The Company has presented plans to address the impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the IFC Environment and Social Performance Standards and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and the Company and will address the compliance gaps with IFC’s requirements.
PS 1. SOCIAL AND ENVIRONMENTAL ASESSMENT AND MANAGEMENT SYSTEMS
Land and Natural Environment:
Pulkovo Airport is located approximately 16km south of the center of St Petersburg. The airport has been in existence since 1932 and it borders the outer limits of the city, with an industrial and commercial area to the north east and residential properties mixed with light industrial facilities to the northwest. The eastern side of the airport borders the Pulkovskoe Highway, which also provides the main entrance to the airport. To the south and west of the airport are residential areas and farmland. Much of the neighboring areas have been developed since the airport started operations back in 1932.
Environmental and Social Assessment:
According to the Russian regulatory requirements, the airport upgrade involving new construction requires a development of an EIA and state approval before construction project begins. The Company has initiated the development an EIA and the assessment of impacts from the construction and operation of the upgraded airport which is conducted by a qualified local contractor.
The PPPA between the City of St. Petersburg and the Company requires that an Environment Baseline Survey is completed and reported to the City of St Petersburg. In accordance with the PPPA, the Company has contracted environmental consultants for the development of the Environment Baseline Survey which will provide details on the potential historical contamination at Pulkovo Airport. Due to the history of the site and airport operations since 1930s it is expected that the baseline study will conclude contamination of the site with aviation fuel, diesel, various oils and other substances. Data collected to date provides evidence of previous uncontrolled disposal of wastes on the airport site. Under the terms of PPPA all existing contamination within Pulkovo Airport existing at the Effective Date is responsibility of the City, while the Company will be responsible for any site contamination arising from reconstruction or demolition. However, in cases when pre-existing contamination may affect project implementation, the Company has a right to negotiate with the City the necessary mitigation measures and reimbursements to the Company from the city. In addition, the company has conducted Environmental and Social Analysis by environmental consultants at the request of IFIs, which highlighted the current gaps with IFI’s requirements and developed an Action Plan for closing the gaps.
Environmental and social management and organization:
Currently, Pulkovo Airport Company has four staff in the Environmental Department responsible for managing environment issues. They are responsible for preparing permit applications, management plans and conducting monitoring and reporting in accordance with permit conditions. This department liaises with other departments at the airport, such as, Airfield Services, Chief Mechanics, and the Engineering Aviation Department to manage environment issues. There is also an Occupational Safety department that is responsible for implementing Russian Federal labor safety laws and for implementing and maintaining the labor safety management system.
The new operator of the Airport, the Company, will develop an environmental, health, and safety (EHS) management system, commensurate with its present operations which will cover construction and operation phases, and which will meet IFC requirements as per PS 1.
Training, monitoring, and reporting:
Following Russian regulatory requirements, the Pulkovo Airport Company has an established program to provide necessary training for all its employees in the field of EHS performances related to its operations, including training of new employees and refresher courses. Company’s workers and technical staff are routinely trained and certified according to Russian labor regulations. The Company will maintain this practice after the transition from the previous operator and upgrade the requirements in relation to the new facilities and aspects of operations. As a part of the ongoing work for development of EIA, an environmental monitoring system for ambient air quality, noise, waste water and storm water will be established.
PS 2. LABOR AND WORKING CONDITIONS
Human Resources Policy and Management:
The Pulkovo Airport Company follows Russian labor regulation in recruiting, retaining and retiring its employees. All new hires are properly informed of the labor conditions, benefits and remuneration prior to employment. Individual employment contracts also specify all benefits according to Russian labor regulations. The HR Procedure define aspects of recruitment, working hours and overtime, holidays, sick and annual leave, wages and benefits, employees’ and employers’ responsibilities, disciplinary practices, promotion, and a grievance mechanism, among others. The Human Resources department is responsible for ensuring compliance with the requirements of the Russian Labor Code and the HR Procedure.
Workers Organizations:
Currently approximately 3,700 of the 4,200 employees of the Pulkovo Airport Company are members of the labor union. There is a collective agreement in operation at the Pulkovo Airport Company that defines responsibilities of employees and the employer and specifies the terms and conditions of employment, including work safety conditions, benefits and remuneration.
Working Conditions:
Working conditions are in compliance with Russian labor regulations and workplaces are routinely monitored in all company’s facilities. Workers on company’s facilities which are classified as hazardous according to the Russian classification system, receive additional benefits and medical check-ups are conducted periodically for such employees. Workplace monitoring program is established as a part of environmental monitoring program and concentrations of main air pollutants are routinely measured to avoid negative impact on workers health.
Occupational Health and Safety (OHS):
Pulkovo Airport Company operates a Corporate Labor Protection Management System, which has been certified in accordance with the Russian regulatory requirements. The Airport has a labor safety policy and all employees are informed of its requirements, which they must follow in everyday operations. All necessary PPE is provided to all employees whose workplaces required it.
Procedures for risk assessment of main activities were developed and all staff undergo regular training on work safety issues and are periodically certified according to Russian regulatory requirements. Root cause analysis is performed on all incidents and corrective action plans are implemented to prevent their re-occurrences. The airport has been collecting accident data since February 2009. Since then the data shows five minor accidents, most of which are falls due to slipping in the Spring, Fall and Winter weather conditions.
Equal Opportunity:
Equal opportunity is guaranteed by the Constitution of the Russian Federation. The Airport is an Equal Opportunity employer. Women, various ethnicities and nationalities, religious groups and people with disabilities are represented amongst the workforce, including management of the Airport.
Retrenchment:
At the beginning of 2010, as a part of transition from the Pulkovo Airport Company to the Company, the Company started staff transition process which will be supported by local HR experts. The Russian speaking personnel will hold the interviews with Pulkovo Airport employees, in order to make an efficient staff allocation and selection process, taking into account both the employees expectations as well as the Company’s requirements.
The transition team will supervise and support the selection process by making recommendations on the future organizational structure and adequate staffing of the departments. The final decision based on the interviews and recommendations will be taken by the Company. The Company envisages – within the framework of its staffing requirements in the individual departments, which still needs to be developed during the transition phase – to offer each Pulkovo employee who is willing to join the new airport company a position which fits within the employee’s skills and expectations. There is no retrenchment currently planned by the Company, but if retrenchment of staff may become necessary at later stages of the transition process, the Company will take any decisions on retrenchment taking into account applicable Russian legislation and best practices, and develop necessary procedures as well as retrenchment plan(s) in accordance with IFC requirements of Performance Standards 2.
PS 3. POLLUTION PREVENTION AND ABATEMENT
Pre-Existing Contamination:
Due to the history of the site and airport operations since 1930s, the various parts of the airport site are contaminated with aviation fuel, diesel, various oils and other substances. Data collected to-date provide evidence of previous uncontrolled disposal of wastes on the airport site. The Company is currently undertaking a baseline survey that will show the extent of site contamination. Subsequently, the terms of rehabilitation and clean-up activities will be negotiated with the City of St. Petersburg as part of PPPA and implemented by the Company.
Solid and Hazardous Waste Management:
The Pulkovo Airport Company has a waste management plan for collection, removal and processing of domestic waste and other operational waste which is approved by the local regulator. It is accompanied by 6 separate annual waste management permits relating to the various airport operations. The airport is using third-party certified contractors to remove the waste from the site. Food and other airline waste from certain destinations must be collected, sorted and incinerated on-site, in accordance with local sanitary requirements.
The company will undertake a review of waste storage areas and the upgrade of collection areas and facilities in order to ensure that waste is collected and removed in accordance with best practice. Waste will be segregated and recycled where practicable and an updated Waste Management Plan will be developed for the construction and operation of the airport as required by the ESAP.
Impacts from Construction:
The potential environmental impacts from construction renovation, expansion activities, and the construction of the new terminal include fugitive emissions and dust, noise, waste management, and additional vehicle traffic movement on the airport highway. The EPC contractor and subcontractors are expected to be legally bound to control these to acceptable levels through application of standard construction environmental controls. Waste Management Plan for construction is to be developed as per ESAP.
Asbestos Containing Materials:
Asbestos-containing materials may be present on site and be part of construction and demolition waste during construction. According to the ESAP, the company must identify all asbestos-containing materials on site and in construction and demolition waste and handle them in accordance with best international practice and IFC requirements.
Air Emissions:
Main sources of air emissions from the airport operations include exhaust gases from aircraft and vehicle movements and stationary sources such as diesel generators, the incinerator and venting from fuel storage tanks. According to company records and analysis conducted by environmental consultants, a large proportion of the 2008 air emissions were a result of the old type of Soviet-built aircraft using Pulkovo (II86, TU134 and TU154). Recently, two of the main airlines using the airport, Rossiya and Aeroflot, have completely phased-out the aforementioned aircraft, which will contribute to improvements in air quality. According to the air monitoring data, the incinerator located on-site used for incinerating airline food and other waste, contributes to the excessive emissions of some pollutants. Currently the Company is exploring options to upgrade of the incinerator to satisfy Russian regulatory requirements and IFC air emission requirements. Upgrade or replacement of the incinerator will reduce the impact of stationary sources on the air quality at the airport. Planned preventive maintenance regimes for stationary equipment will reduce the impact on poor air quality. The planned upgrade of aprons and more efficient aircraft movement following project implementation will reduce air emissions from aircraft idling on aprons and runways.
In accordance with the ESAP, the Company will develop a air monitoring program and conduct negotiations with resident airlines on phasing-out outdated aircraft to improve ambient air quality on and around the airport.
Liquid Effluent:
Domestic liquid effluent from airport facilities is collected and transferred to the municipal sewage system of the City of St. Petersburg. Run-off water from the airport facilities and runways is collected using through the drainage system and is processed in the airport’s waste water treatment facilities before being treated and disposed to the nearby creek. Separate pre-treatment and oil capture facilities are located in the refueling and fuel storage areas. The use of de-icing materials on airport aprons and runways during Fall, Winter and Spring months contributes to higher level of some runoff water pollutants during and after the spring thaw.
Phase 1 construction works include a review and upgrade of all drainage systems, including waste water treatment facilities. New runoff water treatment facilities will be constructed to treat the materials that are being released by the airport and to meet the capacity of existing and future activities, these will include upgraded interceptor arrangements for grits and oils. In addition, there are requirements to construct facilities to capture and potentially recycle de-icing materials. In accordance with the ESAP, the Company will prepare and implement a Master Plan and phased project for upgrades of drainage and water treatment systems for runoff and waste water.
Noise:
Noise pollution from approaching and taking off aircraft is the main source of noise pollution. Situated in the area adjacent to the city, residential and industrial areas, the Pulkovo Airport has noise impacts on the surrounding communities. The most affected communities situated in the Moscoskiy, Krasnoselskiy, Kolpinskiy, Pushkinskiy and Kirovskiy districts of St. Petersburg. Communities of Pushkin/Tsarskoe, Selo, Krasnoye Selo, Gorelevo, to the South, Pulkovo to the east and Aviagorodok, which is adjacent to the Pulkovo 2 site and borders the airport boundary to the north east, are the most vulnerable to noise impacts.
According to the Company, phasing out of the old Soviet-built aircraft will lead to a reduction in noise levels. Additionally, the company is required, as per ESAP, to investigate together with the Russian Aviation authorities’ a possible change of routes for approaching and taking-odd aircraft to minimize noise impacts on the surrounding communities.
A detailed noise modeling will be undertaken as a part of EIA development and Sanitary-Protection Zone study to provide in-depth information of potential noise impacts on the surrounding communities and suggest possible further mitigation measures.
The Company will develop a comprehensive Noise Management Plan to include the following:
- Performance specifications for noise for new equipment, wherever possible, to ensure that the procured item is noise controlled;
- Establish noise monitoring stations based on predominant wind directions; noise sources; flight path, and population. Noise contour modeling will be conducted by compiling data.
- The location of the new international terminal at the centre of the airport will assist with improving noise levels at the airport and will facilitate greater use of both runways.
- Over time the mix of aircraft using Pulkovo Airport will be altered to reflect a more modern mix. The II86, TU134, TU154 aircraft (typically noisy aircraft) is due to be removed from service;
- In conjunction with Air Traffic Control aircraft take off and landing routes will be reviewed to take into account the use of the older, more noisy aircraft and local sensitive noise receptors;
- Work with Air Traffic Control to review the flight zones and introduce more accurate methods and measures of aircraft control;
- Airport operating times will meet environmental regulatory requirements;
- Where noise is attributed to operational airside activities of groundside, distance attenuation and screening will be adopted where practicable;
- All equipment e.g. auxiliary power units and ground support vehicles will be maintained in good working order;
- Engine idling on the terminal aprons will be kept to a minimum.
In addition, the Company us required by IFIs to develop Stakeholder Engagement Plan (SEP) and establish a grievance mechanism to monitor grievances concerning noise for adjusting operations scheduling and developing further mitigation measures.
Sanitary-Protection Zone:
According to Russian regulatory requirements, a Sanitary-Protection Zone (SPZ) study has to be conducted for industrial facilities including airports. The SPZ study evaluates the levels of existing and potential emissions and other polluting factors from the project and specify a buffer protection zone around industrial facilities. Currently, the Company has commissioned the development of an SPZ study for the extension and upgrade of the airport.
PS 4. COMMUNITY HEALTH, SAFETY, AND SECURITY
Community health, safety and security:
To ensure life and fire safety of people in the terminals, the company must design the new airport facilities in accordance with fire safety rules and obtain approvals from the government for the design of a new terminal. During operations, the Company must maintain proper life and fire safety conditions in all public facilities and have to periodically undergo audits by the respective government agencies. A Fire Safety and Evacuation Plan has to be developed and approved by the government before commissioning of the new terminal, in accordance with the ESAP.
Emergency preparedness and response:
Security and safety of passengers, of approaching and departing aircraft is provided by the air traffic monitoring system by the Russian Aviation authorities and emergency preparedness plans for incidents with aircraft and air traffic are approved by the respective government agencies. A special designated emergency response unit and fire brigade is located on site and an emergency response plan is developed and approved by Russian Civil Defense authorities. Emergency response planning during construction will be a legally binding responsibility of the EPC contractor with oversight role by the Company and the local regulator.
Security personnel:
As a high-security zone, the airport and some of its facilities are guarded by government security forces to prevent sabotage, potential terrorist attacks and violation of immigration laws. Government security services act in accordance to their specific instructions and laws of the Russian Federation which aim at preventing breach of security and security abuses and are independent from the airport operations and the Company. The company coordinates its activities with government security services and received necessary clearances for personnel access to the runways and various other airport facilities. In addition to site security, the airport also hosts the representatives of customs and border patrol services and has to coordinate with the respective Federal agencies certain aspects of development of the project, such as design of the terminal and contractors’ access to site.
PS 8. CULTURAL HERITAGE
Cultural Heritage Sites:
There are no sites of historical or cultural significance in the project site. The building of the old Pulkovo airport from 1930s, which is located between Terminal 1 and Terminal 2 represent an example of the Soviet architecture of the time and is considered for historical preservation. According to the PPPA, the Company must and plans maintain the building it its current design and have no plans for alterations.
Chance Find Procedure:
Given the age of the airport and the WWII history of the region there is a risk of unexploded ordnance being present at the airport. An assessment of this will be made as it relates to the areas of the Environment Baseline Survey.
The Company uses the chance find procedure stipulated by Russian regulation for dealing with historical and cultural artifacts during the construction. The procedure requires stop of construction work, notification of company’s management and informing archaeological research center that will conduct further review and assessment of the site. Upon IFC request, the Company will ensure implementation of chance find procedure by its construction contractors.
