The following sections outline the institutional arrangements recommended for implementation of the ESMP.
11.3.1 Inclusion of ESMP in Contract Documents
In order to make contractors fully aware and responsible of the implications of the ESMP and to ensure its compliance, it will be ensured that environmental measures are treated appropriately and separately in the tender documentation and that payment milestones are linked to environmental performance, measured by execution of the prescribed
environmental mitigation measures. Such a procedure would help ensure adequate assessments of project impacts are carried out during Project construction and operation phases, where a consistent approach will be expected on behalf of contractors that warrant data and information collected from monitoring programs are compared to baseline conditions.
The contractor would be made accountable through contract documents and/or other agreements of the obligations and importance of the environmental and social components of the Project. They would be prepared to co-operate with the executing agency, project management unit, supervising consultants and local population for the mitigation of adverse impacts. After the ESMP’s addition in the contract documents, the contractor will become bound to implement the ESMP and to hire trained environmental management staff for implementation and effectiveness of the mitigation measures.
The contractor is to bid for executing the ESMP, including the recommended mitigation measures and monitoring programs, as part of their Bill of Quantities.
The contractor(s) would be required to prepare the following plans before mobilization on the basis of the ECPs (Annex C) and IFC/WBG EHS Guidelines (Annex D), and obtain approval from the Supervision Consultants/ESMU/WEC:
Traffic management plan
Pollution prevention plan
Waste disposal plan
Camp management plan (including drinking water management)
Borrow area and disposal area restoration plan
An emergency response plan,
An occupational health, public health and safety plan.
11.3.2 Implementation Responsibility
It is responsibility of the proponent (WAPDA) to ensure implementation of the ESMP through consultants and contractor(s). The staff of the proponent, consultants and contractors who are responsible for ensuring the implementation of the ESMP would have the capability to handle the complexities and spirit of management strategies.
Training and workshops would be arranged involving proponent, consultants and contractors to share the issues of environmental and social protection.
11.3.3 Construction: Establishment of Environmental and Social Management Unit
An Environmental and Social Management Unit (ESMU) will be established, responsible for implementation of the ESMP and the SIMF. The ESMU will be specially designated for the Project and will include representative of all actors responsible for ESMP implementation. Regular environmental, health and safety obligations in the construction area will also be part of the responsibility of the ESMU.
The following is the list of responsibilities to be performed by the ESMU:
Ensuring effective implementation of the ESMP and SIMF.
Overall supervision, facilitation and coordination with all the stakeholders;
Develop procedures of damages assessment and mode of compensation during project execution;
Ensure that all contractors follow the PEPA regulations and other requirements mentioned in the construction contracts concerning dust suppression, solid waste disposal, municipal wastewater disposal, air pollution, noise and vibration, biodiversity, transport, storage and use of flammable and explosive materials;
Identify any issues of non-compliance and report these;
Suggest mechanisms to link contractor performance in relation to the ESMP to the timing of financial payments, incentives or penalties;
Interaction with the stakeholders for their concerns about the construction activities;
and
Implementation of contingency plans.
The ESMU will ultimately be responsible to the WAPDA Environment Cell (WEC), taking a leadership role in the ESMU, with a senior WEC representative taking responsibility for the ESMU overall. It is important to have representation from stakeholders involved in delivering the Project, including those with contractual responsibilities.
The proposed composition of the ESMU is as follows:
Senior Engineer level WAPDA officer having environmental science background;
Health, Safety, and Environment (HSE) Specialist (to be appointed by WAPDA);
Social Scientist (SS) (to be appointed by WAPDA);
Environment and Social Monitor (ESM) - Representative of Consultant (Design or Supervision); and
Environment and Social Supervisor (ESS) - Representative of Contractor.
11.3.4 Operation: The WAPDA Environment Cell
The ESMU will play an important role during the construction phase, bringing together representatives from the organizations that are active on-site. During the operation period, WEC will be solely responsible for the environmental performance of the operational hydropower station.
WEC was created in 1989 to take stock of Environmental Aspects of WAPDA’s Water Sector Development Projects. Two pronged objectives were focused at that time.
Strengthening, upgrading and enhancing of technical capability of environmental capability in WEC; and
Recommendation of an institutional framework and linkages that would enable effective application of this capability within WAPDA and within the national framework of environmental institutions.
Since its creation, WEC has carried out scores of IEE, EIA, Environmental Management Plan (EMP) and assessment of social and environment management of WAPDA Projects.
In addition, WEC was responsible for decade long monitoring of environmental and social issues of GBHPP, including environmental water flow assessment and evaluation of various reports.
The charter of WEC was chalked in its infancy to go ahead with the environmental studies of various project vis-à-vis:
to carry out various EIA and IEE of Hydropower Projects;
to take stock of implementation of EMP according to EIA;
to help project authorities to monitor the environmental parameters during feasibility design, construction and operation phase of the Projects;
to help WAPDA Authorities to facilitate in environmental auditing;
to carry out assessment of social and environment management; and
to evaluate and comment on the environmental (EIA) reports prepared by Consultants and other Agencies.
11.3.5 Consultant’s Environment and Social Monitor
The Supervision Consultants (SC) will appoint an appropriately qualified specialist as the Environment and Social Monitor (ESM) at the site on a full time basis. The ESM will be responsible to ensure effective implementation of ESMP, and will supervise the contractors for this purpose. The ESM will be a part of the ESMU as described earlier.
11.3.6 Contractor’s Environment and Social Supervisor(s)
The Contractor(s) will appoint adequate numbers of appropriately qualified specialist(s) as the Environment and Social Supervisors (ESSs) at the site on a full time basis. The ESS will be responsible to effectively implement the ESMP during the construction phase, will supervise the construction activities for the environmental and social aspects, and will liaise with ESM for this purpose. The ESS will be a part of the ESMU as described earlier.