Based on the review, no impacts or concerns are expected, which are associated with following Performance Standards:

PS5 Land Acquisition and Involuntary Resettlement as all project activities will be carried out in public land and within the existing footprints, and no additional land will be acquired.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management as the project is in an urban, built and highly intervened environment.

PS7: Indigenous Peoples as there are no indigenous peoples affected by the project.

PS8: Cultural Heritage, as there is no cultural heritage which will be affected within the project footprint. There is a chance find protocol in place, in line with IFC’s requirements.

 If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.  

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as 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 project is expected to have a positive impact by reducing greenhouse gas emissions, air pollution, and noise. Key E&S issues are as follows: (i) client’s capacity to identify and manage E&S risk during construction and operations; (ii) management of the potential social impacts, especially in relation to access limitations and disturbance for residents and businesses during the reconstruction and expansion of the catenary lines, and potential induced effects on private bus operators, due to the introduction of the autonomous trolleybuses and optimization of the public transportation network; and (iii) management of community and occupational health and safety risks during construction.  

 Environmental and Social Assessment and Management System

LET has documented management procedures, including safe working practices, hazardous material and waste management procedures, and environmental performance monitoring, in line with the Ukrainian legislation.

As required by the national legislation, LET conducts environmental impact assessment and occupational health and safety risk analysis for its projects and operations. Identification and evaluation of aspects and impacts and risk analyses of maintenance and operations are maintained for the existing operations and assets and will be updated accordingly when the autonomous trolleybuses will be procured. LET will implement the requirement of the technical specifications and will update the operational procedures.

In line with the legislation, the selected construction contractors for the installation / upgrade of the catenary lines will be required to develop a construction E&S management plan, which will include the relevant mitigation measures and a requirement to manage E&S risks consistent with IFC’s Performance Standards (ESAP item #1).

Identification of Risks and Impacts

Expected environmental, health and safety risks and impacts associated with the installation and upgrade of the catenary lines are typical of construction works in urban areas and mitigations have been included in the technical specification, consistent with good practice as described in the relevant section 4.0 of the WBG General EHS Guidelines.

As indicated above, potential limited social impacts are to be managed, especially in relation to access limitations and disturbance for residents and businesses during the installation / upgrade of the catenary lines, and potential induced effects on private bus operators, due to the introduction of the autonomous trolleybuses and optimization of the public transportation network. External consultants have therefore been hired to perform a social risk assessment and to identify the mitigation measures included in the action plan (please refer to Social Impact Assessment disclosed with the ESRS).

Works on the catenary lines are not expected to last long and may only cause short term traffic and transport disturbances.

Although the autonomous trolleybuses will not be in competition with the private bus operators, as they will be used to extend the existing trolleybus lines and, LAD and LET have indicated that they will review the efficiency of the overlap amongst the various lines, and the review might impact some bus routes. Impacts on private operators are not expected to be significant and the current contracts are valid until November 2023. Based on information provided by the City, it is unlikely that major changes will be required for the bus lines operated by the private operators. As per ESAP item #2, LET, together with Lviv City Council Transport Office and LAD, will carry out a study of bus routes and effect of the new e-bus fleet on routes operated by the public/private operators.  The study will define an action plan to deal with any eventual impacts due to the new configuration and the legal instruments required to implement it. LET, together with Lviv City Council Transport Office and LAD, will engage, in a timely manner, with private bus operators in discussions regarding changes in bus routes and relevant socio-economic impacts.

Measures relevant to external communication and public consultation are described under the section on Stakeholder Engagement.

Organizational Capacity and Competency

The City’s office in charge of investments and projects has the overall responsibility to ensure coordination between LAD and LET for implementation of the projects. The City has recently created an environmental office having an advisory role. The unit currently does not have the role of supervising environmental, health and safety management and compliance for the projects and this needs to be formalized with special arrangements between the institutions

LET has an OHS manager supported by an OHS engineer and an ecologist. LET’s OHS team reports to the technical service manager, who reports to director of the company. LET’s E&S team is responsible for conducting environmental assessments and OHS risk analysis, providing training to staff and contractors, performing inspections, monitoring and reporting performance to local authorities and to senior management, and permitting. The enterprise has employee training programs related to health and safety, traffic rules, passenger safety, defensive driving, waste management, fuel management, emergency response. Standard clauses are included in the contractor contracts to require that contractors have E&S personnel assigned to projects.

Per ESAP item#3, the City will nominate an E&S officer with overall responsibility to monitor and ensure that the project implementation is in line with IFC’s Performance Standards and to report on project’s performance to City’s senior management and IFC. The E&S officer will be responsible for supervising the implementation of the ESAP, including actions which are responsibility of both enterprises, and will report on progress and compliance. For contractors, LET’s E&S officers will ensure implementation of the relevant E&S contractual covenants, including the development and implementation of the contractor’s construction E&S management plans, and requiring the same of subcontractors.

Emergency Preparedness and Response

LET has documented emergency preparedness and response plans including firefighting, evacuation, vehicles accidents, incidents, as required with local legislation and consistent with IFC’s requirements. They conduct emergency and evacuations drills as required. Mandatory emergency response training is provided to the drivers.

Monitoring and Review

LET monitors fuel consumption, greenhouse gas emissions, injury rates, effluent quality of the waste water treatment plant at the workshop and waste generation. E&S performance indicators are reported to and reviewed annually by senior management. As needed, management is providing necessary resources to plan and implement corrective actions to improve performance. 

 Working Conditions and Management of Worker Relationship / Human Resources Policies and Procedures

LET has about 1100 employees (about 40% are women). The trolleybus drivers are about 140, out of which about 25 percent are women, a higher percentage compared to other forms of public transport.

The project is expected to create about 110 positions for drivers of the autonomous trolleybuses and for operation and maintenance of the catenary lines. The installation / upgrade of the catenary lines will require about 65 construction workers (including technical personnel and electricians) from contractors.

LET is guided by the Labor Code of Ukraine and they have documented human resources policies and procedures with company rules, working hours, job descriptions, all in line with Ukrainian regulations’ requirements and consistent with IFC’s Performance Standard 2. LET complies with Ukrainian laws which cover non-discrimination, equal opportunity, child labor, forced labor and harassment.

Enterprise’s contractual requirements include covenants to ensure that their contractors follow local regulations in addition to their requirements that relate to environmental, health and safety provisions. Contractor compliance is supervised by LET’s team during their inspections.

Workers’ Organization

Freedom of worker’s association is ensured by the Ukrainian legislation. There are active unions representing the employees of both enterprises. Collective bargaining agreements are in place for LET staff, defining the terms of employment, working hours, working conditions, and benefits.

Retrenchment

Retrenchment due to the project is not anticipated. In 2011, LET implemented a retrenchment program, due to re-organization and new traffic management plan and its work force dropped from 2500 to 1100.

Grievance Mechanism

LET has documented internal grievance mechanisms, where workers can raise concerns verbally or in writing to the direct supervisors, unions, human resources and/or to the directors of each enterprise. Contractor’s workers can use the internal grievance system. The current system does not allow for anonymous reporting. There is no internal mechanism to address complaints associated with harassment and workers need to follow legal recourses. The City has developed a Code of Conduct (CoC) that includes specific references to sexual harassment, gender-based violence and non-discrimination in the workplace. As part of ESAP item#4, the City will operationalize the CoC by developing trainings for the project staff and contractors, preparing a simplified CoC for contractors to be included in contractual provisions and nominating a harassment/gender focal point/contact person who will be trained in responding to harassment related grievances. LET will take a lead role in ensuring all their contractors adopt and implement anti-sexual harassment policies and training. As per ESAP item#5, LET will enhance the internal grievance mechanism to allow anonymous reporting and addressing harassment related grievances. Both enterprises will also require contractors to implement appropriate internal (workers’) grievance mechanisms, or to adopt, disseminate and use their mechanism and will monitor and report grievances (especially repeat grievances) raised and how they have been resolved (timeline).

Occupational Health and Safety

LET have a documented occupational health and safety management system. The system includes procedures for risk analysis, safe working practices, internal audits, monitoring the workplace hazards, incident and near miss recording and investigation, and work permits. Job safety controls are in place and the workforce receives training on work-related hazards, correct use of equipment, procedures to be followed and personal protective equipment to be used. Occupational health checks include audiometry, blood analysis and cardiological controls. Alcohol tests and control for use of drugs are carried out for each shift at LET. LET has a company doctor in addition to nurses in each shift. Specific provisions on health and safety protection are included in the contractor contracts and are supervised by the enterprise’ supervisors.

Safety performance is monitored and reviewed by management. Incident statistics are collected and analyzed. Incident investigations are consistently carried out and include root cause analyses and identification of corrective actions. 

 Resource Efficiency and Green House Gas Emissions

Lviv is a signatory of the European Covenant of Mayors for Climate & Energy and committed to decrease energy consumption and carbon dioxide emissions by 20% by 2020 versus baseline of 2009. There is an sustainable energy action plan in place, where the progress has been disclosed publicly through a web page: https://www.covenantofmayors.eu/about/covenant-community/signatories/overview.html?scity_id=11896

The project is expected to have a positive impact on energy efficiency as the autonomous trolleybuses will be more efficient compared to existing fleet and normalized greenhouse gas equivalent emissions per km will be lower. Based on available information at IFC’s review, operations of the new autonomous trolleybuses will contribute to a reduction of the City’s greenhouse gas emissions that relate to transportation by 10-12%. GHG emissions of the existing fleet, including buses, trolleybuses and tramways is around 32,586 carbon dioxide equivalent ton per annum (tpa) and upon project completion GHG emission is expected to 28,848 tpa. ET will annually report their resource consumption and GHG emissions to IFC.

Water and Wastewater Treatment

The project will not be water intensive as the construction works will consume negligible water volumes and the new autonomous trolleybuses are expected to be mechanically washed once a week at the existing trolleybus depot. Water will be supplied by the municipality network. Wastewater from the depot, where cleaning and maintenance operations of the autonomous trolleybuses will be conducted, is treated on site for oil removal and discharged to Lviv’s municipal sewer network. Flow rate is around 15 m3/hour and there is an oil trap in place, which is cleaned on a weekly base. Oily sludge is landfilled by an authorized waste management company. Bi annual waste water effluent analysis included pH, iron, ammonium, phosphate, sulphate, suspended solid, chemical oxygen demand, oil and grease among other parameters, as required by the local requirements and were found to be consistent with WBG’s relevant EHS Guideline performance levels.

Air Emissions and Ambient Air Quality

During project construction, emissions from constructions vehicles, generators and / or heaters are expected but will be limited and temporary. Operations of the autonomous trolleybuses are expected to contribute to an improvement of the urban ambient air quality.

Hazardous Materials and Waste Management

Hazardous materials and wastes will mainly include batteries, cleaning and maintenance substances such as solvents, oil, grease, lubricant and paints. All construction and operations waste, including hazardous wastes, will be disposed of and recycled in line with Ukrainian legislations through licensed companies. Waste batteries, plastic, cardboard, metal will be recycled by municipal’s recycling companies.  

 Community Health and Safety

Construction safety measures, to protect the public, will be implemented at the construction sites, including use of barricading and other access control measures near construction areas, traffic safety, control of construction vehicles, safe pedestrian crossings, first aid, clear demarcation and proper illumination of these areas and provision of safety information to citizens and visitors. As indicated under PS1, the construction contractors will be required to include the relevant mitigations aligned with IFC’s Performance Standard 4 within the construction E&S management plans.

Trolley buses will meet the requirements of Ukrainian legislation, including (but not limited to) the Traffic Rules, approved by the Cabinet of Ministers of Ukraine of October 10, 2001 No. 1306 as well as NPAOP 60.2-1.01-06 Rules for Occupational Safety in Urban Electric Transport, where there are requirements including audio announcement systems, breaks, mandatory inspections, parking and storage requirements, life and fire safety, security measures for electricity system, requirements that relate to passengers with disability or requiring special assistance, emergency exits, ventilation hatches and windows. Such requirements are consistent with relevant European standards.

Based on information provided, the operational average speed of the autonomous trolleybuses will be 20-50 km/h. LET has an internal documented procedure in place for safe driving, including speed restriction policy.

LAD is responsible from traffic management system and monitors and controls traffic with closed-circuit cameras. LET, in coordination with LAD, will adopt security measures (e.g. cameras), to mitigate risks of sexual harassment and gender-based violence (“GBV”).

Security Personnel

Unarmed security personnel are present, at the head offices, depots and at the end-stations to control access. There will be no armed security personnel involved in the project.  

 Stakeholder Engagement / Information Disclosure / Consultation

The City discloses information on its projects on its website (https://city-adm.lviv.ua/), and for projects with potentially significant impacts it follows a public hearing process involving stakeholders, including local community leaders, civil society, media representatives, and interested parties.

Given the limited risks and impacts associated with the project, no public hearing was required to be conducted.

This Environmental and Social Review Summary and related Action Plan will be disclosed by the City as described at the “Local Access of Project Documentation” section below. The social impact assessment study included consultation with the affected stakeholders, including business owners, private bus operator companies and their drivers, and is also disclosed together with this ESRS (please refer to Social Impact Assessment).

External Communications and Grievance Mechanisms

The City’s external grievance mechanism includes use of a 7/24 free call line (“1580”), social networks and a mobile application. In addition, the City has seven service points where complaints can be registered. The call line and social network allow for anonymous reporting. All grievances received are processed by the City’s compliance department. The grievances are then forwarded to the related municipal enterprise. The system allows for classification of the complaints per specific topics, including GBV / sexual harassment, and covers instances of GBV / harassment within the public transportation system.

IFC’s review found that the grievance mechanism implemented by the City is effective, concerns are adequately recorded and analyzed, related actions are defined and implemented where feedback is provided to the complaints by emails, phone calls or through face to face interactions. The same system will be in place for the project, including the treatment of complaints associated with the construction phase. As part of ESAP item # 6, LET will require contractors to implement appropriate external (community) grievance mechanism and will monitor and report on grievances (especially repeat grievances) raised and how they have been resolved (timeline).   

 Contact Person: Ms.Iryna Ivanyshyn 

Company Name Lviv Municipal Enterprise “ Lvivelectrotrans “

Address: 2, Sakharova Str., Room 14, Lviv, 79026, Ukraine 

Email: ivanyshyn.i@ukr.net with CC to secretary.let@gmail.com

Phone: +38032-238-68-50

Facsimile: n/a