Environmental and Social Assessment and Management System
Decree 1180/03 exempts mass transit and terminal infrastructure projects from obtaining an environmental license to operate. Nonetheless, due to the need for the project to have a tool for adequately managing the E&S risks and impacts of the project, Transcaribe, the project sponsor, opted for developing an integrated and internationally compliant environmental and social impact assessment (ESIA) for the SITM. The ESIA was prepared by Transcaribe, in accordance to the objectives of the National Master Planning Board, and approved by CARDIQUE Corporación Autónoma Regional del Canal del Dique.
through a number of resolutions passed between 2006 and 2012. The ESIA and ESMS process benefitted from technical input from the E&S teams working at other integrated massive transit projects across the country (Megabus, Metrolinea, Metroplus and Transmetro). Combined, these E&S guidelines and practices will contribute to defining and formalizing the Operations Manual for all future National Urban Transport Projects. To ensure this is taken seriously, compliance with the E&S requirements and guidelines has been linked with either receiving financial rewards or sanctions in all contractual agreements.
The risks and impact identification process took into account the outcomes of the engagement process with affected persons, and considered potential incremental cumulative impacts and risks associated with other modes of transport and emissions of greenhouse gases (GHG) and suspended solids on climate change and public health. Given WB financing, the ESIA was developed aligned with WB E&S Safeguard Policies and Procedures. The approved ESIA includes: - (i) environmental and social baseline, (ii) - risk and impact identification and evaluation, and – (iii) an E&S management system (ESMS) comprised of 8 components, including: (1) Organizational Structure, Objectives and Roles and Responsibilities; (2) Social Management Plan (including stakeholder engagement and resettlement); (3) Environmental Management Plan; (4) Construction Management Plan; (5) Contingency Plan; (6) Monitoring Plan; (7) Supervision Plan; (8) ESMS Implementation Program. The Social Program underpins communication, engagement and information sharing with all stakeholders, on all relevant E&S risks and impacts.
The environmental impacts and risks of Phase I activities are limited to those associated with the construction of infrastructure required for enabling the SITM to operate as designed. Environmental impacts are generally of low risk and temporary in duration, all easily manageable, mitigable and reversible using the application of good international industry practices (GIIP). Construction activities are complete for the most part and involved the clearing of public spaces, the demolition of existing infrastructure and building of new infrastructure. Impacts included emissions of noise and dust from the use of heavy machin
ery and trucks/vehicles on site, inadequate disposal of construction waste leading to land/water contamination, OHS accidents and incidents, poor labor and working conditions, unskilled workforce, accidents due to increased vehicular traffic from the transport of construction materials and waste, unsafe loading/unloading of materials and waste, lack of proper fencing or boundary controls and construction sites, inappropriate use of force by security guards, etc. Social risks and impacts associated with Phase I activities are of medium to high risk as these involve sensitive impacts such as: (i) managing the economic and physical resettlement of peoples living along the right of way of the main trunk line; (ii) reestablishment or improvement of socio-economic conditions of affected persons through community development and livelihood restoration; and (iii) continuous stakeholder engagement and communications with local peoples as a means of sensitizing and educating them about the new transport system, routes, timetables, and codes of conduct. These risks and impacts are not considered to be part of the project to be financed by IFC.
The government led resettlement process carried out by Transcaribe was developed in coordination with other government agencies, using the findings collected in the social impact assessment (SIA) of the ESIA, which included a socio-economic baseline assessment and evaluation, a detailed census survey of directly affected persons/areas and the results from a comprehensive stakeholder engagement process with affected persons and communications with broader project stakeholders. Resettlement was carried out across 7 stretches of the project, the most sensitive and complicated being in the Bazurto area (stretches 5a/b) where the highest number of economically and physically displaced persons and capacity building was required. In total, across all 7 stretches, Transcaribe carried out over 3,000 consultation meetings with local stakeholders, logged over 1,300 grievances, opened nearly 80 information booths across the project area of influence, and carried out dozens of seminars, trainings and other capacity building events.
Land was acquired from a total of 432 owners, while nearly 1,600 street vendors were eligible for compensation due to economic displacement resulting from the clearing of public areas and access roads, in preparation for the SITM. As of March 2015, resettlement activities are 98% complete, with open cases remaining in stretch 5a (Bazurto – Pie de la Popa) and the location of the main bus terminal, where project completion is at 20%. Resettlement will be completed prior to the operation of the IFC-financed project and is not the responsibility of the client.
The results and findings of the Phase I ESIA, ESMS and stakeholder engagement process informed the terms and conditions (T&C), technical specifications and E&S requirements of the transportation concession contracts (TCC). Clause 7, 3 and 2
of the concession contract requires Transcaribe approve all studies prepared by the Concessionaires. Transcaribe’s role as project Sponsor is to ensure that the Concessionaires consistently comply with the T&C of the TCC and to support them in obtaining whatever permits or licenses are required for the O&M of the system. Each Concessionaire is responsible for developing their own E&S assessments, management plans and systems, consistent with the objectives and assumptions stated in the E&S framework prepared by Transcaribe and approved by the Government. As required, Transambiental will prepare an ESMP and ESMS, a Contingency Plan for the Bus Terminal, and a Monitoring and Supervision Plan for all O&M activities.
Environmental impacts of Phase II activities – i.e. those to be financed by IFC - are of medium to low risk and severity and are associated with: (i) reducing the carbon footprint (GHG) of the project, conserving water, and increasing fuel efficiency of the system; (ii) management of solid and hazardous wastes, water discharges, soil, air and noise contamination on-site and along the route, using GIIP, and compliance with the parameters and levels set in the IFC EHS General and Sector Specific Guidelines; and (iii) life and fire safety and emergency response and preparedness at the bus terminal, administrative offices and any supporting facilities under Transambiental’s control. Social impacts are those associated with: (i) retrenchment of bus drivers/operators of the existing system; and (ii) recruitment, capacity building and training of new drivers/operators and all other staff of the SITM. Stakeholder engagement and communications will be ongoing to ensure open and transparent communication with users and the public, as is having a robust grievance redress mechanism.
Transambiental will adopt Si 99’s (parent company) corporate vision, mission and ESHS policies, procedures and sustainability strategy. Si 99 has been involved in structuring and managing integrated bus transit systems since 1999, with the award of the TransMilenio concession in Bogota, Colombia. Si 99 operates against an integrated management system based on ISO 14000, ISO 9000 and OHSAS 18000 that covers the range of ESHS issues. The management system aims to demonstrate traceability in the flow and use of information, continuous improvement in processes, and integrated management of risks and impacts. Following Transambiental’s integrated ESHS management system, the project has procedures for risk and impact identification, auditing and compliance and supervision.
Transambiental carried out a risk and impact identification and evaluation process for the project, where risks and impacts, their appropriate mitigation and management, where mapped and catalogued by area: - mechanical, - electrical, - social, - administrative, - O&M, - Occupational Health and Safety (OHS), - security, - scheduling and programming, - labor, etc. IFC reviewed drafts of the ESIA,
ESMS and risk matrices and considers these to be in alignment with IFC’s PSs. Final versions of these documents and the Environmental and Social Policy will be submitted to IFC once ready, prior to the commencement of operations activities, presently scheduled for the last quarter of 2015. (ESAP Condition 1) The final ESIA and ESMS will be disclosed by IFC as per the Access to Information Policy.
In terms of organizational capacity, Transambiental will either have a dedicated team or contract advisory for managing the E&S risks and impacts of the project. The team will be led by an Environmental Manager and a Social Manager, supported by specialists in OHS, labor and training issues. Retrenchment of drivers/operators will be managed in coordination with Transcaribe as the concession contract requires that the Concessionaire retain/absorb at least 50% of current employees into the new system. All staff, but particularly (new) drivers/system operators, will undergo intensive training on the operational aspects of the buses and routes, including emergency response and preparedness. The training program will be based on the programs already in place for the TransMilenio project. Training, capacity building and incentive programs offered to drivers/operators are critical elements of securing the efficiency and reliability of the system, as it brings discipline and professionalism into the sector, which in turn influences commuter and pedestrian behaviors. Transambiental will provide IFC with a copy of the final training program, organizational chart and structure, with details on each staffs role and responsibility when available, prior to the commencement of operations. (ESAP Condition No. 2) Additionally, Transambiental will incorporate in the terms and conditions of the tender documents of suppliers and/or third party contractors, a requirement to comply with all relevant ESHSS requirements of the project. (ESAP Condition No.3).
The main bus terminal will be used by all three Concessionaires and includes administrative offices for Transcaribe and the operators, maintenance and parking areas for the buses, and an integration loading area for passengers. Transcaribe is responsible for preparing and planning emergency response and preparedness plans (ERPP) and contingency plans for the buses and routes, whilst Transambiental is responsible for the same, inside the bus terminal areas. To effectively respond to an emergency in a timely manner, Transcaribe will engage early on with emergency response organizations prior to the start of operations, to ensure there is a clear chain of command assigning functions and responsibilities to appropriate personnel/organizations. These orders will be documented and shared with drivers and all essential emergency response personnel. Buses, stations, administrative and maintenance areas will be equipped with evacuation routes, fire emergency response and preparedness equipment, including printed instruction
s on how to use the equipment and how to respond in case of an emergency. Transambiental will share with IFC copies of Transcaribe’s ERPP, Contingency Plan, and Inter-Agency Agreements with emergency response entities, for the system. (ESAP Condition No. 4)
Transambiental will implement an E&S monitoring and supervision program for all activities associated with the management of the main bus terminal and any other facilities/activities under its control; the objective being to identify and inform Transambiental management of the performance strengths and weaknesses of its activities, with a view to identifying appropriate and timely mitigation and corrective actions as, where and when needed. Transambiental will submit to IFC the final monitoring report, including targets and/or indicators in the following areas:; (i) resource efficiency and pollution prevention (aligned with those in IFC’s General and Sector Specific EHS Guidelines); (ii) Human Resources (HR) and contractor performance; (iii) emergency response and preparedness; (iv) risk identification, evaluation, mitigation and management process. Contractor performance includes monitoring and supervising the performance of any security forces engaged with the project, whether this be private or State forces. Security forces engaged in the project should undertake a basic level of training on Transambiental’s security policies, procedures and protocols. Monitoring will track grievances collected against security forces to ensure these are not using excessive force with users. (ESAP Condition No. 5)
The SITM will have a Grievance Redress Mechanism (GM) for stakeholders, like that used in the TransMilenio SITM in Bogota. While the GM is managed by Transcaribe, each Concessionnaire will adopt a GM consistent with that of Transcaribe’s and do their part to facilitate users/stakeholders access to the GM, by providing users with relevant information and methods to do so. When and if necessary, Transambiental will provide Transcaribe with recommendations to ensure that the GM achieves its desired outcomes or closes gaps, in alignment with IFC PS 1 guidance. The GM procedure will be made available to users on Transcaribe’s and concessionaire’s own websites and by telephone, email and booths, where people can communicate their opinions and concerns both directly and anonymously. The GM will include a screening mechanism to prioritize grievances in accordance to their seriousness and materiality. Serious or material grievances will be escalated to management for immediate response in a culturally sensitive manner. At least one member of the Transambiental team handling grievances at the bus terminal and/or at the human resources level with workers will be trained in grievance resolution and negotiation. The mechanism will allow for anonymous complaints. All grievances will be logged, tracked and monitored over time. Grievances will be evaluated to identify endemic and recurring issues that shou
ld be handled or mitigated to avoid root problems. Transambiental will provide IFC with a copy of their or Transcaribes GM policy and procedure, demonstrating alignment with PS guidance and requirements, when available. (ESAP Condition No. 6)