In 2017, BCE commissioned Egis Group to prepare the Environmental Impact Assessments (EIAs) for the project in accordance with Serbian requirements supplemented by an Environmental and Social Impact Assessment (ESIA) to meet lenders E&S requirements. The ESIA and a Non-Technical Summary were provided to the lenders in October 2018 and are disclosed together with this review.  The ESIA include a framework Environmental and Social Management Plan (ESMP), which will be developed for the construction and operations phases as part of the company’s commitments as described below.  At the time of IFC’s review, the regulatory EIAs were under preparation and to be submitted to Ministry of Environment of Serbia for approval.

Suez Groupe has a group level Environmental and Social Management System (ESMS) which is consistent with the specifications of the international environmental management standard ISO 14001, and occupational health and safety management system specification OHSAS 18001. Suez Groupe ESMS procedures cover water quality management, air quality and dust control, waste management, noise and construction nuisance reduction, environmental incident response and report, and archaeological chance finds, among others.

In order to meet IFC PS1 requirements, the company will establish and implement an ESMS as per ESAP item 1.The ESMS will define roles and responsibilities of the company and its contractors and suppliers (including in the interim period when BCE and PUC will be simultaneously constructing the new facilities and operating the existing dumpsite , respectively) and will include: (a) an E&S and Occupational Health and Safety (OHS) policy aligned with IFC PSs; (b) procedures for screening, scoping, assessment and management of environment, health, safety and social risks and impacts; (c) stakeholder mapping and engagement procedures including a community grievance mechanism; (d) organization structure; (e) procedures for environmental and OHS training of employees and contracted workers; (f) internal and external communication procedures; (g) emergency preparedness and response; (h) monitoring of E&S and OHS performance; (i) internal and external audit requirements; (j) procedures for management review and for change management; and (k) contractor management. The ESMS will address all E&S aspects identified as part of the E&S assessment, including environmental management, OHS management, social performance management and stakeholder engagement, traffic safety, and community health and safety, and will ensure compliance with IFC Performance Standards. The ESMS will include relevant procedures for the identification, assessment and management of the risks and impacts of the transmission lines, in accordance with national legislation. The company will engage with the City to ensure that key E&S issues e.g., land acquisition / biodiversity, are assessed and associated mitigation measures are consistent with the Performance Standards.  The program will also include provisions and agreements relevant to associated facilities (hot water pipeline for heat offtake), with consideration of the company’s leverage on the operator of such facilities. 

As part of the company’s ESMS, a Construction Environmental and Social Management Plan (CESMP) will be prepared prior to the start of construction to ensure implementation of the ESIA commitments and compliance with national regulations and IFC requirements. The CESMP will include, among others: labor management plan; waste management plan; pollution prevention and control plan; OHS management plan; traffic management plan; habitat protection plan; stakeholder engagement plan (SEP) including grievance mechanism, E&S monitoring plan; emergency preparedness and response plan, community health and safety plan, noise and vibration management plan, soil and groundwater contamination monitoring and management plan, as per ESAP item 2.

As part of the contractual requirements, the company will require project’s EPC contractors to comply with company’s E&S policies and its CESMP in order to implement the relevant mitigation measures identified in the ESIA and to develop the relevant management plans. These requirements will be specified in a contractor management plan, to be developed as part of the ESMS (ESAP item 1). The contractor management plan will include: (i) compliance requirements and checklist; (ii) criteria for screening, qualification review and selection of contractors; (iii) reporting requirements, and (iv) monitoring and audit procedures.

Prior to start of operation, the company will develop an Operations Environmental and Social Management Plan (OESMP) as per ESAP item 3. The OESMP will consist of plans and operational procedures for waste management, soil and groundwater contamination monitoring and management, leachate treatment, air emissions management, noise management, spill response management and hazardous material management, OHS management, emergency preparedness and response, traffic management, security personnel requirements, grievance mechanism for all workers on site and external stakeholder, information disclosure and stakeholder engagement, community health and safety, and environmental and social performance monitoring.

As indicated above, the closest community settlement is around 1.7 km away from the project site.  Given the project location, there will be no need for construction workers accommodation camps, and main public roads will continue to be used by the project-related traffic. As such, limited traffic impact and interaction is expected between project workers / truck drivers and the community. As indicated, after the project construction site will be handed over to the company, PUC and its contractors will continue to operate the existing dump site until its closure by the end of 2019 and a total of about 300 waste pickers will continue to be present at the site. Female waste pickers are a vulnerable group. As indicated in ESAP item 4, the company will develop and implement a code of conduct for its staff and all construction workers addressing sexual exploitation and harassment; the code of conduct will be incorporated in the induction training for all staff and workers of the EPC contractors and their sub-contractors. The company will closely monitor the implementation and will also ensure that there are effective external and internal grievance mechanisms and its employees, contractor’s workers, the waste pickers and PUC staff are informed on how to use these mechanisms.

Organizational Capacity and Competency

As indicated above the project sponsors are Suez, Itochu and Marguerite, an European fund. The industrial sponsors bring a significant organizational capacity and industry sector competency to BCE.  Suez is one of the leaders in waste and water services (leader in EfW and landfill subsectors) with over 160 years of experience developing, designing, permitting, constructing, commissioning and operating solid waste management projects globally (www.suez.com). Suez has partnered with Itochu (www.itochu.co.jp) on several EfW projects.

The company is in progress of establishing its project management organization with the active involvement and support of the sponsors. The company will ensure that sufficient staff and contractor resources are allocated to E&S management at all times. The company will appoint, at a minimum, a project E&S manager, an OHS manager and a community liaison officer, and will establish the relevant E&S organizational structures for construction and for operations phase, with clearly defined roles and responsibilities as per ESAP item 5. The company will require the EPC and O&M contractors to appoint their E&S team, including site safety supervisors and OHS officers, as indicated in ESAP item 6.

Monitoring and Review

The company will monitor key E&S parameters and performance indicators during construction, operations, closure and post-closure, as dictated by the concession agreement.  The monitoring plan will include, among others, air emissions, noise levels, monitoring of leachate, groundwater, surface water, conditions of drainage and stability of the landfill, landfill capping, safety performance, and community relations and complaints.

The lenders’ E&S consultant will undertake independent monitoring of the project and will report to BCE, the City and lenders.

Emergency Preparedness and Response

The company will prepare an Emergency Preparedness and Response Plan (EPRP) (ESAP item 7). The plan will define: coordination with local authorities and emergency response agencies, emergency response team, emergency response actions (including first aid and emergency medical treatment), training, emergency response equipment, and emergency drills. The plan will address preparedness and response for both on-site and off-site emergencies and will include actions to assist and collaborate with the potentially Affected Communities and the local government agencies.  Project facilities will be equipped with fire and emergency alarm systems. The emergency response system will ensure timely observation of and response to fires, spills, leakages, upset conditions, or other hazardous conditions or accidental events. Explosion hazard zones and relevant mitigation measures will be identified. Management of potential upsets of some of the treatment facilities and potential occurrences of surplus production of leachate will be included in the EPRP. The company will require its EPC and O&M contractors to align with the company’s EPRP, to develop and implement relevant procedures and to appoint suitably qualified emergency coordinators as per ESAP item 8.

During the construction period of the project, workforce will be about 200 workers, on average, with about 500 workers at peak. During operations, the workforce on site will be around 120. The current workforce (50 staff) of the PUC will continue to be employed at the existing landfill, during the first year of the construction period of the project. As indicated in the Resettlement Plan prepared by the City (see Performance Standard 5 below), the staff of the PUC will then be assigned to other utility companies of the City.

Human Resources Policy and Procedures

The company will comply with all relevant national employment and labor laws and IFC PS 2. The company will develop and implement a human resources (HR) policy and relevant procedures, aligned with the policies of Suez Groupe. The policy and procedures will cover and ensure compliance with the relevant requirements for the following: (i) nondiscrimination, equal rights and equal pay; (ii) prevention of child labor and forced labor; (iii) freedom of association and right to collective bargaining; (iv) contractor management; (v) terms of employment including recruitment, hours of work, overtime arrangements and overtime compensation, rights to refuse overtime requests; (vi) commitment to apply zero tolerance for any proven case of gender based violence and workplace harassment; and (vii) a formal grievance mechanism. The company will ensure that the EPC and O&M contractors and subcontractors will comply with national laws and its HR policies as indicated in ESAP item 9.

Working Conditions and Terms of Employment

The company will clearly document workers’ terms and conditions of employment and will communicate them at the time of employment, with respect to worker’s entitlement to wages, hours of work, overtime arrangements and overtime compensation, any benefits such as leave for illness, maternity/paternity or holiday, and the grievance mechanism for workers. The company will also ensure that EPC and O&M contractors and their subcontractors are compliant with national law requirements for working conditions and terms of employment and meet the requirements of this Performance Standard for contracted workers.

As indicated above, safe working conditions for the workers of contractors and their sub-contractors will be required under the contractor management plan under ESAP Item 1.

Grievance Mechanism

The grievance mechanism will allow employees to raise any workplace concerns and will address all complaints received, including managing anonymous complaints. Workers will be informed about channels for raising grievances and the grievance mechanism will be extended to contractor and subcontractor workers.

Occupational Health and Safety

Construction and workers of waste management facilities are particularly prone to accidents involving vehicles, trucks and other moving equipment, and therefore a traffic safety management plan will be prepared for both construction and operational phase as per ESAP item 1.

The company will prepare and implement an Occupational Health and Safety Management Plan (OHSMP) for both construction and operational phases as per ESAP item 10. The OHSMP will include detailed procedures for: hazard identification and risk assessment; job and task specific hazard analyses, provision and use of personal protective equipment (PPE); training; safe working procedures; prevention, reporting, recording, investigation, analysis of accidents and incidents, and follow up corrective actions; emergency response; provision of medical care, first aid and provision of medical treatment; workplace and health monitoring; measures for prevention of disease spread; fire prevention and fighting system; inspections and audits; performance reporting; and management review. The OHSMP will be revised and updated for operations and will include procedures to manage OHS risks for the project operations and maintenance. The company will require the EPC and O&M contractors to develop their own management plans to implement company’s requirements.

While hazardous waste will not be accepted and treated at the facilities, accidental presence of hazardous waste in the waste received will be controlled by relevant procedures to handle such waste and minimize risks for the operators. A radioactivity detection system will be installed at the entrance of truck scales to detect potential radioactivity in incoming trucks. The system will be equipped with several levels of the alarm, to be determined for each detector, in accordance with the radiation level.

Asbestos containing construction waste will be separately collected, packaged, stored and disposed of in a clearly designated place for their disposal. The OHSMP will include detailed asbestos handling and disposal procedure and instruction.

Due to site conditions, the existing dumpsite will be considered a hazardous work zone. As indicated in ESAP item 11, prior to commencement of dumpsite closure works, the company will undertake a comprehensive risk assessment that considers geotechnical, hydrogeologic conditions and subsurface waste characteristics with the objective of identifying specific OHS risks. Based on the risk assessment, the company will develop a site closure management plan and implement a work program that is responsive to the risks identified, including specific training of construction workers, installation of site safety measures, provision of appropriate PPE and communication devices, and emergency response.

 Resource Efficiency and Greenhouse Gas (GHG) Emissions

The EfW plant is designed to process a minimum of 340,000 tpa of municipal solid waste with combined heat and power (CHP) recovery allowing to achieve 70% biodegradable landfill diversion. It will use a single waste incinerator incorporating a grate furnace technology with a dry flue gas treatment system. The plant will include a waste reception facility, a grate combustion system, a boiler, a turbine system and treatment facilities for flue gas, bottom ash and air pollution control residues (APCRs).  Incinerator bottom ash will be processed before disposal in the sanitary landfill and solidification of APCRs will be achieved to non-hazardous waste criteria in accordance with EU regulations. The proposed technology is similar to those implemented on other plants operated by Suez in Europe.

The EfW plant is designed to maximize water reuse with zero discharge other than surplus of storm water, sanitary wastewater and leachate from the bunker. Sanitary wastewater will be treated at the LTP. Leachate collected from the bunker will be used in the fly ash stabilization process. Additional water required for the EfW operations like demineralization, boiler and APCR solidification cleaning, bottom ash cooling and sanitary use will be sourced from the city water supply system, and it is estimated at 130 m3/day or 0.15 m3 per ton waste.

A landfill gas (LFG) collection system will be installed prior to construction of the final capping and closure of the dumpsite. A LFG collection system will also be installed in the new sanitary landfill.  Collected LFG will be used in 3.5 MW Landfill Gas-to-Energy (LFG) Facility.

Gross Scope 1 GHG emissions (direct emissions from owned or controlled sources) and Scope 2 GHG emissions (indirect emissions from the generation of purchased energy) during operations are estimated at an average of about 212,000 and about 4,400 tons of CO2 equivalent per annum respectively. Due to energy recovery and methane emission capture from landfills, GHG emission savings are projected at an average of approximately 360,000 tons CO2 equivalent per annum between 2020-2051. The company will report on GHG emissions as part of its annual reporting requirements.

Pollution Prevention

Baseline Studies

A baseline air quality study against the air quality standards established by the EU was carried out by the project at nine locations selected within the dumpsite and in the radius of 3 km around the site. Results showed that air pollution concentration levels were within the Serbian air quality standards and WBG guidelines, although elevated concentrations of nitrogen dioxide and benzene were detected at the dumpsite, possibly related to truck traffic. An air emission dispersion modelling was performed by Egis and the results are presented in the ESIA

The project site is located outside designated water protection zones. A surface water baseline study was performed, and samples collected at several locations, including the Ošljan stream, the Ošljan pond, and Danube river downstream and upstream of the project site.  The Ošljan stream and pond are highly contaminated by the leachate of the dumpsite. No significant differences in water quality were found in the samples collected along the Danube river downstream and upstream of the site. Since all the leachate sourced from dumpsite will be treated in the scope of the project, the project will have a positive impact on water resources in the area.

At the time of appraisal baseline assessment of groundwater quality was not fully completed. Although there are previously performed groundwater measurements around project zone for different purposes, as indicated in ESAP item 12, the company will carry out baseline assessment of groundwater quality upgradient and downgradient of the project site before construction starts. The baseline studies will be continued during construction and will be used to develop the project environmental monitoring program during operations.

Air Emissions

The principal project source of emissions to the atmosphere is in the form of flue gases produced from the incineration of MSW. Flue gases from incineration can contain a range of pollutants, which can exhibit rapid variation in composition and concentration due to the heterogeneous nature of MSW. Reduction of these pollutants is achieved through sophisticated engineering controls during the combustion process as well as through post-combustion flue gas treatment (FGT). The EfW plant will have Selective Non-Catalytic Reduction System (SNCR), involving urea injection, to control nitrogen oxides (NOx).

The incinerator flue gases will exit the energy recovery boiler and enter a FGT system which will remove gaseous pollutants such as sulfur oxides, hydrogen chloride and hydrogen fluoride. Heavy metals and organic pollutants (including dioxins and furans) will be removed through adsorption using activated carbon. FGT performance optimization studies will be carried out during the first year of operations. The studies will require a full year of air emission monitoring data. As part of the project environmental monitoring program (ESAP item 3), the company will develop and implement an ambient air quality monitoring program, to quantify background conditions and to monitor air quality during operations with respect to all emission parameters of concern, as per the relevant WBG EHS Guidelines. Notwithstanding, the company will provide confirmation in the form of a performance guarantee from the technology/equipment provider that emissions to the atmosphere from the facility will comply with applicable performance standards, including the most stringent among Serbian air emission standards, European Union Directive 2010/75/EU on Industrial Facilities Emissions and relevant Annexes/Amendments, and WBG EHS Guidelines for Waste Management Facilities. The provision of a continuous emissions monitoring system (CEMS) is included in the project scope. CEMS will be installed to monitor the pollutants as required by the Directive 2010/75/EU.

Ash Disposal

The bottom ash produced is estimated 25% - 30% of the total MSW treated (by weight). Bottom ash will be disposed of in the sanitary landfill.  BCE estimates that the fly ash produced will be about 2.5% of the total MSW treated (by weight).  Fly ash usually tests as hazardous and must be disposed of properly. BCE intends to treat the fly ash on-site, as part of O&M service, through a stabilization and fixation process, allowing it to be safely disposed as non-hazardous waste in the new sanitary landfill.  The fly ash treatment and disposal will be compliant with EU requirements.

Leachate Collection and Treatment

Leachate from waste piles caused by exposure to precipitation and from residual liquids in the waste itself may contain organic matter, nutrients, metals, salts, pathogens, and hazardous chemicals. If allowed to migrate, leachate can contaminate soil, surface water, and groundwater potentially causing additional impacts such as eutrophication and acidification of surface water and contamination of water supplies.

Leachate will be generated in the EfW waste storage bunker, the sanitary landfill and the existing dumpsite. Additionally, a significant volume of leachate is stored within the waste dump body. While the leachate from the EfW facility will be reused at the facility for processing of residuals and bottom ash quenching, leachate from the new sanitary landfill and existing dumpsite will be collected and treated in the Leachate Treatment Plant (LTP) in compliance with Serbian regulatory requirements, standards established by the European Commission Implementing Decision (EU) 2018/1147 under Directive 2010/75/EU of the European Parliament and of the Council; and applicable WBG guidelines for discharge of effluents to surface water. Leachate inventory in the existing dumpsite will be drained via gravity continuously through a system of drainage pipes. The design treatment capacity of the LTP is 90.000 m3 per annum and the treatment will consist of mechanical pretreatment, acidification, reverse osmosis, evaporation, and a final stage of reverse osmosis. The treated leachate effluent in line with EU requirements will be discharged into the Ošlanj stream.

It is anticipated that through the use of engineering controls and good industry practices, there will be no leakage or fugitive discharge of effluents or leachate from the project site to the environment (including to the sub-surface and ground water). As indicated in ESAP item 13, the company will implement a comprehensive sampling and monitoring program to validate (a) compliance with applicable discharge standards and (b) no contamination of the sub-surface or groundwater attributable to sources within the project site. If monitoring shows material exceedance of applicable standards from baseline conditions established upstream of the project site, the company will inform the relevant government authorities of the exceedance and take immediate remedial actions that are protective of human health and environment.

As part of the engineering controls at the existing dumpsite, water infiltration into the waste dump will be minimized with the installation of an impermeable cap and by regrading of the surface to promote natural drainage to a collection ditch running along the perimeter of the existing dumpsite. Water from the perimeter ditch will drain into a collection lagoon, and if not contaminated will be discharged to surface water.

Wastewater

Process wastewaters generated in the EfW plant and wash water generated within the plant will be collected by a closed-collector system (industrial sewage network) and, after primary treatment (oil separation and sedimentation units), will be re-used for various purposes. Excess amount will be conveyed to LTP for treatment and discharge.

For the community health and safety aspects like air emissions, noise, odor, dust mitigation measures are summarized in PS3. 

The site will be surrounded by a green belt (between 10-20m width) in order to create a buffer zone and minimize dust or litter dispersion. Transportation of waste to the project zone is the responsibility of the City. The company will proactively work with the City to ensure that the transportation plan, inclusive of waste collection trucks and logistics, is adequately managed in a manner protective of community health and safety.

The company will implement all necessary risk management strategies and measures to protect the community from physical, chemical, or other hazards associated with the construction and operations phases. These will include measures related to traffic safety and management, site access controls, such as fencing and warning signs, removal of hazardous conditions on site, community awareness-raising measures, noise and odor control, and control of spreading of garbage and litter outside of the waste management site. All measures will be described in Community Health and Safety plans, developed as part of CESMP and OESMP, as per ESAP items 2 and 3.

During the interim period, BCE will coordinate measures with PUC and the City for health and safety of waste pickers and their households by allowing only registered adults on the site, excluding children and domestic animals, ensuring that personal protective equipment, such as safety shoes, face masks, and protective gloves are provided;  a worker health surveillance program, including regular vaccination and health examinations are executed;  by arranging the disposal layout and providing sorting facilities to improve access to recyclables while reducing their contact with other operations to minimize potential hazards; providing water supply for washing, toilets and areas for changing clothes; implementing trainings and campaigns regarding hygiene, and care of domestic animals; as per ESAP item 14.

Infrastructure and Equipment Design and Safety

As indicated above, the City has committed to design and construct a dam (or retaining structure) at the bottom of the main dumpsite slope to prevent further sliding, and to install horizontal drainage pipes to support the extraction of leachate inventory from the landfill. Existing drainage ditches will be repaired, and peripheral/perimeter intercepting channels will be constructed to limit storm water entering the landfill body and to intercept and drain the storm water around the dumpsite.

The company hired the third-party consultant (Arup) to review the structural safety of the design against international standards. In addition, as per ESAP item 15, the consultant experts will carry out independent review of the construction and will periodically monitor the structural safety of the retaining structure post-construction. The company and its O&M contractor will be responsible for the maintenance of the retaining structure. 

Security Personnel

Security management of the existing landfill is undertaken by the PUC with its own seven staff. The project does not anticipate deployment of armed security forces. Security management procedures, including security policy and code of conduct, will be included in the company’s ESMS, as per ESAP item 1.

A biodiversity assessment was carried out as part of the ESIA studies to identify biodiversity values in the project area. The review concluded that the project site is in modified habitat per PS6, and the site does not overlap with any legally protected nature area.  The site does not overlap with “Usce Save u Dunav”, a Key Biodiversity Area (KBA) and Important Bird and Biodiversity Area (IBA) located about 1 km south of the project site, although it is located in the vicinity of the ecological corridor of international importance of the Danube (“Dunav i njegova zabarena/plavna podrucja uzvodno i nizvodno”) although it.  The IBA trigger species are the White-tailed Sea-eagle (Haliaeetus albicilla – IUCN Red List Least Concern [LC]), the Pygmy Cormorant (Microcarbo pygmaeus – LC), and the Black-crowned Night-heron (Nycticorax nycticorax – LC).   

No globally threatened species were identified in the project area, although a number of species protected by the national legislation were reported by the baseline surveys, and the company has identified and proposed mitigation measures to minimize impacts on such protected species.  The following protected insect species were identified: Pine Ladybird (Exochomus quadripustulatus – strictly protected), Southern Festoon (Zerynthia Polyxena) and Large Copper (Lycaena dispar, IUCN Red List Near Threatened). The following protected bird species were also identified: White Stork (Ciconia ciconia – strictly protected, LC), the Black-Headed Gull (Larus ridibundus – protected, LC), Caspian/Yellow-legged gull (Larus cachinnans/michahellis – protected, LC), Lesser Blackbacked Gull (Larus fuscus – strictly protected, LC) and Great Cormorants (Phalacrocorax carbo – protected, LC). According to the ESIA, most of identified bird species use the landfill as feeding ground, and some of species observed is likely nesting in the project area. To protect locally nesting birds, vegetation clearing will be performed only from the beginning of September to the end of February. If vegetation removal has to be done out of this period, it will be performed under constant supervision of an ecologist (ornithologist) to ensure that, if necessary, appropriate steps is taken.

Two plant species, which are protected according to the national legislation, were also identified during the survey at the site - true comfrey (Symphytum officinale L.) and littleleaf linden (Tilia cordata Mill.) -, in addition to invasive species such as black locust (Robinia pseudacacia), false indigo-bush (Amorpha fruticosa), and tree of heaven (Ailanthus altissima). As part of the mitigations provided in ESIA, the specimen of the protected species will be relocated to a suitable location or used for landscaping of the area. If during construction any strictly protected species is identified by the ecologist, the project will inform the Institute for Nature Conservation of Serbia, which will define the relevant measures to be taken.

The project is committed to select and use plant species for the green belt which are autochthonous to preserve the domestic gene pool. Specifically, midland hawthorn (Crataegus laevigata (Poir.) DC.) and common hawthorn (Crataegus monogyna Jacq.), both protected in Serbia, will be used for the green belt formation. Seeding with native grass and plants will be carried out at the site of existing landfill following closure and revegetation of temporary construction areas. All mitigation measures will be included in the Habitat Protection Plan, which will be developed as part of the CESMP before construction.

 Sites of cultural and archaeological significance are located in the vicinity of the project site but will not be affected by the project construction. These sites include the Monastery of Holy Archbishop Stephan (Slanci Monastery) with its archaeological site located about 1.2 km to the north of the site and Vinca cemetery located 1 km to the south. A registered archaeological site “Osljane”, a villa estate of a Roman military veteran, defined under the Cultural Property Act, is located in the north part of the project site where the LTP will be constructed. The site was known to archaeologists because of an accidental discovery of a Roman pottery and a small scale exploratory excavation was carried out in 1975. The exact location of the villa estate and delineation of the archaeological site boundaries were uncertain in the drawings provided by the Institute of Protection of Cultural Monuments. Therefore, the City carried out geophysical, magnetometric and morphometric surveys at the project site and the results showed no anomalies that may indicate the presence of archaeological features, objects and materials where the project construction works will be carried out.

Notwithstanding, in compliance with the national legislation, the construction works will be executed under an archaeological supervision program by the Bureau for Protection of Cultural Monuments of the City of Belgrade. The company will develop a chance finds procedure and will ensure archaeological monitoring during construction through competent professionals who will be contracted by the EPC contractors prior to any construction works on site as indicated in ESAP item 18.

The primary stakeholders, as identified in the Stakeholder Engagement Plan (SEP) prepared by the City, who will directly be affected by the project are Roma households in the project area, waste pickers and workers of PUC. The SEP and the Resettlement Plan (RP) summarize the project information disclosure and public consultation activities conducted between 2014 and 2018. These activities included media outreach, census and socio-economic surveys with project affected people and series of consultation meetings. The SEP includes a grievance mechanism.

Further public consultation meetings will be conducted within the scope of national EIA process. The City published the RP in Serbian language on its website in October 2018. The ESIA, the Non-Technical Summary and the SEP in Serbian and English languages will be disclosed on the company’s website (https://www.bcenergy.rs). The same documents are disclosed together with this ESRS. 

As indicated in the ESAP item 19, the company will develop its own SEP, to complement and coordinate with the City’s stakeholder engagement, and will develop and implement a grievance mechanism consistent with IFC PS1 requirements. 

Beo Cista Energija d.o.o.

Contact Person: Vladimir Milovanovic
Phone: + 381 11 7154884

Email: bce@bcenergy.

           v.milovanovic@bcenergy.rs

Post: Beo Cista Energija d.o.o., Tošin Bunar 272v, 11070 Beograd