (DOLISA) which is responsible for assisting households out of poverty, the poverty rate in Moc Bai ranges from 7% (TT Ben Cau), 10% in Loi Thuan and as high as 18% in An Thanh commune, the average poverty rate for the Moc Bai core urban area is 11.5%. The reason for the highest poverty rate being given that households in this area rely more heavily on agriculture than on other income generating activities or sectors.

107. Poor households in the area are eligible for professional training through the National Fund for Employment. DOLISA usually takes part in process of decision making on the province’s planning and development orientation and contributes budget requirements (for training programs) and statistics for the SEDPs.

Business and Tourism Associations

108. In Ben Cau town, there are two types of enterprises (private enterprises and limited liability companies). The overall trend, as expressed by the Business Association, is a shift from industrial-based enterprises to trade and services, and this trend is expected to be followed for the next five to ten years. There are no business ventures between the private and public sectors.

109. There is no tourism authority per se in Moc Bai and tourism as a sector is not well developed. While there are some tourist attractions in the area such as Ba Den Mountain and Tay Ninh Holy Church (established by the Catholics who fled from the north in the 1950s), few tourist stay overnight in the town and the town has few hotels and guesthouses. Tourists usually make a day trip to Ben Cau town and stay overnight in Ho Chi Minh City.

Ward and Commune Leaders

110. The leaders consulted that while the infrastructure of Moc Bai town is better than surrounding communes and villages it is still insufficient for a growing town with a special trade zone that requires infrastructure and services to encourage investment which will in turn provide much needed employment opportunities.

111. There are large differences in education levels and poverty rates between the town and surrounding area, these need to be addressed and disparities reduced by improving infrastructure beyond the immediate urban area according to the master plan.

112. A number of requisite projects have not been implemented and there has been no special program for development implemented in area adjacent to the urban core.

Committee on Ethnic Minorities and Mountainous Areas

113. According to Committee for Ethnic Minority and Mountainous Areas (CEMMA) Ben Cau town and surrounding communes are predominantly comprised of Kinh ethnic group with a few households of Hoa, Cham and Khmer ethnic groups. The different ethnic groups have lived together harmoniously for many years. As there are so few ethnic minority people, there are no special festivals or different customs from the Kinh.


114. CEMMA seldom takes part in the town decision-making or participates in the preparation of SEDPs etc due to the very few ethnic minority people that live there and the fact there are no special requirements to be addressed.

Notes of Participatory Workshop Date: 20 October 2011 Venue: Meeting Hall of Moc Bai PPC Participants:

Highlights:

Objectives of the Workshop

To present and disclose the following:

- Component’ objectives; - Description of components (locations, sites, design, cost estimates); - Environmental procedures of the ADB and the Government of Viet Nam ; - Environmental categories of components per ADB and Government of Viet

Nam policies, and; - Environmental and social issues/concerns relative to component location

and design.

To obtain feedback from participants, particularly on:

- Environmental impacts of the subproject/component ; - Proposed mitigation measures; and - Their opinion on the proposed subproject/component.

Feedback from Participants

In general, participants welcomed the proposed design for the subproject/subcomponent, which they deemed as necessary to improve quality of life of local people.

Description of Issue Raised

By Whom? Reference in IEE/CEP Required Follow-up

Actions?

Dust and means of transport during construction affect rural residents

Local residents Risks on health or safety of residents or workers

Dust should be reduced during construction, it is required to carefully drive to ensure safety for local residents, especially pupils.

Disruption of agricultural production during construction

Local residents Income loss Keep access roads to the fields.

Impediments to movements of local people and freight transportation

Local residents Difficult access to service areas

Proper arrangement for civil works. Construct temporary roads for local people.


APPENDIX C: GRM COMPLAINT FORM

Grievance Redress Mechanism – Complaint Recording Form PMU Staff Responsible: (name and role)

Date: (of this record)

Date of Complaint:

Date Resolution Required by (15 days from initial complaint):

Complaint Made by: (Name & Contact Details)

Method of Complaint: (direct to PMU, via Contractor, Via Commune People’s Council)

Details of Complaint: (issues, actions taken so far, when did it start – all details needed)

PMU Actions: (Next steps for PMU to resolve the issue or to move complaint to next level)

Follow Up Actions Needed and Date: (PMU to follow up on resolution if needed, e.g. check contractor actions)


APPENDIX D: PARTICULAR CONDITIONS (FOR BIDDING DOCUMENTS)

The following clauses shall be added to the Bidding Document, Section 8 Particular Conditions in relation to the Environmental Safeguards for the sub-project component:

1. The contractor will undertake to develop and submit to the PMU for approval, a Site-Specific environmental management plan with the following management sub-plans:

a) Construction worker camp management (if a camp is planned) b) Construction drainage; c) Erosion; d) Noise and Dust; e) Borrow Site & Spoil Disposal; f) Solid and Liquid Waste Disposal; g) Construction & Urban Traffic; h) Utility and Power Disruption; i) Community and Occupational Health and Safety; j) Tree and Vegetation Removal and Site Restoration; k) Construction Materials Acquisition, Transport, & Storage, l) Cultural Sites and Chance finds; m) Surface Water Protection; n) Emergency Response Procedures; and o) Site clean up

2. The management sub-plans will be sufficiently detailed as to allow a clear understand of the approach the contractor will take to mitigate environmental impacts during construction. The contractor will adhere to the management sub-plans at all times unless prior agreement has been given by the PMU under extenuating circumstances.

3. The Contractor will include in his response to this bid document, a signed commitment to a) Understand and b) Comply with IFC Environmental Health and Safety guidelines (2007).

4. The Contractor will commit to enabling the independent Environmental Monitoring Consultant (EMC) and the PMU full access to all information and data required in order that the Environmental Management Plan can be fully monitored.