PS5: Land Acquisition and Involuntary Resettlement is not applicable to the project as all project activities will be managed within the existing footprints, no additional bus lane are expected to be built nor additional land will be acquired for the depot reconstruction.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management is not relevant given that the project in-city transportation services operate in a purely urban, built and highly intervened environment.

PS 7: Indigenous Peoples does not apply given the absence of indigenous groups in the area/region.

PS 8: Cultural Heritage does not apply given the project has no expansion beyond its existing footprint. There is no requirement for earth work and demolishment of any structures outside of the depot, and there are no culturally protected structures within the depot.

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because it will have a limited number of environmental and social risks and impacts that can be avoided or mitigated by adhering to generally recognized international industry performance standards, guidelines, or design criteria. The key E&S issues related to this proposed investment are the effectiveness of the implementation agency’s E&S management system and the capacity at the corporate and at the operation levels (depots, workshops, etc.). Other key E&S risks and issues include the following:

- Life and fire safety, and emergency response

- Occupational health and safety

- Wastewater management

- Road transportation safety

 Social and Environmental Assessment and Management Systems

The main component of the proposed investment is the procurement of about 64 buses and new workshop equipment, as well as refurbishment of workshops. All specific activities with potential limited adverse environmental and social risks and/or impacts, for which the development of a full-scale ESIA is not required by the host country’s environmental assessment laws and regulations. An Environmental Impact Assessment (EIA), commensurate with the relevant and specific environmental and social risks and impacts, will be developed to meet requirements of Ukrainian laws. The environmental assessment will consist of the application of pollution standards, design criteria, or construction standards and will be developed consistent with IFC’s Performance Standards. (ESAP Condition No #1). 

Environmental and social risks and impacts of project (bus operation and workshop reconstruction) are limited and the relevant environmental aspects are mainly associated with: (i) reducing the carbon footprint (GHG) of the project, resource efficiency and increasing fuel efficiency of the system; (ii) management of solid and hazardous wastes, wastewater discharges, and potential soil contamination at the depot; (iii), air emission and noise management; (iv) life and fire safety and emergency response and preparedness at administrative offices, depot and any supporting facilities under MTTU’s control; and (iv) occupational health and safety (OHS) of generally small scale construction work.

Social aspects and impacts are mainly those associated with recruitment, capacity building and training of new drivers/operators and other technical personnel of the MTTU.

The new buses will be equipped with low floor, folding wheel-chair ramps and external sonar devices to facilitate access for physically challenged people, and video recorders and surveillance cameras to help improving road safety. To raise the level of comfort, buses will have in-door air conditioning systems. Old buses will be decommissioned based on the cycle of fleet replacement and decommissioning and disposal will be carried out as per relevant laws and regulations.

The MTTU E&S management system is commensurate to address E&S aspects of its operation and being managed by three functional departments: OHS, human resources and technical department.

Operational safety and OHS have a central role in the management system. MTTU has an OHS department represented by a head of department and two OHS engineers/inspectors, reporting directly to the head of MTTU. The OHS management system is structured around a number of regulations, including: 1) Regulation for OHS department; 2) Regulations for operation supervision over occupational health, safety and sanitation; 3) Regulations for OHS training; 4) Regulations for planning and development of OHS instructions, and 5) Regulations for operational control. These regulations detail the tasks and functions of the department and cover all the relevant aspects of OHS management activities and their monitoring.

The organization of personnel training, competency assessment and professional development is carried out by the OHS department. Knowledge tests are administered by a commission, whose chairman is the chief engineer of MTTU, and are held with the participation of inspectors from the state service on labor protection issues. The regulations also include a procedure for training employees and officials carrying out high risk activities as identified by job hazard analyses, as well as organizing safety talks.

MTTU’s emergency plans are available and cover both bus operations and facilities but they are limited to fire response. As an ESAP Condition No #2, MTTU will develop a comprehensive Emergency Preparedness and Response Plan (EPRP) to address all foreseeable incidents and emergency situations, including fires, explosions, road accidents, natural disasters, terrorism and other threats. The plan will contain detailed preparedness procedure to safeguard the health and safety of workers, passengers, and the communities in the event of an emergency. The EPRP will ensure there is a clear chain of command assigning functions and responsibilities to appropriate personnel/organizations, and will include the requirement for induction and refresher training, periodic drills and simulations. The plan and relevant procedure will be documented and provided to all drivers and all essential emergency response personnel. Buses, stations administrative and maintenance areas will be equipped with alarms, monitors and sensors, evacuation routes, and firefighting equipment, including printed instructions how to respond in case of an emergency and on how to use the equipment (ESAP Condition No #2). An Inter-Agency Agreements will be stipulated with emergency response organizations to effectively respond to an emergency in a timely manner .

 Human Resources Policies and Procedures

Recruitment and employment of MTTU staff are guided by the Labor Code of Ukraine, and specifically articles 21-31, 174, 187-191, by the National Profession Classifier of Ukraine ?? 003: 2010 and by the Single Rate and Qualification Directory of Works and Professions No. 1 (general professions for all types of work), No. 69 (automobiles), and No. 87 (utility services in populated areas). Per article 24 of the Labor Code of Ukraine, hiring of employees is based on employment contract or order, reflecting employment terms, working conditions and compensation. The Labor Code articulates requirements of recruitment and hiring process, working age, working hour, job specifications, competencies structure and salary level. The employment contract also includes MTTU specific conditions, such as code of conduct and relevant articles from labor union collective agreements.

MTTU has two types of employment contracts per Ukraine labor law: undefined term (permanent) contracts and part time contracts. MTTU has a total of about 1300 permanent staff and a small number of contracted workers for supporting, non-core works (such as gardening). The bus operation unit has a total of 189 staff among which 72 are female employees (68 of them are bus conductors). MTTU is currently under staffed and will need to hire bus drivers, given the planned increase of buses to operate. However, given the potential introduction of an electronic ticketing program, the number of bus conductors are likely to decrease; as part of the plans, MTTU will look for and identify alternative job positions within the municipal agencies and ensure smooth transitions. MTTU will develop a Human Resources policy and procedure compliant with PS2 requirements and in line with relevant IFC’s Good Practice Note to manage retrenchment process when retrenchment is inevitable (ESAP Condition No. 3).

MTTU endorses the principle of freedom of association consistent with host country law. There are two registered and operating independent unions in MTTU: MTTU Trade Union and All-Ukrainian Union “Protection of Justice”. Workers have the right to join a union and the unions negotiate salary levels and working conditions as part of a collective bargaining agreement, covering both unionized or ununionized workers.

MTTU has grievance procedures that allow workers to raise employment related issues to their immediate supervisor, HR manager and/or manager. Another common way of raising concerns is by approaching union representatives. MTTU Human Resources (HR) department meets with the union regularly to discuss any issues related to employment.

Occupational Health and Safety

Occupational health and safety (“OHS”) is a key component of the company’s management system. Operation related activities are subject to hazard identification and risk assessment to ensure that health and safety controls are in place prior to starting the activity and that the workforce is trained on the work hazards present, the correct use of equipment, the procedures to be followed and protective gear to be worn.

MTTU carries out a risk and impact identification and evaluation process regularly, and risks and impacts, their mitigation and management measures are mapped and catalogued by area: mechanical, electrical, administrative, working with high pressure containers, operation and maintenance, security, etc.

The OHS department is responsible for personal protective equipment (PPE) provision and supervision, job hazard analysis and mitigation, medical exams, regular safety inspections and random inspections. The department issues safety reports which consist of a description of the safety issues identified during the inspections and relevant corrective mitigation measures with completion timeline.  The reports are submitted to the head of MTTU. Progress in the implementation of the corrective measures is being tracked and documented for evaluation of safety performances. All staff receives mandatory intensive training on the operational aspects. Lost time injury frequency rates and near misses are monitored. The strict enforcement of H&S procedures by MTTU is reflected in the positive safety statistics reported.

MTTU implements three stages of supervision of safety performance: 1) daily inspections conducted at each workplace by the relevant supervisors who check equipment, lightning, PPE, safety rules, etc. and record their observations in the control log; 2) every 10 days, the head of each department and head of Structural Division review the daily inspection logs, status of implementation of corrective measures, timeliness and quality of labor safety briefings, compliance of working conditions with requirements, conditions of the firefighting equipment, etc.; 3) once a month, operations and facilities are inspected by a commission consisting of the head of MTTU, the head of OHS department and the chairman of trade union committee. Following the monthly inspection, all departmental heads meet to review status and outstanding issues. Results of the meeting are drawn up in a statement that comes into effect upon the signature of the head of MTTU. IFC reviewed MTTU risk assessments and job hazard analyses, inspection logs and safety reports, and safety statements and considered these to be in alignment with Good International Industry Practice (GIIP) and IFC’s PSs .

 GHG emissions and air emissions

Annual GHG emission reductions of 4,000 tons CO2/year will be achieved by replacing the outdated fleet with diesel-powered Euro 5 buses and by reduced congestion and improved fleet utilization through better traffic management system. The new buses will use more efficient engines.  The dismission of outdated natural gas-powered buses will contribute to reduce traffic congestion. The benefits of selecting diesel-powered Euro 5 buses are included in a Cost and Benefit Assessment which has been carried out as a part of IFC-funded Advisory program. MTTU will prepare and publish a summary sheet (ESAP Condition No #4) presenting all analyses carried out and the positive impact in terms of reduction of cumulated emission levels of particulates (PM10, PM 2.5), and other gaseous emissions from traffic due to the implementation of the program.

Waste-water treatment, management and monitoring

MTTU discharges generated wastewater to the municipal sewage system in compliance with the “Rules regarding Accepting Wastewater from Enterprises into the Mariupol Sewage System”, approved by the decision of Mariupol City Council No. 48 of 18.02.2004. The Rules require that wastewater effluents do not contain pollutants exceeding permitted concentrations. However, MTTU wastewater discharged from workshop facilities in the depot are reported to often exceed the permitted concentrations due to the outdated and ineffective wastewater treatment system used in workshops, resulting in penalties from the municipality utility. MTTU will install new wastewater treatment units with monitoring devices (ESAP Condition No #5). Performance of the new facilities and relevant monitoring data will be reported by MTTU to IFC.

Energy efficiency

Mariupol City is a signatory of the European Covenant of Mayors for Climate & Energy (Decision of Mariupol City Council of 28.08.2013 No. 629-3407). As such, MTTU is committed to be in full compliance with Mariupol sustainable energy action plan and the proposed investment will be part of these efforts, which also include the expansion of the existing traffic planning and management system.

The EIA for the reconstruction of the depot (which will be developed to meet national requirement) will be consistent with PS3 and will describe the technical design of all new infrastructure built for the depot, with focus on the integration of energy efficient systems and relevant proposed measures to increase the efficiency of the operations and infrastructure in terms of conservation and use of resources.

MTTU will develop an energy consumption tracking system to log and analyze energy use to monitor and improve energy efficiency for bus operation and maintenance. MTTU will report energy efficiency tracking and performance to IFC.

Waste management

As part of the actions to dispose of the buses which will be put out of service, MTTU will comply with all national laws regulating management, handling, transport, treatment and disposal of all industrial and hazardous waste and materials, including appropriate recycling of scrap metals. All hazardous waste generated in the scrapping process, such as batteries and used oils, will be collected and disposed of by certified agencies in an appropriate manner. A waste collection area will be established on the premise for the disassembly of old buses .

 The main community, health, safety and security impacts and risks associated with the bus operation are those associated with the safety of pedestrians, bus users, and traffic, and the security of users of the system. Safety measures have been developed and implemented by City via several measures, including installation of traffic stops, crosswalks and pedestrian signaling along the system, particularly along trunk lines and other areas with high vehicular and pedestrian congestion, as well as defensive driving.

The MTTU’s Traffic Organization and Control Unit and the City’s Dispatcher Service (Centralized Control) are responsible for organization and monitoring of the traffic of the municipal and private public transport. The rolling stock (including buses) is equipped with GPS navigation system. MTTU maintains good road safety records of the fleet they operate.

As indicated, the new buses will be equipped with low floor, folding wheel-chair ramps and external sonar devices to facilitate access for physically challenged people, and video recorders and surveillance cameras to help improving road safety.

No armed security used in any of MTTU’s sites. Unarmed security personals are present at the gate of office building and depots to control access.

 Stakeholder engagement and communications about the project and the broader program to meet the commitments under the City’s sustainable energy action plan will be ongoing to ensure open and transparent communication with users and the public, and an effective grievance redress mechanism.

As part of this effort, MTTU will prepare summary information sheets and a public information program on the project, including a comparison and expected benefits from the new fleet of buses, and all relevant information to the public on how to provide comments, requests and complaints about the program.

 Address and contact details of the client:

Mariupol City Council

39, Mytropolytska Str.,

Mariupol, Donetsk Region, Ukraine

+38 (0629) 331 010

+38 (0629) 331 214