The Yangon Dry Port is sited in agricultural fields within MR railway station yard and impacts on indigenous people, biodiversity and cultural heritage are not expected on account of the Yangon Dry Port.                                                   

The key environmental and social (E&S) risks and impacts due to construction and operation of the proposed Dry Port include: physical resettlement of 17 informal settler households and economic displacement of four farmer households; emissions to air, water and land; management of hazardous materials, and hazardous and other wastes; construction worker living condition; construction workers and employees working conditions including occupational health and safety; community health, safety and security among other aspects due to increase in traffic during construction and operation; and adequacy of systems in place to manage these risks and impacts. Accordingly, this is a Category B project as the environmental and social risks and impacts that may result are limited in number and scale, and can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Further, it is possible to readily design and implement engineering and management measures to mitigate the limited adverse impact. The company will implement an appropriate E&S management system to mitigate and manage the E&S risks and impacts in accordance with IFC Performance Standards at the Dry Port.

Environmental and Social Assessment and Management System/Policy

Kerry Logistics Network is publicly committed to responsible corporate citizenship, transparency, accountability, and actively integrating environmental, social and governance (ESG) systems in key business decisions. KLN’s Board oversees the direction of their ESG practices. KLN requires individual business units to set up ESG programs that are aligned with their respective operations. KLN has processes in place to measure, review and regularly report to management ESG performance and pursues continuous improvement. KLN implements, across all of its operation: a global Equal Opportunities Policy that prohibits any form of harassment and discrimination with respect to age, gender, race, ethnic origin or religious belief; policies on preventing child labor and forced labor; Occupational Health and Safety (OHS) Systems aligned with OHSAS 18001 standards; particularly in self owned facilities, procedures to manage emissions, optimize the use of resources and protect natural environment. Several of KLN’s operations have implemented: environment management system aligned with ISO 14001 standards; initiatives to improve energy efficiency, reduce greenhouse gas emissions and reduce water consumption; and obtained LEED Gold certification. KMTL has implemented OHS procedures of relevance to its current operations.

KMTL will, as mentioned at ESAP # 1, for its Yangon Dry Port adopt and implement an Environment, Health, Safety and Social (EHSS) Policy that is aligned and consistent with KLN’s ESG policies and incorporates IFC Performance Standards (PSs). The Yangon Dry Port’s EHSS policy will commit to compliance with the provisions of IFC Performance Standards on an ongoing basis. Further, to effectively implement this EHSS policy, the company will put in place an environment and social management system (ESMS) for the Dry Port’s operations, as indicated under ESAP # 1. The ESMS will appropriately incorporate: national E&S requirements; KLN’s ESG Policies; IFC Performance Standards; and the applicable provisions of the World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines (2007) and the WBG Port, Harbors and Terminals EHS Guidelines (2017). KMTL will, as part of the Dry Port’s ESMS, put in place procedures to periodically review its EHSS Policy and the ESMS to ensure that it remains current to addresses the risks, impacts and opportunities associated with the Dry Port’s operations as they evolve over time. KMTL is encouraged to apply the same E&S standards, policies and ESMS that Yangon Dry Port will adhere to, also at its Mandalay site.

Identification of Risks and Impacts

The company has, in accordance with national regulatory requirements, in December 2016 carried out an Initial Environmental Examination (IEE) for the dry port, which has been submitted for approval. Further, the company commissioned a third party to carry out a review of the land acquisition and resettlement process with IFC Performance Standards as the reference framework. The IEE includes the outline of an environment management plan for construction and operation phases. The company has contractually required the EPC contractor to implement required EHS measures to be stipulated by the company and to comply with labor laws.

The company will, as part of the process for development and implementation of the ESMS for the Dry Port operations, undertake a comprehensive assessment of environmental, occupational health and safety and social (EHSS) risks, aspects and impacts including potential for cumulative impact from the adjoining dry port under development. In light of the fact that another dry port is being developed immediately adjoining the Yangon Dry Port, cumulative impacts may be expected on traffic, air quality, ground water extraction, noise levels, labor influx, wastewater and waste generation. The ESMS will include a procedure setting forth: (a) assessment of aspects where there is potential for cumulative impacts as another dry port is being developed immediately adjoining the Dry Port; (b) operational control procedures and measures to mitigate adverse impacts including commercially reasonable efforts to implement joint/coordinated action with the developer of the adjoining dry port to address any cumulative impacts; (c) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (d) organizational and financial resources for carrying out the measures; (e) an implementation schedule for these activities; and (f) an appropriate incentive structure to ensure plans are implemented. Further, Yangon Dry Port will in its ESMS include procedures to complete appropriate E&S risk and impact assessment in accordance with IFC Performance Standards prior to any expansion and/or significant changes in its operations.

Management Programs

 The ESMS of the Yangon Dry Port will include procedures for: aspect, impact and risk identification; compliance with regulatory requirements; development and implementation of management programs, including standard operating and operational control procedures for managing EHSS risks and impacts from operation and maintenance (O&M) activities, any future proposed expansion and/or any significant changes in operations; incident and accident handling, recording, reporting, investigation and analysis; ensuring that O&M and other contract documents (including eventual contracts for potential future expansion/construction at the dry port) include appropriate E&S provisions; stakeholder engagement and grievance redress; onsite and offsite emergency preparedness and response; maintaining a legal register and a commitment register; compliance monitoring; contractor management and oversight; worker accommodation; security personnel; E&S organization, responsibility and resource allocation; training and awareness; internal and external communication and consultation; monitoring, recording, reporting and documentation of environmental and social performance; bi-annual internal and annual external audit of the ESMS; management review; and EHSS reporting to the KMTL and KLN Board of Directors.

The Dry Port IEE has outlined key aspects to be covered in the construction stage ESMP. Accordingly, to ensure that the Dry Port is constructed in accordance with national requirements and IFC Performance Standards, the company will develop, as part of ESAP #2, a detailed Environment and Social Management Plan (ESMP) for construction phase that meets the requirements outlined in the IEE, IFC Performance Standard’s provisions and applicable WBG EHS Guidelines. The construction stage ESMP will cover aspects including: excavation/backfilling at site and transportation of construction material; concrete mixing, casting and construction at site; management of dust, noise, contaminated runoff, soil and water pollution, domestic waste and sewage; traffic management; equipment operation; construction waste management; equipment repairs; hazardous materials and wastes; labor influx, worker accommodation and activities of construction workers; medical checkup, vectors and disease management; occupational health and safety; local hiring and training; emergency response; monitoring and reporting; and compliance requirements for contractors. The company will make the construction stage ESMP available to the EPC contractor and contractually require the contractor to implement the ESMP. Further, the company will also make the ESMP available to owner’s project management consultant (PMC), to enable effective oversight and monitoring of ESMP implementation by the EPC contractor.

The operation stage management program to be developed by Yangon Dry Port as part of its ESMS will cover aspects including: transportation; increase in vehicular and rail traffic; operation and domestic waste management; operation, cleaning and repairs of equipment, containers and vehicles; hazardous cargos and hazardous materials handling, storage and transport; occupational health and safety; emergency and disaster response (including for fire, chemical spills and mishaps, accidental release of hazardous cargo, medical emergencies and exacerbation during cyclones/storms); emissions to air; management of water and wastewater from operations and domestic use; storm drainage and contaminated runoff management; solid, hazardous and other waste; compliance requirements for contractors; local hiring and training; stakeholder engagement; community grievance redress; and monitoring and reporting.

Organizational Capacity and Competency

The company’s project manager at site is overall responsible for EHSS aspects. The project manager is supported by the PMC and EHSS staff deployed by the EPC contractor. The EPC contractor has deployed one safety officer and 3 safety personnel. EPC contractor has implemented a training calendar comprised of safety induction training, daily tool box talks and weekly safety training. KMTL will, as outlined in the IEE and as mentioned at ESAP # 3, implement an E&S organization at the Dry Port comprised of an EHS auditor and EHS management officer. EPC company’s EHS site officers, as required by the IEE, has already been deployed at the Dry Port site. The EHS management officer will be responsible for oversight of implementation of the ESMP during construction stage and implementation of ESMS during operation stage including monitoring and reporting E&S performance related information to KMTL management, Board, investors and lenders. The EHS site officer deployed by the EPC contractor, together with EPC contractor’s project manager, will be directly responsible for implementation of the construction stage ESMP. Further, the company will deploy a human resource officer at the Dry Port supported by appropriate number of staff. KMTL will also deploy either a qualified staff or a security team trained in fire prevention and control and emergency response. The EHS auditor will, as mentioned at ESAP # 2, undertake quarterly audits during construction to obtain assurance that the ESMP is being implemented. Further, a calendar of EHSS training program covering employees and contract workers will be implemented during both construction and operation. Given the size of the construction site and activities, the organization described above is considered adequate.

Monitoring and Review

KMTL’s PMC and EPC contractor at the dry port site have implemented a safety monitoring program comprised of weekly safety walks, weekly fire extinguisher checks, tool/machinery checks, safety signage and personal protective equipment (PPE) checking, training and accident/incident monitoring. Procedures to follow up and close out the findings from the safety monitoring program are in place. Feedback from the monitoring program is provided to the EPC contractor, who upon implementation of corrective action submits an action taken report with appropriate evidence. Accident/Incident data is reported to KMTL management in monthly project progress reports. KMTL will, on a high priority develop and implement the required ESMP (refer ESAP # 2) and as part of this ESMP, expand the monitoring program to cover all EHSS aspects of relevance during construction including those related to noise, dust, hazardous and other waste, drinking water quality, surface and groundwater quality, incidents, drills, medical checkup, near miss, hazardous conditions, traffic and construction material transport, contracted worker living and working conditions, stakeholder engagement, employee and community grievances and redress.

A comprehensive monitoring program for the operations phase will be established as part of the Dry Port’s ESMS to comply with regulatory monitoring requirements, IFC Performance Standard requirements, applicable WBG EHS Guidelines, and taking into account the identified risks and impacts, and information requirements of key stakeholders and affected community including: emissions to air; ambient air quality; ambient noise levels at sensitive receptors; energy (electricity and fuel) and water consumption; drinking water quality; wastewater generation, treatment and reuse; treated domestic waste water quality; surface water quality; ground water quality; hazardous wastes generated and disposed; waste/expired cargo generated and disposed; other solid waste generated and disposed; health and safety data; accidents/incidents onsite and offsite (environmental, health and safety, security, community health and safety, community relations); training and drills; stakeholder engagement; employee and community grievances and redress; community development initiatives; resource efficiency initiatives; and such other.

KMTL will, as part of the Dry Port ESMS, implement procedures for annual third party and bi-annual internal audit. The analysis of information from the monitoring and audit programs will feed into periodic management system review process to assess efficacy of the ESMS and identify measures to further strengthen the ESMS. 

Human Resources Policies and Procedures

The Yangon Dry Port will have an employee strength of about 100 persons. In addition, the Dry Port will employ 65 contract workers for security, housekeeping, container stripping/stuffing and such other works. About 450 workers have been deployed at the Dry Port site during construction, of which 300 live in onsite worker accommodation. The total influx of workers to this area is potentially double this number due to the ongoing construction work in the other adjoining dry port also.

For direct employees, KMTL has in place a human resource (HR) manual which includes policies and procedures relating to: compliance with applicable labor laws; employment and types of employment; attendance, working hours and overtime; leaves; conduct and discipline;, employee complaints/grievance redress; wage and compensation; bonuses and other benefits; personal particulars; travel related reimbursement; performance appraisal; training and development; equal opportunity and nondiscrimination; and separation. The company will, as indicated at ESAP # 3 update the HR policy for the Dry Port to include lawful provisions related to working age, forced labor, retrenchment, collective bargaining, management of contractor/service provider, contractor/service provider compliance with statutory labor requirements, and ensuring service provider/contractors’ employees access to a grievance mechanism. KMTL makes a copy of the HR manual/handbook available to each employee.

Working Conditions and Terms of Employment

In addition to the HR manual handbook being made available to each employee, the terms and conditions in accordance with national law and the HR manual are specified in the employment contract. The company will implement appropriate audit procedures during both construction and operation to obtain assurance on statutory compliance by contractors/service providers with applicable labor laws.

Workers’ Organization

While there are no workers organizations at KMTL, there is no restriction on forming lawful unions.

Non-discrimination and Equal Opportunity

KMTL has a formal non-discrimination and equal opportunity policy as part of its HR manual and implements it.

Retrenchment

The Dry Port will be recruiting staff and there are no plans for retrenchment. The company will, as part of the HR policies for Yangon Dry Port, develop and have in place a retrenchment policy and procedure that meets PS2 provision and is applicable for any collective dismissals, in the event of any significant future retrenchment.

Grievance Mechanism

The company’s HR procedures have a formal complaint and grievance process. The company will update the HR policies for the Dry Port to enable employees to raise anonymous complaints, and to have provisions for protection of confidentiality and non- retribution. Further, the company will as part of the ESMS maintain grievance records and will monitor redress of grievances. With respect to their contractors’ including EPC and sub-contractors and O&M stage contractors, KMTL will ensure that a formal grievance mechanism is accessible to all contract workers and will require regular reporting from its contractors on the implementation of the mechanism.

Protecting the Work Force

While no instances of child labor or forced labor was identified at site, commitment to prevent child labor and forced labor will be articulated in the updated HR Policies for Yangon Dry Port. The EPC contractor has implemented procedures to prevent child labor during construction at the site.

Occupational Health and Safety

The EPC contractor for the Yangon Dry Port has implemented safety procedures including provision of personal protective equipment (PPE), permit to work system, training, provision of safety signage, accident/incident investigation and analysis, periodic safety check and corrective action processes. While there have been no lost time accidents to date, OHS status on the ground can be improved. Accordingly, the company will, as part of the ESMP for the construction phase, require the contractor to complement and strengthen the current safety procedures and integrate them under a comprehensive OHS management plan including procedures for: job safety assessment/risk assessment, access control, barricading hazardous areas, enforcing usage of PPE provided, access to medical care for illnesses and injuries, medical checkup, mock drills, monitoring lead and lag indicators, traffic and equipment movement, and penalty, rewards and recognition program. The company will monitor implementation by the contractor.

KMTL will, as part of the operation stage ESMS for Yangon Dry Port, detail procedures including for: health and safety (H&S) Policy; H&S objectives; hazard and risk assessment for each key activity; roles and responsibility allocation; safety signage; provision and use of personal protective equipment; safety induction; safety awareness and training to employees including contract workers; worker competency assessment for key high risk activities; radiation exposure safety and regulation in X-ray unit; work permit system; disaster management; emergency response; mock drills; joint disaster and emergency response exercises with relevant external authorities/agencies; medical checkup; fire fighting and other emergency response infrastructure and equipment; composition, terms of reference of joint worker management EHSS  committee meeting, procedures and follow up; lead and lag OHS indicator monitoring; near miss, accident, incident investigation, reporting and corrective action; training on safe procedures for drivers entering the Dry Port premises; internal vehicle traffic movement; contractor/service provider safety evaluation and control; asset safety investigations; procedures for periodic internal and third party audits; check lists for onsite physical situation checks; adoption and implementation of safety risk mitigation hierarchy in risk evaluation and accident prevention;  and ensuring availability of doctors or para-medical staff and access to emergency medical facilities and ambulance together with facilities for administering first aid.

Workers Engaged by Third Parties

There are about 450 contract workers employed at the Dry Port construction site of which about 300 reside in the workers accommodation provided at site. Some of the workers are residing with their families. The construction material, facilities and amenities of the worker accommodation need to be improved. KMTL will, as indicated at ESAP # 4, upgrade the worker accommodation in line with the outline provided in the IEE and the requirements of IFC Performance Standard 2 including related to: appropriate construction material for the accommodation; adequate facilities, amenities and utilities provided; facilities to meet the needs of women workers/women family members of workers; handling, treatment and disposal of waste, wastewater and sewage from the accommodation; fire safety and emergency response; hygiene, disease prevention and vector control; access to medical facilities; avoidance of conflict with host communities; and safety and security. 

While the EPC contractor maintains records of attendance, wages, overtime and payments, KMTL will, as part of the Dry Port’s ESMS, implement contractor management procedures including: (i) a compliance checklist against the applicable legal requirements and IFC Performance Standards; (ii) OHS performance criteria as part of contractor qualification and selection; and (iii) OHS monitoring and audit procedures to obtain assurance on contractor compliance with relevant requirements. The required set of procedures will ensure, among other aspects, the following: compliance of the contractor and its subcontractors with applicable statutory requirements and IFC Performance Standards on labor; consistency of worker accommodation with IEE and IFC guidance; implementation of grievance mechanism; protection of the work force, including engagement of migrant workers, if any, on substantially equivalent terms as non-migrant workers performing same work.

Resource Efficiency

KMTL will, as part of its ESMS for the Dry Port, set specific resource and energy efficiency, water consumption reduction, and greenhouse gas (GHG) emission reduction targets. Accordingly, KMTL will include fuel and energy efficiency parameters in design and procurement of new equipment; undertake rainwater harvesting; reuse water and treated wastewater where possible; implement measures to monitor energy consumption; and implement programs to reduce specific energy consumption.

Greenhouse Gases

While a 1000 KVA electricity connection has been sought from the grid, the total electricity expected to be consumed by the Dry Port in calendar year (CY) 2019 is 2.2 GWh and 5 GWh at full capacity utilization. The total diesel expected to be consumed in CY2019 is 310 tons and 500 tons at full capacity utilization. The total GHG emitted in CY2019 will be 10,000 tCO2e and about 16,000 tCO2e at full capacity including accounting for the truck traffic to and from the dry port. Due to operation optimization and lower fixed energy consumption with throughput increase, the specific GHG emission per TEU is expected to reduce from 0.185 tCO2e/TEU in CY 2019 to 0.115 tCO2e/TEU in 2024. The company will quantify and report annually on GHG emissions in accordance with internationally recognized methodologies and good practice. 

Pollution Prevention and Control during Construction

The environmental impacts from construction activities for the Dry Port (i.e., source and transport of construction material, land clearing and filling, cement concrete batching plant, construction of cargo stack yard, ware houses, internal roads, drainage, access roads etc.) are those typical of most construction sites onshore, and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater from construction camps; increased water usage; and construction vehicle traffic. KMTL has contractually required their EPC and construction contractors to control these to acceptable levels through application of standard construction environmental controls and mitigation measures recommended in the IEE. As indicated under Performance Standard 1, the company will develop and provide the construction ESMP, that meets IFC Performance Standards and applicable WBG EHS Guidelines, to the EPC contractor and require them to implement it. Some of the specific mitigation measures to be applied include: installation of sediment traps to reduce sediment in runoff generated during land clearing/filling; collection, storage and disposal of liquid and solid wastes generated during construction through authorized treatment and disposal facilities; implement measures to minimize risk of spill and overflow during transportation; constructing paved roads early where feasible and cleaning of paved roads; provision of water sprays to control dust on roads and stockpiles; and covered transport of construction materials in trucks.

Temporary impacts to air quality may occur during the construction phase. While the EPC contractor is undertaking water spraying on vehicle movement areas for dust suppression, KMTL will implement additional measures as part of the ESMP to minimize dust during construction period including: covered transport of material; management of fill/excavated earth and construction material, including staggered excavations at neighboring locations and wetting stockpiles; restricting excavations and construction material handling during high wind conditions; vehicular movement planning; minimizing time for which excavated/fill earth is left loose at site; management of pollution from vehicular and equipment emissions; and other measures for minimization of fugitive dust emissions (e.g., covering stockpiles). Increase in ambient noise levels is expected during construction due to increased traffic, use of earthmoving and other construction equipment. The company will: not undertake high noise generation activity at night; and undertake transportation planning to minimize traffic through communities at night.

Groundwater is being used for construction and domestic use, with about 20 m3/day of water consumed during construction. Generation of wastewater is mainly limited to sanitary wastewater/sewage from labor accommodation and project office areas during construction. The Dry Port will, as part of the ESMP implementation, ensure that construction waste water (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through an oil water separator and settling tank. The treated wastewater will be used in dust suppression. The sewage will be treated through septic tank and soak pit. The company will ensure that non-hazardous construction waste will be used for site filling and other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.), garbage from worker accommodation are collected, segregated, stored and disposed of to re-users or in government authorized debris treatment and disposal areas. Hazardous materials (fuel, lubricating oils, paints, batteries etc.) and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, spent batteries etc.) are expected to be generated during construction. These will be hazardous material and hazardous wastes handled/generated at site during construction are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste is disposed through entities authorized to handle, recycle and dispose hazardous wastes.

The company will as part of the construction phase ESMP require and ensure that the construction contractors adopt good EHS practices during construction including: training equipment operators and drivers in safe and defensive driving techniques; developing a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; speed controls; backup alarms; undertake appropriate measures to reduce fugitive emissions from storage and transport of construction and waste material; periodic noise monitoring in nearby resident communities on the transport route; and undertaking community safety awareness program.

Air Emissions and Ambient Air Quality

During operation phase while container stripping and stuffing will be undertaken in covered areas, measures to minimize fugitive dust include provision of dust extraction and bag filter system and flexible curtains in storage and handling areas, paving of roads, provision of floor/paved area sweepers for collecting spilled material, designated vehicle movement areas, closed/covered transport of material.

The Dry Port is expected to handle 250 trucks and three trains per day at full capacity. The Dry Port will develop a dedicated parking space for trucks/trailers. While all equipment operated by the Dry Port will be properly maintained and their emissions will be within national standards and IFC Guideline limits, during operation phase, with the expected increase in truck traffic, fine particulate matter (PM10, PM2.5) and oxides of nitrogen (NOx) levels will likely increase in the ambient. KMTL will, as part of the ESMS for Dry Port include procedures to require its customers/suppliers to implement procedures to ensure that: emissions from trucks/road transport vehicles entering the Dry Port premises are within national standards; and trucks are well maintained. The company will implement procedures to inspect vehicles and monitor compliance of its customers/suppliers with the dry port requirements. The company will implement additional measures to minimize and monitor air quality impact including: (a) minimizing truck dwell time (particularly engine idling time); (b) providing tire wetting facilities; (c) storage planning to minimize restacking operations; (d) to the extent feasible, using cleaner fuels/fuel mixtures in its own equipment and trucks/road transport vehicles; (e) encourage suppliers/customers to also engage truck operators that use fuel efficient vehicles and vehicles that use less polluting fuels; and (f) undertake ambient air quality monitoring.

Electricity will be sourced from the grid and no backup diesel generators will be provided as backup power. The company will put in place procedures to ensure that refrigeration gases used in the reefers meet national ozone depleting substances rules requirements under the Montreal Protocol.

Noise

Daytime baseline noise level monitored at the Dry Port site marginally exceeds the national ambient noise standards, though night time ambient noise level is well within the national standards. The noise is characterized mainly as noise from nearby roads and from movement of trains as the site is located within the railway station yard. The nearest residential community is about 1 km from the site, towards the South – East adjoining the main road and away from the Dry Port, beyond the other dry port that is under development. Access road to the Dry Port site is away from this community. Traffic during construction and operation will ply on the main road and to that extent it will pass through the nearest community. MR employees colony is planned on a plot adjoining the North boundary of the Dry Port and the informal settlers resettlement site is located about 1 km North of the dry port boundary. Traffic due to construction and operation do not pass through these two residential locations. 

Increase in ambient noise level is anticipated due to increased traffic as also dry port operations. In addition to ensuring that the equipment and trucks/road transport vehicles are well maintained and have appropriate mufflers, the company will: undertake transportation planning to minimize night time traffic through the community during operation; deploy traffic marshal in inhabited stretch of the road; and require no horn and speed limit for their owned trucks and trucks coming to their premises in the inhabited stretch during night. The company will explore undertaking these measures jointly/in coordination with the neighboring dry port developer, as part of the cumulative impact mitigation strategy discussed under Performance Standard 1.

Water Usage and Wastewater Treatment

About 5 m3/day of groundwater will be consumed during operation for domestic use, port and container cleaning. The company will, as part of the ESMP implementation and dry port’s ESMS, test the ground water to current WHO Drinking water guidelines and based on the test results, if required, treat the ground water prior to its use for drinking purposes. The Dry Port is expected to generate about 10 m3/day of construction wastewater and 5 m3/day of sewage during construction and about 2 m3/day sewage and 3 m3/day of wastewater during operation. As discussed below under Performance Standard 4, water consumption from the dry port is not expected to have significant adverse impacts on others, although potential cumulative effects due to the presence of the second dry port will need to be assessed as discussed under Performance Standard 1.

During operation, sewage will be treated through septic tank and soak pit. Septic tank sullage will periodically be transported and disposed of in the municipal sewage treatment plant by authorized municipal contractors. Storm water runoff free of contamination will be collected in open drains with sediment traps and discharged directly to the common drain being developed. Surface runoff from maintenance areas or areas where spills of chemicals might occur and cause contamination, will be separately collected and pre-treated in oil/water separators, tested for conformance to national surface water quality standards prior to discharge in the drain. 

Solid Waste Management

Bio-degradable waste will be composted and used for greenbelt development/horticultural purposes. Domestic waste/garbage generated in thein the Dry Port during operation stage will be collected by authorized municipal contractors and disposed of at municipal approved government-operated waste facilities. The company will as part of Dry Port ESMS implementation segregate, label and store solid waste in a designated area during construction and operation.

The Dry Port includes a 30 m2 area for segregated storage of expired products and waste cargo during operation stage. The company will return the expired products to the manufacturer] or dispose this off as per instructions of the manufacturer through authorized contractors in municipal waste disposal facilities.

Hazardous Materials and Waste

KMTL does not have license to handle dangerous cargo. However, the company will, as part of Dry Port’s ESMS implementation, ensure that other hazardous material (fuel, lubricant oils, batteries etc.) and hazardous wastes handled/generated at site during operation are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste is disposed through entities authorized to handle, recycle and dispose hazardous wastes. Container, equipment and vehicle maintenance areas will be appropriately paved, have provisions for spill containment and surface runoff from open maintenance areas will be separately collected and treated through an oil/water separator. Areas where fuels or other hazardous materials are stored will be constructed within secondary containment structures to contain and prevent any leaks from being released to the environment.

The nearest resident community to Yangon Dry Port is about 1 km from the port boundary and is located on a main road, Inn Wa street, that connects to Mandalay- Yangon highway. The access road to Dry Port spurs off from Inn Wa street. While this access road is not through any village, vehicles coming from/going to Yangon will take the Inn Wa street and pass through the   community that is resident along Inn Wa Street. As indicated above, it is expected that number of trucks visiting the Dry Port at capacity will be 250 per day, and train rakes will be three per day. The company will, as part of the ESMS, develop a traffic management plan to minimize community exposure to health and safety risks. The company will explore opportunities for joint/coordinated action with the second dry port developer to minimize community health and safety risks due to increased traffic to both the dry ports. 

Infrastructure and Equipment Design and Safety

The Dry Port has been designed to national and American Concrete Institute international engineering standards. The Dry Port is located in seismic zone III with moderate seismic hazard, which has been taken into account in the design of structures. The site is in a flood prone area so the dry port site has been filled to raise it above the flood levels.

Ecosystem Services

The Dry Port is using ground water for construction and will use it also for operation stage. Communities have been using water from a nearby pond, located about 1.5 km from the project site, for domestic use. Further, KMTL has also provided a tube well. Material impact is not expected on account of this water consumption by the Dry Port. Baseline ground water quality assessment has been undertaken as part of IEE. The company will as part of the Dry Port’s ESMS implement procedures to monitor ground water quality and depth. Further, the company will implement rain water harvesting measures also.

Community Exposure to Disease

The company will as part of the ESMP: provide adequate provisions within the site and worker accommodation for wastewater and garbage collection, treatment and disposal in order to minimize the workers and community exposure to water-borne, water-based and vector-borne diseases; and undertake health check-up of workers including provision of adequate medical assistance or on-site medical facility or access to appropriate medical facility. Further, since the Dry Port is being built on filled land located in a flood prone area, the Dry Port is building a drain to avoid disruption in surface/storm water drainage and to prevent flooding in adjoining areas and fields in the rainy season.

Emergency Preparedness and Response

Outline of an emergency response plan has been delineated in the IEE for the Dry Port. The company will as part of the ESMP, undertake a construction phase hazard and risk assessment and develop an emergency preparedness and response plan. Further, as part of the ESMS development, the company will undertake an operation phase hazard analysis and risk assessment. Based on the hazard analysis and risk assessment, the Dry Port will: develop and implement an onsite and offsite Emergency Preparedness and Response plan for operation phase; have in place procedures, trained personnel, and equipment for responding to emergencies, including fire, chemical spills and mishaps, accidental release of hazardous cargo and medical emergencies; appoint a suitably qualified emergency coordinator; communicate the emergency response plan to key stakeholders including local/district emergency response authorities and neighboring communities; undertake awareness training including drills for building awareness on emergency response; participates in any drills conducted by district/local government emergency authorities; and continually improves the emergency plan based on outcome of the drills.

Security Personnel

Fifteen outsourced security personnel have been deployed at the Yangon Dry Port construction site and 15 security personnel will be deployed upon commencement of port operation. They are not armed and no armed security will be deployed in the Dry Port operation stage as well. The company will as part of the ESMP for the Dry Port for construction phase and as part of the ESMS for operation phase implement formal procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out;  personnel are trained in handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; security personnel are trained in avoidance of human rights violations; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel. 

Stakeholder mapping and Stakeholder Engagement Plan

KLN is committed to ensuring that its businesses engage with key stakeholders on a regular basis across various platforms, such as meetings, interviews, surveys and workshops to gauge their expectations and feedback on how they could address ESG issues effectively. As part of the regulatory approval process, the IEE consultant and KMTL mapped key stakeholders including government and regulators, MR, East Dagon Township Administrator, residents of Ywathargyi, the resettled informal settlers and farmers who had farming rights on the land. The company will as part of the regulatory approval process, map out and identify a wider set of stakeholders for further engagement. Further, the company will, for ongoing engagement with stakeholders during the construction and operation phases, as part of the Dry Port’s ESMS, undertake comprehensive stakeholder mapping to develop a. Stakeholder Engagement Plan (SEP) with stakeholder profile, identification of key concerns, expectations, impact and influence, risk rating of various stakeholder groups, and a community grievance redress mechanism. The SEP will include details on engagement strategy, information disclosure, monitoring, reporting and guidance on maintaining records of stakeholder consultations. Further, the SEP will include a plan for ongoing disclosure of information to key stakeholder groups.

Consultation

The company undertakes consultations for its projects in accordance with the regulatory requirements. As indicated above, company’s processes for ongoing consultation will be further formalized and strengthened as part of the updated SEP. Consultations for the dry port have been undertake with the above identified stakeholders during December 2016 as part of the IEE process. Further consultations will be carried out in accordance with regulator’s recommendation, with a wider set of key stakeholders as part of the regulatory approval process. The key input received in the consultation process was that the stakeholders are generally supportive of the Dry Port but there is an expectation that the company will strictly adhere to the mitigation measures particularly related to dust from site earth filling works, transport of construction material, increased risk of flooding due to earth filling at site, increased risk of accidents due to increased traffic. The company has, as part of the IEE, documented these expectations and g the company’s committed to address these expectations. Additional consultations were undertaken by the third party appointed by KMTL to review land acquisition and resettlement process. This consultation was with the resettled informal settlers and the farmers who had farming rights on the land where the Dry Port is located. The key finding was that overall living conditions of informal settlers have improved at the resettlement site though the there was some loss in income for informal settlers that had livestock. As discussed under Performance Standard 5, the company will implement relevant actions to mitigate the impact.

External Communications and Grievance Mechanisms

The company will, as part of SEP, develop and implement a community grievance redress procedure, which will include: (a) timebound internal resolution and/or escalation steps; (b) make available to affected communities and communicate to affected communities the channels/means for  lodging concerns/grievances; (c) redress the grievances in a time bound manner; (d) upon redress communicate the decision to the aggrieved person/community; (e)  provide a mechanism to appeal against a redress decision in a higher joint committee if the aggrieved persons/community is not satisfied by the redress proposed in the first instance; (f) document grievances received and redressed; and (g) analyze grievance related data to identify patterns and undertake systemic improvements as needed.

Information Disclosure and Ongoing Reporting to Affected Communities

The IEE and Dry Port information will be disclosed in accordance with regulatory requirements as outlined above. Further, the company will disclose the ESRS and ESAP to the neighbouring communities in an appropriate form and language at a third party location nearby. The company will also periodically report information on status of implementation of the ESAP to the affected communities.

 KMTL will disclose this ESRS at Ywartargyi Quarter Administration Office and will be with Mr. U Zayar ( Head of quarter)/ U Win Soe (Assistant).

Any queries and/or comments about the Dry Port may be directed to: