Contents High cout ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK Ê GUJARAT RESILIENT CITIES PARTNERSHIP: AHMEDABAD CITY RESILIENCE PROJECT (G-ACRP) 2022 Prepared by AHMEDABAD MUNICIPAL CORPORATION AND GUJARAT URBAN DEVELOPMENT MISSION ESMF for G-ACRP, 2022 Contents Table of Contents SUMMARY 1 CHAPTER 1. INTRODUCTION TO THE PROJECT................................................................ 1 1.1 Project Description ........................................................................................... 1 1.2 Proposed Project Components .......................................................................... 1 1.3 Purpose of Environmental and Social Management Framework (ESMF) ............. 1 1.4 Methodology Adopted for ESMF Preparation .................................................... 2 1.5 Structure of the Report ..................................................................................... 3 CHAPTER 2. SUMMARY OF BASELINE ENVIRONMENTAL AND SOCIAL CHARACTERISTICS OF AHMEDABAD REGION ........................................................................... 5 CHAPTER 3. POLICY, LEGAL AND REGULATORY FRAMEWORK ...................................... 25 3.1 Environmental and Social Laws/ Regulations Applicable for G-ACRP ................ 25 3.1.1 National Regulations ............................................................................................ 25 3.1.1.1 Technical Guidelines on Sewerage and Drainage at National Level .................................... 26 3.1.2 State-Level Regulations ........................................................................................ 27 3.1.3 The World Bank’s Environmental & Social Standards (ESS) .................................... 28 CHAPTER 4. ASSESSMENT OF PROBABLE IMPACTS DUE TO SUB-PROJECTS ................... 40 4.1 Sub-projects Typology ..................................................................................... 40 4.2 Environmental and Social Risks and Impacts ................................................... 41 4.2.1 Environmental and Social Risks and Impacts in Local Area ..................................... 42 4.2.2 Regional Environmental and Social Risks and Impacts ........................................... 43 4.3 Impact Assessment Methodology ................................................................... 43 4.3.1 Magnitude and Duration of Impacts ..................................................................... 43 4.3.2 Sensitivity of Receptor .......................................................................................... 44 4.3.3 Significance of the impact ..................................................................................... 44 4.3.4 Potential Key Environmental and Social Risks and Impacts .................................... 45 CHAPTER 5. ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK .................. 62 5.1 ESMF Adoption Framework ............................................................................. 62 5.2 Sub-projects Identification .............................................................................. 65 5.2.1 Initial Environmental and Social Examination (IESE) during Sub-project Identification 65 5.2.2 Categorization of the sub-projects ........................................................................ 66 5.3 Sub-project Preparation .................................................................................. 69 ESMF for G-ACRP, 2022 Contents 5.3.1 Preparation of Terms of Reference for Environmental Assessment ......................... 69 5.3.2 Environmental and Social Impact Assessment (ESIA) ............................................. 69 5.3.3 Environmental and Social Management Plan (ESMP) ............................................ 70 5.3.4 Cost for Mitigation Measures including Monitoring Plan ....................................... 71 5.3.5 Proposed Institutional Mechanism and Reporting Requirements for Sub-projects .. 71 5.4 Sub-project Implementation ........................................................................... 72 5.4.1 Incorporating ESMP into Contract Documents ....................................................... 72 5.4.2 Onsite implementation of ESMP ........................................................................... 73 5.5 Monitoring and Evaluation .............................................................................. 73 5.5.1 Sub-Project Monitoring ........................................................................................ 73 5.5.2 Construction Supervision and Quality Control ........................................................ 74 5.5.3 Annual Environmental and Social Audit................................................................. 74 5.6 Public Consultation and Stakeholder Participation .......................................... 75 5.6.1 Public Disclosure .................................................................................................. 75 5.7 ESMF and Technical Assistance (TA) activities .................................................. 75 5.8 Institutional Responsibilities across Sub-project Cycle ..................................... 76 5.9 Conclusion ...................................................................................................... 77 5.9.1 Risk–wise Procedures Matrix ................................................................................ 77 5.10 Addressing concerns of disadvantaged or vulnerable individuals or groups ..... 79 5.11 Linkage to the ESCP ......................................................................................... 79 5.12 Updating of ESMF ........................................................................................... 80 CHAPTER 6. PROPOSED INSTITUTIONAL FRAMEWORK AND BUDGET ........................... 81 6.1 Proposed Institutional Framework .................................................................. 81 6.2 Proposed Institutional Framework for E&S Management ................................ 81 6.2.1 Overview of Proposed Units to manage E&S aspects at Various Levels ................... 82 6.2.2 Monitoring and Reporting .................................................................................... 83 6.2.3 Reporting Formats................................................................................................ 86 6.2.4 E&S Information System ....................................................................................... 86 6.3 Capacity Building ............................................................................................ 87 6.4 Budget for ESMF Implementation ................................................................... 89 CHAPTER 7. STAKEHOLDER ENGAGEMENT, GRIEVANCE REDRESSAL MECHANISM, INFORMATION DISCLOSURE ..................................................................... 93 7.1 Stakeholder Consultation ................................................................................ 93 7.2 National Legal & Regulatory and WB ESS 10 requirements .............................. 93 7.2.1 Stakeholders to be Consulted during Sub-project Preparation ................................ 94 7.3 Grievance Redress Mechanism ........................................................................ 95 ESMF for G-ACRP, 2022 Contents 7.4 Information Disclosure.................................................................................... 97 7.4.1 Procedure for Information Disclosure .................................................................... 97 7.4.2 Information to be disclosed .................................................................................. 98 7.5 Status of Consultations and Disclosure of this ESMF ........................................ 99 7.6 Conclusion .................................................................................................... 101 Note: This document is approved vide resolution number: 136 dated 21/06/2022 by Municipal commissioner, Ahmedabad Municipal Corporation ESMF for G-ACRP, 2022 Contents List of Tables Table 1: World Bank’s Environmental and Social Standards, Gaps vs National Systems, Gap filling measures ................................................................................................................................................ 29 Table 2: Potential Sub-project Components and Activities............................................................................. 40 Table 3: Aspects for Determining the Magnitude of Impacts ......................................................................... 44 Table 4: Criteria for Determining Sensitivity .................................................................................................. 44 Table 5: Assessment of Significance of Negative and Positive Impacts .......................................................... 44 Table 6: Initial Sub-projects ........................................................................................................................... 45 Table 7: Potential key environmental and social risks and impacts for sub-projects typologies ..................... 45 Table 8: Summary of Risks and Impacts and their Significance before and after Mitigation........................... 49 Table 9: Environmental and Social Risks and Impact Mitigation Plan ............................................................. 51 Table 10: List of Non-permissible Activities under G- ACRP............................................................................ 65 Table 11: Sensitive Environmental and Social Components ........................................................................... 67 Table 12: Environmental and Social Categorization of Projects ...................................................................... 67 Table 13: Indicative Environmental and Social risk Category of Sub-projects Types ....................................... 68 Table 14: Phase wise Procedures for different Risk categories of Projects ..................................................... 77 Table 15: Sub-project Monitoring schedule ................................................................................................... 84 Table 16: Overall Project Monitoring Parameters and Schedule .................................................................... 85 Table 17: Outline of the Proposed Capacity Building Program on G-ACRP (2022 – 2027) ............................... 87 Table 18: Proposed Budget for ESMF Implementation ................................................................................... 90 Table 19: Details of Stakeholder Consultations required on Environmental and Social Aspects ..................... 94 Table 20: Information Disclosure Matrix ........................................................................................................ 98 List of Figures Figure 1: Methodology adopted for ESMF Preparation .................................................................................... 3 Figure 2: Geographical Location of Ahmedabad ............................................................................................... 5 Figure 3: Evolution of the City of Ahmedabad .................................................................................................. 6 Figure 4: Administrative Divisions of Ahmedabad City ..................................................................................... 7 Figure 5: Physiography and Terrain ................................................................................................................. 8 Figure 6: Landuse of Ahmedabad City ............................................................................................................ 10 Figure 7: Sabarmati Basin .............................................................................................................................. 10 Figure 8: Hydrology........................................................................................................................................ 11 Figure 9: Expected Improvement in Discharge of Treated Sewage due to the Project .................................... 24 Figure 10: ESMF Adoption Framework ........................................................................................................... 64 Figure 11: E&S Requirements during Sub-project Cycle ................................................................................. 76 Figure 12: Proposed Institutional Framework for E&S Management ............................................................. 81 ESMF for G-ACRP, 2022 Contents List of Abbreviations Abbreviation Expansion Abbreviation Expansion ACRP Ahmedabad City Resilience Project IESE Initial Environmental and Social AMASR Ancient Monuments and Archaeological Examination Sites and Remains Act IFC International Finance Corporation AMC Ahmedabad Municipal Corporation IPF Investment Project financing APD Assistant Project Director IUCN International Union for Conservation of ASI Archeological Survey of India Nature BMC Biodiversity Management Committee LULC Land use and Land Classification BOD Biological Oxygen Demand M&E Monitoring and Evaluation BOQ Bill of Quantities MoEFCC Ministry of Environment, Forests and BP Bank Procedures Climate Change BPL Below Poverty Line NCB National Competitive Bidding C&D Construction and Demolition NDZ No Development Zone CBD Convention on Biological Diversity NEP National Environmental Policy CBO Community-Based Organization NGO Non-Governmental Organization CC Climate Change NMA National Monuments Authority CETP Common Effluent Treatment Plant NOC No Objection Certificate CHMF Cultural Heritage Management Framework NPDM National Policy on Disaster Management CHMP Cultural Heritage Management Plan O&M Operations and Maintenance CMS Conservation of Migratory Species OD Operational Directives COD Chemical Oxygen Demand OHS Occupational Health and Safety CPCB Central Pollution Control Board OP Operational Policies CRZ Coastal Regulation Zone PAF Project Affected Family DPR Detailed Project Report PAP Project Affected Person DTP Directorate of Town Planning PD Project Director EA Environmental Assessment PDO Project Development Outcome EAP Externally Aided Project PIU Project Implementation Agency ECoP Environmental Codes of Practice PMC Project Management Consultant EE Environmental Engineer POP Persistent Organic Pollutants EHS Environmental Health and Safety PPP Public-Private Partnership ESIA Environmental and Social Impact PWD Public Works Department Assessment QA Quality Assurance ESMF Environmental Management Framework RAP Resettlement Action Plan ESMP Environmental and Social Management RPF Resettlement Planning Framework Plan SBM Swachh Bharat Mission ESA Environmentally Sensitive Areas SDGs Sustainable Development Goals SUDU Sustainable Urban Development Unit SEC Sensitive Environmental Components STP Sewage Treatment Plant SHC Stakeholder Consultations ESF Environmental and Social Framework STP Sewage Treatment Plant ESMF Environmental and Social Management SUP Single Use Plastics Framework SW Solid Waste ESS Environmental and Social Standards SWD Storm Water Drains ESZ Eco-sensitive Zone SWM Solid Waste Management FGD Focus Group Discussions TA Technical Assistance GDP Gross Domestic Product TDS Total Dissolved Solids GHG Greenhouse Gas TOC Total Organic Carbon GIIP Good International Industry Practice ToR Terms of Reference GIS Geographic Information System TPD Tons per Day GoI Government of India TSDF Treatment Storage and Disposal Facility GRC Grievance Redressal Committee (for Hazardous Wastes) GRCP Gujarat Resilient Cities Partnership TSS Total Suspended Solids GPCB Gujarat Pollution Control Board TTP Tertiary Treatment Plant GUDM Gujarat Urban Development Mission ULB Urban Local Body Ha Hectares VEC Valued Environmental Components HH Households WB The World Bank ICB International Competitive Bidding WTP Water Treatment Plant IEC Information Education Communication ESMF for G-ACRP, 2022 Executive Summary E-1 GUJARAT RESILIENT CITIES PARTNERSHIP: AHMEDABAD CITY RESILIENCE PROJECT (G-ACRP) SUMMARY A. Project Overview The Government of Gujarat (GoG) has sought assistance from the International Bank for Reconstruction and Development (IBRD, also commonly known, and referred hereafter, as the “World Bank�) for Gujarat Resilient Cities Partnership: Ahmedabad City Resilience Project (ACRP) 1. The Project Development Objective of G-ACRP is to develop resilient and sustainable urban service delivery and financial systems in Ahmedabad. It also aims to support the Gujarat Urban Development Mission (GUDM), a State-level functionary in urban service delivery across the towns and cities of Gujarat to improve their institutional capacities to better plan, manage urban services. The proposed Project will consist of three main components: Component 1: Strengthening Ahmedabad Municipal Corporation’s (AMC) financial systems and performance Component 2: Improving urban services in Ahmedabad: by providing comprehensive support to AMC in improving the quality, efficiency, sustainability, and resilience of select urban services – waste- water management services (sewerage only2), storm water drainage (prioritized in terms of significant infrastructure gaps, poor service levels, and negative environmental and social externalities). Component 3: Developing institutional systems and capacities at AMC and GUDM for state wide capacity building. The project will ensure better environmental and health condition in Ahmedabad and the surrounding region, by upgrading the Sewage Treatment Plants (STPs), related infrastructure and networks to treat the sewage generated in the city to stringent standards; improving drainage networks, canals and lakes and ensuring improved service delivery and management systems. The project will benefit from reduced greenhouse gas emissions due to upgraded treatment systems, and reduced pollution loads in Sabarmati, Khari rivers, canals, lakes and the region, due to stringent standards adopted for treatment of waste water. The World Bank Environmental and Social Framework is applicable to all projects supported by the Bank through Investment Project Financing (IPF) including G-ACRP, in order to achieve environmental and social outcomes consistent with the Environmental and Social Standards (ESSs). Based on this, at this stage, project has been categorised as substantial based on both social and environmental risks and impacts, and an Environmental and Social Management Framework (ESMF) has been prepared for managing the environmental and social risks and impacts of the project and Environmental and Social Impact Assessments have been conducted for the sub-projects which will be implemented during the first two years. The ESMF will be followed also for the rest of the sub-projects and technical assistance under the project. A Cultural Heritage Management Framework, Biodiversity Management Framework, Resettlement Policy Framework and Labour Management Procedures are also being prepared for the Project. B. Environmental and Social Baseline The sub-projects under G-ACRP would be implemented in the metropolitan city of Ahmedabad in Gujarat State. The exact locations of many of the specific project investment activities are not known 1 https://projects.worldbank.org/en/projects-operations/project-detail/P175728 2 Industrial Effluent Management, and Individual or Common Effluent Treatment Plants will not be part of the project ESMF for G-ACRP, 2022 Executive Summary E-2 at this stage. The sub-projects would include major civil works such as the construction of Sewage Treatment Plants, and laying of sewage and drainage networks initially and then Tertiary Treatment Plants, canal redevelopment, lake rejuvenation, and other supportive infrastructure. River Sabarmati flows bifurcates the city and many man-made lakes and canals are present in the city. Most of these are not critical or natural habitats as these are non-perennial, and diffuse pollution due to various human activities has over the years substantially modified their primary ecological functions and species composition. Industrial and waste pollution has impacted the rivers and lakes over the years. City suffers from overall diffused pollution due to its industrial expansion. Sewage treatment is suboptimal owing to old inefficient infrastructure, absence of full coverage of the city. The city has many cultural heritage sites, being the UNESCO World Heritage City. . Feasibility Reports for Initial sub-projects which will be procured through Design - Build – Operate – Transfer (DBOT) format including (i) Rehabilitation of 240 MLD STP at Vasna (Moderate Risk), (ii) Construction of new STP (375 MLD) in place of existing STP at Vasna 126 MLD (Substantial Risk), and (iii) Rehabilitation of 180 MLD STP at Pirana (Moderate Risk), are under preparation. ESIAs are being prepared for these investments, which will be updated at Design Stage after the DBOT contractor finalises the design during implementation stage. Detailed baseline environment and social profile of the Project area have been compiled and analysed in the ESMF and for the initial set of sub-projects as part of ESIA. These will be compiled and presented in all the sub-project ESIAs under the project as well. A rapid assessment was conducted to understand the environmental and social risk and impacts due to proposed upgradation of major canals namely, Kharicut Canal, Chandrabhaga Nalla, and 4 representative lakes (which were village lakes earlier) namely, Ramo Bandh, Isanpur, Shilaj, and Bhadaj Talavs (lakes). The assessment indicated encroachments: Ramol Bandh and Isanpur Gaam Talav - 50 and 100 residential households respectively, while Bhadaj Gaam Talav has one temporary commercial. No encroachments are noticed at the Shilaj Gaam Talav. Similarly in respect of Chandrabhaga nalla squatters and encroachers at the right of way width near Bakri mandi at Ranip for about 50 households are noticed. In the case of the Kharicut canal, encroachments are noticed around the Odhav area of the canal. The findings of the assessment provide initial insights for possible impacts and mitigation requirements and these have been included in this ESMF and RPF. The detailed assessment shall be carried out as part of sub-projects screening and ESIA and mitigation instruments shall be prepared including RAP. The Rapid assessment also suggested community health and safety concerns in respect of drainage and lake/canal development subprojects which will be further studied during respective ESIA preparations. C. Applicable Regulations and Guidance ▪ International, National and State regulations MoEFCC is the apex administrative body in the country for regulating and ensuring environmental protection and lays down the legal and regulatory framework for the same. Today, MoEFCC and the Central and State Pollution Control Boards (CPCB and SPCBs) together form the regulatory bodies; while National Green Tribunal is tasked with providing an effective and expeditious remedy in cases relating to environmental protection, conservation of forests, and other natural resources and enforcement of any legal right relating to the environment. Some of the important legislations at the National Level for environment protection which will apply to G-ACRP includes National Environment Policy, 2006, the Environment Protection (Act) 1986 and The Environmental Protection Rules, various Acts including The Water (Prevention and Control of Pollution) Act, 1974 and The Water Cess Act 1977, The Air (Prevention and Control of Pollution) Act 1981, and others related to Noise Pollution, Wetlands Conservation, Biodiversity, Storage of Hazardous Chemicals, Batteries, Waste Management (including Solid, Hazardous, Plastics, E-Waste), motor vehicle ESMF for G-ACRP, 2022 Executive Summary E-3 movement, and various Labour Laws. In addition, Central Government agencies have issued various guidelines for various aspects and associated aspects of sewerage and drainage projects including discharge standards. Dam Safety Bill of December 2021 of the Government of India will be applicable to Vasna Barrage. State also has various regulations and policies which may apply to the project including Sanitation and Treated water Reuse Policy, Municipal Corporations Act, Infrastructure Development Act, Irrigation and Drainage Act and Rules, Water supply and Sewerage Board Act, Acts on Felling of Trees Town Planning and Urban Development, Fire and Life Safety, Disaster Management, etc. International environmental treaties to which India is a Party, such as Convention on Biological Diversity, Ramsar; Convention on Wetlands, Bonn; Convention on Migratory Species, UN Framework Convention on Climate Change and its Kyoto Protocol may apply to the project. RFCTLARR Act 2013, Minimum Wages Act 1948, Child Labour (Prohibition & Regulation) Act 1986, Sexual Harassment of Women at the Work Place (Prevention, Prohibition and Redressal) Act 2013, Rights of Persons with Disabilities Act, 2016, Right to Information Act 2005 are some of the key legislations relevant for the Project. Besides, many of the labor-related laws that require adherence during construction would apply to the project as well such as the Employees Compensation Act 1923 (for compensation in case of injury, disease, or death arising out of and during employment); Payment of Gratuity Act (on the satisfaction of certain conditions on separation if an employee has completed 5 years’ service; Maternity Benefit Act 1961 (provides for leave and some other benefits to women employees in case of confinement or miscarriage, etc.); Payment of Wages Act 1936 (lays down the mode, manner and by what date the wages are to be paid, what deductions can be made from the wages of the workers); Equal Remuneration Act 1976 (provides for payment of equal wages for work of equal nature to male and female workers and for not making discrimination against Female employees in the matters of transfers, training, and promotions, etc.). Child Labour (Prohibition & Regulation) Act 1986 (prohibits employment of children below 14 years of age in certain occupations and processes and provides for the regulation of employment of children in all other occupations and processes. Employment of Child Labour is prohibited in the Building and Construction Industry. Bonded Labour System (Abolition) Act, 1976 (The Act provides for the abolition of bonded labor system to prevent the economic and physical exploitation of weaker sections of society. Bonded labor covers all forms of forced labor, including that arising out of a loan, debt, or advance). These important environmental and social legislations have been briefly explained in Chapter 3, with a description of its relevance in this project, availability of technical guidelines for its implementation, and institutional responsibility. G-ACRP will also conform to various international conventions, treaties, and instruments, to which India is a signatory to, such as those on cultural heritage, elimination of discrimination against women (CEDAW), crime prevention, and criminal justice measures to eliminate violence against women, etc. ▪ WB ESF & ESSs Applicable to this Project The World Bank’s ESF and ESSs are used to identify, avoid, and mitigate the potential negative environmental and social risks and impacts associated with projects funded by the Bank and enhance the effectiveness of the positive impacts. ESSs 1-6, 8, and 10 apply to the Project. D. Environmental and Social Risk Classification ESMF for G-ACRP, 2022 Executive Summary E-4 This project has been classified as “substantial� for environmental and social risks and impacts, and high risk sub-projects are excluded from being taken up under the project. E&S Assessment of the proposed sub-projects reveals that most of the likely adverse impacts could be minimized or eliminated by following mitigation hierarchy: avoiding risks through good design and following regulations, guidelines; preparing and adopting standard mitigation measures, improved capacities, and good management. Also, there is ample scope to enhance some of the beneficial impacts to be generated from the proposed project. The ESMF prepared for the G-ACRP acknowledges these impacts and integrates measures for assessing, mitigating/managing these during pre-planning, planning, implementation including construction, Operation and Maintenance (O&M) and handover. E. The ESMF Process The ESMF has been prepared based on environmental and social assessments, and consultations. The steps followed in developing the ESMF are provided in Figure A below: Figure A: Methodology for Preparation of ESMF for G- ACRP This document is intended to serve as the ESMF for the G-ACRP. It has been developed for the project to guide the project implementers and other key stakeholders in assessing and addressing the environmental and social risks arising from the project. As per the guiding principles of the ESMF, all projects funded by the World Bank require the borrowers to – (a) achieve compliance with all applicable national, state, and local laws and regulations related to environmental and social matters; and (b) meet the requirements of the ESSs outlined in the ESF. The ESMF is the key E&S risk management tool used by borrowers to identify, assess, mitigate and report on project E&S risks, impacts, and mitigation measures and the effectiveness of their implementation. The ESMF has been prepared with an objective to manage the environmental and social impacts through appropriate measures during the planning, design, construction, and operation of various sub-projects and linked activities/associated facilities of G-ACRP. The framework identifies the level of due diligence required for all categories of sub-projects and provides specific guidance on the policies and procedures to be followed for environmental and social assessment, along with roles and responsibilities of the implementing agencies to ensure effective environmental and social management. This ESMF aims to ensure the following: ESMF for G-ACRP, 2022 Executive Summary E-5 • Integration of environmental and social aspects into the decision-making process at all stages of the entire G-ACRP project and all its sub-projects; including planning, design, implementation, and work closeout, operation, and maintenance (O&M) of sub-projects by identifying, avoiding, and/or minimizing adverse environmental and social impacts early-on in the project cycle, • Enhancement of positive/sustainable environmental and social outcomes through sensitive planning, design, and implementation of sub-projects, • Avoidance or minimization of risks and impacts on cultural properties and natural habitats and/or other direct/indirect impacts through careful planning and environmental and social mitigation measures, • Ensure ongoing consultations with stakeholders throughout the project, the relevant outcomes of which will inform the project design/activities/assessments/mitigation measures. As the exact project locations of some of the interventions are not yet known, to integrate environmental and social considerations in sub-projects and its effective management, the borrower has prepared an ESMF. The ESMF describes the existing environmental and social sensitivities of Ahmedabad, potential risks and impacts due to proposed development, suggested improvements to existing systems, and interventions for better environmental and social outcomes of proposed facilities, and mitigation hierarchy, and monitoring arrangements. Long-term risks and impacts are avoided through exclusions and screening. The ESMF includes guidance for interventions near habitats and heritage areas, assessments of cumulative impacts, in addition to indicative Environmental and Social Management Plan (ESMP) for various types of activities3, it also guides requirements to ensure resilience, resource efficiency, and reduce emissions. As per World Bank Policies, ESMF applies to the entire project; also to linked activities or associated facilities. All sub-projects and linked/associated facilities shall also be categorized, impacts identified and mitigation measures, and monitoring planned and implemented. Environmental Codes of Practices (ECoPs) and guidance to follow World Bank Group EHS General and Industry-specific Guidelines (for Water, and Sanitation). It also includes guidance from World Health Organisation and the World Bank on COVID 19 waste management, health care, and labour management during this pandemic period. The ESMF guides screening, assessing, planning, and implementing mitigation measures; supervision and monitoring mechanisms; and disclosure requirements. Proposed ESF support, training/capacity building activities for ESMF implementation will be supported through Component 1 of G-ACRP at an estimated cost of INR 0.2 Crores (USD 0.027 Million), for the Project period. The ESMF budget does not include Resettlement costs of any nature. These costs shall be borne from the counterpart funding, details of which are further discussed in RPF. The project-specific ESIAs have been prepared for sub-projects which will be taken up initially during the first two years (30 percent of Project Cost), such as upgradation of existing Sewage Treatment Plants and networks, construction of new treatment plants, and upgradation of sewage/drainage networks. Procedure for Environmental and Social Management Each sub-projects under the project shall be screened to determine the level of environmental and social impacts and management plans that would be needed. This will be done to ascertain the level of environmental and/or social impacts and risks due to sub-projects that require mitigation measures as well as the appropriate sub-project categorization. Sub-projects with no material E&S impacts will be required to follow standard environmental and social mitigation measures while those with risks 3 The sub-projects proposed are of different types ranging from upgradation and construction of Sewage treatment plants and tertiary treatment facilities, sewerage network improvements, storm water drainage, improving Lakes and canals. Indicative ESMPs for all types of sub-projects known at this stage are provided in Guidance Manual as part of ANNEXURES. This will enable implementing agencies / contractors to update and use these in ESIAs and follow during implementation. ESMF for G-ACRP, 2022 Executive Summary E-6 and potential impacts shall be subjected to a more in-depth level of environmental and social assessment which will have to be approved by the implementing agencies and reviewed and cleared by the Bank before the commencement of implementation. Figure B: ESMF Process F. Stakeholder and Citizen Engagement Consultations were conducted with concerned stakeholders during the preparation of ESMF. Residents/ communities especially those near the Sabarmati River, inundated areas and canals/ water bodies, and existing/ proposed STP or drainage/ sewerage lines were consulted. Community groups, NGOs, industries, engineers/ employees/ contractors of sewerage and drainage works in Ahmedabad were also consulted. Most of the consultations were virtual given the COVID 19 related restrictions. Stakeholders categories include –(i) Project Affected Parties: residents, taxpayers who are directly affected by poor drainage in the city, (ii) Other Interested Parties: Resident Welfare Associations, , elected representatives, NGOs, and others who work with communities, (iii) Disadvantaged or vulnerable and identified individuals or groups: includes individual/ group that may be excluded from/ unable to participate fully in the mainstream consultation process and as such may require specific measures and/ or assistance to do so like urban poor who live as squatters without formal title of their land. A summary of the key points raised during the stakeholders’ consultations is given below and full details of various discussions with stakeholders are presented in Annexure C (Annexures) of this Report. Project Affected People: Regular clogging of sewer lines, Mixing of water with sewer, Overflow of drain water during the rainy season, People staying close to STP raised concerns about the foul odor, ESMF for G-ACRP, 2022 Executive Summary E-7 People living in villages downstream of Sabarmati brought up concerns about the poor quality of water of the river, Health issues (odour, air quality) for certain people living near CETP and STP. Other Interested Parties: ESMF also benefited from the stakeholder inputs from other Govt institutions relevant to the project, elected members, contractors currently engaged with AMC, and NGOs . Relevant inputs were used to refine the process of preparation of ESMF, such as specific considerations for works near heritage areas, minimizing temporary impacts during construction works, etc. Others: Vulnerable Groups: Stakeholder inputs from vulnerable groups include - Issue of mixing sewage water with drinking water, inadequate service delivery, land ownership issues, air pollution due to proximity to industrial areas, no clear understanding of temporary livelihood disturbances, and access issues during construction works. To facilitate ongoing consultations during the lifecycle of the project a SEP is prepared and disclosed. Relevant outcomes of the consultations will inform the design/preparation of project activities/assessments/ mitigation instruments throughout the project lifecycle. The sub-project environment and social documents will be consulted as disclosed as per ESS10. Special attention will be paid to consultation with vulnerable groups to address their concerns and ensure that they can access project’s benefits following the stakeholder engagement process described in the SEP. G. Gender More than 95% of the contract labor is expected to be men, and women’s participation in contract labor is going to be very low. Data from the gender assessment shows that informal women workers lack the information, networks, and financing to gain the required skill sets for accessing better paying jobs and achieving specialization. In particular, jobs that are traditionally considered to be male dominated; (i.e., masons, heavy capacity vehicle drivers, foreman, rod binder, etc.) are found to be completely inaccessible by women informal workers, evidently causing occupational segregation. The project will address this challenge by developing a unified modular (on-the-job) training delivery system at the AMC level, for informal women workers. This system will roll-out modular trainings over a period of 3-6 months on AMC project sites and target informal women workers who are somewhat familiar with the job role but lack specialized skillsets and/or certification (f.i. mason helpers, loaders). A platform will be established to leverage state’s skill development programs and enable more coverage. The SEA/SH risks of the project has been rated as “low�. The PIU will ensure that contractors maintain harmonious relations with local communities and that laborers/workers adhere to the Code of conduct (CoC). The CoC includes sanctions for non-compliance, including non-compliance with specific policies related to gender-based violence, sexual exploitation, and sexual harassment (e.g., termination). Further, during the project implementation, the following measures will be taken up by the contractor – setting up separate, safe, and easily accessible facilities for women and men in the place of work and the labor camps, displaying signs that the project site is an area where SEA/SH is prohibited, Codes of Conduct are clearly understood and signed by those with a physical presence at the project site, training the project staff on the behavior obligations under the CoCs and disseminating CoCs (including visual illustrations) and continually discuss with employees and local communities. H. Institutional Arrangements for Environment and Social Management Implementation arrangements for the infrastructure and service development component of G- ACRP are mainstreamed into the existing City Authority, the Ahmedabad Municipal Corporation to ensure the best management during the life of the created assets and services. The program activities will be overseen by PIUs established at AMC and GUDM. These will be headed by Project Director and supported by Assistant Project Directors and/or Managers for each type of intervention; such as (i) ESMF for G-ACRP, 2022 Executive Summary E-8 wastewater, drainage, and other general interventions including capacity building, and support studies under AMC sub-projects; and (ii) capacity building activities/ TAs/ studies under GUDM. Each PIU will have four (4) ESF specialists, to coordinate actions on ESSs. The Project Management Consultant (PMC) appointed by AMC will also have E&S experts who will coordinate and support ESF specialists of PIUs during the preparation, implementation, monitoring, and reporting of E&S aspects. PMC of AMC will also coordinate with GUDM for monitoring and reporting of their activities. AMC will collate details on project implementation, monitoring and reporting from GUDM with the help of PMC appointed by AMC; and report to the Bank as part of QPR, and missions. They will ensure that all records on E&S aspects are up to date and well maintained in hard and soft form. E&S Units of PIUs will be known as Sustainable Urban Development Units (SUDU), which could be a lighthouse on E&S aspects for all Urban Local Bodies (ULBs) in Gujarat and upscaled in the long run. The project level ESMF and RPF will be approved by the government. The Project Director is the designated officer for approving the mitigation plans including the ESMP and RAP, with recommendations from E&S specialists. Consultants who prepare E&S documents and deliver capacity building activities will have Environmental, OHS, Biodiversity, Heritage, R&R, Gender experts as required to prepare E&S mitigation/management measures and work with design consultants on integrating E&S aspects in design and supporting ESF specialists of PIUs to ensure that ESMPs and other aspects are incorporated in bid documents. This requirement will be incorporated in the ToR for consultants. Contractors who will implement sub-projects on site will have E&S experts and EHS Site officers to prepare, update ESMPs to reflect actual site/design aspects, to monitor, ensure, report, and maintain up-to-date documentation on the implementation of environmental and social aspects on site regularly. Construction Supervision and Quality Assurance (CSQA) will be ensured by the Project Management Consultant (PMC) who will supervise OHS in an integrated manner with civil work quality to ensure the best results, and monitor Life and Fire Safety on-site during all stages and report regularly to PIU. PIUs have the responsibility to review the sub-project ESF documents prepared by contractors and consultants. ESF documents should only be sent to WB for prior review after PIU’s good quality initial review and sign off. It is also suggested that PIU shares ESF documents with WB by mentioning specific areas in which they need clear guidance. Annual third party E&S Audit will be conducted to monitor compliance to ESMF and other ESF documents (including OHS) on-site and report with suggestive corrective actions in case of non – compliance. The World Bank will review and clear ESF documents for Substantial and Moderate Risk projects, while PIUs will clear Low Risk projects, monitor all sub-projects using the project Management Information System, provide implementation support, and support PIUs in providing trainings on ESF for long term benefits. The proposed institutional framework for E&S management under G-ACRP is in Figure C. ESMF for G-ACRP, 2022 Executive Summary E-9 Figure C: Proposed Institutional Framework for E&S Management under G- ACRP I. Capacity Building G-ACRP envisages capacity building for all agencies involved in the project including PIUs (including Line Departments, Local Bodies, Statutory Boards, Public Undertakings applicable or each sub- projects), and Potential Private Operators, PMCs, Consultants, and Contractors to ensure that the ESMF is effectively operationalized. This will be accomplished by organizing sensitization programs, workshops, and training programs, which will be coordinated and anchored through training institutions and experts. The training program is presented in the ESMF. J. Monitoring and Reporting Three types of monitoring and reporting are envisaged here including third-party, external, and internal. Internal monitoring is a continuous process undertaken by contractors E&S persons, OHS monitoring by PMC and PIU as part of construction supervision, E&S monitoring by SUDU, and third party will undertake annual independent E&S audit. Contractor’s E&S Experts and EHS specialists will monitor daily ESMP compliance on-site at the sub-projects level, and report weekly to the site engineer. The site engineer will submit this to PMC E&S experts who will verify every quarter or as required, and compile these to submit monthly monitoring reports to PIU. PIU also undertakes site visits to monitor once a month or as appropriate, and compile E&S reports over the quarter and submit to the Bank as part of the project’s Quarterly Project Monitoring Report (QPR) or as a standalone E&S quarterly monitoring report highlighting key issues, how issues were managed and any support required. ESMF for G-ACRP, 2022 Executive Summary E-10 The environment and social management instruments at the sub-projects level such as ESIA, and RAP guide the monitoring and evaluation parameters and describe the institutional arrangements to facilitate the ‘process’ and ‘progress’ monitoring. Designated E&S Specialists/experts at various levels shall be responsible for overseeing compliance of the sub-projects to Bank ESF, GoI regulations, and applicable ESMF guidelines. They shall also regularly review the timely implementation of environment provisions as per the ESMP. PIUs and the World Bank review and clear ESF documents. PIUs (with PMC support) will be guided by the Bank continuously on ESF implementation, will report to Bank on progress and issues quarterly through Quarterly Reports and also report to the Bank during its six-monthly supervision missions. Reporting formats shall be developed by PIUs to get progress and results data of the project from the field. This will also help in synchronizing and streamlining reporting requirements from the various work sites. These should be part of the Project Operations Manual. Detailed E&S Management Information System named Environmental and Social Management Information System (ESMIS) linking project details, scheduling, and documentation of the ESIA process, integration of E&S aspects in design, ESMP in bid documents, and ESMF implementation will support the project in the effective preparation and updating of ESF instruments, implementation, supervision, and monitoring. K. Grievance Redress Mechanisms AMC has a functional complaint system (CCRS, http://www.amccrs.com) which includes a web portal and a toll-free number. It records almost 40000-50000 complaints every month. Any complaint registered in the system is forwarded to respective zones for action. The CCRS is integrated with the Gujarat Government’s CM Helpline and any complaints received at CM Helpline are also recorded in the CCRS system. Grievances of PAPs will be first brought to the attention of the site office level of the PIU which shall be redressed within two weeks from the receipt of complaints. Grievances not redressed by the PIU staff (field level) will be brought to the Grievance Redress Committee (GRC) which shall redress the grievances within four weeks from the date of receiving the complaint at PIU. GRC shall be formed at a zonal level comprising of competent members, who can effectively contribute to grievance redressal. GRC team consists of Zonal Officer AMC, Env and Social staff of PIU, a local CBO/CSO representative. The main responsibilities of the GRC will be to (i) provide support to PAPs on problems arising from land/ property acquisition; (ii) record AP grievances, categorize, and prioritize grievances and resolve them; (iii) immediately inform the PMU of serious cases; and (iv) report to PAPs on developments regarding their grievances and decisions of the GRC and the PMU. Other than disputes relating to ownership rights under the court of law, GRC will review grievances involving all resettlement benefits, compensation, relocation, replacement cost, and other assistance; noise, traffic, odor, and other grievances related to the environment. Records will be kept of all grievances received including contact details of the complainant, the date the complaint was received, nature of the grievance, agreed corrective actions, and the date these were affected and outcome. The GRCs will continue to function during the life of the Project including the defects liability period. Cases not resolved at the GRC level would be brought for resolution by Commissioner, AMC. In the case at this level, the dispute is also not resolved, the aggrieved person may take recourse to the civil court and the decision of the Court will be binding on all parties. L. Consultation and Disclosure The ESMF has been prepared following the ESF, relevant International, National, and State Regulations and guidelines. Stakeholder consultations have been conducted at the city level to prepare this ESMF. A stand-alone Stakeholder Engagement Plan has been prepared for the Project. Copies of this ESMF, like other E&S instruments (such as ESIAs/ESMPs/Monthly, Quarterly, Annual Reports, etc) that would be prepared for this project and all its sub-projects will be disclosed and made available to the public by the PIUs. ESMF for G-ACRP, 2022 Executive Summary E-11 Once site-specific sub-projects activities are determined, screening and other E&S instruments such as ESIAs/ESMPs that would be prepared for sub-projects under the Project and similarly disclosed by PIUs as that of the ESMF, following stakeholder consultations. The Draft ESMF was disclosed both in English and Gujarati on the AMC and GUDM website for feedback from stakeholders on Feb 10, 2021, before the appraisal. This was further updated following the consultations held during Feb – March 2022. Sub-project-specific ESIA, ESMPs (for substantial risk subproject to be implemented under the project initially), were disclosed in English & summaries in Gujarati for consultations – hard copies in PIUs and the Zonal Offices of AMC, and soft copy on PIU websites. ESMF and ESIA for initial investment (substantial risk) were disclosed in the country on the website respectively at : https://ahmedabadcity.gov.in/portal/web?requestType=ApplicationRH&actionVal=viewAttachment &queryType=Select&screenId=2900003&AttachmentFileName=ESMF.pdf and https://ahmedabadcity.gov.in/portal/web?requestType=ApplicationRH&actionVal=viewAttachment &queryType=Select&screenId=2900003&AttachmentFileName=ESIA-126-MLD-STP.pdf and in-World Bank external website on Feb 10, 2022. Post disclosure consultations were carried out in Feb and March 2022. Public consultation was conducted June 2022 by AMC in Pandit Dindayal Upadhyaya Auditorium, Bodakdev, Ahmedabad. Invitations (in English and Gujarati) was circulated to various stakeholders such as elected representatives (Councillors), Mayor, Deputy Mayor, CSO, NGOs, Municipal Commissioner, Deputy Municipal Commissioner, heads of Committees and others. Notices were also published in the newspapers in both languages. The key concerns raised by stakeholders have been incorporated in the ESMF and ESIA for 375 MLD STP. The suggestions of the stakeholders by including monitoring of noise, sludge, air and water and its analysis for defining the baseline and mitigation measures. The project suggests improved management of all wastes and treated water quality to confirm with latest NGT suggested standards. Labour health and safety will be given high priority and appropriate measures to follow and monitor labour regulations have been suggested in the ESMP. There will be increased labour opportunities during implementation. M. ESMF Performance Indicators The key performance indicators to be monitored for successful implementation of ESMF will be the following: • The number of sub-projects for which preparation and Implementation of ESIAs / ESMP and (other instruments) were carried out in a time-bound manner and included in Bid Documents. To be reported as part of Quarterly Progress Reports to the Bank, and checked as part of third party E&S audit. The number of subprojects will be determined during the implementation stage of the project in line with the master planning for sewerage and drainage that is currently being prepared. • The number of all incidents (required under Systematic Incident Reporting Tool of the World Bank) during the construction phase. To be reported immediately upon occurrence to the Bank, Safeguard Corrective Action Plan (SCAP) prepared, and actions completed on time. • Status of compliances with regulatory requirements and clearances. To be reported as part of Quarterly Progress Reports to the Bank, and checked as part of third party E&S audit ESMF for G-ACRP, 2022 Executive Summary E-12 • The number of facilities with Improved (as compared to baseline) environmental performance and resource efficiency due to the project. To be reported as part of Quarterly Progress Reports on environmental and social aspects to the Bank, and checked as part of third party E&S audit • 80 percent of grievances were resolved within 30 days of registration. To be measured every quarter by PIUs and consolidated half-yearly for reporting to the Bank. • Number of RAPs fully implemented before initiation of civil works. To be measured annually by PIU N. 80 percent of the community is satisfied with improved service delivery. To be measured through annual beneficiary satisfaction survey. O. Conclusion This ESMF document for G-ACRP is the guidance document for the management of environmental and social aspects for all components of the project. This is a living document and shall be updated, if required, following the consultations, approval, and disclosure requirements of the World Bank. ESMF for G-ACRP, 2022 Introduction to the Project 1 CHAPTER 1. INTRODUCTION TO THE PROJECT 1.1 Project Description The Government of Gujarat (GoG) intends to utilize financial support from the World Bank (280m USD) for the Gujarat Resilient Cities Partnership: Ahmedabad City Resilience Project (G-ACRP)which aims to strengthen the institutional and service delivery systems for Urban Service Delivery and financial systems in the city of Ahmedabad and to strengthen the State institutional capacity for management of services in urban areas in Gujarat. The Project Development Objective of G-ACRP is to develop resilient and sustainable urban service delivery and financial systems in Ahmedabad. The key results areas targeted under this project include (i) resilient urban infrastructure and improved service levels for selected urban services4, (ii) improved financial systems and performance, and (iii) strengthened institutional capacity to better plan, deliver, and manage urban services. 1.2 Proposed Project Components The proposed Project will consist of three main components: Component 1: Strengthening Ahmedabad Municipal Corporation’s (AMC) financial systems and performance: This activity will provide technical support to AMC to address key constraints affecting its financial performance and capacity to deliver and sustain good quality services to a rapidly expanding urban population. The focus of this activity will be on strengthening AMC’s systems for long-term capital investment planning, financing and budgeting, generating municipal revenues, and leveraging land-based financing. Component 2: Improving urban services in Ahmedabad: This activity will provide comprehensive support to AMC in improving the quality, efficiency, sustainability, and resilience of select urban services – waste-water management services, storm water drainage (prioritized in terms of significant infrastructure gaps, poor service levels, and negative environmental & social externalities). This activity will be implemented by adopting a comprehensive service delivery approach in selected service sectors. Component 3: Developing institutional systems and capacities: This activity will focus on strengthening the overall institutional and governance frameworks for urban management, service delivery, and financing in Ahmedabad, and develop a platform to leverage AMC’s good practices to provide capacity-building support to other emerging cities of Gujarat. 1.3 Purpose of Environmental and Social Management Framework (ESMF) Ahmedabad city is unique in its geographic features (such as almost flat terrain, Sabarmati and Khari rivers draining the city and its region, presence of lakes), climatic conditions (hot-semi arid with less rainfall, scorching summers, and very cold winters), and environmental characteristics; and is prone to extreme events (such as floods and earthquake). It is highly industrialized, with a high-density population living hand in hand with a beautiful heritage. Water availability is less - mainly dependent on Narmada waters, while the demand for industrial effluent and wastewater management, sanitation, and waste management are increasing day by day. Today, with its status as a predicted megacity, upgrading and developing sustainable urban environmental infrastructure is very important for its people and environment. 4 Selected urban services include wastewater management, and storm water drainage ESMF for G-ACRP, 2022 Introduction to the Project 2 Since G-ACRP is supported under the Investment Project Financing (IPF) instrument of the World Bank, Environmental and Social Framework (ESF) and Environmental and Social Standards (ESSs) of the Bank apply to the project. The ESF defines an ESMF as “an instrument that examines the risks and impacts when a project consists of a program and/or series of sub-projects, and the risks and impacts cannot be determined until the program and/ or sub-project details have been identified.� Depending on the nature and location of the proposed sub-projects or urban investment activities, the project initiatives are likely to contribute to environmental and social risks and impacts on the project area during their construction and O&M phases. These risks and impacts would assume importance when the sub- projects locations are in proximity to sensitive areas. Hence, there is a need for systematic environmental and social management with a pre-defined framework for risk mitigation. As the sub- projects locations and activities are not finalized, to identify and manage associated risks and impacts, it is required to prepare an ESMF for the project. Thus, the purpose of the ESMF is to describe a framework for the management of the environmental and social risks and impacts during the preparation of sub-projects; including (i) procedures for screening the environmental and social aspects related to the programs, (ii) identification and analysis of the risks and impacts, regulatory mechanisms, and management/mitigation measures and monitoring needs, (iii) details on the institutional roles and responsibilities for environmental and social management (including contract provisions and budget), (iii) strategy and plan for capacity building of key stakeholders, (iv) plan for monitoring the implementation of environmental and social mitigation measures, (v) strategy for public consultation. 1.4 Methodology Adopted for ESMF Preparation The ESMF has been prepared based on environmental and social assessments which involved the gathering of data through both primary and secondary sources. The steps followed in developing the ESMF are provided below: • Review of the Project details and meeting/discussions with various stakeholders, • Field reconnaissance at sample candidate sites to determine the key environmental and social parameters and aspects that are likely to be impacted by the Project activities, • Establishment of the baseline (describing the relevant physical, biological, and socioeconomic conditions) through assessment of the study area, solid and biomedical waste management through desk research, surveys, and discussions with stakeholders. This also included desk research of similar bank operations to understand probable social and environmental risks and impacts, • Defining the legal/regulatory framework that will influence the implementation of the proposed projects and sub-projects including a review of national and state-level acts and policies applicable to the proposed project and the World Bank (WB) Environmental and Social Framework (ESF) and identifying existing gaps in the current implementation practices associated with the type of sub-projects, • Carrying out consultations with all relevant stakeholders those who have been identified through stakeholder and institutional analysis: these include government, communities, and institutions. The objective of the consultation sessions is focused to improve the project's interventions about the environment and social management and seeking views from the stakeholders on the environmental and social issues and the ways these could be resolved, • Identifying the risks and impacts of the activities supported by the project on the environment and the society to develop screening criteria, environmental and social instruments that need to be prepared for each sub-projects, ESMF for G-ACRP, 2022 Introduction to the Project 3 • Defining the framework for management and mitigation methods to manage the impacts, enhance project environmental and social benefits, and for improving stakeholder capacities to manage the project, • Outline the procedures to be followed to comply with the WB ESF and National/State/Local level rules and regulations including preparation of various environmental and social documents, monitoring mechanism, stakeholder engagement, disclosure requirement, grievance redress, and institutional arrangement, • Preparing the monitoring plan to oversee the implementation of management and mitigation methods, • Discussing the existing grievance redressal mechanism and citizen engagement measures and defining the proposed mechanisms for the project, • Identifying the institutional capacity building and training requirements for implementing the mitigation measures, • Preparing an estimated budget to undertake the provisions of the ESMF. Figure 1: Methodology adopted for ESMF Preparation 1.5 Structure of the Report The ESMF has been structured as follows: EXECUTIVE SUMMARY: A non-technical summary of the ESMF CHAPTER 1. INTRODUCTION TO THE PROJECT: provides a brief overview of the project background, provides a description & objective of the project, its various components, scope & purpose of the ESMF, approach & methodology. CHAPTER 2. BASELINE ENVIRONMENTAL AND SOCIAL CHARACTERISTICS OF AHMEDABAD: Presents a synthesis of the baseline physical, economic, infrastructural, environmental, and social aspects and sensitivities of the city and its region and presents the existing institutional structure. It compiles the key points derived from baseline analysis, relevant to the environmental and social management of G-ACRP. A detailed baseline description is presented in Annexure A (of Annexures). ESMF for G-ACRP, 2022 Introduction to the Project 4 CHAPTER 3. REGULATORY FRAMEWORK: discusses applicable National/ State/ local regulations, WB ESF/ ESSs, and applicable standards/guidance CHAPTER 4. ASSESSMENT OF PROBABLE IMPACTS DUE TO SUB-PROJECTS: presents the expected risks and impacts of the proposed project CHAPTER 5. ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK: discusses the framework to be adopted for sub-project Identification and Initiation, screening, and categorization of the Projects, mechanism for assessment of impacts during project preparation, preparation of mitigation and monitoring measures, public consultations, and addressing the concerns of the disadvantaged groups. It also presents the linkage of ESMF to ESCP and other project documents and ESMF updating mechanism. CHAPTER 6. INSTITUTIONAL FRAMEWORK AND BUDGET FOR ESMF ADOPTION discusses the role and responsibilities of various institutions and capacity building needs for management of environmental and social aspects, budget for ESMF implementation CHAPTER 7. STAKEHOLDER ENGAGEMENT, GRIEVANCE REDRESSAL MECHANISM, AND INFORMATION DISCLOSURE present the mechanisms for grievance redressal, consultations, and disclosure of information on environmental and social aspects of G-ACRP. ANNEXURES of the report includes 1. ESMF GUIDANCE MANUAL with: a) Documentation formats to be used for screening of sub-projects b) Sample terms of references - for Impact Assessment, engaging environmental and social specialists, and for auditing compliance to ESMF c) Guidance materials for licenses, permits, clearances under various regulations, site selection, public consultation, and consensus, indicative Environmental and Social Management Plans, monitoring plans for typical typologies of sub-projects, grievance management, Outline of Biodiversity Management Plan to be prepared with ESIA. 2. ANNEXURES with: a) Annexure A: Detailed Environmental and Social Baseline of Ahmedabad b) Annexure B: Details of Applicable National and State Regulations c) Annexure C: Details on Stakeholder Consultations d) Annexure D: Dam Safety Cultural Heritage Management Framework (ESS 8), Resettlement Planning Framework (ESS 5) and Labour Management Procedures (ESS 2) are being prepared as separate documents. ESMF for G-ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 5 CHAPTER 2. SUMMARY OF BASELINE ENVIRONMENTAL AND SOCIAL CHARACTERISTICS OF AHMEDABAD REGION A summary of the baseline environmental and social characteristics of the project area, namely, the city of Ahmedabad is presented in this chapter. A detailed description of the baseline conditions with analysis is presented as Annexure A (Annexures). List Aspects Description Key pointers for E&S risk identification and NO: Management 2.1 Geographic Gujarat in the North-Western coast of India is among its most urbanized states with a Increasing demand for infrastructure and services to Location strong industrial base. Located to the north-central part of the state at nearly 100km from ensure sustainable development. the coast (Gulf of Khambhat), is Ahmedabad its most important mega city witnessing high industrial and population growth in the city and its larger region. Figure 2: Geographical Location of Ahmedabad 2.2 The City, its form, and functions 2.2.1 Evolution of the city The city could be segmented as (i) the ‘walled’ city (within the fort walls - 15th century) – Specific development patterns and issues in each of the old central city of Ahmedabad; (ii) industrial and residential localities to the Eastern the three urban morphologies here need to be peripheral areas of the Old City (dating back to the year 1860); and (iii) plotted residential considered to avoid, minimize, and manage colonies and institutional areas in the ‘new city’ to the west of the old city across environmental and social risks and impacts related to Sabarmati – depicting a clear evolution over time. Today, the city is divided into seven developing infrastructure and laying networks. administrative zones - Central, East, West, North, South, Southwest, and Northwest. It has evolved as a concentric compact city around the Sabarmati River, with a density of around 14,450 people/sq.km. The city is in a high growth trajectory, being at the locus of industrial development ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 6 List Aspects Description Key pointers for E&S risk identification and NO: Management Figure 3: Evolution of the City of Ahmedabad 2.2.2 Urban Planning and Gujarat (and Ahmedabad, its city) has a very robust urban planning mechanism under the The efficient spatial planning scheme could be Development Gujarat Town Planning and Urban Development Act (GTPUDA) of 1976 which uses utilized for upgrading existing industrial/other mechanism Development Plans and Town Planning Schemes as the planning tool for managing developments which impact the environment and peripheral urban growth, mostly in case of agricultural land repurposed for sustainable the people. There are opportunities for robust urban use. This helps in the development of a gridiron road network, and allot required environmental and social considerations and space for roads, open greens, utilities, housing, and commercial/industrial uses. resilience in planning and developing Ahmedabad as a light house/mode city for sustainable development. 2.3 Demographics 2.3.1 Population Profile The population of Ahmedabad the fifth largest city in India was 5.57 million in 2011 There is an urgent need to strengthen/ provide new and Decadal Growth (Census) estimated to be 6.3 million by 2020. With the increasing opportunities for trade environmental infrastructure and services to cater to Rate and commerce and as a center for higher education, this heavy growth continues. The city the needs of the existing urban population and has a sex ratio of less than 1(male Population 2,938,985, female Population 2,638,955) expected future growth. and shows a 2.4 percent annual growth in population. 2.3.2 Child Population) The total child population (0-6 Age Group) in Ahmedabad city as per census 2011 was While the city is growing at a fast pace in terms of its and youth 621,034. The total male child population was 336,063 and the total female child density it fares poorer in terms of social indicators population Working population was 284,971. The percentage of the youth population (15-24 years) is 19.26. such as sex ratio and literacy. It has a large working- Age The working-age group (15-59 years) population is 66.78 percent age population. ST population in the city is just around 70,000. 2.3.3 Sex Ratio (Females The sex ratio of Ahmedabad city is 897 females for 1000 males. The child sex ratio of girls Per 1000 Males) is 848 girls per 1000 boys. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 7 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.3.4 Literacy The literacy rate of Ahmedabad is 89.60%. The total literate population of the city is 4,376,393. The population of literate males is 2,402,523 and while that of literate females is 1,973,870. 2.3.5 Density of The Gross density of AMC in 2011 was 120 persons per hectare, which is the average gross Population density for a metropolis as per Urban Regional Development Plan Formulation and Implementation guidelines. 2.3.6 SC/ ST population The SC/ ST Population in the city is 10.66 and 1.2 percent respectively 2.4 Population Distribution 2.4.1 Administrative AMC has 6 zones named based on their respective locational directions, with wards in Sewerage, Drainage services, Water Supply, and Divisions each zone headed by corporators/councillors. As per sections 63 and 66 of the Bombay maintaining Heritage are among the important Provincial Municipal Corporation Act, the AMC is responsible for certain obligatory and obligatory services to be ensured by AMC for all its discretionary services. citizens. Figure 4: Administrative Divisions of Ahmedabad City ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 8 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.4.2 Housing & Urban The percentage ofthe population living in urban slums is 4.49 and in congested houses is It is important to ensure that all areas are served with Poor 36.42. Overall, 77.39 percent are residing in their own houses while 20.57 percent are the best environmental infrastructure, for the safety residing in rented houses. Service levels and access to infrastructure vary across various of the city, and its environment. housing/income levels. 2.5 Physical Characteristics 2.5.1 Physiography and The city, in the west coastal plan physiographic region, is 40-60m above sea level with a Topography is almost flat; hence, it will be difficult to Terrain master slope towards the South. The area is monotonously flat except few mildly get a natural slope for sewage, drainage networks. undulating topographies: small hills of Thaltej-Jodhpur Tekra and Vastrapur. The The lowest point available is near the Sabarmati River Sabarmati flows for 14 km through the city and divides it into eastern and western parts. edge and hence, most STPs are located along the The ground slopes gently towards the river and to the south with more slope along the River edge at the South of the city. Also, since the city western side. is bifurcated into east and west sides STP for the eastern side preferably are located on the east bank and vice versa. These are important pointers for the future location of STPs. ▪ Master plan suggested locations for STPs are mostly near river edge. It is important to consider flooding and arrange protection weirs and / or buffers along the river edges while designing STPs, drains and outfalls. ▪ Figure 5: Physiography and Terrain ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 9 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.5.2 Climate The city has a semi-arid hot climate with summers from March to July, monsoons from ▪ River pollution would be more pronounced during mid-July to near around September, and dry winters from November to February. The summers and hence monitoring of quality and average temperature of the city ranges between 12 to 41 o Celsius. The average annual quantity parameters for the design of STPs shall rainfall received is 932 mm. The monsoons are often characterized by torrential infrequent preferably be conducted then. rains, sometimes leading to flash floods. Water is maintained in the River mostly through ▪ Preferably avoid construction works during peak supply from the Narmada canal. Wind speeds are high from May to July. Predominantly, rains and there should be a system to alert the winds are from the south west tending to carry sand and odors from south west to the construction sites to avoid causalities. east of the city where industries are mostly located. ▪ Adopt disaster preparedness in all infrastructure for flash floods. ▪ Monitor waste water and bypass arrangements continuously. The direction of the prevailing winds is to be ascertained with regard to other polluting landuses (such as industries), the location of various units of the treatment plants, distance to habitations, and other sensitive receptors during environmental and social assessments. 2.5.3 Geology and Soils Soils are fertile. The soil is either coarse sandy or fine sandy loam, with less clay content ▪ It is important to avoid/minimize the pollution of and has good to excellent drain-ability, with soil depths more than 100 cm. Spread of riverbeds. alluvial bed from and to end of the district is an important feature. Alluvial bed/sediments ▪ Good ground and tree cover/ green belt shall be carry polluted discharges through villages downstream up to the Gulf of Khambhat and integrated into designs as the soil conditions can impact downstream villages support this. ▪ Dust pollution due to construction (movement of vehicles, storage of materials, wastes, construction, and demolition) to be prevented using buffers and screens, mainly during summers when air-borne sand movement may be higher in the region ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 10 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.5.4 Land use and The city forms part of two major industrial growth corridors of Gujarat (Mahesana, ▪ Industrial landuse of the city and agricultural Landcover Ahmedabad-Vadodara-Surat-Valsad(together 72% urban population) and Ahmedabad- landuse of the neighboring areas are important Rajkot-Junagarh (9% of state’s urban pointers to risks and impacts and stakeholders of population by 2021, excluding the sewerage/drainage projects. Ahmedabad)). The urban-rural disparity in terms of access to infrastructure, services, and facilities is high. The ratio of Built-up area to Agriculture/waste/open land is 10:90 in the case of Ahmedabad district. The city has 80% residential and 13% industrial landuse. Figure 6: Landuse of Ahmedabad City 2.5.5 Hydrology and Sabarmati, a rain-fed river originating in ▪ The rivers are seasonal with less flow, with many Rivers Rajasthan bifurcates the city into east and users in the region. It is important to conserve, west parts, flows to the south, and reaches clean, and reuse available waste water and ensure the Gulf of Khambhat (which opens into to good flow through the rivers. Arabian sea) 100 km south of the city. Kharicut ▪ It is important to monitor the quality of water canal through the city drains to Khari river reaching Sabarmati through the Narmada Canal running through its eastern periphery. These and from downstream (ground and surface) areas regional arteries pass through many other through which these rivers flow after receiving towns, villages with mainly Agricultural the treated sewage from the city. landuses before and after the city carrying the ▪ Designs shall withstand any safety impacts or risks waste, agricultural runoffs, wastewater and on all project components, activities due to chemicals/ from various landuses, effluents natural / manmade disasters and any impacts due from the city and its region. Summer flow to Vasna Barrage and this shall be through Sabarmati depends on the release of comprehensively reviewed, and appropriate Narmada water through the canal. interventions adopted for safety and resilience in DPRs. Figure 7: Sabarmati Basin ▪ Undertake hydrological and flood assessment, including a study on Dam break analysis &flooding Stimulation, preparation of inundation maps and ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 11 List Aspects Description Key pointers for E&S risk identification and NO: Management Emergency Action Plan for Vasna Barrage, Ahmedabad, Gujarat o Outcome/output of these assessments shall Figure 8: Hydrology be incorporated in the design and subsequently assessed in C-ESIA & mitigation measures if required included in C-ESMP. o Emergency Preparedness and Response Plan and Disaster Management Plan shall be part of all ESIAs ▪ Also, impacts of effluents/bypass from STPs during heavy rains on the rivers and Vasna barrage shall be assessed and a suitable design and STP operations protocol/manual shall be prepared. ▪ Disaster Management Plan shall incorporate considerations for any impact due to Vasna barrage and flooding on STPs to its south during heavy rains/flooding/other disasters. ▪ There is no International Water Way involved in this case either Sabarmati, Khari or Gulf of Khambat. Sabarmati and Khari rivers all originated and are only flowing in and through India whereas Gulf of Khambat is only within the jurisdictional boundary of India and is not shared with other riparian states. 2.5.6 Groundwater Scenario 2.5.6.1 District Ground Multiple aquifers exist thanks to alluvial plains. However, ground water is overexploited ▪ Ground water quality pre-and post-construction Water Scenario for various purposes, including industrial uses. Due to over-exploitation, the water levels of the proposed investments could be a good in the phreatic aquifer have declined alarmingly rendering them almost dry. In North pointer of regional pollution load. This should be Gujarat, about 93% of the area falls within the water level of 20 m bgl. built into the Monitoring Plan for contractors. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 12 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.5.6.2 City Ground Water AMC draws water from some 363 tube wells (406 installed, but 43 are non-functional). ▪ Project activities shall also ensure ground water Scenario There are many private borewells/tube wells across the city. An increase in the withdrawal conservation and recharge (for example reuse of from the groundwater table over years has increased the failure rate of the tube wells. It wastewater for industrial/agricultural purposes; can be observed that the TDS in borewells is beyond the BIS standard 500 mg/ l and thus drainage projects to incorporate rainwater the hardness of water is quite high. harvesting structures) 2.5.7 Extreme Events The mega city of Ahmedabad tops the list of cities in the composite risk and vulnerability ▪ Disaster Management Plan should be part of all ranking of cities in Gujarat. sub-projects’ ESIAs 2.5.7.1 Earthquakes The city of Ahmedabad falls in the Moderate Seismic Zone – III. During the earthquake of ▪ It is important to incorporate earthquake- 2001, sewage networks of Ahmedabad were subject to damage. resistant design features in all infrastructure proposed under the project, for the safety of the people and structures, and to prevent the accidental spill of pollutants. 2.5.7.2 Cyclones Though the southern part of the Ahmedabad district near the coast is highly vulnerable to ▪ Movement of dust and sand (and other air borne tropical cyclones generated in the Arabian sea; it is not so in the case of the city area which pollutants) in this semi-arid area viz a viz the wind is in the northern part. The city falls in the mean wind speed zone of 34-39 m/ sec zone. speed shall be considered in all ESIAs 2.5.7.3 Flooding Cities like Ahmedabad, Surat, and Bharuch are located on the flat alluvial plains of large ▪ Design should integrate features to protect rivers, which are flood-prone. Infrastructure and services were impacted due to floods in networks, and infrastructure facilities created 2018 and 19. from the effects of flooding. High Flood Level shall be considered for the design of all infrastructure, electrical and mechanical systems; equipment and storage of chemicals, fuels, and materials for construction and operation 2.5.8 Sensitive Ecosystems 2.5.8.1 Protected Areas Nal Sarovar protected area and wildlife sanctuary is 62 km west of the city No impact is expected on this area considering the catchment, distance, location of STPs, Rivers, and wind direction 2.5.8.2 Key Biodiversity Kanewal Lake (72 km from Ahmedabad), Baskarpara wetlands (60 km near Viramgam), ▪ In the case of large infrastructure facilities (such Areas around Bhal area (near around 80 to 100 km), and wetlands of Kheda – Pariej (60 km) are major as STPs, Tertiary Treatment Facilities) planned in Ahmedabad sensitive ecosystems in the larger region. The biodiversity area of Thol Lake Wildlife north or northwest zones of the city, impacts on environmental components of the Thol Sanctuary ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 13 List Aspects Description Key pointers for E&S risk identification and NO: Management Sanctuary is around 30 km to the North of the city. Other key nationally recognised shall be assessed. Thol area being a harbor to wetland is Santej Lake and Chandola Lake. migratory birds it becomes essential to assess the STP locations and the vicinity for the presence of Kamla Nehru Zoological Garden Kankaria (Kankaria Zoo) is within the AMC boundary and migratory birds (i.e. roosting sites, feeding sites, has a considerable number of birds apart from the caged animals. Also, animals inside the etc. zoo are sensitive to the activities contributing to Noise & Vibration pollution. ▪ Similarly impacts of any infrastructure development under the project in areas near Santej and Chandola Lake need to be assessed. ▪ Impact on zoo animals shall be assessed in case of any sub-project near the zoo (east central part). 2.5.8.3 Key sensitive Key sensitive landuses in Ahmedabad city include (i) its main river Sabarmati which ▪ Sabarmati, Khari and many of the urban lakes are landuses in bifurcates the city into two, (ii) Kharicut Canal which passes through the east part of the modified habitats due to urban activities and Ahmedabad City city and meets Khari River which eventually joins Sabarmati near Kheda, (iii) Near around pollution 122 big and small lakes in the city including the larger Vastrapur, Kankaraia and Chandola ▪ Impacts on Sabarmati and Khari, and villages lakes; which are also receptacles for untreated waste, drainage, and sewage, (iv) many along these need assessment if treated sewage is gardens, parks and open grounds in the city. No. of Public Parks is 256 and the area under discharged into these. Public Parks is 2,240,000 sq. m. ▪ Impacts on Lakes and their catchments need assessment for infrastructure which might impact these 2.5.8.4 Forest Cover There are no important forests in the city area except urban forests developed by the ▪ The concept of urban forests and sponges could AMC. As per the Tree Census of 2012, there were 618,000 trees in the City. The area be utilized in various sub-projects and plans covered under green space is 4.66%, and there are 9 Municipal Nurseries and 43 Urban including plans, urban resilience studies, lake, or Forestry Sites in the city. canal redevelopment; for reducing heat effects and pollution, effective drainage management, and water recharge. 2.5.8.5 Flora Tree cover in the study area is either as farmland, homestead, or roadside plantations. ▪ The area is rich in important native flora. All STPs There are many dominant tree species in the study area including large native trees like and infrastructure created shall ensure good Azadirachta indica (Neem), Mangifera indica (Keri), Tamarindus indicus (Amali/ Imli). green belts (with indigenous species) as part of Gardens Department of AMC plants many varieties of trees/ plants in their gardens and layout design to mitigate air/noise pollution and road verges. to improve water retention and soil conservation. ▪ All ESIAs shall assess risks and impacts on flora, and suggest minimizing tree cutting and other ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 14 List Aspects Description Key pointers for E&S risk identification and NO: Management impacts, and ensure mitigation measures including a compensatory plantation. ▪ Treated sludge shall be monitored for confirming accepted standards for use in gardens and plantations. If it is non hazardous, where it is converted into ‘Bio manure’ and sold provided it gets Fertilizer (Control) Order certification as city compost. Or else it shall be used for permitted uses or landfilled / used as landfill cover as per National Regulations. Sludge monitoring shall be included in the monitoring plan. 2.5.8.6 Fauna Some of the common fauna found in the study area are marked as vulnerable in the IUCN ▪ All ESIAs shall present a list of fauna including Red List. This includes Sarus crane, Black-Headed Ibis (Threskiornismelanocephalus), vulnerable/sensitive ones. Oriental Darter (Anhinga melanogaster), Peafowl (Pavocristatus), Indian Flapshell turtle ▪ Any threats to such fauna shall be assessed and (Lissemys punctata), many varieties of reptiles, mammals, and insects. presented in ESIA by specialists and mitigation shall be ensured following mitigation hierarchy. 2.5.8.7 Heritage This is the first Indian city to get inscribed on the World Heritage list by UNESCO in July ▪ It is important to engage with the Heritage Cell 2017. The heritage resources in Ahmedabad include: (i) The entirety of the walled city with and Archaeology Department to assess and many protected monuments, (ii) The pols - houses grouped into pols, (iii) The traditional monitor the risks and impacts of proposed individual houses. Ahmedabad is also home to some renowned modern buildings which developments in heritage areas. are considered landmarks. The heritage cell of AMC looks after tangible and intangible ▪ Prior approval is required for construction cultural heritage. activities in a regulated area of these monuments from the Director of Archaeology, Gandhinagar, Archaeological Survey of India. ▪ Screening matric shall include this requirement ▪ ESIA consultants and contractors shall have appropriate capacities (such as Heritage Conservation exert) for assessing and preparing mitigation measures in case of such sub-projects; if so found during screening. 2.6 Economic Activities ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 15 List Aspects Description Key pointers for E&S risk identification and NO: Management 2.6.1 Employment A third of the population is in the working-age group with a work participation rate being ▪ Industrial growth is high and the hon’ble High Characteristics 37% as per the 2011 census, high percentage of self-employed (50%). Employment is Court of Gujarat has taken action to disconnect all almost distributed among secondary (47.76%) and 50.30% tertiary sectors. Primary industrial effluent inflows into sewer system. commodities manufactured in the ULB are chemicals, medicines, and cotton cloth Possible reuse of treated sewage for industrial use will be assessed as part of the project ▪ Construction activities might see labor influx from surrounding regions or other parts of the country 2.6.2 Agriculture and Agriculture or fisheries is not the mainstay in the city area. With workers in these sectors ▪ Fauna flora in the rivers shall be listed and Fisheries being just around 0.73 percent of the total population. The fish population is reported in assessed for impacts at the ESIA stage and shall the lakes of Ahmedabad and the Sabarmati River. Fishes are seen in Narmada Canal and also be used in screening and as a monitoring the inflow into Sabarmati city stretch. These are mostly exotic. Fishing as a temporary indicator. activity occurs downstream of Vasna barrage usually post-monsoon when water is released from the Dharoi dam. 2.6.3 Tourism and There are many tourist destinations in Ahmedabad city and around, including monuments ▪ Tourist/festival seasons shall be considered, and recreation and lakes, while the surrounding region has some wetlands and sanctuaries. City also construction activities shall be accordingly celebrates most national festivals and State level festivals and processions. scheduled; especially during Navratra. 2.6.4 Industries Ahmedabad is an industrial base for sectors such as chemicals, textiles, drugs and ▪ Industrial effluents (treated/untreated) from pharmaceuticals, and food processing industries. Total water consumption by industries CETPs, the mega line, and emptied into urban is around 299.7 MLD and industrial effluent generation is 150.88 MLD. There are 7 CETPs drains and sewer networks need to be arrested to with a total treatment capacity of 132.45 MLD. Gaps are observed in terms of the quality ensure optimal functioning of STPs. Hon’ble High of treated effluents and hence Up-gradation/expansion of CETPs are proposed. Three Court of Gujarat has constituted a task force GIDC estates, in Naroda, Odhav, and Vatva, were located beyond the textile industrial comprising of AMC, GPB, and other stakeholders areas, where unorganized industries developed, employing many unorganized workers. to tackle this issue by identifying and These areas witnessed the rapid development of slums. The eastern periphery of the city disconnecting all industrial connections to thus developed with the emergence of industrial suburbs with small-scale industries and sewers, and these industries will be allowed to housing for workers and low-income groups. Major treated industrial effluent outlets to operate only after setting up ETPs or connecting rivers are MEGA Pipeline Outlet and ATPA CETP outlet. Projects on Industrial effluent their effluents to CETPs. The task force has management are not part of this project. disconnected more than 380 connections till Dec 2021. ▪ AMC shall ensure periodic monitoring of the quality of treated trade effluents discharged by industries into Khari and Sabarmati (directly into ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 16 List Aspects Description Key pointers for E&S risk identification and NO: Management drains, and from CETPs into Mega pipeline) and data sharing with stakeholders including GPCB for stricter actions on polluters. ▪ GPCB shall arrange strict monitoring to ensure proper functioning of STPs without impacts due to industrial discharges. 2.7 Major Infrastructure and Services 2.7.1 Transportation The number of vehicles on road is increasing at a quick rate in Ahmedabad. Presently ▪ Safety shall be ensured for workers and transport demand of the city is met by public and intermediate public transport modes communities during sewer/drainage network including intra-city buses, auto-rickshaws, hired cars, and personalized modes. The major laying and specialized works like micro-tunneling public transport accounts for MRTS (Ahmedabad Metro), AMTS, and the BRTS (Janmarg). especially in congested central part. The road network in Ahmedabad may be classified as a ring-radial form. There is a total of ▪ Utility shifting will also be a critical aspect, 20 radials (arterials and collectors), 12 are in the west and 8 in the east. The area under especially in congested central and eastern parts. roads is 7.91% as against the desirable 15-18%. Many trips using heterogeneous modes ▪ Conflicts of proposed infrastructure development are made daily in both directions across the river. Construction of Phase 1 of Ahmedabad including network lines with other construction Metro is expected to be completed in 2024. activities such as that of the ongoing metro will need to be addressed. ▪ These shall be considered in the design, work schedules, and ESIAs. 2.7.2 Water supply Sabarmati River was the historical source of water supplemented by additional supply ▪ The city essentially needs to incorporate from the barrage on Mahi River. However, with the growth of the city and limited mechanisms to reuse treated water considering availability of raw water in Sabarmati and Mahi, the city in recent past had invested to the water scarcity. source the Narmada River water delivered through the Main Canal as well as branch canals ▪ It is important also to ensure the quality of at Shedhi and Dholka. There are 3 water treatment plants of 1450 MLD treatment treated effluents and sewage meeting permissible capacity, 124 MLD groundwater supply from bore wells, 481 km of transmission main standards is discharged from STPs for the benefit length, 3753 km of water distribution lines, supplying water to 124 distribution zones at of downstream uses. supply continuity of 2 hours/ day. There are reports that communities to south of ▪ Ground water monitoring is important for heavy Ahmedabad mostly uses deep bore wells for water abstraction as rivers and shallow wells metals are polluted. Ground water quality assessed for the project in various parts of the city ▪ It is important to have comprehensive industrial shows pollution by Chromium, Lead, Iron, Nickel (alloys, batteries, and Catalysts), waste and waste water management in the city. Cadmium (from incineration of municipal waste such as plastics and nickel-cadmium This will also make economic sense and minimise batteries), Zinc (from alloys, pesticides, catalysts, PVC stabilisers, fertilisers, paints, diffused pollution. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 17 List Aspects Description Key pointers for E&S risk identification and NO: Management pigments and dyes) and certain other metals. These are may also be from electronic, batteries and other wastes. Secondary data also conforms Chromium pollution especially in borewells near industrial areas. It is used at a higher rate in dyeing tanning industries. 2.7.3 Sewage/ The city area doubled between 2001 to 2020, with a proportionate increase in the ▪ All premises should be connected to sewer lines Wastewater wastewater infrastructure. Around 96 percent of households have access to individual to ensure full treatment of liquid waste thus Management toilets with a third of slums still without access to individual toilets. Ahmedabad city has generated. 1,827 community toilet blocks with (84non-functional) 7,160 seats, 314 toilet blocks with ▪ All illegal connections and cross connections shall 1,256 pay and use toilet seats, and around 807 bathing units. There is a need to ensure be identified and curbed. full coverage of all housing typologies and public areas with adequate and appropriate ▪ Catchment wise approach is important for toilet and bath facilities. comprehensive coverage 2.7.3.1 Sewage Collection The 14 STPs are connected to 68 pumping stations and 366 km of trunk mains and 3302 ▪ Upgradation or construction of STPs or sewerage km of collection networks, with 1245 MLD treatment capacity. Major STP outfalls are New system shall consider the current environmental Pirana 180 MLD and 155 MLD, Old Pirana106 & 60 MLD STP, Vasna 35 MLD, 240 MLD STP, performance of upstream infrastructure as well. 126 MLD, 48 MLD, Vinzol 35 MLD, 70 MLD and 100 MLD. Decentralized STPs at ▪ Improvements to trunk mains and drains and Shankarbhuvan 25 MLD, Jalvihar 60 MLD, and Lambha 5 MLD. missing links is important and shall be considered under the project (as separate sub-project or 2.7.3.2 Sewage Pumping There are 10 terminal sewage pumping stations and 58 intermediate sewage pumping component of same sub-project as required for stations in the AMC area. Pumping stations and networks are upstream infrastructure for contracting mechanism and management) for full sewage treatment plants. Proper functioning of these upstream infrastructures such as upgradation pumping stations, networks, and illegal connections explains the quality and quantity of waste water reaching the influent tanks of treatment units. 2.7.3.3 Sewage Treatment Existing treatment system: Today, there are 18 STPs in the city with 9 on the East and 5 on ▪ It is important to ensure full treatment of the West sides of River Sabarmati. The large capacity STPs are clustered in three locations wastewater generated in the city by appropriate of Pirana and Vinzol in East and Vasna in West. The total capacity is 1248 MLD. Treatment development of additional STPs and network types include Up-flow Aerobic Sludge Blanket (UASB), Activated Sludge Process (ASP), upgradation. Sequential Batch Reactor (SBR). ▪ All STPs shall conform to national regulations – preferably NGT suggested standards (which is Proposed STPs: AMC has initiated the construction of new STPs (127 MLD in total) at stringent in key parameters than the WB EHS Makeksaban (30 MLD), Saijpur(7 MLD) , Kotarpur(60 MLD), . The total capacity of sewage suggested in Indian Regulation - EP Rules 1986: treatment would be 1345 MLD as against the projected sewage generation of 1742 MLD General Discharge Standards for Discharge of for the year 2035. Treated Effluents to Surface Water and / or Reuse of Treated Wastewater: The government of Gujarat had instituted a water reuse Irrigation; NGT order is a modification over this policy, aimed at reusing 100% of waste water by the year 2030. AMC is currently using 446 ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 18 List Aspects Description Key pointers for E&S risk identification and NO: Management MLD treated sewage (around a third of the total treated sewage generated) in regulation) and design shall be stringent to ensure downstream agricultural, horticulture, industrial reuses. The further potential for reuse environmental quality. water for industrial, horticulture/ agriculture purposes as approximately 300 MLD, ▪ Networks shall be monitored with sensors to implementation of proposed projects. ensure no industrial effluent reaches the STPs due to illegal dumping through manholes/other The existing SCADA system captures the performance data partially and does not cover mechanisms and DPR/ design should ensure this. the entire wastewater system. ▪ SCADA shall fully cover the entire STP operation and capture all performance-related data (automated quantity and quality data linked to alert system). ▪ Tertiary treatment and reuse of treated wastewater for gardening, downstream agricultural use, and industrial use are important for the water-scarce region. 2.7.3.4 Sewage/ Performance Assessment System (PAS) Project notes that coverage of toilets, sewer ▪ Web-based monitoring of the performance of Wastewater networks and quality of treatment, the collection efficiency of sewage networks, wastewater/drainage system in its entirety, Management: adequacy of treatment capacity are satisfactory. However, the extent of reuse and including grievances and its resolution on time Service Levels and recycling of treated sewage is only 53% pointing to the opportunity in this regard. Most of would help resolve complaints and support in Complaints the complaints received by AMC are regarding chocking of drains (57%). Followed by ensuring best environmental quality. frequent blockage/ breakdown of drainage (20%) and silt disposal by the contractor(16%). Complaints are also noted on missing manhole covers, overflowing of mains/ distribution lines, missing, issues with public toilets, and storm waterlogging. The ratio of complaints per 1000 connections stands at a city level average of 144 with the highest ratio of 392 in Central Zone and the lowest of 36 in North West + South West Zones which points to the age of network and density of connections in the respective zones. 2.7.4 Storm Water The natural drainage of the city is towards the south. The AMC has planned and ▪ It is important to monitor industrial effluent and Drainage implemented a stormwater collection and disposal system divided into 6 zones. There are wastes disposed into AMC drains 31 pumping stations together in North-south, east, and west zones (with no stations in ▪ There shall be continuous monitoring of CETP central and New West). The major outfalls of treated/ untreated, domestic/industrial treated effluents wastewater are The outfalls of the Old City area, Stormwater Drain Vasna, stormwater ▪ All industrial areas (outside GIDC areas) shall be drain from Danilimbda Area, and Interceptor outlets. clustered and the appropriate treatment/ environmental infrastructure shall be arranged to arrest the flow of trade effluents to drains. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 19 List Aspects Description Key pointers for E&S risk identification and NO: Management All the nallas (drains) opening in the river were connected through a diversion interceptor ▪ Hon’ble High Court of Gujarat has constituted a line in the Riverfront development stretch on both banks and partially treated in STPs on task force comprising of AMC, GPB, and other both the sides of the bank of river Sabarmati excess quantity of sewage from interceptor stakeholders to tackle this issue by identifying and is discharged into river through an outlet after Vasna barrage. disconnecting all industrial connections to sewers, and these industries which will be Industrial units outside GIDC areas are discharging their treated effluent into stormwater allowed to operate only after setting up ETPs or drains of AMC. Trade effluent (treated effluent from 4 CETPs-Vatva, Odhav, Naroda, Narol) connecting their effluents to CETPs. The task force from GIDCs discharged into river through Mega Pipeline. All CETP member units have has disconnected more than 380 connections till provided at least functional primary ETP to meet the inlet norms. Dec 2021. 2.7.5 Solid Waste The city generates around 4000 TPD of solid wastes (70% from households) including 3000 ▪ It is important to ensure no waste reaches the (including Plastics) TPD of solid waste 1000 MT of construction and demolition waste. Wate is segregated and drains/sewage network. Manhole/cover design and Sludge stored at the source and collected separately. Existing treatment facilities include 1000 and its security are important. Management TPD Composting facilities (three plants on PPP format), 1000 TPD for C&D Waste, 100 TPD ▪ In addition, it is important to ensure proper waste for Plastic waste, 400 TPD Material Recovery Facilities (MRFs). Waste to Energy Plants collection and transport from all parts of the city (two, 1000 TPD each) is under construction. For disposal, there are 7 RDF facilities, MRFs, including from project facilities and activities, one sanitary landfill site (42.3TPD of rejects/inerts), and a 40-year-old municipal dumpsite there should be facilities for managing wastes (biomining in progress). Fires and methane generation are key issues in the dumpsite. during emergencies as well so that it does not find Drains, silt pits, and canals are cleaned pre-monsoon. Microplastics of 75micrometer to a way to drain/sewage network. 5mm are reported in the sediment of the Sabarmati river in the city area. Notwithstanding ▪ Periodic cleaning of drains, sewers, canals, existing arrangements, it is reported that wastes are found in city drains mechanisms to trap wastes before entering the river are essential. Monitoring of waste Around 1000 ragpickers in the AMC area, are grouped as an association, provided with management, awareness, and grievance health check-ups, ID cards, safety gears, and incentives for waste collected (only from management system is essential. MRFs, not from dumpsite). In addition to conservancy tax on sewerage and drainage, AMC charges Rs 1 as cess per head per day, and Rs 2 per commercial unit per day as part of ▪ It is required to improve sludge dewatering property tax as directed by SWM Rules, 2016. mechanisms (better screw presses etc.) at STPs and transporting sludge to the plant and keep the Sludge Treatment by Radiation: AMC with Bhabha Atomic Research Centre (BARC) has sludge quality at acceptable levels. installed a Gamma Irradiation Plant (100 TPD capacity) for the Hygienization of Sewage ▪ Grit shall be recycled/reused safely and sent to Sludge (based on Cobalt-60) at Shahwadi to convert the sewage sludge to Bio-fertilizer, C&D waste processing facility. Screenings shall be with a design life of 50 years (since 2015). Around 450T of sludge is processed in the unit sent to SWM facilities for recycling, treatment or till March 2021. The STPs at Vinzol show heavy metals in quantities higher than accepted disposal as appropriate. Complete data on these standards and not accepted for radiation. Sludge is not treated during monsoons shall be managed by STP operators. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 20 List Aspects Description Key pointers for E&S risk identification and NO: Management considering high moisture content. AMC has applied for FCO approval for use of this ▪ Arrangements to continuously monitor and finished product in agriculture. Field trial on the use of the finished product on wheat, ensure safe sludge parameters shall be made at potato, tomato crops suggests the addition of up tov1 T/ ha. Currently, AMC is using this all STPs, and the sludge from plants that show in its gardens. Grit generated from this plant is disposed of in the open areas around while non-acceptable quality shall not be accepted at the grit at STPs is dumped in dumpsites or low-lying areas. the hygienization facility. ▪ Sludge treated in hygenisation facility shall be used in gardens, provided it gets Fertilizer (Control) Order certification and for wider use subject to FCO certification for such use. 2.8 Baseline Environmental Quality 2.8.1 Air Quality CEPI Index of Ahmedabad (Naroda and Odhav industrial areas) is 57.11 and is classified as ▪ Mitigation measures shall be planned for dust/ air Other Polluted Industrial Area (CEPI <60). Sulfur Dioxide and Nitrogen Dioxide show an pollution during construction and O&M, mainly in increase since 2016. The main sources of air pollution here are vehicles and emissions areas closer to habitations and other sensitive from coal-fired power plants. The burning of rubbish and garbage at the Pirana dumping receptors. yard and ceremonial burning (religious) add to air pollution. To protect local communities ▪ There is an opportunity to tap and use gases (eg: from rising air pollution levels, AMC has developed two key tools: an air quality index Biogas, bioCNG) generated as a fuel substitute (AQI), and Air Information & Response (AIR) Plan. Some of the STPs have facilities to collect and this shall be ensured in the design of STPs. and use gases generated as biogas (Eg: Pirana) 2.8.2 Soil Quality Key soil polluted areas of Ahmedabad include its waste dumping sites and Industrial areas. ▪ Designs, construction protocols, and schedules Sludge and grit disposal from treatment plants are mostly in the open, except a tenth of it shall guide minimizing the impacts on soil quality. is currently treated in the radiation facility and used in gardens. Sabarmati sediment may ▪ Construction materials, wastes, chemicals, and be polluted from runoffs from industrialized/urban areas along its flow path. Vatva TSDF fuels shall be covered and safely placed to avoid in Ahmedabad has been closed and capped. There is at present no TSDF/ incineration spillage (even during extreme events). Grit and facility in the city and the nearest one is at Viramgam (60 km from the city). Grit from STPs sludge storage, drying, and disposal need to be and Hygenization facilities are disposed of in open or low-lying areas. well planned at the layout/design stage. 2.8.3 Water Quality CPCB River water quality monitoring data (2019) shows that DO levels of Sabarmati waters ▪ It is important to conduct appropriate quality drop while BOD and COD rise drastically as one moves downstream from Dharoi dam. testing of inflow sewage & outflow of treated Water near Vasna Narol bridge shows parameters beyond permissible limits with high sewage while conducting ESIAs/Audits. From pollution. GPCB (2020) observed improved quality of river Sabarmati at Miroli, A/C with various STP units for audit; minimum 1-day River Vatrak at Vautha and V.N. Bridge during the lockdown, with reduction of BOD and composite sample constructed by hourly Grab COD. The National Green Tribunal (December 2019) observed high pollution levels in the samples of at least 1lit at end of every hour from ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 21 List Aspects Description Key pointers for E&S risk identification and NO: Management Khari River and KhariCut Canal. A study by IIT Gandhinagar points to the presence of heavy each unit process of STP and then taking 100ml metals in the River Sabarmati - copper levels were 7 to 9 times higher than Bureau of from each of these 1-liter samples collected Indian Standards (BIS) limits. Nickel was found to be 2 to 5 times higher; iron, 4 to 5 times thereby totaling quantity of 2400ml for 24hrs. higher; selenium, 4 to 10 times higher; and chromium, 8 to 9 times higher. ▪ It is important to ensure arresting the inflow of industrial wastes, wastewater wastes, Sewage Discharge and Resultant Pollution due to existing STPs: Existing STPs were litter/leaves while designing new networks, designed to comply with the sewage discharge standards (BOD<20mg/l, COD<100mg/l, managing existing networks. TSS<30mg/l. However test results indicates that these need process/technology up- ▪ Waste traps and sensors at pumping stations and gradation to comply with the suggested discharge standards. AMC aspires to achieve the the network would help in monitoring polluting latest stringent standards suggested by National Green Tribunal for best environmental sewer stretches and prepare action plans to arrest effects. Existing STPs shall be upgraded so that they meet the discharge criteria set by NGT flows from such areas. (BOD<10mg/l, COD<50mg/l, TSS<20 mg/l, TN<10 mg/l, TP<1mg/l) and as desired by AMC, ▪ While upgrading existing or constructing new and WB EHS. In addition, monitoring mechanisms shall be improved for sewage quality STPs it is important to encourage policy, area and overall environmental improvement. improvements, and design interventions to (i) Industrial Pollution: Many farmers mainly to the east and south of the city raise the issue integrate mechanisms to detect inflow of heavy of illegal dumping of chemical effluent from industrial areas (mainly to the east of the city). metals and phenolic compounds into all STPs, (ii) GIDC Industrial estates have CETPs, most of the industries have established ETPs, mega Design to include appropriate treatment pipelines and is planning to have a mega line to Deep-Sea Disposal Outfall discharge trade mechanisms for pollutants, phenolic compounds, effluents to the ocean. and other parameters following MoEFCC/ NGT guidance (shall be assessed in the DPRs or feasibility reports). 2.9 Institutional Urban Development and Urban Housing Department, Government of Gujarat; AMC, ▪ Capacities to manage environmental and social Baseline Ahmedabad Urban Development Authority (AUDA), Gujarat Urban Development Mission, aspects is moderate. AMC has environmental are the key institutions implementing this project. Various state government departments engineers and planners to oversee infrastructure are involved in water supply and drainage in Gujarat, including; ii) Narmada and Water development and operation. However, dedicated Resources, Water Supply and Kalpsar Department, (ii) Gujarat Water Supply and Sewerage environmental and social capacities are essential Board (GWSSB) (iii) Gujarat Water Infrastructure Limited (GWIL) (iv) Irrigation Department at the PIUs and for long term comprehensive (v) Industries Department, and (vi) Forest Department in addition to Gujarat Pollution environmental and social management of the Control Board (GPCB). These institutions and applicable directions of the National Green region. Tribunal will be directly/indirectly consulted/approached for various project activities. ▪ Of particular importance in the case of this project are the Drainage department, Garden Department and Biodiversity Management Committee, Town Planning Department of AMC, ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 22 List Aspects Description Key pointers for E&S risk identification and NO: Management Heritage Department, industries department, Irrigation/water resources department, and GPCB. Estates wing and Urban Community Development wings of AMC are involved in assisting the land/Row procurement, R&R of PAPs, livelihoods support activities. PIU shall closely coordinate with these two departments regarding identification and mitigation of impacts on account of land acquisition/ construction stage economic displacement. AMC and GUDM with augmented capacities for environmental and social management, the Industries Department/GIDC, Water Resources Department, and GPCB can together effectively plan, monitor, and ensure a good living environment for the people. 2.10 Regional Impacts The geographic scope of larger cumulative impacts would be Ahmedabad city and ▪ Sabarmati, Khari and most Lakes in the city are downstream villages, till Vautha where Sabarmati& Khari meets other rivers like Vatrak, non-perennial, and modified habitats. However, and there are coastal impacts on water (tidal influence, water mixing and salinity). impacts on Thol, Santej wetlands outside AMC limits and that on Chandola Lake and any other Natural environmental drivers/stressors are the slight natural slope of the city to the lake which hosts migrant / other species shall be south, wind direction predominantly from the southwest, river flow paths, and extreme examined during ESIA. Cumulative impacts shall events. The key ecosystem components in the project area are be considered as part of ESIA for sub-projects with (i) Water: the two rivers Sabarmati and Khari; Lakes: Water quality degradation impacts on listed VECs. Proposed infrastructure from multiple point source discharges. shall consider impacts of / on other projects (ii) Air (odor): The population and heritage areas mostly to the central and southern (existing and proposed) in their influence or parts of Ahmedabad impact area (for example: proposed barrage near (iii) Land and Soil: Diminished land fertility and agricultural productivity in Koteswar STP). downstream villages affected by polluted inflow from upstream areas including the city of Ahmedabad (iv) Biodiversity: Thol sanctuary and Santej Lake, in case of sub-projects in the North ▪ Impacts on heritage components shall be or northwest zones of the city, Chandola Lake to south east and other Lakes if assessed and Heritage Management Plan shall be found important for biodiversity during ESIA. ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 23 List Aspects Description Key pointers for E&S risk identification and NO: Management The stretch from Vasna to Vautha is considered as the critical stretch, carrying pollution prepared as part of ESIA in case of any impacts (but diffused – industrial pollution from the entire region, wastes and sewage from rural identified. and peri-urban areas as well - not fully attributed to pollution from STPs in the city) from both the rivers and canal. Further, the stretch from Ahmedabad (Sabarmati Ashram) to ▪ Health Impacts due to no-flow on Sabarmati shall Vautha is considered as among the most polluted stretches in India by River action Plan be minimised. It is not advisable to let sewage or for Ahmedabad, NGT and CPCB. This region south of the city will be the impact area for drainage into city riverfront. Aerators may be a the project overall though pollution is heavily contributed by the entire region - north of temporary solution, but flow shall be ensured for Ahmedabad through the irrigation canals, to the west of Ahmedabad through canals, land best effects. pollution from highly industrialised peri-urban and rural areas, east of Ahmedabad through Kharicut canal and Khari river. Unless reuse of treated sewage is suggested, the ▪ Climate Resilience and Disaster Management Plan Impact area for STPs at Vinzol area will be till the point Khari meets Sabarmati River, while shall be made as part of DPR for all infrastructure impact area for those STPs at Pirana, Vasna and upstream discharging into Sabarmati (ie. under the project, specially those in proximity to If no reuse is suggested) will be villages downstream of Sabarmati. Impact area for those Vasna Barrage (diversion structure). All types of STPs which reuse treated sewage through Fatehwadi will be villages (industrialised) near infrastructure downstream of Vasna Barrage Visalpur and changodar in the command area of Fatehwadi Canal. All these will fall under (including all existing structures and their the larger project impact area till Vautha. STPs have Consent from CPCB to discharge of upgradation) need to take precautions to protect treated sewage in Sabarmati or Kharicut Canal. Currently discharge of treated sewage facilities and operations during such extreme through Fatehwadi Canal for supporting downstream agriculture follows a request from events. Irrigation Department, to serve the water scarce region. ▪ Guidance on management and mitigation Sabarmati has no flow most of the days in a year. It receives required water to retain water measures to be followed under (i) Policy and at the city’s riverfront for aesthetics and recreation. Water in the riverfront can be Institutional aspects, (ii) Infrastructure and stagnant for 25 – 45 days during summers. Dilution of pollutants due to river water / flow service improvements for Wastewater and happens only during monsoons. Drainage, and (iii) Improving regional Barrages are certified safe by State Dam Safety Organisation and owner, Irrigation (Water environmental conditions; during design/ESIA Resources) Department during their pre and post monsoon inspection reports annually and implementation, operation & maintenance of and required maintenance activities are carried out regularly. A new barrage is proposed sub-projects are presented in Annexure A upstream of Vasna Barrage to extend the riverfront. This will be near proposed Koteswar (Annexures). STP, but not considered an associated facility under ESS1 definition. Flooding during monsoons / extreme events need consideration while designing and upgrading STPs, and ▪ Flooding and other issues downstream of the other infrastructure. River Action Plan for Sabarmati (suggested by NGT and reported Vasna Barrage will be analysed during monthly by GPCB) considers aspects like managing environmental flow, good irrigation implementation stage, and required measures practices, Flood Plain Management, and greening the river edges. will be incorporated in the detailed design for ESMF for G- ACRP, 2022 Summary of Baseline Environmental and Social Characteristics 24 List Aspects Description Key pointers for E&S risk identification and NO: Management STPs for safety (Refer Annexure D on Dam Safety, Annexures) The project would ensure reducing the pollution load (BOD, COD, TSS, Ph, N) in Sabarmati and Khari, and reducing GHG emissions. . Reuse of treated sewage shall be encouraged. For discharge of treated sewage into Fatehwadi Canal, (i) this shall be agreed with GPCB, and Consent shall be amended to reflect such discharge through Fatehwadi Canal, (ii) detailed study, consultations and perception survey shall be undertaken on all impacted downstream villages on usage of this water for irrigation during the Detailed Design Stage, before confirming reuse of treated water for irrigation, as requested by Irrigation Figure 9: Expected Improvement in Discharge of Treated Sewage due to the Project Department. It is estimated that the project can ensure around 85 percent reduction in pollution load ▪ Screening, categorisation and extent and type of on Sabarmati and Khari (Vahela, and then the River) by upgrading and constructing new E&S due diligence for sub-projects are guided by STPs conforming to NGT standards. AMC plans to convert at least 50 percent of its existing this ESMF. treatment system to SBR technology by 2025. G-ACRP aims to support AMC in achieving ▪ Key agreements including due diligence this goal. G-ACRP would better manage around 875 MLD of sewage with attention on requirements, reporting requirements, and energy efficiency and reuse (however, type of treatment technologies for each STP will be institutional capacities, are included in ESCP. finalised only by the DBOT contractor during implementation stage). By providing treatment for additional 350 MLD of sewage, the project would reduce 261100 tCO2e annually. In addition, the project also would improve canals and lakes which are Stagnant, overloaded open collection sewers or ditches/canals are likely significant sources of CH4. ESMF for G- ACRP, 2022 Regulatory Framework 25 CHAPTER 3. POLICY, LEGAL AND REGULATORY FRAMEWORK Applicable National and State regulations and the World Bank Environmental and Social Framework and Standards guide effective management of environmental and social aspects; including siting criteria, environmental pollution control requirements, institutional mechanisms, occupational health and safety requirements, resource utilization, considerations for cultural heritage, and social aspects as well as land acquisition, labor and working conditions, livelihoods, consultations, and information disclosure. A compilation of the key environmental and social regulations and guidelines applicable to various aspects under consideration in this project is presented here. 3.1 Environmental and Social Laws/ Regulations Applicable for G-ACRP There are several national/state-level regulations and policies potentially applicable to G-ACRP sub- projects. Following section details out regulatory framework applicable to G-ACRP. 3.1.1 National Regulations The need for protection and conservation of the environment and sustainable use of natural resources is reflected in the constitutional framework of India and the international commitments of India. The Constitution under Part IVA (Art 51A-Fundamental Duties) casts a duty on every citizen of India to protect and improve the natural environment including forests, lakes, rivers, and wildlife, and to have compassion for living creatures. Further, the Constitution of India under Part IV (Art 48A-Directive Principles of State Policies) stipulates that the State shall endeavor to protect and improve the environment and to safeguard the forests and wildlife of the country. After the Stockholm Conference, the National Council for Environmental Policy and Planning was set up in 1972 within the Department of Science and Technology to establish a regulatory body to look after the environment-related issues. This Council later evolved into a full-fledged Ministry of Environment and Forests recently renamed as Ministry of Environment, Forests and Climate Change (MoEF & CC). MoEF & CC was established in 1985, which today is the apex administrative body in the country for regulating and ensuring environmental protection, and lays down the legal and regulatory framework for the same. Since the 1970s, several environmental legislations have been put in place. Today, MoEF & CC and the Central and State Pollution Control Boards (CPCB and SPCBs) together form the regulatory bodies; while National Green Tribunal is tasked with providing an effective and expeditious remedy in cases relating to environmental protection, conservation of forests, and other natural resources, and enforcement of any legal right relating to the environment. Some of the important legislations at the national level for environment protection are as follows: Act/Rule/ Guidelines Regulations/Policies related to Environmental Conservation & Management • National Environment Policy, 2006 • The Environment Protection (Act) 1986 and The Environmental Protection Rules 1986 • Environmental Impact Assessment Notification, 2006 • The Water (Prevention and Control of Pollution) Act, 1974 and The Water Cess Act 1977 • The Air (Prevention and Control of Pollution) Act. 1981 • The Noise Pollution (Regulation and Control) Rule,2000 • The Wildlife Protection Act, 1972 • The Wetlands (Conservation and Management) Rules, 2017 ESMF for G- ACRP, 2022 Regulatory Framework 26 • The Biodiversity Act of India, 2002 • The Manufacture, Storage And Import Of Hazardous Chemical Rules, 1989 • Batteries (Management and Handling) Rules, 2001 • The Motor Vehicle Act, 1988 & Motor Vehicles Rules, 1989 Regulations Related to Waste Management • Solid Waste Management Rules, 2016 • Construction and Demolition (C&D) Waste Management Rules, 2016 • Plastic Waste Management Rules, 2016, amended 2018 • Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, amended 2019 • E-Waste Management Rule, 2016, amended 2018 Pesticides/ Insecticide related Regulations: • Insecticide Act 1968 and Rules 1971 • Draft Bill on Pesticide management, 2020 introduced in Rajya Sabha in March 2020 Other Regulations/Policies/Guidelines applicable to various construction/implementation activities • Central Ground Water Authority- ‘Guidelines to control and regulate groundwater extraction in India’ September 2020 • The Building & Other Construction Workers (Regulation of Employment & Conditions of Service) BOCW Act, 1996 • Child Labour (Prohibition and Regulation) Act, 1986 and Rules, amended 2016 and • Child Labour (Prohibition and Regulation) Amendment Rules, 2017 • Minimum Wages Act, 1948 • The Bonded Labor System (Abolition) Act 1976 • Workmen’s Compensation Act, 1923 & Rules 1924 • Interstate Migrant Workmen Act 1979 • Ancient Monuments and Archaeological Sites & Remains (Amendment and Validation) Act 2010 • Indian Treasure Trove Act, 1878 • Right to Information Act, 2005 • Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act 1989 and further Amendments 2018. • The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 • The Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013 • Acts/ Rules applicable to land acquisition, RoW use, encroachments on municipal drains, etc.: The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation, and Resettlement Act, 2013. The Honourable Supreme Court of India order, on removal and restriction of encroachment of religious structures on the public space. These important environmental and social legislations have been briefly explained in Annexure B (Annexures), with a description of its relevance in this project, availability of technical guidelines for its implementation, and institutional responsibility. 3.1.1.1 Technical Guidelines on Sewerage and Drainage at National Level Central Government agencies have issued various guidelines for various aspects and associated aspects of sewerage and drainage projects. The most important guidance applicable to this project is listed herewith a description of the guidelines presented in Annexure B (Annexures). ESMF for G- ACRP, 2022 Regulatory Framework 27 Central Public Health and Environmental Engineering Organisation (CPHEEO), Ministry of Urban Development (MoUD) • Manual on Sewerage and Sewage Treatment Systems, 2013 • Manual on Storm Water Drainage Systems, 2019 • Manual on Operation and Maintenance of Water Supply System, 2005 • Manual on Solid Waste Management (applicable to screenings, sludge, grit, other wastes from premises) • Manual on Municipal Solid Waste Management – 2000 • Manual on Water Supply and Treatment -1999 Guidelines and Advisories • Guidelines for Decentralized Wastewater Management • Standard Operating Procedure (SOP) for Cleaning of Sewers and Septic Tanks • Advisory note on Septage Management in Urban India • National Policy on Fecal Sludge and Septage Management • Advisory on Public And Community Toilets • Advisory on Tariff for Water supply and Sewerage • Recent Trends in Technologies in Sewerage System. Central Pollution Control Board • Guidelines for Management of Sanitary Waste, 2018 • Guidelines on Environmental Management of Construction & Demolition (C & D) Wastes 3.1.2 State-Level Regulations Key State-level regulations applicable to the project include the following. Specific regulations applicable for sub-projects shall be updated and discussed in ESIAs. A detailed description of these regulations is presented in Annexure B (Annexures). • Gujarat Provincial Municipal Corporations Act, 1949 • The Gujarat Infrastructure Development Act, 1999 • Gujarat Irrigation and Drainage Act, 2013 • Gujarat Irrigation and Drainage Rules, 2014 • The Gujarat Water Supply and Sewerage Board Act, 1978 • Saurashtra Felling of Trees (Infliction of Punishment) Act, 1951 • The Gujarat Highways Ac, 1955 • The Gujarat Water and Gas Pipelines (Acquisition of Right of User in Land) Act, 2000 • Gujarat Industrial Development Act, 1962 • The Gujarat Special Economic Zone Act, 2004 • The Gujarat Vacant Lands in Urban Areas (Prohibition of Alienation) Act, 1972 • The Gujarat Town Planning and Urban Development Act, 1976 • The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation, and Resettlement Gujarat Amendment) Act, 2016 (effective from August 2016) • The Gujarat Ancient Monuments and Archaeological Sites and Remains Act, 1965 • The Gujarat Fisheries Act, 2003 • The Gujarat Public Premises (Eviction of Unauthorised Occupants) Act, 1972 • The Gujarat Slum Areas (Improvement, Clearance, and Redevelopment) Act, 1973 • Gujarat Special Investment Region Act, 2009 • Gujarat State Disaster Management Act, 2003 • Gujarat Municipalities Act, 1963 • Gujarat Regularisation of Unauthorised Development Act, 2011 ESMF for G- ACRP, 2022 Regulatory Framework 28 • Gujarat Street Vendors (Protection of Livelihood and Regulation of Street vending) Rules, 2016 • Gujarat Government-Policy for Reuse of Treated Wastewater, 2018 • Gujarat Government-The ‘Urban Sanitation and Cleanliness Policy, 2018 • Gujarat (Right of Citizens to Public Services) Act, 2013 • Gujarat Fire Prevention and Life Safety Measures Act, 2013 • Gujarat Green Cess Act, 2011 Essential Compliance Requirements In the absence of compliance with existing regulations, environmental parameters would be impacted. To ensure avoidance, mitigation, and management of impacts, all proposed sub-projects must meet the compliance requirements set out by regulators. Annexure B (Annexures) also presents the compliance requirements for sub-projects. 3.1.3 The World Bank’s Environmental & Social Standards (ESS) The World Bank’s Environmental and Social Standards (ESS) are a cornerstone to its support for sustainable development. The Environmental and Social Standards set out the requirements for Borrowers relating to the identification and assessment of environmental and social risks and impacts associated with projects supported by the Bank through Investment Project Financing. The objective of these policies is to prevent and mitigate undue harm to people and their environment in the development process. Any project that is likely to pose any form of adverse environmental and social risks and impacts will trigger the relevant ESSs. The relevance of project activities to various ESSs and gaps with respect to country regulations are described below in Table 1. ESMF for G- ACRP, 2022 Regulatory Framework 29 Table 1: World Bank’s Environmental and Social Standards, Gaps vs National Systems, Gap filling measures ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ESS 1 ▪ To identify, evaluate and manage the The ESS1 applies to all projects/sub- ESS1 is applicable for all projects, sub-projects, and Associated Assessment environmental and social risks and impacts projects with the environment and/or Facilities5. As per EIA Notification, 2006, Sewerage/drainage and of the project in a manner consistent with social risks and/or impacts. G-ACRP projects do not require prior Environmental Clearance (EC). Management the ESSs. involves construction and upgradation of However, ESF/ESS1 requires that risks and impacts of projects of ▪ To adopt a mitigation hierarchy approach to: sewerage and drainage networks, are assessed and managed. Gaps with national systems exist Environmental - Anticipate and avoid risks and impacts treatment plants, improvement of water regarding assessments, consultations, monitoring, and ESCP. and Social Risks - Where avoidance is not possible, bodies and will have environmental and The following additional measures are required: and Impacts minimize or reduce risks and impacts to social impacts during the planning and • Conduct an environmental and social assessment of the acceptable levels implementation phases. proposed project duly identifying risks and impacts; also - Once risks and impacts have been ESS 1 is relevant including cumulative impacts in case of STP clusters minimized or reduced, mitigate An Environmental and Social Management • Undertake stakeholder engagement and disclose - Where significant residual impacts Plan (ESMP) must be prepared to take into appropriate information following ESS10. remain, compensate for, or offset them, consideration the potential social and • Develop project level GRM in accordance with SEP and were technically and financially feasible environmental impacts or risks already worker GRM in accordance with LMP - To adopt differentiated measures so that identified & assessed in ESIA. • Develop an ESCP, and implement all measures and adverse impacts do not fall Organizational structure with roles and actions set out in the ESCP (part of the legal agreement), disproportionately on the disadvantaged responsibilities of the team within the and or vulnerable, and they are not implementing organization is required. • Strengthen organizational capacity and competency to disadvantaged in sharing development Considering the land acquisition, manage E&S risks benefits and opportunities resulting from burrowing & trenching activities, and • Training for security and safety workers the project disturbance to the local public due to • Emergency preparedness and response ▪ To utilize national environmental and social construction activities and additional • GBV/ SEA/ SH risk mitigation plan institutions, systems, laws, regulations, and traffic along common property/ roads, a • Conduct monitoring and reporting on the procedures in the assessment, Stakeholder Engagement Plan (SEP) needs environmental and social performance of the project development, and implementation of to be developed and implemented as well against the ESSs projects, whenever appropriate as adequate disclosure needs to be done. This should aim to inform the community about project-related adverse impacts or 5Ref para 11, ESS1, ESF 2016 ESMF for G- ACRP, 2022 Regulatory Framework 30 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ▪ To promote improved environmental and risks. Grievance Redressal Mechanism social performance, in ways that recognize (GRM) will be implemented in this project and enhance Borrower capacity System of ESS implementation monitoring with periodic audits will be established at the site. ESS 2: Labour ▪ To promote safety and health at work The ESS 2 applies to workers (construction The National legal provisions almost cover all requirements in and Working ▪ To promote the fair treatment, non- & operation) directly engaged by the ESS2 except relating to community workers and a functional Conditions discrimination, and equal opportunity of borrower (direct workers), EHS, workers GRM for different types of workers. project workers engaged through third parties (contracted Hence, an overall project-level Labour Management ▪ To protect project workers, including workers), as well as workers engaged by Procedure (LMP) will be prepared to meet the ESS2 vulnerable workers such as women, persons the client’s primary suppliers & contractor requirements. with disabilities, children (of working age, (primary supply chain workers). The project-specific OHS management plan will use following this ESS), and migrant workers, The project will involve the employment of appropriate good international practices/standards (such as contracted workers, community workers, direct and contracted workers during WBG EHS guidelines, ILO standards, International Tunnelling and primary supply workers, as appropriate. construction and operation phases. Association standards) which will be followed in conjunction ▪ To prevent the use of all forms of forced The nature of work on all projects has with requirements defined under various Indian legislations. labor and child labor. requirements of skilled manpower. Legislation related to Interstate migrant workers and their ▪ To support the principles of freedom of ESS 2 is relevant rights to be assessed for each sub-projects. Guidelines and association and collective bargaining of directives issued by the Central Government time-to-time for project workers in a manner consistent with migrant workers due to pandemics should also be taken into national law consideration. ▪ To provide project workers with accessible Further, the LMP will contain: means to raise workplace concerns − Risk assessment of labor influx on adjoining host communities, − Assess the risk of social conflicts, pressure on resources, and adaptive behavior of communities to address the associated risk emerging from labor influx − Prepare mitigation Plan – LI as part of the LMP. − How the implementing agency, as a part of oversight procedures will need regular monitoring of compliance to the aforementioned guidelines/ requirements and ensure that these are met at project sites. ESMF for G- ACRP, 2022 Regulatory Framework 31 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures − Internal audits and follow-up on corrective actions to be undertaken to assess the efficacy of the oversight system at the project site. − Recognizing and addressing the needs and requirements of the female workers/laborers. Refer to Factories Act for health, safety, and welfare facilities/ amenities to be provided for workers and specifically for female workers. − Ensure adequate facilities and amenities, including health & sanitation, security, waste management, and disposal measures, adequate living/ sleeping facilities and space per person; potable water that meets national standards and standards as laid down by ILO; toilets, washing, and cleaning facilities; canteen/ mess or fuel for cooking; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste at the labor camp. − Facilities for female workers to be ensured at the site and in labor camp such as separate toilet facilities and creche for children etc. The agency will periodically review and monitor the condition of the labor camps at all the mentioned project sites. The worker accommodation (where needed) standards as laid down by ILO to be followed. The implementing agency as a part of oversight procedures will need regular monitoring of compliance to the aforesaid guidelines/ requirements and ensure that these are met at project sites. Internal audits and follow up on corrective actions will also need to be undertaken to assess the efficacy of the oversight system at the project site Borrowers should develop site-specific HR policies in line with the HR Policy at their State & City level. They or their appointed contractor, if any, should inform their employees about their rights under national labor and employment laws. ESMF for G- ACRP, 2022 Regulatory Framework 32 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures Equal opportunity should be given to both men and women depending on their skills and capacity wages, work hours and other benefits should be as per the national labor and employment Laws at the project sites. Grievance Redressal Mechanism for workers should be framed under the LMP and the same to be implemented at the project level. (Project level GRM described in the SEP) This is applicable both during the construction and operation phase and should be supervised by AMC. Provide workers (contractual and AMC workers) with a safe and healthy work environment, considering risks inherent to the project sector. Manual scavenging is prohibited under the act namely ‘The Prohibition of Employment as Manual Scavengers and their Rehabilitation Act 2013’. Any such activity needs to be reported to the concerned authorities. ESS 3: Resource ▪ To promote the sustainable use of The project aims to prevent pollution of The majority of ESS3 requirements are addressed directly by Efficiency & resources, including energy, water, and raw the city and its region by ensuring full existing regulations and indirectly for resource efficiency, Pollution materials treatment of wastewater by upgrading and pollution prevention, and management aspects. Prevention and ▪ To avoid or minimize adverse impacts on constructing STPs and improving resilience More specifically the following compliance requirements shall Management human health and the environment by through drainage improvements. be followed: avoiding or minimizing pollution from Risks and impacts on all environmental − Water for construction activities should be sourced & project activities components due to construction and managed according to local permission & capacity. ▪ To avoid or minimize project-related operation of sewage plants, networks − Localized and temporary impact on water quality is likely emissions (drainage and sewage) canal during the construction phase. However, impacts would be ▪ of short and long-lived climate pollutants developments, etc. temporary and manageable. ▪ To avoid or minimize the generation of In case the construction & operation phase − Contractors should implement measures during hazardous and non-hazardous waste involves any hazardous material, chances construction for the management of construction debris ▪ To minimize and manage the risks and of groundwater and soil contamination generated during construction. Further, PIU will ensure impacts associated with pesticide use cannot be ruled out. Contractor through its contractors that wastes like packing material, (construction & OM will be accountable for metal, debris, cement bags, drums/ cardboards, etc. are the collection and safe disposal of collected, stored, and disposed of to re-users or hazardous material and needs to keep a inappropriate authorized debris disposal areas. ESMF for G- ACRP, 2022 Regulatory Framework 33 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures record of mitigation measures to safeguard − The project site should be having appropriate facilities for against any future liability. Waste oil and collection, treatment, and disposal of sewage (septic tank other hazardous chemicals, construction, and soak pit) which is used both during construction and and demolition wastes from construction operation phases should be ensured activities may result in contamination of − Estimates of water abstraction and wastewater generated ground and nearby surface water. during the operational phase and expected impacts on the Assessment to include a reasonable existing sewerage system. evaluation of the volume of water − Extraction of gas generated due to treatment processes, extracted and wastewater produced and energy extraction Operation phase will generate Sludge and − Use of resource-efficient pumps, fuelling mechanisms Grit − Ensure the best treatment standards for sewage, and ESS 3 is relevant Monitor incoming and treated wastewater for pollution levels − Assess risks and impacts up/downstream of Vasna barrage; pollution and health and safety impacts, as part of the ESIA for the STPs in the southern part of the city near Sabarmati, and mitigation measures applied accordingly. − PIU through its contractors to ensure the implementation of mitigation measures for pollution impacts in ESMP ESS 4: ▪ To anticipate and avoid adverse impacts on This Standard applies to projects which National and State Acts cover for all ESS 2 and ESS 4 Community the health and safety of project-affected entail potential risks to the health and requirements, gaps exist for community exposure to health Health and communities during the project life cycle safety of affected communities from issues. Safety from both routine and nonroutine project activities. The project will involve − Assess risks and impacts of the health and safety impacts circumstances the transportation of large components, related to the Vasna barrage before finalising Detailed ▪ To promote quality and safety, and which may pose safety risks to the affected designs and mitigation measures applied accordingly. considerations relating to climate change, in communities. Impacts due Electrocution − A rapid assessment conducted during Nov 21 indicates that the design and construction of and Firing due to short-circuit, Accidents Phase 2 sub-projects sites and conditions (Kharicut canal, infrastructure during trenching, burrowing, cutting, Chandrabhaga Nala, and lakes) may cause community ▪ To avoid or minimize community exposure chipping and piling, Physical injuries, health and safety impacts and require mitigation measures to project-related traffic and road safety accidents by entering construction site by − The gaps need to be addressed through suitable provisions risks, diseases, and hazardous materials locals, side slip of embankments, loose soil, in ESMP. Also, contractor obligation as part of ESMP for ▪ To have in place effective measures to Trip and fall hazards or by diseases due to Community health and safety to include the need for labor address emergency events unhygienic condition, etc. Influx Management Plan, Traffic, and road safety management Plan. ESMF for G- ACRP, 2022 Regulatory Framework 34 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ▪ To ensure that the safety of personnel and ESS 4 is relevant − A GBV/SEA/SH risk rating using the World Bank’s SEA/SH property is carried out in a manner that Risk Rating Tool will be generated and appropriate avoids or minimizes risks to the project- GBV/SEA/SH risk mitigation measures will be implemented affected communities using relevant good practice notes developed by the World ▪ To ensure that potential GBV/SEA/SH risks Bank. to communities and within the occupants of the labor camps themselves are mitigated ESS 5: Land ▪ To avoid involuntary resettlement or, when Land required for up-gradation of The gap exists specifically related to aspects such as Acquisition, unavoidable, minimize involuntary sewerage and drainage networks, STP identification of non-titleholders as PAPs; cut-off dates for Restrictions on resettlement by exploring project design facility. Private landowners, Hawkers & non-titleholders and valuation of structures with depreciation. Land Use, and alternatives. Squatters may be impacted during The gaps identified are addressed with suitable provisions in Involuntary ▪ To avoid forced eviction construction. RPF (See ESMF guidance manual section XI). Any adverse Resettlement ▪ To mitigate unavoidable adverse social and ESS 5 is relevant impacts related to physical or economic resettlement or loss economic impacts from the land acquisition of income due to loss of access are assessed during sub-project or restrictions on land use by (a) providing DPR preparation or implementation, then sub-project level timely compensation for loss of assets at RAPs will be prepared and implemented under the broad RPF replacement cost6 and (b) assisting guidance, as a mitigation measure. The RPF also addresses displaced persons in their efforts to impacts regarding temporary restrictions in movement due to improve, or at least restore, their livelihoods the laying of sewerage lines, phase 2 activities at Kharicut and living standards, in real terms, to pre- canal, Chandrabhaga Nalla, and lakes where encroachments displacement levels or to levels prevailing of 50-100 households, temples, parks (CPRs) are observed before the beginning of project (based on the rapid survey, exact impacts will be known during implementation, whichever is higher. ESIA) ▪ To improve living conditions of poor or Vendors, Squatters, Encroachers displaced and/or livelihoods vulnerable persons who are physically impacted. displaced, through the provision of adequate housing, access to services and Grievances will include adverse land-related impacts, loss of facilities, and security of tenure access, loss of income and livelihood, disruption in existing ▪ To conceive and execute resettlement livelihoods, disturbance, and related environment-related activities as sustainable development concerns caused by the construction activities. It should programs, providing sufficient investment incorporate procedures for lodging grievances, processing of resources to enable dis- placed persons to grievances, resolving grievances, and closing of grievances. benefit directly from the project, as the nature of the project may warrant ESMF for G- ACRP, 2022 Regulatory Framework 35 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ▪ To ensure that resettlement activities are The grievances would be addressed through direct & indirect planned and implemented with appropriate methods, call, email, SMS, social media, written, online, dis- closure of information, meaningful Suggestion Box, Community Meetings, and Meetings with consultation, and the informed participation Authorities responsible for welfare and development of the of those affected city. There would be one Grievance Redressal Cell (GRC) in AMC specific to the project. ESS 6: ▪ To protect and conserve biodiversity and The proposed project is in Ahmedabad city No specific Gaps to be addressed as policy/regulations support Biodiversity habitats wherein the presence of zoological park, biodiversity conservation, and livelihoods based on these exist. Conservation ▪ To apply the mitigation hierarchy and the gardens, many lakes, canal, and the and precautionary approach in the design and Sabarmati and Khari river and the project Biodiversity Management Plan will be implemented if Sustainable implementation of projects that could have may pose a threat to the biodiversity significant risks and adverse impacts on biodiversity are Management an impact on biodiversity through habitat loss, degradation and identified at the sub-projects stage. of Living ▪ To promote the sustainable management of fragmentation of habitat, invasive species, Natural living natural resource overexploitation, hydrological changes, If the project occurs within or has the potential to adversely Resources ▪ To support livelihoods of local communities, nutrient loading, pollution, etc. affect an area that is legally protected, designated for including Indigenous Peoples, and inclusive However, since most of the specific sites protection, or regionally or internationally recognized, it will economic development, through the for the project have not yet been known, be ensured that any activities undertaken are consistent with adoption of practices that integrate the ESIA will assess whether project the area’s legal protection status and management objectives conservation needs and development activities will have impacts on natural priorities. habitat and biodiversity. Impacts on Sabarmati, Khari rivers due to discharge of treated sewage from all STPs, and Thol sanctuary in case of sub-projects located to north or northwest zones of the city will be assessed ESS 6 is relevant ESS 8: Cultural ▪ To protect cultural heritage from the ESS 8 is relevant. Ahmedabad is a World No Gaps exist as existing regulations guide the protection of Heritage adverse impacts of project activities and Heritage City with many heritage precincts, cultural heritage. Provisions from the National Act meet the support its preservation monuments, and features, mostly in the ESS 8 requirements. Intangible cultural heritage aspects are ▪ To address cultural heritage as an integral ‘old city’ area. Works related to sewerage also conserved by City regulatory requirements – by the aspect of sustainable development network augmentation are proposed in the Heritage Department of AMC. ▪ To promote meaningful consultation with old part of the city, and hence there is a stakeholders regarding cultural heritage likelihood that the areas have several sites ESMF for G- ACRP, 2022 Regulatory Framework 36 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ▪ To promote the equitable sharing of and structures with religious, cultural, Areas within the radii of 100m and 300m from the “protected benefits from the use of cultural heritage archaeological, and historical significance. property� are designated as “prohibited areas� and The risks and impacts to cultural heritage “regulated areas� respectively. No development activity is include vibration and activities such as permitted in the “prohibited areas�. Development activities drilling, excavations, demolitions, causing a are not permitted in the “regulated areas� without prior disturbance, or other physical changes, permission from the Archaeological Survey of India (ASI) if the including air or water pollution-related site/remains/ monuments are protected by ASI or the State damage and risks to heritage structure, Directorate of Archaeology. Based on the location of the access restrictions to communities during preserved and protected sites and the nature of the proposed works, etc. The possible chance finding of project activities, the assessment will be undertaken for the notified cultural heritage site, beliefs, identifying adverse impacts on any such Cultural Heritage etc. may be located near the project areas. sites and CHMP will be developed for sub project. ESS 8 is relevant The Chance Finds Procedure will be provided in the ESMP in case of discovery of any artefacts/ structures, places with beliefs, and/ or settlement of yore in the future at the proximity of the project area. Implementation agencies including contractors, sub-contractors, and PMC officials will be provided with capacity building training on Chance finds procedures compliance. All impacts and risks on heritage will be addressed using a Cultural Heritage Management Plan (CHMP) as part of ESMP if screening indicates impacts on cultural heritage. Consultations with some stakeholders were held as part of ESMF consultations. Heritage core (the UNESCO World Heritage City) is excluded for any project interventions. Meaningful consultations will be held with stakeholders regarding cultural heritage in areas other than heritage core- All heritage in the city has been officially mapped, documented by AMC (Heritage Department). Special emphasis will be given on the importance of identifying cultural heritage in collaboration with communities during the stakeholder engagement process as part of ESIAs. ESMF for G- ACRP, 2022 Regulatory Framework 37 ESSs ESS Objectives Relevance to G-ACRP (Component 2) ESMF compliance requirements, Policy Gaps in National regulations vis a vis ESSs and proposed gap filling measures ESS 10: ▪ To establish a systematic approach to The G-ACRP includes the construction and There is a provision of public hearing in EIA notification . Stakeholders stakeholder engagement that will help upgradation of wastewater and drainage Further RFCTLARR Act 2013 mandates consultations with Engagement Borrowers identify stakeholders and build networks, treatment plants, improvement affected persons. However, the statutory process does not and and maintain a constructive relationship of water bodies, etc. All the proposed require the preparation of a SEP or equivalent document as Information with them, in particular, project-affected projects will immensely benefit the local well as conducting meaningful consultations and Disclosure parties population and may also expose them to information disclosure, that is accessible to all stakeholders. ▪ To assess the level of stakeholder interest environmental & social risks during the Measures to address the gap include – and support for the project and to enable construction & implementation phase. stake- holders’ views to be considered in Stakeholder Engagement Plan (SEP) preparation: project design and environmental and social As such, to have prior informed social Identification of project affected persons, interested parties - performance approval and mitigate the social civil societies, residents, Vulnerable groups – aged, women, ▪ To promote and provide means for effective implications, stakeholder engagement, disabled, children need to be engaged, informed, record their and inclusive engagement with project- consultation, feedback is required. views, suggestions & grievance and address the concerns. affected parties throughout the project life cycle on issues that could potentially affect ESS 10 is relevant Project Grievance Mechanism by addressing ES performance them feedbacks by the formal and informal process. ▪ To ensure that appropriate project Grievance redress system development – support task team, information on environmental and social the single-entry point at the AMC level. risks and impacts is disclosed to An appeals committee will be set up for the grievant if they stakeholders in a timely, understandable, are not satisfied by the outcome of GRM. accessible, and appropriate manner and format ▪ To provide project-affected parties with accessible and inclusive means to raise issues and grievances and allow Borrowers to respond to and manage such grievances. Note: ESS 7 and ESS 9 are not included in the table as they are found not applicable to the Project. ESMF for G- ACRP, 2022 38 The World Bank Group’s Environmental Health and Safety Guidelines The World Bank Group’s Environmental, Health, and Safety (EHS) Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP). EHS Guidelines are applied as required by their respective policies and standards. These industry sector EHS guidelines are designed to be used together with the General EHS Guidelines document, which guides users on common EHS issues potentially applicable to all industry sectors. The EHS Guidelines contain the performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable costs. Application of the EHS Guidelines to existing facilities may involve the establishment of site-specific targets, with an appropriate timetable for achieving them. The applicability of the EHS Guidelines should be tailored to the hazards and risks established for each project based on the results of an environmental assessment in which site-specific variables, such as host country context, the assimilative capacity of the region. Defined as the exercise of professional skill, diligence, prudence, and foresight that would be reasonably expected from skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. The circumstances that skilled and experienced professionals may find when evaluating the range of pollution prevention and control techniques available to a project may include but are not limited to, varying levels of environmental degradation and environmental assimilative capacity as well as varying levels of financial and technical feasibility. Applicability of specific technical recommendations should be based on the professional opinion of qualified and experienced persons. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures than those provided in these EHS Guidelines are appropriate, given specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternate performance level is protective of human health and the environment. The World Bank Group EHS Guidelines for Water and Sanitation, and General EHS Guidelines contain information on cross-cutting Environmental, health, and safety issues that can be downloaded via the following links. https://www.ifc.org/wps/wcm/connect/29f5137d-6e17-4660-b1f9-02bf561935e5/Final%2B- %2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES&CVID=jOWim3p https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainabilit y-at-ifc/policies-standards/ehs-guidelines As the component includes developing guidelines and systems for COVID-19 related waste management, sanitization, and public hygiene practices to be rolled out across all urban areas� – this activity should be informed by available guidelines on the COVID response E&S documents (https://worldbankgroup.sharepoint.com/sites/wbunits/opcs/Pages/pc/Operations-COVID19- Coronavirus-Information-03092020-081859/Overview-03092020-081941.aspx) ESMF for G- ACRP, 2022 39 In addition, the Bank Directive on disadvantaged and vulnerable individuals/groups (2016)6 and the labor influx guidance note (2016)7 will also be consulted for addressing various project activities. 6https://policies.worldbank.org/sites/ppf3/PPFDocuments/e5562765a5534ea0b7877e1e775f29d5.pdf 7http://pubdocs.worldbank.org/en/497851495202591233/Managing-Risk-of-Adverse-impact-from-project-labor-influx.pdf ESMF for G- ACRP, 2022 Assessment of Probabale impacts 40 CHAPTER 4. ASSESSMENT OF PROBABLE IMPACTS DUE TO SUB- PROJECTS 4.1 Sub-projects Typology The G-ACRP project is envisaged to support the drainage and sewerage network and its management in Ahmedabad across three components: The proposed sub-projects mainly focus on wastewater infrastructure, stormwater infrastructure, and the improvement of lakes/canals within the AMC area. In this section, the potential sub-projects are further divided into specific sub-project components and activities under each component to assess the potential environmental and social impacts. The following Table 2 presents the various components under the possible sub-projects and the activities that may come under various components. Table 2: Potential Sub-project Components and Activities Sub-projects Components Activities Wastewater/Sewage i. Expanding and rehabilitating the • Demolition of some/ all the existing Management sewerage network and treatment structures infrastructure: • Site clearance, excavation/ earthworks/ • Up-gradation of existing STPs trenching • Construction of new STPs and • Dismantling/discarding old support infrastructure, equipment/parts • Rehabilitation of existing sewage • New construction activities, site networks, expanding sewage development, supportive infrastructure network including, pumping stations, manholes, ii. Developing treatment infrastructure for disposal facilities, alternate energy reuse of treated wastewater: means, reuse/recycling facilities • Tertiary treatment facilities for • Installing pipelines/machinery/ treated sewage equipment • New/expanding distribution • Shifting of existing roadside structures, network for sewage, only under/above ground utilities • (Note: Industrial waste water • Electrical and mechanical installations management facilities or networks • Storage of materials, wastes, by-products, or support infrastructure will not fuel, and chemicals be set up under this project) • Labor camps • Laboratory and offices, testing, monitoring facilities, and analytical activities • Green belt • Operations and management Stormwater iii. Expanding and rehabilitating the • Excavation/earthworks/ trenching drainage drainage network in the city: • Installing pipelines/machinery/ management • Rehabilitation of existing networks, equipment expanding drainage networks • Construction work employing traditional • Reviving the natural drainage system techniques, micro tunneling, and other of the city including major canals technology running across the city through • Removal of silt/waste coordinated technical solutions to • Sidewalls and supportive infrastructure address water contamination issues: including rainwater harvesting, silt • Canal improvements, rehabilitation of trapping, pumping stations, manholes, existing networks, expanding drainage sensors, and monitoring facilities networks ESMF for G- ACRP, 2022 Assessment of Probabale impacts 41 Sub-projects Components Activities • Installation of Storm Trap structures • Shifting of existing utilities • Labour accommodation • Operations and maintenance • Greening Rejuvenation of Lake development/ Rejuvenation • De-silting, De-weeding, Bioremediation Water bodies, Canal i. In-Situ Cleaning • Excavation/earthworks/ trenching Redevelopment ii. Catchment Area Treatment • Earthwork in embankment with (Afforestation, improvement of compaction, pitching to prevent rain cuts stormwater drainage) • New construction work iii. Strengthening of Bund • Installing pipelines/ machinery/ iv. Fencing (compound wall, chain link equipment fencing) v. Shoreline Development (Peripheral Pathway, Tree plantation) vi. Waterfront Eco-Development (Construction of Gate, parking area, play/ sitting area) vii. Measures for Prevention of Pollution (Interception & Diversion of sewage flow, Package STP, Public toilets) Canal Development • Excavation/earthworks/ trenching, i. CC lining in the Canal • Removal of silt/waste ii. Drainage Lines parallel to either • Construction work side of Canal iii. Miscellaneous work (cleaning, slope stabilization) River Rejuvenation • Excavation/earthworks/ trenching i. Installation of Weirs • Desilting, drilling ii. Creation of French Well iii. Industrial Effluent outfall Tapping RCC Pipeline 4.2 Environmental and Social Risks and Impacts Sub-projects include sewerage and drainage network laying and improvement of existing networks, construction of new STPs and upgradation of existing STPs, Lake/canal redevelopment. The project will ensure the overall health of the inhabitants, environmental improvement, and resilience of Ahmedabad city by improving stormwater drainage, sewerage systems, providing technical support for municipal revenue mobilization, developing a GIS-based real-estate asset inventory management system, appropriate tariff strategy for core urban services, technical support for land-based financing. The project also aims at longer-term sustainable development of the State and its cities through support to the Gujarat Urban Development Institute through GUDM to develop a lighthouse approach to absorb international best practices, implement them in leading cities and replicate them in the rest of the State. In addition, the project would support institutional capacity building, awareness creation, and studies (Technical Assistance). Proposed sub-projects would improve the environmental quality and thereby the quality of life in Ahmedabad. Sensitive environmental components such as the Sabarmati river and canals which run through the city, Khari River which passes near the city, urban lakes of Ahmedabad, and its open spaces would benefit by reduced pollution due to wastewater and overall environmental improvement of air water and soil, thereby supporting biodiversity. This would result in positive impacts on the flood management scenario in the city during monsoons and extreme events. Proper management of the improved facilities would promote resilience. ESMF for G- ACRP, 2022 Assessment of Probabale impacts 42 Expected risks and impacts due to construction and upgradation of sewerage and drainage networks, treatment plants if facilities are not properly planned, designed, and managed include (i) impacts on water environment of the water body receiving treated water or near construction/ storage areas, (ii) increased possibilities for pedestrian-vehicular conflicts and accidents during laying of networks mainly through congested inner city areas, (iii) noise and vibration due to construction activities disturbing surrounding structures including heritage structures in the vicinity, (iv) noise, light, water, dust, air, land pollution and disturbance to fauna/flora and nearby communities due to construction, activities, usage, O&M activities, (v) occupational and community health and safety (OCHS) risks on workers and communities, (vi) public inconvenience due to shifting of utilities, material transport, storage, construction and maintenance of proposed infrastructure, (vii) liquid and solid wastes during network laying, upgradation and construction of treatment plants and operations, construction and demolition waste which may include existing asbestos, batteries, hazardous wastes and e-wastes which need to be disposed carefully, (viii) sludge, other wastes and effluents/backwash water during O&M stages, (viii) labor camp related pollution and burden on shared resources, (ix) disturbances to activity spaces, parks, open spaces, natural habitats in the vicinity of work areas due to storage of materials and parking and movement of laborers, and construction vehicles, (x) solid, hazardous and e-wastes, (xi) physical and/or economic displacement due to land acquisition requirements and construction stage impacts, (xii) SEA/SH impacts due to influx of labour etc. Proposed components will involve several interdependent facilities and activities and all may not be financed under the project. Hence, the impacts of associated facilities may become relevant and will be identified during the design stage. G-ACRP is aimed at improving the environmental quality and overall quality of life of the city by improving sewage/drainage infrastructure and services to ensure the latest standards/guidelines set as per regulations. Hence, the overall impact would be beneficial to the people of Ahmedabad and those downstream of the receiving waterbodies. Most of the risks will be limited and largely localized, temporary i.e. during the construction stage. 4.2.1 Environmental and Social Risks and Impacts in Local Area The proposed project involves various activities during the construction and operation phases. The potential environmental and social risks and impacts of the proposed project in the local area on water quality and quantity, air quality, noise levels, and socioeconomic aspects of the area. Water: The main surface waterbodies in the city are rivers and lakes. The river Sabarmati bifurcates Ahmedabad into the western and the eastern parts. The Khari River runs almost parallel to the Sabarmati towards the east, beyond the city limits. One of the oldest irrigation schemes of Gujarat, the ‘Kharicut canal scheme’ passes through the eastern part of the city, also serving as a stormwater drain during monsoon, draining into the Khari River. The Kankaria, Vastrapur, Thaltej, and Chandola are among the many important ponds/ lakes in the city. The proposed project activities may potentially impact water quality and quantity during the construction, operation, and maintenance phases of sub-projects. Air Quality: Ahmedabad city with an estimated population of 7.3m residing in the municipal area spread over 488q. km, under the jurisdiction of AMC, is the country’s seventh-largest metropolis. The city can be described with three major zones a) the ‘walled’ city (within the fort walls) – old city of Ahmedabad in the central area to the east of River Sabarmati; b) industrial and residential localities to the eastern peripheral areas of the Old City; and c) plotted residential colonies and institutional areas in the ‘new city’ to the west of the old city across Sabarmati. ESMF for G- ACRP, 2022 Assessment of Probabale impacts 43 With the high population density and the metropolitan nature of the city, it has many vehicles, industrial and commercial activities which results in various sources of urban air pollution in the city. The proposed project activities may potentially impact the air quality during construction, operations, and maintenance of sub-projects with the addition of construction vehicles, construction activities, use of machinery, and fuel combustion. In addition, the odor may emanate from STP processes/release of gases, use of chemicals, sludge, and treated sewage and may impact the communities near STPs, pumping stations, and discharge points. Ambient Noise: The city has a dense population, commercial and industrial activities, a dense road network, and several sensitivities such as residential areas, heritage monuments, hospitals, schools, religious buildings, etc. Therefore, the proposed activities may potentially impact negatively on the ambient noise in the proximity. Socio-economic: Proposed infrastructure developments are in different parts of the city. Proposed sewerage and drainage networks will be along the main city roads, some in the very congested central city. Some of the sites may have sensitive land uses, receptors, heritage sites, and natural habitats, nearby. The proposed activities may negatively impact the traffic movement, may add to inconvenience of local public, may also impact the religious activities by an increase of air pollution, noise levels, construction vehicles and machinery, access restrictions, etc. The city has 54 heritage monuments (many dating back to the 15th century) protected by the Archaeological Survey of India - 32 in the Central Zone including fort walls and gates, traditional houses ('pols'), and their features. Many cultural/heritage areas which are mainly in the central city will be impacted by ongoing works - mainly network laying and lake/ Canal Improvement works. 4.2.2 Regional Environmental and Social Risks and Impacts The regional impacts of existing systems are mainly due to the discharge of treated sewage into the Rivers and Canals and sludge disposal. People of downstream villages of Sabarmati and Khari depend on the rivers mainly for irrigation. Pollution levels in the rivers are very high currently. Vasna barrage across Sabarmati to the South of the city regulates water flow downstream of Sabarmati. Any impact due to floods/disasters may also impact the STPs in the vicinity on the east and west banks of Sabarmati and its discharge of effluents. 4.3 Impact Assessment Methodology The methodology to assess the impacts at the sub-project level is presented here. Impacts are assessed based on Magnitude, Duration, Significance, and Likelihood of the impacts and Sensitivity of the receptors. 4.3.1 Magnitude and Duration of Impacts The assessment of magnitude is undertaken in two steps. Firstly, the key issues associated with the G-ACRP are categorized as beneficial or adverse. Secondly, potential impacts shall be categorized as High, Average, Low, or negligible based on consideration of the parameters such as: • Temporal extent (duration) and the likelihood of the potential impact; • The spatial extent of the potential impact; • Reversibility of the Impact; • Likelihood of the impacts ESMF for G- ACRP, 2022 Assessment of Probabale impacts 44 The magnitude of the potential impacts of G-ACRP is identified according to the categories outlined in Table 3. Table 3: Aspects for Determining the Magnitude of Impacts Aspects Magnitude Duration of the Long term (more than 20 Medium Term - Short Term - 1 to 2 Temporary - with no potential impact years) The lifespan of the years or Less than detectable potential Program (5 years) the lifespan of the impact project The spatial extent Regional – much beyond City - Beyond Site - Within project Micro - A specific of the potential project boundaries immediate Project site boundary location within the impact components, site project component boundaries, or local with no detectable area potential impact Reversibility of Irreversible - Potential Largely Reversible- Reversible - Baseline No change - Baseline potential impacts impact (including positive Potential impact returns Naturally or remains constant impact) is effectively requires a year or so with limited permanent, requiring with some intervention within considerable intervention interventions to return a few months to return to baseline to baseline Likelihood of Certain - Commonly occurs Likely - Usually seen Occasional - Occurs Unlikely to occur potential impacts under typical operating or occurring under most under abnormal, occurring construction conditions situations exceptional, or emergency conditions 4.3.2 Sensitivity of Receptor The sensitivity of a receptor shall be determined based on a review of the population (including proximity/numbers/vulnerability) and the presence of features on the site or the surrounding area. The criteria for determining receptor sensitivity of the program’s potential impacts are outlined in Table 4. Table 4: Criteria for Determining Sensitivity Sensitivity Levels Description High The vulnerable receptor with little or no capacity to absorb proposed changes or minimal/limited opportunities for mitigation Medium The vulnerable receptor with some capacity to absorb proposed changes or moderate opportunities for mitigation Low The vulnerable receptor with good capacity to absorb proposed changes or/and good opportunities for mitigation Negligible Non-vulnerable receptor 4.3.3 Significance of the impact The significance of potential impacts is established using the impact significance matrix shown in Table 5 below. Table 5: Assessment of Significance of Negative and Positive Impacts ESMF for G- ACRP, 2022 Assessment of Probabale impacts 45 Sensitivity/ Vulnerability/ Importance of Resource/ Receptor Low Medium High Magnitude of Negligible Negligible Negligible Minor Negative Impact Low Negligible Minor Moderate Medium Minor Moderate Major High Moderate Major Major Positive Impact Magnitude of Negligible Negligible Negligible Minor Low Negligible Minor Moderate Medium Minor Moderate Major High Moderate Major Major 4.3.4 Potential Key Environmental and Social Risks and Impacts The project activities are taken up over several years in phases (work packages) and the sub-projects proposed for implementation during the Initial Phase (first two years) are presented in Table 6 below. Separate ESIAs are being prepared for these after screening and categorization as guided by this ESMF. Table 6: Initial Sub-projects Phase 1 No of Capacity works (MLD) East Component 1 Sewage Treatment Plant Rehabilitation Pirana 180 MLD STP (ASP) – Improving Treatment Technology 1 180 and associated infrastructure West Component 1 Sewage Treatment Plant Rehabilitation/Construction Vasna 126 MLD STP (UASB) – to be upgraded to 375 MLD STP, – 1 126 to 375 Improving Treatment Technology and associated infrastructure Vasna 240 MLD STP (ASP) – Improving Treatment Technology 1 240 and associated infrastructure Most of the sub-projects would involve similar risks and impacts considering the nature of activities and broad locations. The sub-projects proposed for implementation during the subsequent phase (year 3 onwards) include Kharicut Canal Development, Chandrabhaga Nalla and Lake development, Conservation of Lakes, etc. A rapid assessment was conducted during Nov 2021 for phase these sub-project activities. Potential key environmental and social risks and impacts for the overall project activities are presented in Table 7 below. Separate ESIAs will be prepared for all project activities after screening and categorization as guided by this ESMF. Table 7: Potential key environmental and social risks and impacts for sub-projects typologies Sl No Sub-projects Components Potential E&S Risks, Impacts, and Opportunities (during Typology pre-construction, construction & O&M) 1 Wastewater/ i. Expanding and Preconstruction/ construction: Sewage rehabilitating the Management sewerage network and Landuse changes treatment infrastructure: • Negative: expansion of existing footprint, more coverage due • Up-gradation of existing to new construction/upgradation STPs ESMF for G- ACRP, 2022 Assessment of Probabale impacts 46 Sl No Sub-projects Components Potential E&S Risks, Impacts, and Opportunities (during Typology pre-construction, construction & O&M) • Construction of new STPs • Positive: Use of allotted space for appropriate land use, and support improving tree cover through a green belt & greening lake infrastructure, fronts, recreational facilities • Rehabilitation of existing Impact on-site and current users • Negative: Topography and drainage impacts on site, utility networks, expanding shifting, site alterations, clearance, siltation, drainage sewerage network clogging, waterlogging ii. Developing treatment • Positive: Opportunity to improve efficiency infrastructure for reuse Impacts on Air of treated wastewater: • Negative: Burning during site clearance, diesel Gensets and • Tertiary Treatment vehicle emissions, dust due to transport, increase in traffic & Facilities for Treated congestion while laying pipes, debris stockpiles, open storage sewage of materials, trenching, borrowing, topsoil removal, wind- • New/expanding blown dust, fire, and spills; increased impacts during disasters distribution network • Positive: Controlled activities on-site minimize gaseous emissions 2 Stormwater i. Expanding and Impacts on Water Bodies drainage rehabilitating the • Negative: Works on or near water bodies, material spill and management drainage network and leakages near storage areas, lack of waste/water containment Pumping Stations, allied on-site, lack of facilities (sanitation, waste management) at works in the city labor camps, bypass into waterbodies due to works, increased 3 Rejuvenation iii. Lake development/ impacts during disasters of Water Rejuvenation • Positive: Careful sourcing/reusing of treated water for bodies, Canal iv. Canal Redevelopment construction Redevelopme Impacts on Soil nt • Negative: wastes, existing sludge and grit, reduced permeability heavy runoff/sediments due to soil compaction, soil erosion, spilt cement, oil or chemicals, construction/demolition, hazardous and plastic wastes, topsoil loss, excavation/bulk earth movement, compaction) • Positive: compaction, grading minimizing erosion; greenbelt development improves tree cover Impacts on health of Fauna, Flora (biodiversity) • Negative: clearance of natural vegetation and roadside trees, birds/ animal habitats, clearance of weeds/herbs/ grass leading to the displacement of insects & birds, dust accumulation on plants, animals due to vehicle movements through unpaved areas, construction works, runoff polluting streams, waterbodies and flora/fauna therein, noise and vibration effects due to equipment, machinery, vehicles, activities. Direct impact by increment in noise & vibration due to construction activities on animals present in the zoo. • Positive: More trees planted by developing green belt Occupational Health and Safety of workers involved • Negative: waste, wastewater, accidents due to work types/ activities, vehicles/ heavy equipment, slips, fall, fire; lack of PPEs, training, guidance; increased impacts during disasters (esp. flooding, impact on project works/ activities leading to loss of time/ resources, site isolation) • Positive: Employment opportunities and facilities Community Health and safety • Negative: Disturbance and safety issues during works, Waste dumps creating dust, health impact, visual blight, accidents, congestion; excavation & trenching leading to falling, trip, congestion, pollution, Damage to building & infrastructure, roads, common property during pipeline laying, shifting of utilities, material transport, and storage, Risk of Communicable Diseases, the burden on shared resources by locals and the workers, pollution, and disturbance due to sourcing of ESMF for G- ACRP, 2022 Assessment of Probabale impacts 47 Sl No Sub-projects Components Potential E&S Risks, Impacts, and Opportunities (during Typology pre-construction, construction & O&M) materials, high noise & vibration due to machinery and work activities affecting sensitive receptors, Health, and safety of downstream users of polluted waters • Positive: Traffic Control during construction, better facilities arranged for communities, emergency responses, awareness increased Disturbance to Cultural Heritage, Visual blight • Negative: noise disturbances to visitors and users, vibration due to earthwork, compaction, micro-tunneling nearby affecting the safety of structures • Positive: Improvement for the area, increased awareness, facilities Impact on Socio-Economic, Households, communities • Negative: Displacement of squatters/ encroachers occupying Chandrabhaga river/Nalla bank who may be at risk due to Nalla overflow and erosion of banks during floods, limited impact of livelihoods as livelihood not observed in the specific locations, some impact on loss of access and traffic flow during implementation. There may be temporary impacts on shopkeepers, hawkers/ street vendors in market areas, and pedestrians and businesses in the congested area during implementation. • Positive: R&R will reduce health and safety issues related to bank erosion and impact during floods, the additional road on RCC works for better mobility, overall improvement in quality of life due to Nalla enclosure and reduction of solid waste currently discarded in open Nalla which leads to unsanitary conditions and risk to public health, Improvement in traffic flow, increased awareness, facilities, etc Operations and Maintenance: Impacts on Air • Negative: diesel Gensets and vehicle emissions, dust due to transport, debris stockpiles, and dust, open storage of materials, fire and spills, chlorine leakage, odor from operations, and sludge • Positive: lesser generation of gases, emissions & decreased odor nuisance (less dependence on electric fuel due to use of energy-efficient appliances) Impacts on Water • Negative: runoff of effluent/backwash water, solid waste storage, sludge and leachate, partial reuse of non-chlorinated treated water for site purposes, oil, plastics, and wastes carried through networks, lack of facilities (sanitation, waste management) at site office or camps, bypass into waterbodies due to O&M • Positive: Better quality of treated water possible to reuse reducing dependence on freshwater, the better quality of retained water in water bodies, microclimatic improvements; improved recharge and groundwater resource Impacts on Soil • Negative: wastes, sludge and grit, soil erosion, spilled cement, oil or chemicals, hazardous, plastic, and other wastes, excavation/ compaction during network O&M • Positive: better quality of sludge which can be used as a soil enricher, reuse of grit, less pollution of soil, sediments due to better collection and treatment of wastewater, clean lakes Impacts on health of Fauna, Flora (biodiversity) ESMF for G- ACRP, 2022 Assessment of Probabale impacts 48 Sl No Sub-projects Components Potential E&S Risks, Impacts, and Opportunities (during Typology pre-construction, construction & O&M) • Negative: dust accumulation on plants, animals due to vehicle movements through unpaved areas or O&M; site runoff polluting streams, waterbodies, and flora/fauna therein; noise and vibration effects due to equipment, machinery, vehicles, and activities; noise, light, and wastes due to increased tourism activities at lakes/rivers/canals. Direct impact by increment in noise & vibration due to construction activities on animals present in the zoo. • Positive: Improved tree cover and greenery supporting fauna Occupational Health and Safety of workers involved • Negative: waste, wastewater, accidents due to O&M activities, vehicles/heavy equipment, slips, fall, fire, lack of PPEs, training, guidance, flooding/disasters impacting project activities and workers • Positive: Employment opportunity, Improved OHS, better insurance ad work conditions, quality of life Community Health and safety • Negative: disturbance and safety issues during O&M, odor nuisance, Waste dumps, grit and sludge creating dust, health impact, visual blight, accidents, congestion; excavation & trenching leading to falling, trip, congestion, pollution, Damage to building & infrastructure, roads, common property during pipeline O&M, shifting of utilities, material transport, and storage, Risk of Communicable Diseases, high noise & vibration due to machinery and work activities affecting sensitive receptors, Health, and safety of downstream users of treated waters in case of poor treatment quality • Positive: Overall improvement of the environment, health and living conditions, resilience, and image of the city and its communities - forward linkage to overall socio-economic improvement Resettlement and Livelihoods impacts • Negative: Temporary disturbance to business or economic displacement due to access restrictions during construction; temporary traffic congestion and diversion of traffic. • Positive: Works on govt land and existing RoW, no future requirement to cause temporary disturbance to businesses or economic activities. Impacts on Cultural Heritage, Visual blight • Negative: noise disturbances to visitors and users, vibration due to O&M works • Positive: Better environment and services in heritage areas improving the quality of such areas and visitor satisfaction Impact on Socio-Economic, Households, communities • Negative: temporary or permanent loss of homes, livelihood and income loss, loss of access to public services. • Positive: improvement in quality of life post-relocation, better access to public services and access to the sewerage network, Overall improvement in community health and living conditions, health resilience. Summary of key risks and impacts and their significance before and after mitigation are presented in Table 8 below. ESMF for G- ACRP, 2022 Assessment of Probabale 49 impacts Table 8: Summary of Risks and Impacts and their Significance before and after Mitigation Negative Impacts Positive Impacts Significance Potential Risks and Impacts Negative Impacts Before Spatial Reversible after Considerations Significance of Duration Likelihood Magnitude Sensitivity Mitigation of Extent or not in the Long-Term Positive Impacts Negative Plan/ Mitigation impacts Preconstruction/ construction Project Negligible Landuse changes Long term Irreversible Certain Low Low Nil Minor Positive extent Negative Negligible Impact on-site and current users Short Term Site Reversible Occasional Low Low Nil Moderate Positive Negative Largely Moderate Impacts on Air Short Term Regional Likely Medium Medium Negligible negative Minor Positive Reversible negative Largely Moderate Impacts on Water Bodies Short Term Regional Certain Medium High Minor Negative Moderate Positive Reversible negative Project Largely Impacts on Soil Short Term Likely Low Medium Minor negative Negligible negative Minor Positive extent Reversible Impacts on health of Fauna, Flora Moderate Short Term Site Reversible Occasional Low Medium Negligible negative Moderate Positive (biodiversity) negative Occupational Health and Safety of Moderate Short Term Site reversible Likely Low High Minor Negative Moderate Positive workers involved Negative Moderate Community Health and safety – Short Term Local reversible Likely Low High Minor Negative Minor Positive Negative Disturbance to Cultural Heritage, Moderate Short Term Local reversible Occasional Low High Minor Negative Minor Positive Visual blight negative Resettlement and livelihoods Minor Temporary Local Reversible Unlikely Low High NIL Minor positive impacts – Phase 1 sub-projects Negative Sub Irreversible Ranging Resettlement and livelihoods Long and short project or Moderate and likely from low to Medium Moderate to minor Moderate to high impacts sub-projects term location- negative reversible high specific Irreversible Ranging Impact on Socio-Economic, Long and short Sub Moderate and likely from low to Medium Moderate to minor Moderate to high Households, communities term project or negative reversible high ESMF for G- ACRP, 2021 Assessment of Probabale 50 impacts Negative Impacts Positive Impacts Significance Potential Risks and Impacts Negative Impacts Before Spatial Reversible after Considerations Significance of Duration Likelihood Magnitude Sensitivity Mitigation of Extent or not in the Long-Term Positive Impacts Negative Plan/ Mitigation impacts location- specific Operations and Maintenance Moderate Impacts on Air Regional reversible Occasional Low High Minor Negative Moderate Positive Short Term negative Largely Impacts on Water Short Term Regional Occasional Medium High Major Negative Moderate Negative Major positive Reversible Project Moderate Impacts on Soil Short Term reversible Occasional Medium Medium Minor Negative Major positive extent negative Impacts on health of Fauna, Flora Temporary Site Reversible Occasional Low Medium Minor Negative Negligible negative Major positive (biodiversity) Occupational Health and Safety of Moderate Medium Term Site Reversible Occasional Low High Minor Negative Major positive workers involved negative Moderate Community Health and safety Temporary Local Reversible Occasional Low High Minor Negative Major positive negative Resettlement and livelihoods Minor Temporary Local Reversible Occasional Low High NIL Minor Positive impacts Negative Impacts on Cultural Heritage, Temporary Local Reversible Occasional Negligible High Minor Negative Minor Negative Major positive Visual blight The potential environmental impacts and risks for sub-projects and proposed mitigation measures and E&S instruments which would incorporate/guide on such mitigation measures are summarized in Table 9 below about the World Bank’s applicable ESSs. ESMF for G- ACRP, 2021 Assessment of Probable Impacts due to Sub-projectss 51 Table 9: Environmental and Social Risks and Impact Mitigation Plan Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: 1 ESS 1: - Sub-projects involve upgradation of existing - Identify, evaluate, and manage the - ESMF Assessment and STPs, construction of new STPs, drainage, environmental and social risks and impacts of - ESIA Management of sewage networks, tertiary treatment facilities, the project in a manner consistent with the ESSs - SEA/SH mitigation Environmental upgradation of waterbodies, which would and National or State regulations plan and Social Risks enhance sewage collection, treatment, - For sub-projects Identification of project- - ESMP and Impacts recycling, and overall environmental affected persons, interested parties, Vulnerable - ESCP improvement groups will be undertaken - Disposal of treated sewage and sludge may - Evaluation of cumulative impacts, risks, and have adverse impacts on other users like impacts due to associated facilities farmers, in the downstream villages which are - Develop monitoring plans and audits outside municipal areas. - Outline Institutional responsibility and capacity - Lack of access to services for addressing building effluent-related issues in the municipal STP. - Stakeholder engagement - Stringent monitoring and publication of the test results in the public domain with details of the pollution can be uploaded to the website. 2 ESS 2: Labor and - Occupational Health and Safety of workers Guidance - LMP Working while working on large construction works - WBG EHS guidelines to be followed - ESMP Conditions mainly during upgradation of existing plants - Assess and manage labor influx risk based on - C-ESMP - Exposure to hazardous waste will cause appropriate instruments; Prepare site-specific occupational health, EHS risks on staff, laborers Labor Influx Management Plan and/or a during construction, laying of networks, and Workers’ Camp Management as part of ESMP, O&M. in consultation with communities considering - The influx of migrant labor, communicable the institutional capacity of the implementing diseases agency; the presence of contractors without - Gender-based violence strong worker management and health and - Conflict with the local community safety policies; anticipated high volumes of - Conflict of locals with security at the site labor influx; pre-existing social conflicts or ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 52 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: tensions; local law enforcement, prevalence of gender-based violence and social norms, local prevalence of child and forced labor. ESMP implementation by contractors to be ensured Capacity Building - Training and awareness among workers on safety and work conditions, physical, Chemical, Biological, and Radiological hazards - Awareness on Fire, Material Safety, Emergency Response, COVID protocols, Incident Response and Monitoring Equipment, Gears - Provision of Protective Personal Equipment, First aid Kits, signages, and guidance on site - Provide appropriate fire safety tools Practices - Good, safe housekeeping on site - The integrity of Workplace structures - Safe practices for heavy machinery/equipment on-site, OHS, safety while shifting utility and electrical, mechanical works (installation of equipment, testing, etc) - Minimize interactions with hazardous materials, wastes, and tools by providing barricades, safe handling practices - Safe refuge during emergencies - Labour camp: Location to be identified considering risks. Plan to be approved by the site engineer. Rest areas, isolation facility, Water, Sanitation, Lighting, first aid, Stay ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 53 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: facilities, Covid-19 protocols at Labour camp. Labor camp to have waste, wastewater, toilet management, access roads, noise/light issues, fuels to minimize environmental impacts - Reduce labor influx; use local laborers - Ensure worker registration and insurance, ambulance facility on-site, good tie-ups with specialized hospitals for Worksite accidents Monitoring - Conduct health screening at regular intervals - Conduct OHS audit at regular intervals as part of Quality Assurance - Conduct gender analysis, establish grievance mechanism, and prepare labor management plan to address gender-based violence and conflicts. 3 ESS 3: Resource - Air Emissions and Ambient Air Quality Guidance - ESIA Efficiency & (i) Indiscriminate open-air burning during site - National, State, local regulations, and - ESMP Pollution clearance. guidelines, WBG EHS guidelines to be followed Prevention and (ii) use of diesel-powered generator sets and - ESIA to also consider Cumulative Impacts of Management vehicles with poor or high emission rates. these (iii) Dust & emission due to increasing in Capacity Building traffic & congestions while laying networks - Training and awareness on monitoring, and transporting construction materials containing, managing pollutants and materials; (iv) limited air pollution due to gases also, during emergencies produced as part of the sewage treatment - Awareness to neighbors on upcoming works, process and to use/ follow protective measures (v) Odor nuisance due to wastes accumulated Equipment, Gears during construction, O&M, chemicals/fuels - Provision of Protective Personal Equipment, used First Aid Kits, signages, and guidance on-site to ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 54 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: - Noise increases due to transport, machinery, protect against pollution, Hazardous and work activities, also during O&M substances - Wastewater, Water Conservation, Ambient Practices Water Quality & Contaminated Land Air Emissions and Ambient Air Quality (i) Improper sludge, wastewater management - Provide construction/ demolition Site may lead to leachate, and contamination of enclosures water bodies groundwater, and land - Avoid indiscriminate burning of wastes, (ii) Wastes are transported by drains and burning/wasting of gaseous bioproducts at the emptied into receiving water bodies site to reduce air pollution. (iii) Construction/operation stage - Safe & covered storage of materials, chemicals, impacts on waterbodies fuels, wastes; good housekeeping on site (iv) Improper treatment may lead to - Ensure PUC certificates for all vehicles odor, health issues for downstream users, - Adopt processes to minimize air/ gaseous and reputational risks emissions and reuse (v) Recycle, Reuse of treated Water Noise increases due to transport, machinery, and (vi) Waste generated on-site if not work activities, also during O&M managed properly during Construction and - Preference for Silent machinery O&M could result in visual blight, and land, - Adopt noise reduction strategies water pollution - Enclosures, buffers for the site; PPEs - Pollution Impacts on Biodiversity Wastewater, Water Conservation, Ambient Water (i) Impacts on the receiving waterbody and its Quality & Contaminated Land biodiversity - Proper segregated storage, collection, - Energy Conservation: Possibilities to minimize transport, treatment, and disposal of all wastes energy use, possible reuse/recycle of resources, as per categories (General SW, BMW, Plastics, improve biodiversity E-Waste, Hazardous wastes, silt, C&D wastes) during construction & operation, and dispose of wastes at least once a week - Ensure no wastes reach drainage/sewage networks by adopting roper design standards and monitoring ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 55 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: - Minimize wastes/pollutants reaching waterbodies - Proper treatment of sewage, wastes. Pollutants - Recycle, reuse treated water - Proper storage, transport, treatment, disposal of sludge as per its constituents Pollution Impacts on Biodiversity - Site enclosures, buffers, cut-offs, greenbelts - Undertake activities to improve biodiversity; environmental improvement of receiving areas, provide tree cover, plantations, minimize the discharge of pollutants Energy Conservation - Use energy-efficient equipment, processes; recycle wastes, materials Monitoring - Monitoring of Discharge of treated sewage for all parameters which impacts receiving waterbodies, its biodiversity including migratory birds, and downstream uses - Prepare hazardous waste management plan following the National Laws & standards. - Sludge & Grit Management Plan, including treatment, drying, stabilizing, and final disposal of sludge; cleaning and reusing/recycling Grit. Sludge & other waste storage/stockpile should be in designated areas with on the impermeable surface - Monitor gaseous/ air emissions from STP ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 56 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: 4 ESS 4: - Water quality & Availability Guidance ESIA, ESMP (with Traffic Community - Structural Safety of Project Infrastructure - National, State, local regulations, and Management Plan, Health and Safety - Life and Fire Safety (L&FS) guidelines, WBG EHS guidelines to be followed Labour Influx (i) Incidents/ Accidents at all construction sites - Prepare a plan for the emergency response also management plan, fire due to traffic while network laying, worksite considering Vasna barrage safety plan) hazards at STP, Drainage Pumping Stations Capacity Building (ii) Fire safety issues due to electrical circuits, - Training and awareness on monitoring, storage & use of fuels for supplementary ensuring safe practices: Pollution and Work power, accidental fires, labor camps Safety impacting community Health and safety - Traffic Safety - Training on safe practices & containment of (i) Increased traffic, Traffic congestion, pollution during emergencies resultant noise, delays - Awareness to neighbors on upcoming works (ii) Road safety during network laying especially - Fire drill, emergency preparedness drill in congested areas, areas near schools, involving communities residential areas Equipment, Gears - Transport of Hazardous Materials - Provision of Protective Personal Equipment, - Disease Prevention first aid kits, signages, and guidance on-site to - Assessing the health situation of the people protect against pollution, Hazardous with respect to the pandemic and risks due to substances use of polluted water for irrigation, livestock Practices and domestic use. Water Quality and Availability (i) Debris, noise (disturbance), and air pollution - Minimize erosion, disturbance to water bodies due to demolition, clearing of existing - Improved treatment of Sewage to take care of structures, sites, pipe networks all pollutants in the treated sewage to reach - Emergency Preparedness and Response environmentally acceptable results; Proper (i) Risk due to existing Vasna Barrage segregated storage, collection, transport, (ii) Potential impacts from flooding treatment, and disposal of all wastes as per (iii)Earthquake safety categories (General SW, BMW, Plastics, E- Waste, Hazardous wastes) and dispose of ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 57 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: - Rapid assessment conducted during November wastes at least once a week; Minimise 2021 for sites of phase 2 sub-projects namely wastes/pollutants reaching waterbodies Kharicut Canal, Chandrabhaga Nalla, and 4 - Site enclosures, buffers, cut-offs, greenbelts to representative lakes (Ramo Bandh, Isanpur Gaam, avoid wastes/wastewater/pollutants reaching Shilaj Gaam, and Bhadaj Gaam lakes) indicated waterbodies possible community health and safety concerns such - Safe & covered storage of materials, chemicals, as odor, polluted water, safety concerns related to fuels accidental drowning among others. The findings of Structural Safety of Project Infrastructure the Rapid assessment provide initial insights for - Infrastructure and construction to follow possible impacts and mitigation requirements while National guidelines, standards, and WB EHS; detailed analysis shall be carried out as part of sub- also, to take care of disasters including projects screening and ESIA. earthquakes and flooding - Consultation with communities to plan and reduce noise, vibration during construction and operation, Use PPEs, barriers Life and Fire Safety (L&FS) and General site hazards minimization during construction, Transport of Hazardous Materials - Demolition activities to be under controlled environment - Prepare and enforce traffic management plan - Prohibit access to the construction sites by any person having no work permits. - The proposed site should be marked and cordoned off any access by the public - Waste to be well managed, Safe Transport of hazardous material following existing regulations, Store hazardous material and waste in safe impermeable containers above ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 58 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: flood level, without leaching to nearby land/waterbodies, or resulting in fire - Ensure Fire safety & provide extinguishers, sprinklers, etc. as appropriate Traffic Safety - Follow Traffic Management Plan approved by Traffic Police Department - Arrange Flagstaff, signages - Drivers to have a valid license - Safe practices for heavy machinery/equipment on site Disease Prevention - Communicable & vector-borne diseases prevention - Labour camp management, Heath check-ups, Covid-19 Protocol - Reduce air, water, land pollution - Ensure PUC certificates for all vehicles - Undertake activities to improve biodiversity; provide tree cover, plantations, minimize the discharge of pollutants Emergency Preparedness and Response - Ensure that STP structures are earthquake resistant - STPs to be above HFL level - Good, safe housekeeping on site - Minimize interactions with hazardous materials such as Asbestos, wastes, and tools by providing barricades ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 59 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: - Use energy-efficient equipment, processes; recycle wastes, materials • Conduct gender analysis, establish grievance mechanism, and prepare labor management Monitoring • Prepare hazardous waste management plan following the National Laws & standards. • Sludge & Grit Management Plan, including treatment, drying, stabilizing, and final disposal of sludge; cleaning and reusing/ recycling Grit. Sludge & other waste storage/ stockpile should be in designated areas with on the impermeable surface • Monitor quality of treated sewage discharged; receiving waterbody to take corrective action if it exceeds prescribed limits to minimize impacts on downstream users 5 ESS 5: Land Land required for the proposed project is owned by - RAP including LRPs will be prepared for RPF (part of ESMF) Acquisition, government depts (Vinzol is under AMC, Koteshwar resettlement and livelihood compensation RAP Restrictions on is with AUDA) Development activities will be aspects. LRP Land Use and undertaken within the boundary for Vinzol and in - For pipeline laying, there will be no SEP Involuntary Koteshwar there is no encroachers or squatters and displacement, but economic impacts may arise Project GRM Resettlement land is in use for government work. only. These will be mitigated through RAP and For rehabilitation of existing drains and micro its Entitlement Matrix implementation. tunneling, work will be undertaken along the - . existing alignment on the roads. Additional land will - Public Consultations – feedbacks, disclosure, not be acquired. During the construction period, GRM, address E&S performance; grievances by there may be disruption of business of shop keepers formal & informal process. and hawkers, and street vendors who are doing the - Prior information on all activities ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 60 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: business in specific locations in narrow, congested, - No forced eviction, best alternatives to or market areas. involuntary resettlements A rapid assessment conducted during November 2021 for some of the drainage sector subproject sites such as Kharicut Canal, Chandrabhaga Nalla, and 4 representative lakes (Ramo Bandh, Isanpur Gaam, Shilaj Gaam, and Bhadaj Gaam lakes) indicated possible R&R impacts on account of encroachments: Ramol Bandh and Isanpur Gaam may result in R&R impacts of 50 and 100 residential households respectively while Bhadaj Gaam may result in R&R impact of temporary tea stall (commercial). No R&R impacts are noticed in the Rapid assessment at Shilaj Gaam lake. Similarly, Chandrabhaga nalla may trigger R&R impacts (squatters and encroachers) at ROW width near Bakri mandi at Ranip for about 50 households. In the case of the Kharicut canal, encroachments are noticed around the Odhav area of the canal. The findings of the Rapid assessment provide initial insights for possible impacts and mitigation requirements while detailed analysis shall be carried out as part of sub-project screening and ESIA. 6. ESS 6: - Assess the impact on natural habitat and - Minimize pollution risks by providing the best ESMP and Biodiversity Biodiversity biodiversity during the Construction and O&M available environmental technology for Management Plan as part Conservation and stages treating all pollutants (good design) of ESMP in case screening Sustainable - Assess biodiversity in heavily modified habitats - Provide mitigation measures as part of the indicates any biodiverse Management of - of Sabarmati or Urban Lakes in Ahmedabad ESMP of the ESIA. area being affected Living Natural and downstream uses & impacts: on habitat - Ensure participation of Garden Department, Resources loss, degradation and fragmentation, invasive existing Biodiversity committee of AMC in ESMF for G- ACRP, 2022 Assessment of Probable Impacts due to Sub-projectss 61 Sl World Bank ESSs Risks/ Impacts/ Opportunities Mitigation Measures Instruments applicable No: alien species, overexploitation, hydrological Preparation and Monitoring of mitigation changes, nutrient loading, and pollution. measures - Assess impacts on zoo animals in case of sub- - Ensure participation of zoo department in project development near the zoo. preparation and monitoring of mitigation measures 7 ESS 8: Cultural - Screening on impacts to cultural heritage - Avoidance/Minimising damage to structures; CHMP, if heritage Heritage - Dust, materials stacking, discharges near incorporate mitigation measures structures are found to be heritage structures/areas - Screening mechanism to identify risks and within 300 meters of the - Pipeline laying may affect heritage structures, impacts on cultural heritage subproject sites. movement routes – temporarily or - The chance finds procedures to be included ESMP, with Chance Finds permanently - Training on managing cultural heritage & Procedures and CHMP as - Earthwork impact on structures mostly during chance find procedures part of ESMP in case network laying, lake upgradation - Heritage cell of AMC to be involved in screening indicates any - The chance finding of artifacts, structures, screening, identification of due diligence major Heritage area within sacred places requirements, finalizing and monitoring 100 to 300 meters of the - Need specialized inputs & consultations for mitigation measures existing alignment. identification of impacts, mitigation measures, implementation and monitoring 8. ESS 10: - The project activities will immensely benefit the - Identification of project affected persons, ESMF, ESIA, Stakeholders local population and at the same time expose interested parties, Vulnerable groups will be RAP, SEP Engagement and them to minor negative environmental& social engaged, informed, record their views, Information risks during the construction & implementation suggestions & grievance and address the GRM Disclosure phase. concerns. Consultations will be carried out to IEC activities - As such, to have prior informed social approval solicit suggestions to plan and address and mitigate the social implications stakeholder measures for managing risks and impacts engagement, consultation, feedback is required arising from proposed project activities during construction and operation. ESMF for G- ACRP, 2022 Environmental and Social Management Framework 62 CHAPTER 5. ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK The ESMF has been prepared to assist in the screening, assessment, management of environmental risks of the project at an early stage in project planning and integrate mitigation hierarchy during the sub-project design, implementation and operation. The framework will help provide specific guidance on the policies and procedures to be followed for environmental assessment. The environmental and social assessments need to be carried out based on the provisions of the National laws and the relevant World Bank’s Environmental and Social Standards. The Environmental and Social Management Framework procedure specifies measures for addressing the negative risks and impacts and for enhancing the beneficial impacts. In addition, organizational capacity, and training requirements, required to check and ensure the effectiveness of the plan throughout the lifecycle of the project, have also been discussed. A systematic methodology has been provided in the subsequent sections that can be followed along with engineering and institutional interventions required for the sub-project activities for effective integration of the environmental and social considerations and ESF. The objective of ESMF is to frame guidelines and procedures to address the environmental and social risks and impacts associated with the implementation of G-ACRP. The specific objectives are as follows: • Outline the process to identify and assess the environmental risks/ impacts/ issues relevant to the proposed project/sub-projects • Ensure that the environmental and social management plans are aligned with the requirements of the country system as well as with the World Bank ESF requirements • Establish clear procedures and methodologies for the environmental and social screening, review, approval, and implementation of sub-projects to be financed under G-ACRP • To ensure that mitigation measures are designed to effectively mitigate the potential adverse environmental and social impacts • To specify appropriate roles and responsibilities at the national, state, and municipal levels and outline the necessary reporting procedures, for managing and monitoring environmental and social concerns related to sub-projects and to strengthen the capacity of various institutions on ESF compliance. 5.1 ESMF Adoption Framework The ESMF adoption framework or procedure for E&S management is presented in the following Figure 10 which is detailed in the subsequent sub-sections. At the onset of the sub-projects identification stage, the project proponent excludes those sub-projects/activities/locations which are to be avoided as per the exclusion criteria developed as part of this ESMF (refer Section 5.2.1). The sub-projects which are eligible to be considered after considering the exclusion criteria are taken ahead for detailed design (or preparation of feasibility reports in case of PPP projects where design/ technology will be developed at a later stage). After a sub-project has been developed with outline design or preliminary feasibility report (with design, indicative technologies in case of PPP projects), location/ site and network/alignment applicable, screening of environmental and social risks is carried out through a process called Initial E&S Examination (IESE). This is carried out using the screening format presented in ESMF Guidance Manual. After screening, the project risk can be rated and the type of E&S instruments to be prepared can be arrived at. The recommendations from these E&S instruments need to be incorporated by the detailed design team while planning the project, preparing the design, costing, technology, and monitoring/management aspects and incorporated into the tender (bidding) documents, to enable the contractor to include the avoidance, mitigation/management measures ESMF for G- ACRP, 2021 Environmental and Social Management Framework 63 while preparing the bid cost estimates and commit to implementing the sub-project based on these aspects. The contractor shall update E&S instruments based on site/design changes or stakeholder discussions and use these for implementing the E&S aspects right from the time of award of the contract by having the requisite institutional capacity for E&S aspects, timely updating of E&S instruments, implementing ESMP and mitigation/monitoring measures and timely reporting of E&S implementation and monitoring. ESMF for G- ACRP, 2021 Environmental and Social Management Framework 64 Figure 10: ESMF Adoption Framework ESMF for G- ACRP, 2021 Environmental and Social Management Framework 65 5.2 Sub-projects Identification G-ACRP is expected to have various types of sub-projects and TA, some of which are in the identification stage at the time of preparation of this ESMF. The key type of sub-projects expected is sewage treatment plant upgradation, sewage networks, the establishment of new STPs, drainage network, pumping stations, lake/canal redevelopment. TA components include preparation of master plans, city resilience plans, etc. The magnitude and likelihood of E&S impacts will differ depending on sub-project components, activities, and locations. Hence, to understand the probable E&S impacts early on, it is important to screen sub-projects and exclude those which are not eligible to be considered under the program. It is also important to screen the project components and locations of eligible investments to understand the Risk levels (Low, Moderate, Substantial, and High) and to prepare E&S instruments commensurate with the expected risk level. Impacts are not expected to be diverse, unprecedented, or irreversible. It is expected that the sub-projects risk levels would range from low to substantial, mostly during the construction stage, and manageable using appropriate environmental and social management plans. 5.2.1 Initial Environmental and Social Examination (IESE) during Sub-project Identification Stage 1: Exclusions to be considered during the Sub-Project Identification Stage G-ACRP will not support sub-projects that will involve the following: Table 10: List of Non-permissible Activities under G- ACRP Sl No: Non-permissible Activities 1 Sub-projects in sites/ locations which should be excluded as per prevailing Rules/ Laws on Natural Habitats and Forests or Archeologically Protected Monuments (National, State, Local): (i) any construction in demarcated Forest areas or protected natural areas or their buffers, (ii) any sub-project which would impact critical natural habitats, (iii) any sub-project which shall be excluded as per AMASR Act, (iv) any sub-project components or activities in the Historic Walled City of Ahmedabad – the UNESCO World Heritage Site 2 Sub-projects in sites/ locations which should be excluded as per applicable siting criteria prescribed by GPCB, Master Plan, Excluded Disaster Zones, or other applicable criteria set out by National, State, Local Body 3 Sub-projects involving (i) Activities that impact the safety of Dams/Barrages, (ii) purchase, storage, and use of Banned Pesticides/ Insecticides/ chemicals/Asbestos, (iii) Construction of CETPs / ETPs or any facilities to manage industrial / hazardous wastes or effluents 4 Sub Projects displacing more than 200 tribal households or 100 Primitive Tribal households Such projects will be excluded during the Project Identification stage itself. PIU/ Line Department shall scrutinize the project for any of the above activities/ components and avoid taking up such sub-projects for implementation. PIU should maintain a record of such sub- projects excluded from G-ACRP using this Stage 1: Exclusions List. Stage 2: Screening The E&S examination (IESE) of each sub-project under the G-ACRP will be undertaken to determine the anticipated E&S risks, impacts and opportunities based on which the appropriate E&S instruments for mitigating the negative risks and impacts and enhancing the benefits will be ascertained. The requirement of the instrument will be based on the project categorization and will constitute either of - (a) Detailed Environmental and Social Impact Assessment (ESIA), or (b) Limited Environmental and Social Impact Assessment confined to the project area and (c) use of Environmental and Social Management Plan (ESMP). For the upgradation of existing facilities, an E&S Audit of the facility will be also undertaken as part of ESMF for G- ACRP, 2022 Environmental and Social Management Framework 66 ESIA. The E&S instrument will be determined by the Bank’s ESF in conjunction with the Government of India’s regulatory requirements. The IESE will be undertaken by the E&S specialists of the PIU and will comprise a combination of the literature review, stakeholder consultations and the site reconnaissance survey. The key steps involved in the process are briefly outlined below. - Step 1: (a) Review available project details, location map, and regulatory aspects, (b) conduct reconnaissance site visits for ground-truthing and screening, (c) ascertain if the sub-project is an eligible investment as per Stage 1: Exclusion List o Wherein the proposed activity is restricted, and change has been made in project design to avoid such prohibitions, Step 1 needs to be performed again - Step 2: Screen for the presence of any environmentally sensitive areas, project components of high risk, and probable benefits as per Stage 2: Screening Criteria (Refer ESMF Guidance Manual) - Step 3: Determine - the project category based on screening and appropriate E&S instruments that shall be prepared to incorporate necessary mitigation measures. Since G-ACRP is a substantial risk project, all sub-projects / TA activities screened and categorised as High Risk are also excluded from the project - Step 4: Revisit the screening checklist and ascertain the outcomes of the screening checklist. Undertake the detailed screening process for the proposed investments in consultation with the line department/s. The PIUs and Line Departments shall have detailed topographic maps of all the proposed sub- projects sites with details of ecologically sensitive areas, habitat areas, Reserve Forest, Wildlife Sanctuary, etc. to undertake screening exercises. PIU shall organize a meeting with all the Line Departments and the concerned officials of the Pollution Control Board, State Environment & Forest Department, and other agencies before starting the process to gain a better understanding of the clearance process. The outcome of this screening process will help prioritize the various investments and where required, start the clearance process on time e.g. sub-projects sites (requiring Forest/ other clearances). Projects for which the clearance process may be longer can be sequenced/phased later in the overall project implementation plan. However, the clearance processes for such projects/sites shall be initiated at the earliest. This shall help ensure that no sub-projects are impacted due to delays in the clearance procedures and regulations. PIU E&S specialists shall submit duly checked and signed screening forms to Project Director, PIU, or his nominee. Based on the IESE undertaken, and discussions with various agencies concerned, E&S Specialists of the PIU would undertake sub-projects categorization. 5.2.2 Categorization of the sub-projects E&S risk categorization of sub-projects is undertaken based on: • type, spread, and scale/footprint of the sub-projects • location sensitivity of the sub-project (See Table 11) • expected magnitude and likelihood of E&S risks and impacts, including risks to resources, sensitive locations, and people, impacts on greenfield/brownfield sites including (e.g., rehabilitation, maintenance or upgrading activities); whether the risks are irreversible, unprecedented or complex and need to be avoided or if the risks could be managed using a proportionate E&S management plan based on mitigation hierarchy ESMF for G- ACRP, 2022 Environmental and Social Management Framework 67 • the technical/institutional capacity and commitment of the Borrower to manage such risks and impacts in a manner consistent with the ESSs, including the country’s policy, legal and institutional framework; laws, regulations, rules, and procedures applicable to the Project sector, State and local requirements; the Borrower’s track record of past Project implementation; and the financial and human resources available for management of the Project; • other areas of risk that may be relevant to the delivery of E&S mitigation measures and outcomes, depending on the specific Project and the context in which it is being developed, including the nature of the mitigation and technology being proposed, considerations relating to domestic and/ or regional stability, conflict or security. Possible sensitive environmental and social components which can be affected by proposed sub- projects and need to be considered while screening includes the following: Table 11: Sensitive Environmental and Social Components Sl. No Sensitive Environmental and Social Components 1. Habitat for migratory species; Breeding and spawning ground of species (including seasonal); Coral Reefs* 2. Estuary, Creeks, natural drainage system, Rivers, Natural lakes, swamps, Marine ecosystem, Ramsar Sites 3. Forests, Urban Forests, Zoological parks, and Mangrove Forests/ Mangrove Covers* 4. Important Bird and Biodiversity Area (IBA) 5. Archaeological monuments/sites, Religious, heritage historic sites, and cultural properties 6. Scenic areas, Hill/mountains, Areas of scientific and geological interests 7. Seismically and geologically active areas 8. Defence installations, especially those of security importance and sensitivity to pollution 9. Airport and other sensitive installations 10. Areas like National Parks, Sanctuaries, Biosphere Reserves, etc. protected under Wildlife Protection Act, 1972, including Tiger reserves, Elephant Reserves * 11. Migration route of wildlife/ Wildlife Corridors * 12. Delineated CRZ Areas as per CRZ Notification * 13. Tribal Settlements * * Note: Not known to be in Ahmedabad, but included for exhaustiveness Based on IESE using screening format, G-ACRP sub-projects will be categorized as High, Substantial, Moderate, or Low based on ESSs of WB. As per National Regulations, there is no requirement of ESIA for drainage, sewerage projects except Common Effluent Treatment Plants (in case of industrial effluents). Considering potential E&S risks and impacts their magnitude and likelihood, proposed sub- projects will be categorized in a four-point scale: Table 12: Environmental and Social Categorization of Projects Proposed Sub- Description projects Categories The extent of Type of Projects and Management Tools Environmental and Social Risks S1 Substantial Risk Projects with potential Significant adverse social or environmental risks or/ and impacts that are significant, mostly irreversible, and possibly addressed through mitigation measures E&S Instruments: Detailed Site-Specific ESIA, RAP (if applicable) and ESMP by Separate Consultant other than DPR consultant; or if ESMF for G- ACRP, 2022 Environmental and Social Management Framework 68 Proposed Sub- Description projects Categories The extent of Type of Projects and Management Tools Environmental and Social Risks prepared by DPR consultant it should be reviewed by Independent Consultant and cleared M1 Moderate Risk Projects with potential moderate adverse social or environmental risks or/and impacts that are few, generally site-specific, largely reversible, and readily addressed through mitigation measures E&S Instruments: ESIA, RAP (if applicable), and ESMP by DPR consultant while preparing DPR L1 Low Risk Projects with minimal or no adverse social or environmental risks or/and impacts E&S Instruments: ESMP Based on the above indicative categorization of key sub-projects is presented in the following Table 13. Table 133: Indicative Environmental and Social risk Category of Sub-projects Types Sl. Type of Sub-Projects Probable Categorization * No A. Sewage Collection, Transport, Treatment & Disposal Laying of Sewerage Network S Construction of Pumping Stations M Construction of STP S Upgradation of existing STP S Tertiary Treatment Plants S B. Storm Water Drainage Laying of Drainage Network S Construction of Pumping Stations M C. Urban Lake Improvement Comprehensive improvement of the lake and surrounding areas S Pathways, cleaning, and fencing of the Lake M D. Construction of other small buildings/ training centers L E. Renovation of Canals S * Note: This is only an indicative categorization based on sub-projects types. However, actual categorization shall consider project activities/components (as it would differ based on requirements), and its risks/impact and spread in the environment, locational sensitivities (Table 11), and regulatory requirements. Also, in case a sub-project has more than one among these subcomponents, the higher risk category applicable for any subcomponent would be considered as the risk category for the sub-project. As per World Bank Policies, ESMF applies to the entire project, to linked activities or associated facilities (meeting criteria as per para 11, ESS1, WB ESF). All sub-projects and linked/associated facilities shall also be categorized, impacts identified and mitigation measures, and monitoring planned and implemented. ESMF for G- ACRP, 2022 Environmental and Social Management Framework 69 5.3 Sub-project Preparation Based on the procedures listed above for each type of risk, it is required to carry out ESIA which is materially consistent to manage potential environmental and social risks and impacts commensurate to the scale and nature of the sub-project according to the World Bank’s ESF. PIU will identify, manage, and mitigate environmental and social impacts based on the magnitude and nature of potential impacts. In case of existing facilities, ESIA also shall include E&S Audit to determine the extent and nature of all E&S areas of concern at an existing project or activities in case of High and Substantial risk sub-projects; whereas audit can be standalone (without ESIA) in case of Moderate and Low-risk sub-projects. 5.3.1 Preparation of Terms of Reference for Environmental Assessment Based on the screening and categorization, the Terms of Reference for ESIA shall be prepared by the PIU. This shall include the scope of ESIA, including preparation of baseline and surveys/studies required for this, the need to consider three alternative scenarios including no project scenario, evaluation of impacts and risks, stakeholder consultations, preparation of mitigation plan, institutional set up for managing/monitoring and budget for implementing mitigation measure. PIU shall appoint consultants to prepare ESIA using this TOR. ESIA ToR for investments which might be impacted by flooding issues related to Vasna Barrage shall include the capacities to undertake studies if any required, and incorporate findings in ESIA/ESMP. 5.3.2 Environmental and Social Impact Assessment (ESIA) ESIA evaluates a project's potential E&S risks and impacts in the project area of influence, examines the alternatives (minimum three; including no project scenario), identifies measures to mitigate the E&S risks and impacts, and improvement of benefits throughout the project implementation. Wherever feasible, preventive measures would be undertaken. • The borrower is responsible for carrying out the ESIA as outlined in the ESMF and national regulations. ESIA shall start along with the preparation of draft project documents (DPRs)/ Feasibility Report (after pre-feasibility report) ideally so that the findings/avoidance/mitigation/management measures can be incorporated early on into the design. • In the case of S1 sub-projects, the E&S assessment shall be undertaken by consultants other than DPR consultants based on an agreed ToR to ensure independence in the assessment of the impacts and to avoid conflict of interest. If the environmental assessment for S1 projects are being undertaken by DPR consultants for better integration with project design or considering the lack of available additional firms/expertise for a certain type of sub-projects, it is recommended to employ independent consultants (suitably selected with required expertise) to review the same before approval and to ensure that all critical issues of environmental management are addressed in the project. Based on the outcome of consultations and survey results, mitigation plans as needed depending upon the nature and scale of risks and impact will be prepared. The outcome of consultations will be incorporated into the mitigation plan or designs or both. The draft ESIA with mitigation plans (ESMP) will be disclosed, and consultation will be held with the stakeholders including communities to explain a) the proposal, b) alternatives considered, c) expected impacts, d) content of the mitigation plans, e) process involved in the implementation of mitigation plans, f) responsibility of various institutions involved, g) grievance mechanisms, h) explanations on their comments/queries. Minutes of the stakeholder consultations would be presented in the ESIA. The Guidance Manual of this ESMF presents detailed requirements and guidance for ESMF for G- ACRP, 2022 Environmental and Social Management Framework 70 effectively analyzing, assessing, and incorporating the requirements for biodiversity, cultural resources, energy efficiency, and pollution control in IESE and ESIAs. In case of DBOT projects, since designs would be prepared/or changed after issuing the contract, ESIA/ESMP prepared before bidding will have to be freshly prepared/updated (as the case may be) by the ESIA consultant appointed by the Contractor. This will be reviewed by AMC – moderate risk projects will be cleared by AMC, and substantial risk ESIAs will be cleared by the Bank. Actual flood risk assessments & Emergency Action Plan (ESS 4) will only be undertaken as part of the C-ESIA and reflected in the ESMP that will be prepared for specific investments, during implementation. • Relevant inputs of the stakeholders and public shall be incorporated in the project through specific public consultations (minimal two public consultations; one at the start of the EA process and the other on the Draft Report) with prior notice. • Also, the draft ESIA shall be made available in a public place in English and local language – Gujarati - well; accessible to affected groups if any; and local NGOs. • Implications of the available legislation and regulatory requirements and the requirements of the ESF of the World Bank are also to be reviewed as part of the ESIA. The ESIA report shall meet the requirements of national and state-level legislation and disclosure requirements of the World Bank. Necessary clearances from National/ State agencies and World Bank shall be obtained for ESIA before the start of work as applicable. • ESIA report shall include an Executive summary, Introduction/ Project background, Project Description including review of (three) alternatives (including no-project scenario), Review of Legislations, Baseline environmental conditions, E&S Audit of existing facilities proposed for upgradation or integrated with the sub-project; Impact Evaluation, Public consultation details, Management and Monitoring Plan, implementation ESIA Budget. • Considering the multiplicity of sub-projects in various sectors, it is important to develop a Management Information System which will help schedule and alert the relevant project authorities at various levels on the need to prepare ESIAs well in advance before procurement initiation. • Draft final reports along of the ESIA along with observations/comments of the Technical Review Committee (which will include E&S review) or E&S specialists shall be forwarded to the Executing Agency/ World Bank for its review, comments, and clearance as applicable (H1 (if identified at a later stage)/ S1 sub-projects/ or any special projects will be sent to the World Bank for review and clearance; M1 and L1 projects will be cleared by PIU E&S Specialists; while all sub-projects E&S instruments will be presented in the Environmental and Social Management Information System (ESMIS). The consultant’s contract will have adequate provisions to ensure that they would incorporate all the comments and finalize the ESIA report/ ESMPs. • The final version of ESIA and ESMPs for S1 sub-projects in English with a non-technical summary in the local language – Gujarati, shall be disclosed as per applicable disclosure policy in the websites of the executing agency/relevant departments and will be made available in places accessible to the local people. Final ESIAs forS1 projects shall be sent to the Bank for clearance and disclosure. PIU shall include links to all ESIAs/ ESMPs sub-project wise in ESMIS. 5.3.3 Environmental and Social Management Plan (ESMP) • The management plan shall consider various activities proposed under the sub-project and provide management measures to be followed for different phases of implementation, along with the responsibility allocation for implementation and monitoring. • Apart from addressing the issues, management measures shall also explore enhancement opportunities and their inclusion in project components. ESMF for G- ACRP, 2022 Environmental and Social Management Framework 71 • The management measures identified shall be made part of the sub-project components and shall be included in the bid documents appropriately. • Indicative ESMPs for various sub-projects/activities expected are provided in the Guidance Manual of the ESMF. Also, refer to respective sections on Biodiversity & Living Natural Resources, Energy Efficiency and Pollution Prevention and Cultural Resources which will help in the preparation of sub-project ESMPs. • For construction/ EHS impacts; guidance includes The World Bank Group General EHS Guidelines contain information on cross-cutting environmental, health, and safety issues potentially applicable to construction and can be downloaded via the following link. https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site /sustainability-at-ifc/policies-standards/ehs-guidelines WBG Groups industry sector guidelines applicable to Water and sanitation are available at: https://www.ifc.org/wps/wcm/connect/0d8cb86a-9120-4e37-98f7- cfb1a941f235/Final%2B- %2BWater%2Band%2BSanitation.pdf?MOD=AJPERES&CVID=jkD216C World Bank EHS guidelines applicable to Waste Water and Ambient Water quality can be downloaded and used as international best practices from https://www.ifc.org/wps/wcm/connect/3d9a54ae-c44c-488d-9851-afeb368cb9f9/1- 3%2BWastewater%2Band%2BAmbient%2BWater%2BQuality.pdf?MOD=AJPERES&CVID= ls4Xbfn For Water Conservation, the following will be used: https://www.ifc.org/wps/wcm/connect/8e307e4e-7668-4049-b163-f8d00f0cdef7/1- 4%2BWater%2BConservation.pdf?MOD=AJPERES&CVID=ls4XhtY As the project includes developing guidelines and systems for COVID-19 related waste management, sanitization, and public hygiene practices to be rolled out across all urban areas. This activity would be informed by available guidelines on the COVID response E&S documents. (https://worldbankgroup.sharepoint.com/sites/wbunits/opcs/Pages/pc/Operations- COVID19-Coronavirus-Information-03092020-081859/Overview-03092020-081941.aspx) 5.3.4 Cost for Mitigation Measures including Monitoring Plan The ESMP Cost shall be integrated into the Detailed Project Report (DPR) and sub-project bid documents. This shall include the cost for all mitigation measures and monitoring required during various stages of the project. Details on including these costs for mitigation measures in the cost tables of the contract shall be presented in ESIA. PIU should ensure the preparation and implementation of Contractors-ESMP and the inclusion of ESMP cost in contract documents. The cost for implementation of the management measures, the institutional arrangements for monitoring, etc shall be included in the sub-project cost and ESMP and Monitoring Plan shall be presented in bid documents so that the contractor/ PPP operator can bid realistically for implementing the mitigation/ management plans. 5.3.5 Proposed Institutional Mechanism and Reporting Requirements for Sub-projects Successful implementation of ESSs in sub-projects can be ensured by defining the role of various officials in its implementation. ESMP for each of the sub-projects should present the ESMF for G- ACRP, 2022 Environmental and Social Management Framework 72 institutional responsibilities and timeframe for the implementation of mitigation measures and monitoring. 5.4 Sub-project Implementation Sub-project Implementation starts with inviting bids from the potential implementation partners for each of the sub-projects identified. Right from the RFP preparation stage for inviting the bids, it is important to incorporate E&S conditions, so that the contractors are aware of and are prepared with adequate finances and institutional setup to ensure implementation of E&S enhancement and mitigation measures. 5.4.1 Incorporating ESMP into Contract Documents This subsection provides guidelines on the integration of the ESMP/Indicative ESMP documents into the contract documents. With the revision to the World Bank’s Standard Bidding Documents in January 2017, Environmental Health and Safety (ESHS) requirements are well defined in the bid documents. Also, an ESHS Performance Security has been incorporated into the requirements (in Standard Bid Format) from potential bidders for the implementation of works under project financing. This revision incorporates changes to enhance environmental, social, health, and safety performance during all stages of the sub- project. ESHS Performance Security Depending on the associated risk of the sub-projects, an ESHS Performance Security, of 1-3 percent of the total contract value shall be maintained as per the Guidance provided supplementing the World Bank’s Standard Bidding Document. The total performance security for contracts will typically be 10 percent of the total contract value of which 3 percent should be allocated to the ESHS performance security, while where a contract has performance security of 20 percent the ESHS performance security is to be maintained at a maximum of 5 percent of the total contract value. The E&S Specialists and procurement team of the project executing agency will be required to work together closely to ensure that the ESHS aspects are incorporated in the bidding document. Comprehensive MIS database developed by the project which tracks the project progress and aligns the same with the ESF implementation such as ESIA report preparation, procurement of relevant clearances, ESMP implementation will help the executing agency to effectively supervise and monitor all sub-projects. The Technical team along with E&S specialists of the executing agency/ PIU shall align the language in the ESIA/ESMP with that of bid documents. Adequate E&S staffing should be part of the ESMPs that are incorporated into contract documents for construction contractors and for site-specific plans to be developed by the contractors. The budget for complying with the ESMP needs to be worked out for each sub-project by working out the cost of implementing each mitigation measure. Where this is not possible, the provision of a minimum of 3 percent of the sub-project cost needs to be earmarked for complying with the ESMP, after carefully adding all design-related mitigation measures in the project BOQ. In any event, the contractor is required to provide a costing at a minimum of this amount in his BOQ, listing itemized values for ESMP implementation. The language should indicate that the contractor will be required to provide an itemized costing with the BOQ with this as the minimum allocation. ESMF for G- ACRP, 2022 Environmental and Social Management Framework 73 For large-scale contracts that are assessed as substantial risk during environmental screening, it is also requested for the contractors to have the following certifications in the Eligibility and Qualifications Subsection, in Section III of the Standard Bidding Documents, under Contractor Requirements. • Registration with ISO 14001 (Environmental Management) • Registration with ISO 45001/ OSHAS 18000/ or equivalent on (Occupational Health and Safety Management) • If not already registered, must be willing to register as such before requesting mobilization amount or any other payment for the contract • EHS personnel on-site with relevant accreditation (QCI-NABET, ANSI-USA, SQA – SCOTLAND, NEBOSH or similar) who can conduct a hazard risk assessment and manage OHS during large construction works. 5.4.2 Onsite implementation of ESMP The contractor shall implement all the ESMP measures applicable for the project right from the pre-construction stage and ESMP implementation is part of their responsibility as per procurement conditions. C-ESMP shall be updated as and when there is change/updation of designs or locations. This shall be discussed with site engineers and workers and a record of its implementation shall be maintained. Project supervising consultants will monitor the implementation of ESMP measures during implementation and report to PIU who will be supported by PMC. The contractors/ NGOs/ CBOs who would be implementing the projects/ or are part of implementing team on-site shall have environmental, health and safety specialists for onsite implementation of ESMP. 5.5 Monitoring and Evaluation 5.5.1 Sub-Project Monitoring PIU through PMC and supervision consultants shall monitor all projects that it finances to ensure conformity to standards during construction, operation, and maintenance. E&S Monitoring will be carried out through E&S compliance reports that form part of Quarterly Progress Reports (refer ESMF Guidance Manual for Format). Based on the a) verification of progress reports and field visits, b) E&S compliance reports and c) compliance with other loan disbursement conditions, subsequent instalments will be disbursed. PIU shall make adequate internal arrangements to monitor the ESMP implementation quarterly, receive regular monitoring and progress reports from sites, and in turn submit regular progress reports including environmental compliance reports to The World Bank. The model format for the preparation of the ESMP compliance report is provided in The Guidance Manual. Also, the status of compliance to Agreed Actions of previous World Bank missions can be discussed in the QPR. PIU will undertake quarterly field visits (or as required) to those sub-projects which are under implementation to review the implementation of ESMP and the findings will be shared with respective implementing agencies for their follow-up. The non- compliance and their remedial measures will be highlighted in these reports which will be communicated and followed up. ESF document preparation and on-site implementation will be followed up and monitored through the ESMIS which will be integrated with the overall project MIS. This will be developed by the PIUs as part of the project. ESMF for G- ACRP, 2022 Environmental and Social Management Framework 74 5.5.2 Construction Supervision and Quality Control Construction Supervision and Quality Assurance (CSQA) will be carried out by PMC. PMC will supervise work quality during preparation and implementation. They will also have a dedicated Environment, Health, and Safety officer to monitor hazard risk assessments, ESMP implementation, labor-management, and occupational health and safety risks. For projects involving Natural Habitats and Cultural Resources; the PMC will also monitor the implementation of mitigation measures through experts with specialization in biodiversity conservation and cultural resources. 5.5.3 Annual Environmental and Social Audit PIU will undertake annual audits of its portfolio to review the status of ESMF compliance. The audit will focus on the process followed for the categorization and approval of E&S reports disclosures and related aspects; audit of pollution monitoring, and on-site audit of OHS measures. Also, in case of any non-compliance to ESMF, the scope of the subsequent audit will cover its examination and suggestion on remedial. The audit will also be based on field visits to all ongoing S1 category sub-projects and sample M1 and L1 category sub-projects to verify the implementation on the ground and solicit feedback from the affected people and other stakeholders. The audit will be carried out every year for the activities completed until the previous financial year. The draft report shall be forwarded to the World Bank for review and suggestions and upon approval after incorporating the comments of the Bank and other reviewers, the final audit report will be disclosed. The Terms of Reference for ESMF Audit are presented in The Guidance Manual. The Auditors shall: • Support the PIU in preparing the audit plan. • Prepare compliance reports for sub-project activities in line with ESMF and other statutory requirements as applicable through scheduled or unscheduled audits. • Conduct random field visits and review compliance, especially in environmentally or socially sensitive areas. Special attention will be paid to consultation with vulnerable groups to address their concerns and ensure that they can access project’s benefits following the stakeholder engagement process described in the SEP. • Review the performance of the project through an assessment of periodical monitoring reports submitted by the line departments, contractors/ PMC. • Share audit findings with the PIU to aid in timely decision making (12 month interval (implementation calendar year), starting by the end of first 12 months of work start) and adopting appropriate mitigation action/s, if necessary. PIU will review these audit reports and identify the technical, managerial, policy, or regulatory issues concerning the compliance of the ESIA/ ESMP. The identified technical issues will be duly incorporated in the subsequent projects, policy and regulatory issues will be debated internally by the PIU and line departments to determine appropriate interventions. These interventions/action plans will be communicated to site officers/ implementing agency/contractor for actions. These interventions may include appropriate revision of institutional aspects, monitoring mechanism, revision/updating of ESMF document, or suitable analytical studies to influence policy or programs of the State/City. The audit observations/recommendations will be complied with and followed up as part of monitoring by PIU/PMC. This ESMF ensures the following monitoring and reporting requirements: ESMF for G- ACRP, 2022 Environmental and Social Management Framework 75 • Reporting on ESMPs: Monthly (or as and when required) Implementation Report by Contractor to Site in-charge/ implementing agency; Monthly Supervision Report by Site in-charge/ implementing agency to PIU, Quarterly report by PIU to the World Bank (based on a monthly report by Site in-charge/ implementing agency, Monitoring report by Quality assurance Consultants and quarterly supervision by PIU). Quarterly Report by PIU quarterly reports to the World Bank should also give an update on the status of each ESMP/ESIA for the ongoing / proposed works, details on ESMP implementation for ongoing works, compliance / non- compliance with regards to each action in ESMP/ESIA, any issues and good practices to be brought to the attention of the Bank Status of Agreed Actions on E&S of previous mission/s etc. It should also present compliance to regulatory requirements, and monitoring outcome/output indicators defined in this ESMF, including no: of projects with improved environmental performance and resource efficiency. (Refer Annexures; A.ESMF Guidance Manual, Section III: Documentation Formats B. Format for quarterly reporting on Environmental and Social Aspects) • An annual visit to sample sites by PIU (including accompanying the World Bank Missions), • EHS report by PMC as part of CSQA along with monitoring of Civil Works when the works are ongoing and at work exit/operations. • Annual Environmental Audit for select sub-projects (all S1 and select M1, L1) by independent consultants/auditors, • Detailed Management Information System – ESMIS - linking project details, scheduling, and documentation of the ESIA process and ESMF implementation will support the PIU in effectively guiding the preparation of ESF documents for other sub-projects, implementation of ESMPs, supervision, and monitoring. 5.6 Public Consultation and Stakeholder Participation 5.6.1 Public Disclosure The following documents shall be disclosed in the Offices and websites of the PIU/ AMC/ GUDM and/ or other project agencies as applicable. a. ESMF for G-ACRP with non-technical summary in Local language – Gujarati. SEP and ESCP are prepared as stand-alone documents. RPF and LMP are included in this ESMF. b. Approved ESIA reports in English, with its non-technical summary in the local language; namely Gujarati, c. ESMP and other ESF documents d. Monitoring Reports e. Final Reports of Annual E & S Audits 5.7 ESMF and Technical Assistance (TA) activities This section discusses the applicability of ESMF for Technical Assistance (TA) studies/activities/plan preparations undertaken with support from the World Bank Loan: City Resilience Plans, preparatory studies/research activities, and detailed project report preparation for components not directly implemented under the project are expected to be undertaken under G- ACRP, which may be important for the successful implementation of this project or to ensure sustainable future activities. When Plans, feasibility, or DPRs are prepared, the corresponding ESIA and ESMP preparation will be undertaken following the ESMF requirements after Screening and categorization as discussed in the above subsections. The outputs and reports of these studies will be submitted for the Bank’s review and endorsement. These will be approved by the competent authorities as outlined earlier for each risk category and disclosed. These will be prepared in a manner consistent with ESMF for G-ACRP sub-projects. However, the implementation of these RAPs/ ESMPs for TA activities depends upon the decision of PIU and are not subject to the Bank’s supervision. However, in case any of these are included for implementation in due course under this project, ESIAs shall ESMF for G- ACRP, 2022 Environmental and Social Management Framework 76 be updated if more than 3 years old and implemented following all mechanisms as applicable to sub-projects (described in previous subsections). 5.8 Institutional Responsibilities across Sub-project Cycle Sub-projects Cycle and ESMF requirements, with institutional responsibility and tools to be used, are presented in Figure 11. Figure 11: E&S Requirements during Sub-project Cycle Thus, provisions in the ESMF for ESF implementation include: • Dedicated E&S Specialists (and Biodiversity/ Cultural Resources Specialists for applicable sub-projects): Contractor, PIU, PMC, for ESIA, RAP preparation/updating, approval, disclosure, supervision, and reporting, • Monitoring report by PMC (on Construction Supervision and Quality Assurance (CSQA)) who will monitor Civil Works and OHS when the works are ongoing and at work exit/operations stage, • Reporting on ESMPs: Monthly (or as and when required) Implementation Report by Contractor to Site in-charge/ implementing agency; Monthly Supervision Report by Site in-charge/ implementing agency to PIU, Quarterly report by PIU to the World Bank (based on a monthly report by Site in-charge/ implementing agency, Monitoring report by Quality assurance Consultants and quarterly supervision by PIU), • Annual Environmental Audit for select projects (all S1, and select M1, L1) by independent consultants, and ESMF for G- ACRP, 2022 Environmental and Social Management Framework 77 • Capacity building and cross-learning for E&S Management. 5.9 Conclusion 5.9.1 Risk–wise Procedures Matrix For quick guidance, a tabulated summary of key environmental and social impacts and mitigation/management measures for probable types of sub-projects/project components are provided in Table 14. This is just indicative and shall be updated and used as per probable impacts linked to project details and locational characteristics. A matrix is presented here, which could guide the procedures to be followed for each type of potential E&S risks and impacts. Colour codes have been given to signify the risk categories. Table 144: Phase wise Procedures for different Risk categories of Projects Sub-Project Procedures Responsibility Phase Substantial Risk Projects Moderate Risk Projects Low-Risk Projects Sub-project IESE of the sub-project (Using IESE of the sub-project IESE of the sub-project PIU Identification/ Exclusion Criteria & Screening(Using Exclusion Criteria (Using Exclusion Criteria Pre-Feasibility Format in ESMF Guidance & Screening Format in & Screening Format in Manual (Annexures) ESMF Guidance Manual ESMF Guidance Manual Risk Categorisation (Annexures) (Annexures) Risk Categorisation Risk Categorisation Consultations with key Consultations with key Consultations with key PIU stakeholders (as per SEP) and stakeholders (as per SEP) stakeholders (as per SEP) vulnerable groups such as ST, and vulnerable groups and vulnerable groups Women, disabled, etc. such as ST, Women, such as ST, Women, disabled, etc. disabled, etc. Preparation of ToR for ESIA Preparation of ToR for Prepare ESMP (outline Prepared by PIU, (outline provided in ESMF ESIA to be prepared provided in ESMF reviewed, and cleared Guidance Manual (Annexures) along with DPR (outline Guidance Manual by the WB provided in ESMF (Annexures) Guidance Manual (Annexures) Feasibility Conduct ESIA (ToR provided in Conduct IEE/ESA or E&S Use ESMP prepared also PIU, Consultants Study/ Design ESMF Guidance Manual Audit (in case of the using the ECOPs in ESMF (Annexures) by Independent existing facility) and Guidance Manual ESIA Consultant. Include E&S prepare ESMP also using (Annexures). Conduct Audit in ESIA if it concerns an ECOPs (in ESMF E&S Audit in case of an existing facility. In case DPR Guidance Manual existing facility consultant prepares ESIA, (Annexures) by separate Independent Review Feasibility/ Design to be conducted before Consultant. Update finalization & clearance by the ESMP based on the Bank design by DBOT Consultant Public consultations (as per Public consultations (as Public consultations (as PIU SEP) per SEP) per SEP) Prepare a plan for mitigation of Prepare a plan for Prepare a plan for PIU GBV and address gender- mitigation of GBV and mitigation of GBV and related concerns and inclusion address gender-related address gender-related of marginalized/stigmatized concerns and inclusion concerns and inclusion groups, if required, based on of of marginalized/stigmatized marginalized/stigmatized ESMF for G- ACRP, 2022 Environmental and Social Management Framework 78 Sub-Project Procedures Responsibility Phase Substantial Risk Projects Moderate Risk Projects Low-Risk Projects the outcome of the groups, if required, groups, if required, consultation based on the outcome of based on the outcome of the consultation the consultation If required, prepare RAP If required, prepare RAP If required, prepare RAP PIU, independent following the RPF (prepared following the RPF following the RPF consultant and included in ESMF) for the (prepared and included (prepared and included project (sample in ESMF in ESMF) for the project in ESMF) for the project Guidance Manual (sample in ESMF (sample in ESMF (Annexures). Guidance Manual Guidance Manual (Annexures). (Annexures). If required, prepare Use ECOPs on Use ECOPs on PIU, independent Biodiversity and/ or Cultural Biodiversity/ Cultural Biodiversity/ Cultural consultant Heritage Management Plan as Heritage (in ESMF Heritage (in ESMF required (as part of ESIA) using Guidance Manual Guidance Manual the Framework in ESMF (Annexures) if (Annexures) if Guidance Manual applicable; to prepare applicable; to prepare (Annexures). ESMP ESMP Detailed Ensure Mitigation measures Ensure Mitigation Ensure Mitigation PIU – PIU technical Design & (from ESMP) are included in measures (from ESMP) measures (from ESMP) specialist to send Tendering Design included in Design included in Design documents to E&S Specialists to ensure required procedures are met, before finalizing the designs Ensure ESMP, Monitoring Plan, Ensure ESMP, Ensure ESMP, PIU - PIU procurement and LMP aspects are included Monitoring Plan, and specialist to send pre Monitoring Plan, and in Bidding Documents LMP aspects are & post review LMP aspects are included in Bidding documents to E&S included in Bidding Documents Documents Specialists to ensure required procedures are met, before initiating the bidding process Documents shall include a Documents shall include Documents shall include PIU clause for women's a clause for women's a clause for women's employment in project work employment in project employment in project during the construction and work during the work during the operation period. construction and construction and operation period. operation period. Construction Implement and monitor ESMP Implement and monitor Implement and monitor PIU Works ESMP ESMP Update ESIA (and ESMP) as Update IESE (and ESMP) Update ESMP as PIU, Contractor/ required as required required Consultant SEP, GRM SEP, GRM SEP, GRM RAP before construction RAP before construction RAP before construction commences commences commences During ESMP & ESHS Audit by external ESMP & ESHS Audit by ESMP & ESHS Audit by PIU, External Auditors Construction consultants (Annual Audit) external consultants external consultants Works Construction Supervision & (Annual Audit) (Annual Audit) Safety Audit (Continuous) ESMF for G- ACRP, 2022 Environmental and Social Management Framework 79 Sub-Project Procedures Responsibility Phase Substantial Risk Projects Moderate Risk Projects Low-Risk Projects SEP, GRM Construction Supervision Construction Supervision RAP before construction &OHS/ Safety Audit by & OHS/ Safety Audit by commences PMC- as part of CSQA PMC – as part of CSQA (Continuous) (Continuous) SEP, GRM SEP, GRM RAP before construction RAP before construction commences commences Just before ESMP, RAP implementation& ESMP Audit (self-audit ESMP Audit (self-audit PIU, Consultant, Closure/ ESHS Audit and correction by PIU) by PIU) Contractor Work exit – Post Construction 5.10 Addressing concerns of disadvantaged or vulnerable individuals or groups Disadvantaged and Vulnerable households defined under the project include people living in slums and low income areas, ST, family/household headed by women/female, physically challenged, Below Poverty Line (BPL), and illiterate persons/households. This ESMF takes into consideration the risks and impacts on disadvantaged or vulnerable individuals or groups. It shall be ensured that i) terms of reference for undertaking ESIAs/RAPs adequately cover such categories of potentially impacted persons. ii) questionnaires and consultation checklists used for conducting census & socio-economic surveys and focus group discussions covered such groups. iii) ESIAs/ RAPs that are undertaken: • cover such groups in the consultation meetings including the issues and concerns raised by these groups and document them effectively. • identify additional measures that could be provided to address these groups • present mechanisms and modes by which the project will disseminate information to groups and consult with them to elicit their participation in the project interventions and which shall be included in the SEP. 5.11 Linkage to the ESCP The Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents, or plans, as well as the timing for each of these. The ESCP will be part of the legal agreement and will be signed by Implementing agency/s (IAs). IAs will require to comply with the provisions of any other E&S documents required under the ESF and referred to in the ESCP, such as the Environmental and Social Impact Assessments (ESIAs), Environmental and Social Management Plans (ESMPs), Stakeholder Engagement Plan, Resettlement Action Plan, etc. The ESCP will be prepared by the borrower considering the findings of the environmental and social assessment based on the ESMF, the Bank’s environmental and social due diligence, and the results of engagement with stakeholders. It will include the commitment of the implementing agency to (i) prepare and implement the plans required as per ESF, with timeframe and responsibility, (ii) improve institutional capacity for environmental and social management right across all stages of the project cycle, and value chain, (iii) integrate environmental and social considerations essential for long term sustainable outcomes. Adherence to the ESMF processes and provisions will therefore be ensured through the ESCP. Detailed Inputs for ESCP (which can be included in abridged form in respective parts of ESCP) ESMF for G- ACRP, 2022 Environmental and Social Management Framework 80 A. Comprehensive E&S risk and impact assessments shall be conducted for all sub-projects following ESMF procedures, including screening and categorisation. Implement other instruments prepared to comply with all applicable ESSs B. Designs shall withstand any safety impacts or risks on all project components, activities due to natural / manmade disasters and any impacts due to Vasna Barrage and this shall be comprehensively reviewed, and appropriate interventions adopted for safety and resilience in DPRs. • Undertake hydrological and flood assessment, including a study on Dam break analysis & Flooding Stimulation, preparation of inundation maps and Emergency Action Plan for Vasna Barrage, Ahmedabad, Gujarat. • Outcome/output of these assessments shall be incorporated in the design and subsequently assessed in C-ESIA & mitigation measures if required included in C-ESMP. • Emergency Preparedness and Response Plan and Disaster Management Plan shall be part of all ESIAs C. Comprehensive program for sensor based monitoring and actions, on industrial discharge into sewer systems while improving the sewer network and pumping stations D. Capacities to be improved at AMC in the form a Sustainable Urban Development Unit, to look at environmental pollution issues on ecosystem components comprehensively. E. Feasibility Reports for some of the initial investments (Vasna 40 MLD STP and Vasna 126 MLD STP) suggests that treated water shall be discharged into Fatehwadi Canal, for irrigation. This reuse is important considering the request from irrigation department as the region is water scarce. For this, it is required that AMC (i) agree with GPCB and Consent shall be amended to reflect such discharge through Fatehwadi Canal (ii) detailed consultations and perception survey shall be undertaken on all impacted downstream villages on usage of this water for irrigation during the Detailed Design Stage, before confirming that treated water is to be reused for irrigation, (iii) AMC should engage an agricultural scientist or tie-up with an agricultural university or institute for advice on the utilization or the rate of application of the effluent for irrigation considering the agro-climatic conditions and stakeholders views. Irrigation Management Plan shall be prepared in consultation with the agricultural scientist or agriculture university/institute and submit to GPCB which should verify the same while issuing Consent to the industry. The treated sewage should meet (a) the standards prescribed in the new Consent Conditions (for those parameters suggested in the Consent), and (b) standards for irrigation under Environment (Protection) Rules, 1986 and the standards suggested by the study (for those parameters not mentioned in Consent Conditions). F. In case the discharge is permitted to Fatehwadi Canal, by GPCB, there should be mechanism to continuously and automatically monitor quality of water released from Vasna Barrage into the Fatehwadi canal at (i) the point of outlet from Barrage and (ii) and appropriate downstream point after the last discharge point from STPs at Vasna. Based on this, there shall be mechanism to alert downstream users on the quality of water available in the canal. G. All sub-projects which involve irrigation / other canals shall consider catchments and regional impacts in a comprehensive manner while designing investments and ESIAs shall assess regional impacts, integrate relevant institutions, and consult with relevant stakeholders, in and beyond AMC limit. 5.12 Updating of ESMF Revision/Modification of the ESMF: This ESMF will be a “live document� enabling revision, as and when necessary. Unexpected situations and/or changes in the project or subcomponent design would therefore be assessed and appropriate management measures will be incorporated by updating the Framework to meet the requirements of the country’s legislation and the World Bank ESF. Such revisions will also cover and update any changes/modifications introduced in the legal/regulatory regime of the country/ state. Also, based on the experience of application and implementation of this framework, the provisions and procedures would be updated, as appropriate in consultation with the World Bank and the implementing agencies/departments. The finalized version of the updated ESMF will be submitted to WB for its review and approval, and redisclosed by both the borrower and the Bank following the disclosure procedures. ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 81 CHAPTER 6. PROPOSED INSTITUTIONAL FRAMEWORK AND BUDGET The existing institutional framework for project management and E&S aspects in AMC and GUDM are presented in Chapter 2. This chapter draws from the lessons learned from an analysis of the existing institutional setup, gaps and suggests institutional setup to effectively implement E&S aspects of G- ACRP. 6.1 Proposed Institutional Framework Considering the need to manage E&S aspects sewerage and stormwater drainage It is recommended to create a Separate ESF Cell in AMC named the Sustainable Development Unit, to integrate environmental and social aspects well into all operations of the drainage Department, those under G- ACRP and all other activities carried out by AMC in this sector to ensure long term sustainable outcomes and health benefits to the inhabitants. The proposed institutional framework for the E&S management for G-ACRP includes the setting up of a PIU in AMC and GUDM for respective sub-projects management. For overall project support, the services of a Project Management Consultant (PMC) will be used. 6.2 Proposed Institutional Framework for E&S Management The proposed Institutional Framework for E&S Management for G-ACRP is presented in Figure 12. Figure 12: Proposed Institutional Framework for E&S Management ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 82 6.2.1 Overview of Proposed Units to manage E&S aspects at Various Levels The program activities will be overseen by PIU established at AMC. PMC will will also help AMC co-ordinate with GUDM in reporting, by collecting E&S reports from E&S experts of GUDM and submitting to the Bank through QPR. PIU will be headed by Project Director and supported by Assistant Project Directors and/or Managers for each type of intervention; such as (i) wastewater, drainage, and other general interventions including capacity building, and support studies under AMC sub-projects; and (ii) capacity building activities/ TAs/ studies under GUDM. PIU of AMC will draw expertise of ESF (Environmental and social) from the experts at the Proposed Sustainable Urban Development Unit (SUDU) of AMC. SUDU will have ESF specialists, preferably two to look at environmental aspects and the other two on social aspects with overlaps and coordinated actions on ESSs. Working with G-ACRP PIU will build their capacities on E&S aspects through on-job training. They will also contribute their ESF expertise on other projects of AMC in this sector initially, and in the long run, is expandable to all activities of AMC for overall better environmental and social outcomes. E&S specialists will be required at GUDM to manage the E&S aspects of TA activities which will be carried out by GUDM. SUDU of AMC and E&S Specialists of GUDM (SUDU of GUDM) proposed here will contribute their expertise and capacity acquired through on-job training to the proposed Center for Excellence in GUDM under the Capacity Development Component, so that E&S considerations get embedded in all urban development activities across the State in the long run. The SUDU GUDM E&S specialists act as E&S secretariat of the Proposed Centre of Excellence and could be a lighthouse on E&S aspects for all ULBs of Gujarat and upscaled in the long run. The PMC will have two Environmental experts (one Environmental Engineer and EHS specialist, and another Environmental Planner/Specialist) and two (2) Social Development and Gender Experts who will coordinate and support ESF specialists of PIUs during the preparation, implementation, monitoring, and reporting of E&S aspects. Experts on Cultural Heritage, Biodiversity Conservation, Hydrology and EHS shall also be made available by the PMC as required. They will ensure that all records on E&S aspects are up to date and well maintained and easily accessible in hard and soft form. Consultants who prepare E&S documents and deliver capacity building activities will have Environmental, Biodiversity, Heritage, R&R, Gender experts as required to prepare E&S mitigation/management measures and work with design consultants on integrating E&S aspects in design and supporting ESF specialists of PIUs to ensure that ESMPs and other aspects are incorporated in bid documents. This requirement will be incorporated in the ToR for consultants. Contractors who will implement sub-projects on site will have E&S experts and EHS Site officers to prepare, update ESMPs to reflect actual site/design aspects, to monitor, ensure, report, and maintain up-to-date documentation on the implementation of E&S aspects on site regularly. Considering the Occupational and Community Health and Safety (OCHS) issues which would be important while upgrading existing STPs and laying of networks along congested roads, PMC OCHS specialist will monitor OHS aspects on-site and report regularly to PIU as part of CSQA. Annual E&S Audit will be conducted through third party E&S auditors who will monitor compliance to ESMF, OCHS on-site (may be same consultants or separate for ESMF ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 83 compliance and OHS) and report with suggestive corrective actions for non – compliance. 6.2.2 Monitoring and Reporting Three types of monitoring and reporting are envisaged here including Third Party, external, and Internal. Internal monitoring is a continuous process undertaken by contractors E&S persons, PMC (who will carry out regular monitoring on all E&S aspects and special monitoring on OHS and CHS hand in hand with Civil Work Monitoring) and PIU; and a third party will undertake an annual E&S audit. Sub-project level monitoring will be as follows: ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 84 Table 155: Sub-project Monitoring schedule Sub-project Category Internal Monitoring External Auditing Stage Agencies Contractor / PMC PIU WB CSQAC/ supervision E&S Auditor Consultant consultant during design or O&M Design Stage Inclusion of findings of ESIA in Design, Include ESIA findings in Design, BoQ, Bid Clear Design review & Design Review Annual E&S Scheduling Design, BoQ, Bid documents suggest corrective Audit, submit documents actions during semi- to PIU and Implementation Updating of the ESMP annual missions/ finalize Labour Housing /Camp technical visits as incorporating required PIU, WB ESMP, CHMP Implementation comments OHS Management Plan Labour Camp Prepare before the Review Clear Traffic Management Plan start of site works Waste Management Plan Tree cutting, compensatory plantation, and Green belt Enhancement measures ESMP Implementation Daily monitor; submit a Review weekly Review Monthly report Review QPR, verify & OHS weekly report to PMC report of the of PMC, verify on-site suggest corrective Review fortnightly and contractor, verify monthly or as required, actions during semi- submit a monthly Labour Camp on-site quarterly or suggest corrective annual missions/ report to PIU Traffic Management as required, actions, compile QPRs technical visits as Waste Management suggest corrective and submit to WB required Biodiversity, Tree cutting, actions, prepare a compensatory plantation, and Green monthly report belt with details, Enhancement measures Monitor as required/as corrective actions Monitoring of environmental and per plan, submit as part social parameters of the week’s report O&M Stage Monitoring of environmental and Monitor as per Plan Verify, suggest corrective actions, monitor social parameters ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 85 Contractors E&S Experts and EHS specialists will monitor daily ESMP compliance on-site at the sub-project level, and report weekly to the site engineer. The site Engineer will submit this to PMC E&S experts who will verify every week or as required, and compile these to prepare monthly monitoring reports to PIU. PIU also undertakes site visits to monitor once a month or as appropriate, and compile E&S reports over the quarter and submit to the Bank as part of the project’s Quarterly Project Monitoring Report (QPR) or as a standalone E&S quarterly monitoring report highlighting key issues, how issues were managed, and any support required on E&S. The environment and social management instruments at the sub-project level such as ESIA, RAP guide monitoring and evaluation parameters and describe the institutional arrangements to facilitate the ‘process’ and ‘progress’ monitoring. Designated E&S Specialists/experts at various levels shall be responsible for overseeing compliance of the sub-projects to Bank ESF, GoI regulations, and applicable ESMF guidelines. They shall also regularly review the timely implementation of environment provisions as per the ESMP. PIUs and the World Bank review and clear E&S documents. PIUs have the responsibility to review the sub-project ESF documents prepared by consultants. ESF documents should only be sent to WB for prior review after PIU’s good quality initial rev iew and sign off. It is also suggested that PIU shared ESF documents with WB by mentioning specific areas in which they need clear guidance. PIUs (with PMC support) also report to the Bank during its six-monthly supervision missions. The following aspects shall be monitored and reported as per the frequency provided in Table 16 below. Corrective actions shall be initiated in a planned manner as appropriate to ensure compliance with the ESMF/ESMP measures. Table 166: Overall Project Monitoring Parameters and Schedule Sl.No. Particulars Frequency Reporting Monitoring Responsibility responsibility Input Monitoring 1 ESMF Compliance, Status Monthly/ PMC, E&S Auditor PIU - Project Director Report, including any issue Quarterly and ESF Specialists with screening results, the status of conduct of ESIAs including required plans like CHMP, BMP; and actions taken for compliance on site 2 Site visit reports of Monthly PMC, ESF APD of PIUs respective sub-projects in specialists of PIU respective sectors 3 Regulatory clearances - Quarterly PMC, ESF APD of PIUs Environment specialists of PIU 4 R&R plans including Quarterly PMC, ESF APD of PIUs livelihoods support, specialists of PIU entitlements 5 Community consultations Quarterly PMC, ESF APD of PIUs specialists of PIU 6 Grievance redressal Monthly or as PMC, ESF APD of PIUs soon as reported specialists of PIU Output/ Outcome Monitoring 1 Water Quality of receiving Yearly Twice (Pre PMC, ESF PD of PIUs Waterbodies and Post specialists of PIU monsoon) in coordination with GPCB ESMF for G- ACRP, 2021 Institutional Framework and Budget for ESMF Adoption 86 Sl.No. Particulars Frequency Reporting Monitoring Responsibility responsibility 2 Air Quality near work Quarterly PMC, ESF APD of PIUs areas, facilities specialists of PIU in coordination with GPCB 3 Areas with water Pre and During Officials of APD of PIUs stagnation monsoons concerned sectors 4 Increased no: of Annually Officials of APD of AMC PIU premises/area covered concerned sectors with drainage and sewage facilities developed under the project 5 No: of worksite incidents Quarterly or PIU ESF specialists PD of PIU (all types covered under within 4 hours of Systematic incident any incident Reporting Tool (SIRT) in various project sites (during Construction and O&M) 6 Impacts on cultural Monthly PIU ESF Specialists PD of PIU heritage or Biodiversity & PMC during the project implementation 6 Grievances on Monthly PIU ESF specialists PD of PIU environmental pollution issues related to project facilities include issues with STPs not working, untreated water being disposed on land or water bodies, drainage channels clogged, labor issues on work sites 6.2.3 Reporting Formats Reporting formats shall be developed by PIUs to get progress and results data of the project from the field. This will also help in synchronizing and streamlining reporting requirements from the various work sites. These should be part of the Project Operations Manual. 6.2.4 E&S Information System Detailed E&S Management Information System ESMIS linking project details, scheduling, and documentation of the ESIA process, integration of E&S aspects in design, ESMP in bid documents, and ESMF implementation will support the project in the effective preparation and updating of ESF instruments, implementation, supervision, and monitoring. It is preferable to have an online ESMIS for ease of updating data, management, and retrieval. Even in the absence of such a system or delays in establishing it, the ESF specialists of PIUs shall prepare a datasheet in tabular format and maintain an MIS to track all requisite ESF instruments for sub-projects right at project commencement. This Project Info-Table or MIS shall be continuously updated as and when each sub-project starts or as required. The decision to start preparations for each sub-project shall be conveyed to the PIU ESF specialists and/or procurement plan for each quarter shall be shared well in advance with them to initiate the process to ensure screening, categorization, and preparation of ESIAs. PIU with the support of PMC shall update and maintain ESMIS. ESMF for G- ACRP, 2021 Institutional Framework and Budget for ESMF Adoption 87 6.3 Capacity Building G-ACRP envisages capacity building for all agencies involved in the project including PIUs (including Line Departments, Local Bodies, Statutory Boards, Public Undertakings applicable or each sub-project), and Potential Private Operators, PMCs, Consultants and Contractors to ensure that the ESMF is effectively operationalized. This will be accomplished by organizing sensitization programs, workshops, and training programs, which will be coordinated and anchored through training institutions and experts. Indicative details of the training program are presented in Table 17. This will be elaborated and a proper training plan and schedule/module will be devised by PIUs through the support of national training institutions and PMC. The proposed ESF support, training/capacity building activities for ESMF implementation will be supported through Component 1 of G-ACRP at an estimated cost of INR 0.2 Crores (USD 0.027 Million), for the Project implementation period as presented in Table 18. Table 17: Outline of the Proposed Capacity Building Program on G-ACRP (2022 – 2027) Sl Training Programs and Contents Presenter/s Frequency and Targeted No Modules Duration, Location Participants A Project Level Training Programs 1 G-ACRP ESF On-boarding of - World Bank’s ESF and Concept of ESMF, Project Cycle The World Bank and Half or One-day PIU Project key staff - Applicable regulations and Sensitivities: National, State, Reputed ESIA training interactive Director/ Local/ others Organisations (Year 1: At Project Assistant Project initiation; Year 2: Directors, other Before Start of Staff, ESF/E&S activities; Year 3: Mid Experts of PIU, Term Corrective) PMC other Location: Virtual project agencies 2 Project Level 360o Orientation Program Two days interactive PIU/ Local Body Module 1: About G-ACRP - About project sectors and baseline situation in PIU Project Director/ (First Three modules – all staff, PMC (if Program Ahmedabad; existing and proposed system and Assistant Project together in a day; onboarded) involvement of the AMC, GUDM, and The World Bank Director fourth module on the technical review (including Financing Instrument) second day) committee - Technical and Financial Aspects members, all sub- - Project Implementation Set up (Year 1: After Project project staff Module 2: ESMF and the - World Banks ESF (ESSs) and ESMF for G-ACRP The World Bank, PIU Kick-off; before selected for all Project Cycle; and Regulatory - Applicable regulations: National, State, Local/others ESF Specialists initiating sub-projects to Aspects - Project Cycle of G-ACRP implementation), Year date ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 88 Sl Training Programs and Contents Presenter/s Frequency and Targeted No Modules Duration, Location Participants - ESMF incorporation in Project Cycle during Identification 2: Start of Year 3: Year (Screening, Categorization), Preparation, Appraisal, – After Implementation Module 4 (Day 2): Implementation (Monitoring, Audit) initiation) All E&S Module 3: Overview of - Overall Project Locations Reputed National ESIA Specialists, Locations and Project - Expected impacts: activity-wise training Organisations, experts already Activities; Impacts - Need for mitigation/management Department of Location Virtual in Year onboarded Environment, 1; and Year 2, 3 Pollution Control preferably at Board Ahmedabad in case of Module 4: Sub-project level - ESIA& Audit: EA process, Identification of Environmental Reputed National ESIA post-COVID 19 E&S Assessments, Mitigation/ Impacts, Impact Identification Methods, Identification of training Organisations situations Management measures, Mitigation Measures, Formulation of ESMP, Climate and/ or hiring Institutional Aspects, budget Change adaptation and mitigation Plans, Implementation, adequate experts (Case studies) and Monitoring, Institutional Mechanism trained in ESF if - Session on Cultural Heritage Management available - Session on Biodiversity Conservation and Management - Session on Climate Change and Resilience - Session on Occupational and Community Health and Safety - R&R policies and procedures, National & World Bank Requirements, LA process, Identification of PAPs, Social Entitlement Frameworks, Social Impact Assessment, RAP Techniques Beneficiary Assessments 2 Implementation Experience Sharing Program One day; interactive PIU and staff of all Module 1: Experience Sharing - Experiences on implementation of ESMF/ ESMP in E&S, EHS, Heritage Year 2 - end, Year 4 - Departments of on ESMP Implementation implemented projects and Biodiversity start and at the close of AMC, PMC, - Best Practices-Site visits to project sites (or virtual visits) Specialists PIUs, PMCs, the Project (Year 5) – technical review Consultants near implementation committee Module 2: Review of Audit - Discussion on the results of the annual audit on ESMF & ESMF Audit completion stage members, CBOs, Results corrective actions Consultants Contractors, et al Module 3: Stakeholder - Stakeholder Analysis ULB/PIU, PMC as applicable Participation and Community - Participation models in various projects by CBOs, Engagement Communities, Individuals, Private parties, PIUs Module 4: Best Practices - Site visit to select sub-projects to display best practices in E&S, EHS, Heritage Showcase any field/aspect (or virtual in case of restrictions) and Biodiversity ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 89 Sl Training Programs and Contents Presenter/s Frequency and Targeted No Modules Duration, Location Participants Specialists PIUs, PMCs, Consultants B Site Level Training Programs 1 ESMP Implementation Module 1: Environmental Enhancement and Occupational Reputed National ESIA One day; Every Year, Contractors staff, Health and Safety training Organisations starting from Second Supervisors, Line - Clearance/ permits/ regulatory aspects or by hiring adequate departments, - Cultural Heritage Management on site experts PMC - Biodiversity Management on site - Occupational Health & Safety Training - Staff & Labour Code of Conduct - HIV/AIDS prevention Training, Best hygiene practices - Emergency Response System - Behavioural Training - Implementation of ESMP provisions Module 2: Review of Sub-project Level Environmental Actions - Review of Environmental Actions at each sub- project - Lessons learned - Course Corrections Modules for training may be developed to respond to the capacity-building needs of the various target groups/stakeholders. A more comprehensive plan on training and capacity building will be included in the Operations Manual for the project. This may further be finetuned by PIUs/ PMC after onboarding. Other training on project sectors may be conducted through State Level Training Institutes as required. A module on ESMF implementation shall be included in all project technical/ capacity-building efforts. These training activities covering all suggested modules may also be temporally clubbed with other Project training/capacity building exercises. 6.4 Budget for ESMF Implementation To effectively implement the environmental management measures suggested as part of the ESMF, necessary budgetary provisions will be made in the DPRs for the individual sub-projects. The tentative budget for each of the sub-projects should include E&S management costs along with the cost to include good engineering practices and the cost of environmental and resettlement monitoring. As presented in sub-section 5.5.1, the budget for complying with the ESMP needs to be worked out for each sub-project by working out the cost of ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 90 implementing each ESMP mitigation measure. Where this is not possible, the provision of a minimum of 3 percent of the sub-project cost needs to be earmarked for implementing ESMP measures. Also, provision for ESHS performance security is made to ensure ESMP implementation. All administrative costs for implementing the ESMF shall be budgeted as part of the budget for human resources and other facilities while preparing the budget for PIU establishment and operations. Drawing from the project experience and current indicative costs of Substantial Risk projects the following Table 18 provides a rough estimation of costs for ESMF implementation. All ESF instruments have been inbuilt into the project modality and will be financed through the project and detailed project cost tables will include the necessary costs accordingly. The associated cost to implement ESMPs as well as training for project staff, contractors, etc. have been integrated into the project budget. The sub-projects will ensure that all works contracts will include the ESMP, and the cost of implementing the ESMP will be identified as an item in the Bill of Quantities of the DPR. The budget for ESMF implementation has been calculated which should be made part of overall program costs for G-ACRP to ensure smooth implementation of E&S aspects using this framework. The budget is worked out for 5 years. Table 18: Proposed Budget for ESMF Implementation Unit Rate Sl Unit Rate per No: of Total Cost Total Cost Proposed E&S Management Quantity (INR) or Assumptions NO month years (INR) (USD) ** Rate/ Year 1 E&S Personnel 2 in AMC, 2 in GUDM; 4 specialists @ Rs 150000 per a ESF Specialists, PIU 4 150000 600000 5 3000000 40219.86862 specialist per month for 5 years 2 Specialists (E&S), Rs 120000 per specialist per b ESF Experts, PMC 2 120000 240000 5 1200000 16087.94745 month for 5 years Considered sharing between sub-projects. c Environmental Engineers/ Site Engineers 20 100000 2000000 5 10000000 134066.2287 Approximately 2.5 years per sub-project 2 Training/ Capacity Building One day; Three years; select audience- intensive a ESF Onboarding 3 100000 3 300000 4021.986862 training b 360o Orientation 3 200000 3 600000 8043.973723 Two days; Three years, PIUs c Experience Sharing 3 100000 3 300000 4021.986862 One day, a larger audience, 3 years d Site level workshops 40 20000 40 800000 10725.2983 half day, 4 years, all sites (40 expected) 3 Supervision, E&S Coordination a Sub-projects screening by PIUs 40 30000 - 1200000 16087.94745 40 sub-projects assumed Co-ordination and Travel for ESMF implementation by PIU (including site b 500000 5 2500000 33516.55718 lumpsum per year verifications, discussions, compliance monitoring, review committee meetings) ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 91 Unit Rate Sl Unit Rate per No: of Total Cost Total Cost Proposed E&S Management Quantity (INR) or Assumptions NO month years (INR) (USD) ** Rate/ Year 4 Preparation of E&S Instruments Preparation of ESF Instruments including Approximately 12 substantial risk sub-projects, 5 Low a 40 59000000 - 59000000 790990.7494 ESIAs, RAPs risks, 23 moderate risk sub-projects 5 Other ESMF Implementation Support lumpsum per year (may be combined also with item a CSQA and OCHS Audit 1 1500000 5 7500000 100549.6715 5(b) below) b Annual E&S Audit 1 2500000 4 10000000 134066.2287 Every year starting year 2 (4 yrs) Sub Total 96400000 1292398.445 12 Contingencies Contingencies & Miscellaneous; including 15 Perce overall coordination and planning, Percentage Percentage 14460000 193859.7667 percent ntage emergencies Approx. 1 percent cost is considered as sub-projects ESMP Monitoring Costs (1 % of the cost for are not known. The rest of ESMP cost will be covered 1 Perce 13 investments approx. incl. contingency Percentage Percentage 1108600 14862.58212 in the sub-project ESIA and ESMP budget. percent ntage costs) Institutional costs are already added above for various specialists/ travel etc. 5 per G-ACRP will engage professional IEC agencies or 14 IEC Awareness 25000 1500000 3 4500000 month enhance the existing capacities at AMC Approx. 70 consultations per year @INR 5000 per 15 Stakeholder Consultations 70 5000 350000 3 1050000 consultation, total 3 years considered Existing fully function GRM at AMC will be updated to 16 Project GRM 100000 3 300000 to meet G-ACRP requirements Support for R&R (other than resettlement Details to be given in the RAP if required to be 17 assistance/compensations prepared for sub-projects Grand Total 111968600 1501120.794 Say 11.2 Say 1.50 Grand Total in Words crores INR Million USD ESMF for G- ACRP, 2022 Institutional Framework and Budget for ESMF Adoption 92 * Monitoring needs will be finalized at the ESIA stage for moderate and substantial/ high-risk sub-projects; based on sub-projects locations and sub- projects types and impacts. The budget for this will be part of each sub-projects costing. The team feels that specific costing for monitoring activities recommended in various Indicative ESMPs cannot be estimated at this stage, since sub-projects are not yet identified. However, based on a similar experience, one (1) percent of the investment cost is added here for monitoring. Besides, ESMP monitoring costs will be included in individual ESIAs – ESMP, bid documents, and additional mitigation/ monitoring shall be the contractor's responsibility. ** USD conversion rate adopted as on October, 2021 I USD=74.6 INR (https://www.fbil.org.in/#/home The ESMF budget does not include Resettlement costs of any nature. These costs shall be borne from the counterpart funding. The Project Director is the designated officer for approving the documents, with recommendations from E&S specialists. ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 93 CHAPTER 7. STAKEHOLDER ENGAGEMENT, GRIEVANCE REDRESSAL MECHANISM, INFORMATION DISCLOSURE 7.1 Stakeholder Consultation The project is required to engage with multiple and varied sets of stakeholders for different activities under the project components. The stakeholder engagement process is a dynamic process that will be implemented throughout the project lifecycle. Stakeholder involvement, interest, and influence in the project activities will vary during the various phases. Therefore, this section of the ESMF will give a broad framework for consultations. A detailed standalone Stakeholder engagement Plan (SEP) is prepared for the project. Based on the nature and timing of activities SEP describes how two-way communication between the Implementing Agency and the affected communities and stakeholders would be achieved throughout the project cycle. Consultations are used as a tool to inform and educate stakeholders about the proposed actions which are going to impact them both before and after the development decisions were made. The involvement of the various stakeholders ensures that the affected population and other stakeholders are informed, consulted, and allowed to participate at various stages of project preparation and implementation. Consistent with the requirements of ESS 10 on Stakeholder Engagement and Information Disclosure, this chapter describes the applicable legal and regulatory framework besides the requirements under WB’s ESS 10 and the process of consultations on ESMF. The process of consultations is aimed at and mandates that Project components, including the E&S instruments, are explained to stakeholders well, setting expectations on the overall project cycle. A brief account of consultations with about 21 stakeholders, held during Apr-Jul 2021 is summarised in this chapter. Further, a “Stakeholder Engagement Plan� (SEP) is prepared and separately disclosed, duly taking into account the existing institutional and regulatory framework within the context of GoI and State’s legal instruments as well as the compliance requirements of Environmental and Social Framework (ESF) of the World Bank. The SEP outlines the process of identification of stakeholders duly considering all stakeholders relevant to the overall Project including its components and sub-components. The stakeholders include those currently associated with the Project and those who will be associated with the Project at a later stage during implementation. Stakeholders are identified and categorized into: i) project-affected parties, ii) other interested parties and iii) disadvantaged and vulnerable groups. The SEP provides for systematic consultation with all those inter-project beneficiaries, project- affected people, women, vulnerable and poor members of the community, and other stakeholders to understand their interests and influence over the project. 7.2 National Legal & Regulatory and WB ESS 10 requirements Stakeholder Engagement is mandated within the existing institutional and regulatory framework of the National and State legal instruments as well as the ESS compliance requirements of Environmental and Social Framework (ESF) of the World Bank and is mentioned below: • The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 • The Right to Information Act 2005 • ESS 10: Stakeholder Engagement and Information Disclosure, ESF, World Bank ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 94 The Environmental Protection Laws mentioned above mandate that stakeholders have the right to environmental information as well as to participate in developing, adopting, and implementing decisions related to environmental impacts. The provisions of environmental law provide the assurances for a public hearing during the process of project planning and ensure the public discussion during implementations for select identified projects. Public representative bodies have an obligation to take into consideration citizens’ comments and suggestions. • The Land Acquisition Act, 2013 maintains the ethos and culture of public participation through social impact assessment. • The Right to Information Act, 2005 provides for setting out the practical regime of right to information for stakeholders to secure access to information under the control of public authorities, to promote transparency and accountability in the working of every public authority. • The ESS-10, Stakeholder engagement, and information disclosure mandates stakeholder engagement as an inclusive process conducted throughout the project life cycle. The World Bank’s Environmental and Social Framework (ESF)’s Environmental and Social Standard (ESS) 10, “Stakeholder Engagement and Information Disclosure�, recognizes “the importance of o pen and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice� (World Bank, 2017: 97). Specifically, the requirements set out by ESS10 are the following: • Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope, and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. • The Borrower will maintain and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not. 7.2.1 Stakeholders to be Consulted during Sub-project Preparation The following stakeholders need to be consulted during Project Implementation Table 19: Details of Stakeholder Consultations required on Environmental and Social Aspects Project Stage Consultation Activities Remarks Project activity Household-level consultations through sample At the start of the sub-project, preparation questionnaire surveys or FGDs on service levels, and during the detail designing needs, impacts, and risks they expect from sub- stage project, their information and engagement needs/ preferred modalities Consultation with all line departments and other At the start of the sub-project, concerned Government establishments including and during the detail designing GPCB as well as private agencies stage Focus group discussions with people including During the visits to project sites vulnerable groups residing/ working near the sub- project sites, treated wastewater disposal areas, soak pits, pump houses, and related infrastructure – on issues/ risks faced and expected views on mitigation measures and engagement during all stages ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 95 Project Stage Consultation Activities Remarks Consultations with affected persons – including At various stages since the waterlogged areas, people/ premises near drainage/ beginning especially during ESIA, sewage lines laid under the project, people who will RAP be potentially displaced either physically or economically or face loss of access during project construction or operation. Activity Focus group discussions with the people residing/ During the ESMP monitoring at Implementation working near the project sites and people who are worksites including E&S Audit, impacted by the project – physically or economically RAP implementation - on risks/ impacts they experience during implementation and effectiveness of mitigation measures, proposed improvements Informal discussions with the construction workers During the ESMP monitoring at and construction supervision staff (contractor, worksites E&S Audit consultants, and PIU) OHS risks during implementation and effectiveness of mitigation measures, proposed improvements Informal discussions with commuters and the public During the ESMP monitoring at along with the roads/ sites near which works are worksites E&S Audit implemented (and proposed mitigation measures) Implementation Discussions/ Meetings of concerned departments During works and operation/ & O&M (wase water/ drainage/ water) with GPCB, Traffic maintenance activities Police and Water Supply and waste management Department on pollution concerns due to works or facilities developed; discussions with Estates department of AMC and Land Acquisition unit of District Administration as the case may be to understand the progress and issues pertaining to land take (if any) Stakeholder engagement is an ongoing process and will be taken up in accordance with the SEP. Relevant outcomes of the consultations will inform the design/preparation of project activities/assessments/ mitigation instruments throughout the project lifecycle. Special attention will be paid to consultation with vulnerable groups to address their concerns and ensure that they can access project’s benefits following the stakeholder engagement process described in the SEP. 7.3 Grievance Redress Mechanism Grievance redress mechanisms (GRMs) can be an effective tool for early identification, assessment, and resolution of grievances associated with projects. A project-specific GRM has been prepared for the Gujarat Resilient Cities Partnership: Ahmedabad City Resilience Project . The grievance redressal mechanism aims to achieve a mutually agreed resolution of grievances raised by stakeholders. An individual or a group can register a complaint or an expression of dissatisfaction that is related to an impact caused by a project activity, which has affected an individual or group adversely - e.g. problems related to dust deposition, noise, or vibration). Grievances could either be less serious or more serious which if not addressed effectively may pose a risk to the operations of the Project. These could include complaints on forceful eviction, loss of livelihoods without compensation, etc. A GRM to uphold the Project’s social and environmental performance is designed to address concerns and complaints promptly and transparently with no impacts (cost, discrimination) for any grievances made by project-affected people (PAPs). The key objectives of the GRM are: • Receive, Record, categorize and prioritize the grievances. ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 96 • Settle the grievances via consultation with all stakeholders (and inform those stakeholders of the resolutions) • Forward any unresolved cases to the relevant authority. The types of grievances stakeholders may raise include, but are not limited to: • Non-payment of compensation and forceful eviction of project-affected people • Construction-related impacts – cracks, damages to structures; dust damaging crops/ trees • Health and safety risks to communities, workers etc, including grievances related to GBV/SEA/SH risks. • Negative impacts on the environment. • Negative impacts on communities, which may include, but not be limited to financial loss, physical harm, and nuisance from construction or operational activities. AMC has a functional complaint system (CCRS, http://www.amccrs.com) which includes a web portal and a toll-free number. It records almost 40000-50000 complaints every month. Any complaint registered in the system is forwarded to respective zones for action. Each complaint has a proper system by which it can be escalated if the applicant is not happy with the resolution. If some complaints come directly to the zonal office (mostly from the urban poor) they are recorded in the CCRS system. The CCRS is integrated with the Gujarat Government’s CM Helpline and any complaints received at CM Helpline are also recorded in the CCRS system. Grievances of PAPs will be first brought to the attention of the site office level of the PIU which shall be redressed within two weeks from the receipt of complaints. Grievances not redressed by the PIU staff (field level) will be brought to the Grievance Redress Committee (GRC) which shall redress the grievances within four weeks from the date of receiving the complaint at PIU. GRC shall be formed at a zonal level comprising of competent members, who can effectively contribute to grievance redressal. GRC team consists of Zonal Officer AMC, Env and Social staff of PIU, a local CBO/CSO representative. The main responsibilities of the GRC will be to (i) provide support to PAPs on problems arising from land/ property acquisition; (ii) record AP grievances, categorize, and prioritize grievances and resolve them; (iii) immediately inform the PMU of serious cases; and (iv) report to PAPs on developments regarding their grievances and decisions of the GRC and the PMU. Other than disputes relating to ownership rights under the court of law, GRC will review grievances involving all resettlement benefits, compensation, relocation, replacement cost, and other assistance; noise, traffic, odor, and other grievances related to the environment. The GRC will meet every month (if grievances are brought to the Committee), determine the merit of each grievance, and resolve grievances within a month of receiving the complaint. Records will be kept of all grievances received including contact details of the complainant, the date the complaint was received, nature of the grievance, agreed corrective actions, and the date the corrective actions were affected, and the outcome. The GRCs will continue to function during the life of the Project including the defects liability period. For the G-ACRP, the most likely complaints will be from the public as regards construction works at STPs, trunk line laying, burrowing, trenching, adjacent land parcel impacts, material transport, waste dumping, visual & environmental quality deterioration, social rights, etc. Cases not resolved at the GRC level would be brought for resolution by Commissioner, AMC. In the case at this level, the dispute is also not resolved, the aggrieved person may take recourse to the civil court and the decision of the Court will be binding on all parties. Project level GRM will be established in accordance with SEP while worker GRM will be established in accordance with LMP. ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 97 7.4 Information Disclosure 7.4.1 Procedure for Information Disclosure G-ACRP -related information will be disclosed through a public consultation and making relevant documents available in public locations as well as the AMC website (https://ahmedabadcity.gov.in). The project agencies and associated line departments will provide relevant ESF-related information promptly, in an accessible place, and the manner and language understandable to affected persons and other stakeholders. For illiterate people, other suitable communication methods will be used, if found necessary. The draft ESMF report must be discussed with the project agencies and relevant stakeholders before making it available at the offices of PIU/ AMC. A concise summary of the project and draft ESMF report (in the local language - Gujarati), providing all necessary details of proposals, implementation arrangements, sub-project locations, likely issues and mitigation, and monitoring measures and grievance redress mechanism, shall be made available to the stakeholders. This should also provide the contact information of the project agency/ PIU. This summary shall also be displayed at the notice boards of PIU, its concerned zonal/ ward offices, and related line departments for ease of access to citizens. During project implementation, relevant information about any major changes to the project scope will be shared with beneficiaries, affected persons, vulnerable groups, and other stakeholders. SEP shall be disclosed as early as possible and updated as required. ESCP shall be disclosed, updated, and included in legal documents. The following documents shall be made available at the offices of PIUs, and other public places such as the concerned zonal/ ward office of AMC for public reference and shall also be uploaded on the websites of PIUs. 1. Summary of G-ACRP project (in English and local language - Gujarati) 2. SEP, LMP, RPF, CHMF, BCMF and ESCP 3. Grievance Redress Mechanism and contact details 4. Draft ESMF Report (in English; translated summary in Gujarati) Once the draft is finalized after consultation with the stakeholders including the implementing agencies, the following documents will be made available at offices of PIUs (AMC & GUDM) and zonal/ ward offices of AMC for public reference and shall also be uploaded on respective websites. 5. Final ESMF Report (in English); with translated summary (Gujarati) 6. All ESIAs (with ESMPs with CHMPs, BMPs as applicable)and RAPs, for initial 30% investments as per Country’s requirements/ readiness criteria 7. Final versions of SEP, LMP, RPF, CHMF, BCMF and ESCP During implementation, the following shall be disclosed in hard/ soft form and accessible to the public. 8. Updated/ amended ESMF, RPF, LMP, SEP, CHMF, BCMF & Summary (in English & summary in Gujarati) as required 9. Redisclosure of SEP and ESCPs after updation 10. Sub-projects ESIAs (with ESMPs, CHMPs, BMPs), RAPs, (English, with Summary in Gujarati) as per ESMF 11. Corrective action plan if any prepared during project implementation (English) 12. E&S Monitoring Reports (English) The following documents will be submitted to the World Bank when final for disclosure on Bank’s external website. PIU will send written endorsement to The World Bank for disclosing these documents: 1. Draft ESMF (with translated summary). ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 98 2. Final ESMF (with translated summary)and RPF, LMP, CHMF, BCMF (in English & summary in the local language –Gujarati) 3. A new or updated ESMF and corrective action plan prepared during project implementation, if any; and 4. ESIAs (with ESMPs with CHMPs, BMPs as applicable) and RAPs, CHMPs for H/S rated sub- projects and for all sub-projects under initial 30% investments which need prior clearance from the World Bank 5. E&S monitoring reports 6. Final SEP and ESCP In addition, all E&S screening sheets and E&S instruments for all sub-projects will be available in ES MIS. 7.4.2 Information to be disclosed Table 20 below specifies the type of information to be disclosed and frequency of dissemination: Table 200: Information Disclosure Matrix Topic Documents to be Frequency Where Disclosed E&S Documents ESIA, ESMP, RAP, LMP, Once in the entire − World Bank’s external website. CHMP, BCMF ESCP project cycle. Update − On the website of PIUs (soft copy) E&S Audits as necessary and (AMC, GUDM as applicable) E&S corrective actions if redisclose. To remain − The borrower will make the ESIAs, any on the website and ESMPs, RAP, LMP, CHMP, BMP (hard other disclosure copies) available at a place accessible to locations throughout displaced persons and local NGOs, in a the G-ACRP project form, manner, and language that are period understandable to the PAPs in the following offices: • PIU office: AMC – main, zonal/ ward offices, GUDM • Office of the contractor on site Grievances Grievance redressal Continuous process − World Bank’s website. process throughout the − On the websites of PIUs (AMC, GUDM as project cycle applicable) − Hard copies in the local language in the following offices: • AMC-main, zonal, ward offices • Office of the contractor • GUDM (if applicable) − PAPs to be informed on one to one contact SEP, Public Minutes of Formal Within two weeks of − On the websites of PIUs (GUDM/ AMC Consultation Public Consultation meeting as applicable) Meetings − Hard copies in the local language in the following offices: • AMC – main, zonal/ ward • Office of the contractor In addition to the information specified in Table 20, the following information shall also be displayed/disseminated, wherever applicable. ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 99 1. Project-specific information needs to be made available at each contract site through public information table 2. Project information brochures shall be made available at all the project sites as well as the office of PIUs. 3. Reports and publications, as deemed fit, shall be expressly prepared for public dissemination e.g., English versions of the ESIA, RAP, ESMP (with CHMP, BMP as applicable), and Executive Summary in the local language (Gujarati). 4. Wherever civil work will be carried out aboard will be put up for public information which will disclose all desired information to the public, for greater social accountability. 5. All information will be translated into the local language and will be disclosed to the public through the concerned PIU offices, or their websites. 7.5 Status of Consultations and Disclosure of this ESMF Consultations were conducted with concerned stakeholders during the preparation of this ESMF. Residents/ communities especially those near the Sabarmati River, inundated areas and canals/ water bodies, and existing/ proposed STP or drainage/ sewerage lines were consulted. Community groups, NGOs, industries, engineers/ employees/ contractors of sewerage and drainage works in Ahmedabad were also consulted. Most of the consultations were virtual given the COVID 19 related restrictions. A wide range of consultations was held with the following categories: • Project Affected Parties: those which are affected or likely to be affected by the project. These include stakeholders who are directly affected by poor drainage in the city as well as officials in certain Departments of AMC like finance, drainage, etc. • Other Interested Parties: The term “other interested parties� refers to individuals, groups, or organizations with an interest in the project, which may be because of the project location, its characteristics, its impacts, or matters related to the public interest. These would include Resident Welfare Associations, other Departments in AMC, elected representatives, NGOs, and others who work with stakeholders. • Disadvantaged or vulnerable and identified individuals or groups refer to disadvantaged or vulnerable refers to those who may be more likely to be adversely affected (may be temporary). Such an individual/ group that may be excluded from/ unable to participate fully in the mainstream consultation process and as such may require specific measures and/ or assistance to do so like urban poor who live as squatters without formal title of their land. The Stakeholder consultations helped to achieve a good understanding of the stakeholders and their concerns; understand the impacts, the Project could have on stakeholders and the influence stakeholders could have on Project preparation and implementation (including improving design, also including delaying implementation, or undermining success). A summary of the key points raised during the stakeholders’ consultations is given below and full details of various discussions with stakeholders are presented in the project’s SEP and Annexure C (Annexures) of this Report. Project Affected People (including vulnerable groups): • Regular clogging of sewer lines • Mixing of drinking water with sewer/wastewater • Overflow of drain water during the rainy season • People staying close to STP raised concerns about the foul odor ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 100 • People living in villages downstream of Sabarmati brought up concerns about the poor quality of water of the river • Health issues for certain people living near CETP and STP. Other Interested Parties Departments under AMC: • UCD: Drainage Problems in the slums; Mixing of drinking water and wastewater; Some unauthorized dwellings may be present in the canal/ lake rejuvenation footprints of proposed project sites; South Zone faces water logging problems more than other zones. • Drainage Department: Drainage Problems in the slums; Mixing of drinking water and wastewater • Sewage treatment plant Department: Rehabilitation work started in old lines as often major breakdowns happen there. All rehabilitation works take place with no dig technology to minimize the disruption; No-dig technology is specialized work and requires specialized labor from outside Ahmedabad. For this labor camps may be required. • Heritage Department: There are no standard vibration limits set for works near heritage structures; if a project requires detailed impact assessment or not is decided on a project-to- project basis. • Roads Department: Any encroachment on the roads is looked into by the Estate Department; All utility lines are laid before roads construction work starts; Any private company doing excavation has to give security deposit for excavation; Community Health and Safety during construction lies with the contractor. • City Planning Department: More than 85% of the city is covered under the TP Scheme; there are no unauthorized structures on the road; there is no provision for compensation for unauthorized structures. • CCRS: Three methods of registering complaints – toll-free number, CCRS on the internet, and physical registration in ward office; CCRS receives about 50,000 complaints every month; CCRS data and state-level Grievance System data are mutually exchanged widely; regular feedback is sought on GRM through citizens’ feedback. • Solid Waste Management Department: Ahmedabad is one of the well-performing cities under SBM and the Department has taken a lot of initiative to collect, sort, and dispose of solid waste in the city. It is also planning to launch a project of “waste to energy�. The Kharicut canal and the lakes are cleared regularly and a CCTV camera is installed to monitor. The Department has a Scheme for Rag Pickers. Nearly 1000 rag pickers are registered. The Department has set up composting plant through PPP mode. • Zonal Heads: On the eastern side, dense population especially near the Kharicut canal creates a problem; on the Southern side main issue is that the main trunk is silted leading to breakdowns; No systematic drainage line is there as there is a lot of encroachment; in the central zone, lines are very old and are often choked due to silting; encroachment on government land on the main trunk line is a major issue; encroachment is a problem in narrow zones. Others: • AUDA: During peripheral development, enhancement of infrastructure was not envisaged; untreated water in the downstream of Sabarmati which is used for agriculture is a major source of concern; sensor-based systems are provided in STPs to measure the pH level of ESMF for G- ACRP, 2022 Stakeholder Engagement, GRM, Information Disclosure 101 water released; the contracts for execution of drainage or water supply works do not have a specific clause for air pollution prevention. • Contractors maintaining STP: SCADA sensors erode and stop working because of gases in the plant and high temperature; due to mixing of industrial effluent with sewage the color of the treated water becomes yellow once which made the recipient farmers of Juhapura Canal complain to AMC. After that incident water is again being discharged into the Sabarmati River; the issue of foul smell is often brought up from the community; during monsoon, they need efficient pumping. Contractors normally have an extra team during monsoon. 8 • Contractors working on Drainage: Lack of space to safely store equipment; regular monitoring by PMC as well as AMC on quality of work however no reporting is done on social and environmental standards and issues; they follow strict labor standards. • Mumbai Ahmedabad Fast Track Train: Some good practices of land acquisition like consultations, transparency, direct access to the project authorities for grievances are observed and could be followed in G-ACRP. • Mahila Housing Trust: Sewage is often clogged and the pumping station does not work; the issue of vectors like rats in the chawls (old rental housing mostly of more than one storey; mostly offered by industries to workers) of central Ahmedabad where the sewer lines are very old; in periphery slums, the individual connection of sewer lines is a problem they have mostly soak pits; solid waste is collected but not recycled; vulnerable groups do not have access to the GRM of AMC. Kharicut Canal is dry and has become a solid waste dumping ditch • SEWA: There could be several settlements that are on encroached land or houses are on the drain. Some of the slums have the issue of drainage and mixing of drinking water with drain water; some unauthorized dwellings (encroachments) on the proposed project sites may be interrupted; the conditions in the dumping sites are extremely hard with no provision of water, toilets, sheds, etc. • Elected Members: Ahmedabad is a growing city and in the next 30 years its population will double itself; rehabilitation of old drainage system; reuse and recycling of water is one of the priorities. Recycled water from STPs to be used by farmers downstream of Sabarmati and fulfilment of NGT suggested limits. Vulnerable Groups • Stakeholder inputs from vulnerable groups include - Issue of mixing sewage water with drinking water, inadequate service delivery, land ownership issues, air pollution due to proximity to industrial areas, no clear understanding of temporary livelihood disturbances, and access issues during construction works 7.6 Conclusion ▪ This ESMF document for G- ACRP will act as the guidance document for the management of environmental and social aspects for all components of the project. This is a living document and shall be updated, as and when necessary; following the consultations, approval, and disclosure requirements of the World Bank. -------------------------------------------------------------------------------------------------------------------------- 8 Hon’ble High Court of Gujarat has constituted a task force comprising of AMC, GPB, and other stakeholders to tackle this issue by identifying and disconnecting all industrial connections to sewers, and these industries which will be allowed to operate only after setting up ETPs or connecting their effluents to CETPs. The task force has disconnected more than 380 connections till Dec 2021. ESMF for G- ACRP, 2022