Environmental and Social Assessment and Management System, Policy, Identification of Risks and Impacts
and Management Programs
The Municipality of Bogota has environmental and social policies that apply to both IDU andTRANSMILENIO
S.A., and which are generally consistent with IFC’s PS requirements. The environmental policies are available
through the website of the Environmental Secretariat at http://www.ambientebogota.gov.co/web/sda/politicasambientales.
IDU’s social management policy is described in the Guideline for Social Management for Sustainable Urban
Development
(https://www.idu.gov.co/Archivos_Portal/Transparencia/Informacion%20de%20interes/Publicaciones/2017/09%20Septiembre/02%20Gu%C3%ADa%20de%20gesti%C3%B3n%20social.pdf) which includes provision
for social risks and impacts management and public participation during the development of feasibility studies,
project design, pre-construction, construction, and maintenance of urban infrastructure. IDU subscribes to the
United Nations Global Compact and its principles in the areas of human rights, labor, environment, and anticorruption.
Both IDU and TRANSMILENIO S.A. have an Integrated Management System (“IMS”) in place for managing,
monitoring and evaluation of the environmental, occupational health and safety, and social performance of their
activities. The IMS includes processes and procedures for quality control, accountability, inspections and
monitoring, reporting, and management review.
As part of the client’s policies and as reflected in the IMS of TRANSMILENIO S.A. and IDU, there is a
requirement for environmental and social assessments to be undertaken, with the assistance of external experts,
in the development of all new projects, depending on the size and complexity of the project. IDU’s social
management department carries out socio-economic surveys and censuses and socioeconomic assessments.
Based on the results of the environmental and social impact assessments, project developers prepare project-specific management plans), which specify mitigation measures for all project phases.
The management plans entailing land acquisition and resettlement are developed and implemented by IDU, with
the assistance of other government entities that provide complementary social services, such as the Education,
Social Integration, and Health Secretariats. The elements of the City’s program include clearly articulated
objectives, strategies, assignment of responsibilities, supervision and audit programs, and a feedback mechanism
for the review of environmental and social policies. For EHS matters, IDU has also developed a control and
monitoring manual (Manual Único de Control y Seguimiento Ambiental y de SST del IDU), which functions as
a management tool for all parties involved in a project (IDU, Interventoria and Contractors) and provides
guidance on the basic EHS requirements for every stage of the project cycle.
IDU undertook the basic concept studies of the TransMiCable project in 2009. In 2013, a detailed feasibility
study was commissioned as well as a detailed environmental and social impact assessment (ESIA) was
conducted, although it was not required by the legislation in force. In line with the ESIA, which is consistent
with IFC Performance Standards, IDU developed a PIGA and a social management plan specific to the TMP
project and obtained required permits and approvals from the relevant authorities including the Ministry of
Environment.
During construction IDU has required the project contractors to implement the applicable management plans
(namely MAO - Manejo Ambiental de la Obra) and to have E&S supervisors and vegetation management
specialists, responsible for the implementation and compliance with IDU’s requirements. Interventoría verified
compliance on site and reported performance to IDU on periodic basis. Project contractors were required to
conduct environmental and occupational health and safety risk analyses for the construction phase and develop
a construction phase management plan including the definition of specific mitigation measures, program for
inspections and monitoring, and near miss and incident reporting.
As indicated, Trasmilenio will be responsible for the operation of the cableway and its stations. The company’s
IMS is comprehensive and include procedures covering relevant E&S aspects, such as risk management, social
management, contractor management, emergency preparedness and response, and citizen participation. As per
Environmental and Social Action Plan (ESAP) action #1, Bogota Distrito Capital will ensure TRANSMILENIO
S.A. review and extend the scope of its integrated management system to include TransMiCable operations. This will include the E&S requirements for the selection, contracting and supervision of the operator of the
cableway.
Organizational Capacity and Competency
As discussed above, IDU has overall responsibility for the construction of the project. At the institutional level,
responsibilities for EHS and social performance are shared across different management areas, including the
environmental, land acquisition, and citizen services departments. The environmental department has a staff of
65 and is responsible for environmental impact assessment, obtaining relevant project permits and monitoring
contractor’s compliance. The social department (or citizen services) has a staff of 72 and is responsible for
management of social aspects associated with project development and implementation, including stakeholder
engagement and grievance mechanism. The land acquisition department of IDU has a team of 356 dedicated
staff. As part of IDU’s standard contract documentation, the construction contractors are required to assign an
EHS and social team, which for TransMiCable included six community liaison officers and a supervisor,
responsible for community safety, traffic safety, disclosure of information, and operation of the grievance
mechanism, and two environmental officers and four supervisors. During construction, each subcontractor was
required to have their dedicated E&S team.
TRANSMILENIO S.A. has a dedicated EHS and social team which liaises with IDU during project construction
and will manage and supervise the E&S aspects and compliance of the project operations. As per the ESAP #2,
Bogota Distrito Capital will designate a senior official at IDU and at TRANSMILENIO S.A. with overall
responsibility for ensuring and reporting on compliance with IFC Performance Standards and implementation
of the agreed ESAP, in addition to the national requirements.
Both IDU and TRANSMILENIO S.A. have an E&S induction program for new employees, which includes
labor rights and working conditions. Specific guidance is provided to contractors’ personnel on how to interact
with the affected communities including vulnerable or disadvantaged individuals or groups in the area.
Emergency Preparedness and Response
Project contractors prepared and implemented an emergency preparedness and response plan including
construction site evacuation, fire and medical emergencies. The plan included a communication protocol with
the local authorities. At the construction sites visited, emergency response resources and equipment were
available, including first aiders and emergency response team deployed at each construction site. The contractors
hired a third-party health service provider
TRANSMILENIO S.A. has an emergency preparedness and response plan for operations including mass-transit
system evacuation procedures, life and fire safety, and medical emergencies. Evacuation routes and emergency
equipment are clearly marked at the existing bus stations and there are alarm and announcement systems. Bogota
Distrito Capital will ensure that a project specific emergency preparedness and response plan will be prepared
and incorporated to the TRANSMILENIO S.A.’s integrated management system that will include
TransMiCable operations as per ESAP action #1.
Monitoring and Review
It is a requirement by the Municipality of Bogotá that independent consultants are contracted to supervise the
implementation of municipal projects, in order to increase accountability and transparency. For each project the municipality establishes a monitoring committee, including social and environmental subcommittees, with the
participation of representatives of IDU, contractors, and the independent supervision consultant
(Interventoría).TRANSMILENIO S.A., as a municipal corporation, is also required by the municipal regulations
to engage independent consultants to monitor and supervise the implementation of service contracts and
concessions, and will define a similar engagement for the operation phase of the aerial cableway.
Project supervisor and contractor supervisors are conducting site inspections and daily toolbox talks with the
construction workers. Inspections focus on safety of the access roads, fencing, personal protective equipment
use, behavioral safety, excavation, heavy-duty vehicles, minimization of nuisance to the residents, and
community safety. The contractors are required to carry out a monitoring program covering elements such as
waste management, effluent management, energy (fuel and energy) and water consumption, incident and near
miss rates, and training hours. E&S performance is reported monthly to IDU’s management.
TRANSMILENIO S.A. has a monitoring and reporting system for its operations. This includes incident rates
(for employees, contractors, third parties and passengers), energy and water consumptions. E&S performance
is reported to Bogota Distrito Capital`s senior management monthly. As per ESAP action item #1, Bogota
Distrito Capital will ensure that the scope of TRANSMILENIO S.A.’s monitoring and reporting system will be
reviewed to include TransMiCable operations and ensure that all E&S performance data, including but not
limited to incidents, energy/water consumption, waste management, noise, vibration, complaints will be
monitored and reported to senior management.
Although project is not located in an area with significant cultural or historical value, there are archaeological
sites within 5 to 10 km from the project area. Necessary permits/licenses were obtained from competent
authorities, such as Colombian Institute of Anthropology and History and the Environmental Secretariat, and an
archaeologist was employed by the contractors to monitor the excavation/demolition works. IDU’s IMS
guidelines include a requirement for the suspension of construction activities and immediate contact with
competent authorities in the event of a chance find of archeological artifacts. The guideline includes a procedure
requiring the continuous guarding of the area to prevent theft in case of chance finds until a time that these
authorities can assess the find and implement a plan for its recovery.