Policy and Environmental and Social Management System:

Cube has developed and implements an EHS policy and a corporate ESMS compliant with IFC PS requirements that covers all operations of Cube and incorporates procedures for: impact and risk identification; implementation of screening criteria and decision tree; third-party ESDD of road assets to be acquired; development, implementation, monitoring of management programs; periodic third-party audits of the implementation of corrective action plans based on ESDD findings; responsibility and resource allocation; contractor oversight and contractor environmental, health, safety and social (EHSS) organization; stakeholder communication and consultation; internal and annual external audits of the ESMS; management review and reporting to the Board of Directors.

GAEPL, the Project SPV has developed and is in the process of implementing a project specific ESMS (aligned with the corporate ESMS) including amongst others; management program for identified risks and impacts; an appropriate E&S organization; procedures for stakeholder engagement and grievance redress; emergency response procedures; legal register and compliance monitoring procedure; EHSS training procedures; monitoring plan aligned with the management program and incorporating GIIP provisions; reporting; procedures for periodic internal and corporate audits; and management review. GAEPL has adopted O&M manual developed by Cube Highways which includes procedures for highway operations, inspection, safety management, road asset management, over environmental management aspects such as carriageway waste management, oil/ chemical spill contingency plan and storm water management plan.

Identification of Risks and Impacts and Management Programs:

Cube carries out third-party ESDDs for all road assets prior to acquisition to identify the key risks and impacts associated with the project and key gaps with respect to IFC’s PSs. In line with its corporate ESMS, in February 2019, Cube carried out a third-party ESDD to identify the key risks and impacts associated with the project and to identify key gaps with respect to IFC’s PS. The due diligence involved documentation review, site assessment, right-of-way (RoW) survey and stakeholder consultations. In addition, a rapid enumeration of encroachments along the road was undertaken with photographic documentation, which collected approximate size of affected structures, nature of construction and its usage. This survey formed the basis for identifying encroachment and impacted structures at the ESIA stage.

For GAEPL, a PS-aligned E&S Impact Assessment (ESIA) was undertaken, which included baseline surveys and studies covering ambient air quality, soil quality, surface and groundwater quality, noise, and ecological aspects were carried out, and socio-economic baseline studies were conducted in the project area of influence and community consultations, through focused group discussions, key informant interviews and individual and household level interview. Resettlement Action Plan (RAP) was prepared (copy of reports is disclosed) and included a survey of all the structures affected by the road expansion and the households impacted and the development of an entitlement framework based on: (i) identification of gaps between IFC PS5 and government-managed land acquisition and rehabilitation process for the re-alignment through review of land acquisition process, legacy issues and compensation payment details to confirm Project Affected Persons/Families (PAPs/PAFs); and (ii) consultations with the PAPs and PAFs and other community members to understand their views and obtain their input regarding social issues and livelihood restoration options. The GAEPL RAP is currently being implemented.

As per the corporate ESMS, Cube contractually requires its operations and maintenance (O&M) contractors to abide with the EHS requirements included in the applicable and relevant Standard Operating Procedures (SOPs), which are part of the ESMS and to adhere to applicable E&S legal/national requirements and IFC PS requirements. For GAEPL, the contractual obligations included the requirement for EPC contractor to develop detailed E&S management plans using framework management plans as reference (included as part of the ESIA) prior to start of construction, to abide with the EHS requirements and applicable social and environmental legal/national requirements and fully implement EHSS measures defined in the project ESIA, ESMP and RAP/LEP.

GAEPL is implementing the contractual requirement for EPC contractor to develop a HSE plan prior to start of construction including the following amongst others: (i) management system for HSE implementation; (ii) organization structure; (iii) training and capacity building of its own staff and sub-contractor staff; (iv) emergency preparedness and response system; (v) monitoring and review; (v) reporting; (vi) stakeholder engagement; and (vii) grievance redressal mechanism aligned with Cube’s existing grievance redressal mechanism.

Organizational Capacity and Competency:

Cube has a 7-member qualified and dedicated E&S team in place at the corporate level, who are responsible . for oversight of all roads in the portfolio. The corporate team oversees pre-acquisition screening, ESMS implementation for roads where IFC has an investment and follow up on implementation of the ESDD action plans. Cube’s E&S team is supported by external third-party consultants who are involved in undertaking: (a) screening for presence of critical habitat and Indigenous Peoples (if identified as an issue based on early stage review  of every new potential acquisition); (b) ESDDs against IFC PS requirements (prior to acquisition); (c) E&S assessments as required (ESIA, RAP, LEP); (d) periodic E&S/ESMS audits for assets financed by IFC; and (e) safety audits. The same team at the corporate level will continue to be responsible for E&S management of the road projects which will be housed within the InvIT, including those financed by IFC.

EHSS aspects of the GAEPL road are being monitored by Cube’s E&S inhouse team (as the site is in close proximity) and a dedicated EHSS manger from Cube Corporate office has been deployed. . In addition, the EPC Contractor, L & T has a dedicated EHS In-Charge who is responsible for EHS performance across the road and is supported by 3 EHS officers, overseeing three road segments. RAP-LEP Implementation Agency (TILA Consultants) has been hired since June 2022 and are leading the implementation on the ground.

Emergency Preparedness and Response:

Cube ensures that an on-site emergency response plan (ERP) is prepared for each road asset and is aligned with PSs. The ERP is included as part of the OHS and Environment management plan within the ESMS. As required in corporate ESMS, GAEPL has developed and implements an ERP which builds the relevant emergency response requirements included in corporate ESMS and covering various scenarios and types of emergencies such as natural disasters (e.g., floods) and specific hazards like fire, chemical spill, and other environmental pollution incidents.

Monitoring and Review:

Cube’s ESMS has adequate procedures for monitoring the implementation of E&S mitigation measures and for monitoring the E&S performance of its road assets on an ongoing basis. There is provision for biannual internal audits and an annual external audit of the ESMS; management review and EHSS reporting to the Board of Directors. Annual ESMS audits through third-party consultant would continue to be undertaken in-line with corporate ESMS. In addition, an internal audit review of HR and payroll is conducted through yearly internal audit (conducted through third party engaged by Cube corporate strategy team.)

During the construction phase, GAEPL is required to conduct get bi-annual third-party EHSS audits to monitor and report on EPC contractor and subcontractor compliance with EPC contract provisions covering aspects of construction phase environmental mitigation measures, compliance with labor laws, working conditions and terms of employment, occupational health and safety prevention and control, and other applicable project E&S requirements (ESAP#1). First EHSS audit was conducted in November’22 and subsequent audits are to be conducted on bi-annual basis. 

Environmental monitoring during the operation phase will be aligned with the permit requirements and will be undertaken for ambient air quality, stack emissions from generator sets at toll plazas, ambient noise levels and water quality. GAEPL has developed a detailed EHSS monitoring plan covering aspects such as OHS, road safety, noise monitoring, implementation of resettlement and livelihood restoration, stakeholder consultations and community and employee grievances, in addition to all monitoring required under the permit.

As part of its ESMS, GAEPL has developed resource efficiency management program which includes reuse of water and treated wastewater where possible; reuse of materials in maintenance and resurfacing activity; implementation of measures to monitor energy consumption; installation of solar panels and energy efficient lighting and implementation of programs to reduce specific energy consumption.

Specific SOPs have been developed by Cube as part of ESMS, implementing E&S GIIP for major maintenance activities (including environmental management of hot mix plant and construction camps), optimization of water consumption, energy conservation, vegetation management, greenhouse gas (GHG) accounting and reduction, solid and hazardous waste management and pesticide use and management.

Cube is in the process of estimating GHG estimation for GAEPL (Scope 1, 2 and 3).

Noise modelling was undertaken as part of ESIA study for to assess the incremental increase in noise levels for expansion from existing four to six lanes. Based on predominant land use, road was divided into four sections and sensitive receptors on either side of the road under expansion were identified. Noise modelling also included greenfield Khurja realignment which is largely passing through agricultural area and incremental change in noise level was assessed to be less than 0.3 dB (A). Noise measurements were conducted within the area of influence of projected traffic induced noise propagation along the project road and baseline noise levels (Leq day (0600 to 2200 hours) and Leq night (2200 to 0600 hours) in dB(A)) were measured for a period of 24 hours during working and non-working days. Projected traffic volumes and average speeds of the vehicles were used as input for scenarios for years 2020, 2025, 2030, 2035 and 2040 without and with mitigations in place. Incremental average noise level over the night-time period at all receptor locations was assessed to be less than 3 dBA for the projected years 2025 onwards. Noise monitoring will be undertaken and appropriate mitigation measures will be implemented as needed. The grievance redressal mechanism will provide a channel for affected parties to raise concerns if any related to noise aspects.

Emissions to air are expected from hot mix plant, batching plant and operations of [back up] DG sets at toll plazas and in camps. While the operation of hot mix plant and batching plant will be temporary only during maintenance activity and DG set operation is intermittent, GAEPL will ensure that the emission control meet GIIP, including applicable and relevant sections of the WBG EHS Guidelines and implement mitigation measures as included in the ESMP (part of ESIA).

During construction phase, about 6.45 kiloliters per day (KLD) of drinking water and 10 KLD for civil works is required. The construction related water is being sourced through third party vendors, with related compliance met. Sewage generated from toilets at construction camps is managed through septic tanks.

Water requirement during operations will be limited to drinking, sanitation and horticultural activities. Toll plazas will be provided with septic tanks for collection of sewage generated. Any equipment and vehicle maintenance areas will be appropriately paved and have provisions for spill containment.

Cube developed and implements SOPs on solid and hazardous waste management which are part of the ESMS. Solid waste generated during the construction phase from the camps comprises of food waste and recyclables such as packaging material. Hazardous waste, such as used oil, empty paint cans, or contaminated cotton rags, are stored and disposed of through licensed contractors. During operations, solid waste will be primarily generated from toll plaza and rest areas. In case of maintenance activities, the bituminous layer would be excavated during the repair of pavements and road sections and will be required to be disposed of. Hazardous waste will be stored at toll plaza and disposed of as per existing regulations as is followed by Cube for all road assets. Any e-waste (damaged lights, electronics from toll plaza, etc.) will be recycled through authorized recyclers. Areas where fuels or other hazardous materials are stored will be constructed within secondary containment structures with access control and signage. Waste management plan developed as part of ESIA will be implemented by GAEPL.

Project road has flat topography with gradual decrease in elevation and there are no major water bodies along the project road. The topography may be altered slightly due to the widening of road but these changes are envisaged to be small and restricted to the immediate vicinity of the existing road. The ESIA includes mitigation measures for stormwater management, and which is being implemented by GAEPL such that no change in natural drainage flow and continued use of existing micro drainage channels patterns. In addition to existing culverts and bridges, new cross drainage structures shall be proposed in the project design to take care of the increased run off and maintain the existing drainage of the project AoI. This will be confirmed as part of third party EHSS audit during construction phase (ESAP#1). During operation phase, GAEPL will develop and implement drainage inspection, repair and periodic maintenance procedures as part of the ESMS. Surface runoff from open maintenance areas will be separately collected and treated through an oil/water separator. This will be further confirmed as part of ESMS audits to be conducted on annual basis (included as part of ESMS to be adopted by GAEPL).

At the time of acquisition, Cube undertakes historical accident data analysis with the identification of blackspot/critical locations, deviations from specifications in safety features and recommendations for future implementation. During O&M stage, Cube undertakes monthly accident data trend monitoring, root cause analysis of accident trend and identification of mitigation measures, monthly compliance of routine maintenance related issues, awareness campaigns with local authorities and villages/towns along the road, road furniture implementation (traffic lights, sign-posts, traffic signs, guardrails, marker posts, fences, reflectors, etc.) and quarterly safety training to the O&M teams.

Total truck movements per day during the construction phase is anticipated to be approx. 360 which can be easily accommodated within the existing traffic load of the highway. While the four-lane road has been constructed in conformity to Indian Road Congress (IRC) standards, maintenance of the road was observed to be in poor condition especially in the first 10 km urban stretch near Ghaziabad. Preliminary third-party safety audit was commissioned by Cube for the road in July 2021 to identify potential unsafe locations/stretches prone to accidents and to identify and recommend measures to improve road safety. As per accident data records available, 344 accidents were recorded in 2016 and 265 in 2017. Total of 531 accidents were reported from Jun’2022 to Apr’2023. Speeding was reported to be the major cause of accidents in all the years for which records are available. A heat map of year wise accidents was developed, identifying 22 accident-prone locations along the road (as per Preliminary Safety audit report dated July 2021).

As included in ESAP#3, GAEPL will carry out a detailed road safety audit, in line with the recommendations provided in the preliminary road safety audit and aligned with International Road Assessment Programme (iRAP) and implement procedures and measures to minimize community health and safety risks, including, among other measures, ensuring safe corridors and crossings for pedestrians, and implementing other accident prevention measures like appropriate speed limits, speed control devices near crossings, appropriate signage, access controls, roadside lay byes, rest areas, and real time warning systems. Safety audit will also cover assessment of all encroachments within the RoW and specific structures at risks because of road traffic and will recommend appropriate mitigation (including if required physical displacement) to be incorporated into the construction plans and identify measures to mitigate safety risks as needed. As part of periodic safety review during road operations, Cube will review the adequacy of these safety measures and make improvements as needed.

While SOS service and emergency contact numbers are displayed at various locations, as indicated, GAEPL will implement an ERP and an automated information system (Highway Traffic Management System) during operations which is being adopted by Cube for its other road projects.

GAEPL will ensure that its operations do not contribute to flooding/ aggravation of any flooding by ensuring that any drains, culverts and cross drainage structures that are within its scope are properly maintained, remain clean and do not impede runoff flows. The procedures for maintenance of drains, culverts and cross drainage structures have been developed as part of the O&M manual. Gender based violence (GBV) though not expressed in much detail during the consultations does pose risks given the context of overall factors such as women’s exclusion in key decision making in the family, lower educational attainment, rising cases of child marriages, girls dropping out of school, and lower female worker participation rates. Instances of harassment of women when they are crossing the highway or walking along it were brought up in several discussions.

As included in ESAP#4, GAEPL will implement a Gender Action Plan that identifies the key risks to women as well as opportunities for their increased participation in project benefits. This Gender Action Plan will also guide the mitigation measures on gender aspects during RAP and LEP implementation. Grievances on GBV and sexual harassment will be channelized through the Grievance Redressal Mechanism (GRM). GAEPL will train the project HR team and site teams as well as contractors on handling gender issues with a Survivor Centric approach. Code of conducts for drivers would be developed and the contractor management plan would include designated rest areas for trucks and information on the grievance management (during construction phase).

The security at toll plazas is contracted out to two agencies. Altogether at both plazas, there are 44 security personnel along with eight armed guards. Until now, there have reportedly been no incidents involving security personnel. GAEPL has developed and implements a security management plan to screen the records of security personnel employed; define objectives and permissible actions for security personnel; ensure security personnel are trained in avoidance of abusive conduct, human rights, gender based violence and sexual harassment and the use of firearms; record, investigates and ensures corrective actions are implemented in relation to security incidents; and ensures that complaints against security personnel are investigated and appropriate disciplinary actions are implemented. Security management plan also covers engagement with public security forces in the context of eviction of encroachers (if any) to prevent the used of forced evictions and related violence.

The company uses RoadAID (http://www.roadaid.in/ - an app developed for tracking road safety-related aspects) providing its teams with a centralized platform allowing to report and monitor O&M activities in real-time and enabling to perform analytics to identify maintenance defaults, accelerate decision making for maintenance and maintain permanent record of activities. The app helps in maintaining oversight on contractor activities along the highway alignment for routine maintenance and it is loaded on handsets/ mobile phones and provided to each supervisor (of the contractor and SPV). Cube’s grievance mechanism is available for stakeholders like road users and communities along the road to file grievances. A review of some the grievance data shows that stakeholders were using the grievance register at the toll plazas as well as the online interface to register grievances related to delays at the toll plaza as well as occasional traffic congestions, among others.

Cube conducts awareness campaigns with local authorities and villages/towns along the road to promote safe driving behavior. Going forward, GAEPL will also focus its awareness campaign on providing awareness to informal settlers/users from encroaching the RoW and making them aware of the removal procedures and grievance redressal mechanism in place.

The ESMS has procedures in accordance with PS 8 provisions to mitigate any adverse impacts on cultural heritage. For GAEPL, the expansion of the road to six lanes will require removal of 5-10 cultural structures including religious and non-religious structures, which will be either fully relocated or partially removed in consultation with affected communities. As included in ESAP#6, GAEPL will prepare a Cultural Heritage Management Plan which will specify: (a) identification and details of structures that are to be relocated; (b) documentation of process for relocation; (c) consultation with users of these structures prior to removal; (d) gaps with PS8 provisions and identification of feasible retroactive corrective action (if any); and (e) a process for future relocation of such structures that meets the requirements of PS8. Feasible corrective actions will be undertaken by SPV in accordance with local law and guidance from the relevant authorities.

As part of the ESMS, a SOP on community development, stakeholder engagement and community grievance redressal has been developed and is implemented for each of the road assets. This includes identification of stakeholders, overview of stakeholder engagement methods, details of information to be disclosed to the community as part of stakeholder consultations, details of community development activities and community grievance mechanism (GM) aligned with PS requirements.

Cube has an active Cube Roots Foundation (an independent not for profit society) that undertakes Corporate Social Responsibility and other charitable activities as a part of its engagement with the communities where it operates. Major initiatives include raising awareness on road safety, water conservation, afforestation, using renewable energy for offices and lighting as well as skill development.

During the ESIA consultation process, GAEPL and its consultants conducted various activities as part of the development of the public consultation program to determine the relevant stakeholders. Consultations carried out included interviews and surveys of families, consultations at the village and district levels and focus group discussions with women, farmer groups, shop-owners and other commercial establishments impacted by the road widening and development of the new bypass.

There appears to be no overt opposition to the six laning of the road. The ESIA team carried out the consultations and engagement with no material disruption from the community, except for a few households refusing to be surveyed. However, the local community did raise concerns, and these are being addressed through the various mitigation measures and management plans. Most of the concerns of landowners were around the compensation values, while those of informal settlers were around livelihood disruption. The 30 families who will need to be relocated were concerned about alternate housing as well as the ability to continue with their livelihoods, as most of them were dependent on the roadside location for their clientele. Women were concerned about safety and security with increased traffic and were looking at the initiatives from the project to improve lighting at bus stops and safer and accessible road crossings. Other community concerns revolved around traffic and pedestrian safety, bypass impacting local traffic and deterioration of air quality and drainage. The ESIA and RAP have been disclosed and consultation on the management plans held with the affected households.

A detailed stakeholder engagement plan, grievance mechanism and a gender action plan have been prepared to address stakeholder concerns as well as to provide avenues to raise grievances as the project develops into operations. The RAP and LEP provide a detailed implementation plan and sequence of events, as well as guidance on how stakeholder engagement and grievance management will need to be undertaken during RAP and LEP implementation and in future for the project. These are being implemented by the RAP implementation agency as well as by the EPC contractor, who have been given orientation by the Cube team before their mobilized at site, The Cube team oversees the overall engagement process and frequently participates at key events, including engagement with the Lohar community on relocation options and implementation progress.

The company will make publicly available this ESRS and ESAP and will keep a copy available at SPV office together with executive summary of ESIA/RAP in vernacular language . 

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

Point of Contact: Dr. Ashok Sharma

Title: Chief E&S Officer

Telephone Number: +91 (0120) 4868300

Email: ashok.sharma@cubehighways.com

Mailing Address: World Trade Tower (WTT), Unit No.1901, 19th Floor, Tower B, NOIDA-201301 (UP)

INDIA

Website: www.cubehighways.com