Environmental Management Plan for sub-project in SREMSKA ... · to the site of the proposed...

Draft Document v 6.0 Prepared by: Srdjan Susic, Environmental consultant

Belgrade, 6 March 2019

INCLUSIVE EARLY CHILDHOOD EDUCATION AND CARE

(ECEC) PROJECT

Environmental Management Plan for sub-project in

SREMSKA MITROVICA

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TABLE OF CONTENTS TABLE OF CONTENTS ....................................................................................................................................... 2 LIST OF ABBREVIATIONS ................................................................................................................................. 3 1. SUMMARY ............................................................................................................................................. 4 2. BACKGROUND INFORMATION AND GENERAL DIAGNOSTIC ASSESSMENT ............................................. 7

COUNTRY BACKGROUND ................................................................................................................................... 8 TRIGGERED WORLD BANK SAFEGUARD PROCEDURES ................................................................................................ 8 PROJECT DESCRIPTION ...................................................................................................................................... 8

3. APPROACH AND METHODOLOGY .......................................................................................................... 9 4. SUB-PROJECT DESCRIPTION ................................................................................................................. 10

BROADER LOCATION ....................................................................................................................................... 10 SITE DESCRIPTION .......................................................................................................................................... 11 PLANNED INTERVENTIONS ................................................................................................................................ 11 RELEVANT CONSIDERATIONS............................................................................................................................. 18

5. ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES .......................................................................... 20 6. CLAUSES FOR ENVIRONMENTALLY SOUND CIVIL WORKS CONTRACTS ................................................. 20 7. IMPLEMENTATION ARRANGEMENTS ................................................................................................... 20 8. MONITORING ARRANGEMENTS ........................................................................................................... 21 9. REPORTING ARRANGEMENTS .............................................................................................................. 22 10. ENVIRONMENTAL IMPACT ASSESSMENT REPORT ........................................................................... 23 11. ENVIRONMENTAL MITIGATION PLAN .............................................................................................. 25 12. ENVIRONMENTAL MONITORING PLAN ............................................................................................ 36 13. REPORT ON PUBLIC CONSULTATIONS.............................................................................................. 41 14. ANNEXES ......................................................................................................................................... 44

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LIST OF ABBREVIATIONS ACM – Asbestos containing material EA – Environmental Assessment ECD – Early Childhood Development ECEC – Early Childhood Education and Care EIA – Environmental Impact Assessment ESMFD - Environmental and Social Management Framework Document EMP – Environmental Management Plan HEPA – High-efficiency particulate arrestance INP - Institute for Nature Protection of Serbia IPCM - Institute for Protection of Cultural Monuments of Serbia MEP – Ministry of Environmental Protection MESTD – Ministry of Education, Science and Technological Development of Serbia NGO – Non-Governmental Organization NOx – nitrous oxides OH&S – Operational Health and Safety OP – Operational Procedure PAH – polycyclic aromatic hydrocarbons PIU Project Implementation Unit PM – particulate matter RS – Republic of Serbia WB – World Bank

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1. SUMMARY According to the Environmental and Social Management Framework Document for the INCLUSIVE EARLY CHILDHOOD EDUCATION AND CARE PROJECT (ECEC) and the World Bank Environmental Safeguard Operational Procedure 4.0.1, the Bank requires Environmental Assessment of sub-projects proposed to be financed with a Bank loan in order to ensure that the projects are environmentally sound and apply sustainable decision-making processes. This Project is foreseen to expand access to quality ECEC services, in particular for children from socially disadvantaged backgrounds. This Project is expected to encompass four main components:

i. Component 1 - Increasing the supply of ECEC services (approximately 35 million USD) ii. Component 2: Ensuring the Quality of Inclusive ECEC Services (approximately 5 million

USD) iii. Component 3: Outreach to parents and young children (approximately 10 million USD) iv. Component 4 - Project Management and Monitoring and Evaluation (approximately 4

million USD)

This Environmental Management Plan (EMP) is prepared in order to identify adverse environmental impacts of the sub-project located in Sremska Mitrovica, including site-specific impacts that could be overcome with proposed mitigation measures. This EMP ensures compliance relevant national legislation and WB requirements related to environmental impact assessment procedures and physical cultural resources, and is in line with the Environmental and Social Management Framework document that was completed and subject to public consultations in Belgrade on November 4, 2016. In addition, this EMP is based and provides compliance with, relevant WB OPs that provide general policies, guidelines, codes of practice and procedures to be integrated into the implementation of all sub-projects considered for financing. This Plan consists of 14 chapters dealing with specific issues, as follows. Chapter 2. Background information and general diagnostic assessment. This Chapter provides an overview of basic country information and the current environmental institutional architecture in the Republic of Serbia. It identifies the Ministry of Environmental Protection (MEP), as the key institution in Republic of Serbia responsible for formulation and implementation of environmental policy matters, while other institutions, such as the Institute for Nature Protection of Serbia (INP), the Institute for Protection of Cultural Monuments of the Republic of Serbia (IPCM) and the administrations of local municipalities address additional aspects of environmental management in the country. Concerning national environmental legal and environmental impact assessment frameworks in the Republic of Serbia, contained in the legislative system of the Republic of Serbia, as regulated by the Law on Environmental Impact Assessments, preparation of an Environmental Impact Assessment is not required for activities foreseen by the proposed sub-project (improving and extending the existing ECD infrastructure and construction of the new ECD infrastructure) in Sremska Mitrovica. In addition, this Chapter also addresses the triggered World Bank safeguard procedures, ECEC project falls into the category B concerning OP/BP 4.01 ENVIRONMENTAL ASSESSMENT, with its potential adverse environmental impacts on human population or environmentally important areas-including wetlands, forests, grasslands, or other natural habitats - are site specific, with only a few/if any, irreversible. This also applies to the proposed sub-project in Sremska Mitrovica. Finally, this Chapter provides detailed information about the ECEC project as a whole. Chapter 3. Approach and methodology, discusses the developed and agreed methodology for developing site-specific EMPs to include primary data collection and analysis, mapping and analysis of secondary data through a desk study concerning publicly available information, including data on the location of the proposed sub-project. This methodology is entirely consistent with ESMF document developed for the Project.

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Chapter 4. Sub-project description, provides an in-depth description of the planned activities for the sub-project located in Sremska Mitrovica and is planned to be implemented under Component 1 of ECEC project. The sub-project is located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica, in the cadastral land plot no. 1032. The land plot in question has an area of 2509 m2, and is registered in the Cadaster of immovable properties as public property with title registered in the name of City Sremska Mitrovica. This land plot and adjacent land plot no. 1031 are placed under the previous protection categorized as "Conglomeration of a memorial character". The land plot adjacent to the site of the proposed sub-project is registered as property of the Serbian Orthodox Church and contains the church of Saint Archangel Michael, registered and protected as a cultural monument of great importance. Currently, the site of this sub-project contains an existing kindergarten facility built in 1970's, with the capacity that does not meet the needs of this pre-school institution.. This building is located along the construction line parallel to the street, measuring approximately 43.5x14.5m, with a gross surface area of 532 m2. Within the facility there are six classrooms for children, sanitary facilities, a small kitchen and a room for education and other staff. There is one underground fuel tank and one underground septic tank in close proximity to the existing building. Both of these tanks are currently out of use, decommissioned and are not visibly marked. Both tanks are in relatively poor condition and it is not known if they leak. The exact volume of both tanks is not known. The contents of both tanks was not checked. The building has only ground floor and is constructed of pre-fabricated gypsum elements on the inside (divisive walls), asbestos panels on the facade and the roof constructed of asbestos-containing corrugated elements. According to the official Project for Building Permit, the existing building is planned to be demolished at a certain future stage. Based on the information received from the PIU staff at the meeting held in MoESDT on 1 August 2018, in spite of the plans laid down in the Project for Building Permit, this sub-project envisages reconstruction of the existing facility and construction of a new ECD facility in its immediate proximity. According to the presented information, demolition of the existing infrastructure is not planned and the existing building will be reconstructed and connected to the new building. The conceptual solution for the new facility foresees a new kindergarten facility with a ground floor and one additional floor. The new building is located in parallel with the existing one, along the construction line in the northwest part of the plot. In this way, the southeast orientation of the children's rooms are turned to the inner courtyard. With the existing facility, the object is physically connected with a closed corridor that connects the existing building with the dining room and has exits to the yard. In this way, minimal intervention on the existing kindergarten facility was achieved, and a fusionary connection between the old and the new part was achieved. The location of the proposed sub-project currently possesses major infrastructure connections: drinking water, fire hydrants, waste collection and disposal service; electric lighting installation; telephone installations and city’s gas pipeline. Since the construction site is located in the existing and operational urbanized area, the environmental impacts during execution of civil works will be limited to the ones which are common to all construction activities – air, dust and noise pollution, vibrations and local soil and possibly groundwater disturbance. Most of the negative impacts will be felt only temporarily (during the execution of works) and will be limited in scope. In this regard, it is important to ensure maximum protection of facility users during the reconstruction and construction works on site, by implementing adequate measures. Chapter 6. Environmental management responsibilities, identifies and discusses responsibilities of relevant parties (MOESTD, ECEC PIU, contractors, supervisors and others) to address each potential environmental and other impacts identified by the EMP and relevant mitigation measures. Chapter 7. Clauses for environmentally sound civil works contracts, states that the most environmental impacts during the re-construction/construction phase will be possibly mitigated by including appropriate clauses into the civil works contracts. This Chapter concludes that construction

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and other civil works contracts have to include this EMP with its Environmental Mitigation Plan and Environmental Monitoring Plan in a form to be fully binding to the contractors. Chapter 8. Implementation arrangements, states that MOESTD will be responsible for overseeing the overall project implementation. Project management functions and day to day operations are be the responsibility of MOESTD and the ECEC Project Implementation Unit (PIU). PIU within MOESTD will also coordinate the overall working plan related to this sub-project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks. During the operational phase, when the facilities envisaged in this sub-project are constructed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment). Chapter 9. Monitoring arrangements, ECEC project will be monitored by MOESTD and the PIU. Information and data collected at each of the implementation agencies will be fed into overall monitoring and evaluation framework. MOESTD will oversee M&E activities regularly through project reports, evaluate results achieved and guide the implementing agencies on corrective management actions. The main responsibility for implementation of EMP-related measures lays with the contractor, who needs to take into account and apply on a daily basis all proposed preventive and mitigation measures. The designated supervisory body needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor, and issue corrective instructions and/or orders, if necessary, in conjunction with the investor and ECEC PIU. The main inspection responsibility is, according to national legislation, given to the municipal staff (environmental Inspectors, communal inspectors, health and safety inspectors, building inspectors) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP), in accordance with the relevant legislation in Serbia. The Contractor is obliged to perform all activities defined within the Environmental Monitoring Plan of this EMP for which the Contractor is contracted. The designated supervisory body is responsible to monitor all construction activities, including environmental protection during project implementation. Chapter 10. Reporting arrangements, provides detailed information on four separate monitoring lines and general reporting requirements: Tier 1. Contractor to Supervisor-The Contractor will prepare its compliance reports in respect to implementation of this EMP as EMP Quarterly Progress Reports and submit these to the designated supervisory body. These reports will be submitted in both Serbian and English languages, in hard copy and electronic versions. These reports will document the implemented environmental mitigation and protection measures, together with prescribed monitoring activities carried out during that quarter’s reporting period. The Contractor will take care of the quality of the environment according to the mitigation and monitoring plan, which are parts of this EMP. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation. Tier 2. Supervisor to Investor-The designated supervisory body will submit EMP Quarterly Progress Reports and the mid-term Environmental Report to the investor (municipality). Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the designated supervisory body will forward these reports to the investor (municipality) not later than 3 working days after the intial submission of the reports by the contrctor. Tier 3. Investor to ECEC PIU/MoESTD-The investor (municipality) will submit EMP Quarterly Progress Reports and and the mid-term Environmental Report to ECEC PIU/MoESTD. Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the investor will forward these reports to ECEC PIU not later than 3 working days after the intial submission of the reports by the contrctor. Tier 4. ECEC PIU to WB-ECEC PIU shall provide at least semi-annual reports to MOESTD

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and WB, as layed out in the Project Operations Manual and Project Apppraisal Document, regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed. Monitoring and compliance in accordance with ESMF and this site-specific EMP, during project implementation will be undertaken by ECEC PIU (environmental specialist), and reported in writing to the Bank at least once during the lifetime of this sub-project. For all reporting, in case of any kind of accident or endangerment of environment happens and/or in case of health and safety related incidents, including but not limited to serious injury at work, loss of limb or death due to site related activities, reporting to ECEC PIU and WB will be immediate. This reporting will be done from Tier 1 to Tier 4 immediately and in its totality not exceeding 24 hours following the incident. The Contractor has the final responsibility for reporting and addressing the incidents to the designated supervisory body and the relevant authorities of the Republic of Serbia. ECEC PIU has the final responsibility for reporting and addressing the incidents to WB. Chapter 11. Environmental Impact Assessment Report, provides a diagnostic overview of main parameters assessed in the physical/natural environment (groundwater, landscape and visual environment, existing or future land use and water and energy resources) and public hazardous elements (air quality, water quality, soil pollution, waste, noise and vibrations, biodiversity). All potential impacts examined are assessed to be negative, their magnitude is confined to the localized area of their appearance and their extent is localized to the sub-project site. Most of the identified impacts occur during the construction phase of this sub-project, their duration is mainly long and they are all reversible. The likelihood of identified impacts is assessed as unlikely, apart from the likelihood of impacts arising from waste generation and management, that is deemed certain. Significance of almost of identified impacts is minor, apart from impacts arising from waste generation and management, that is deemed significant. Chapters 12. Environmental mitigation plan and 13. Environmental monitoring plan provide a detailed and specific overview of environmental risks associated with this sub-project and adequate mitigation measures, providing information on the responsibility of different stakeholders in implementing this Plan and safeguarding the environment in the sub-project operational area. Main identified risk areas are possible adverse environmental, health and safety impacts due to poor design and planning, inadequate application of EMP due to weak linkages of EMP with other contract documents, possible adverse environmental, health and safety impacts due to absence or non-observance of relevant procedures, Possible adverse environmental and health effects related to OH&S issues, water and soil pollution, waste generation, noise pollution and air pollution. Chapter 14. Report on public consultations, provides the proofs concerning public disclosure obligations under ECEC ESMF, list of participants of public consultations and minutes from the public consultation meeting.

2. BACKGROUND INFORMATION and GENERAL DIAGNOSTIC ASSESSMENT This Environmental Management Plan (EMP) is prepared in order to identify adverse environmental impacts of the sub-project located in Sremska Mitrovica, including site-specific impacts that could be overcome with proposed mitigation measures. This EMP ensures compliance with relevant national legislation and WB requirements related to environmental impact assessment procedures and physical cultural resources and is in line with the Environmental and Social Management Framework document1 that was completed and subject to public consultations in Belgrade on November 4, 2016. 1 ESMF document can be accessed here: http://www.mpn.gov.rs/wp-content/uploads/2016/11/ESMF-ENG-2.pdf

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In addition, this EMP is based and provides compliance with, relevant WB OPs that provide general policies, guidelines, codes of practice and procedures to be integrated into the implementation of all sub-projects considered for financing. Country Background Ministry of Environmental Protection (MEP), is the key institution in Republic of Serbia responsible for formulation and implementation of environmental policy matters. Other aspects of environmental management are addressed by other institutions, such as the Institute for Nature Protection of Serbia (INP), the Institute for Protection of Cultural Monuments of the Republic of Serbia (IPCM) and the administrations of local municipalities. Concerning national environmental legal and environmental impact assessment frameworks in the Republic of Serbia, contained in the legislative system of the Republic of Serbia, as regulated by the Law on Environmental Impact Assessments, , preparation of an Environmental Impact Assessment is not required for activities foreseen by the proposed sub-project (improving and extending the existing ECD infrastructure and construction of the new ECD infrastructure) in Sremska Mitrovica. Triggered World Bank safeguard procedures ECEC project falls into the category B concerning OP/BP 4.01 ENVIRONMENTAL ASSESSMENT, as its potential adverse environmental impacts on human population or environmentally important areas-including wetlands, forests, grasslands, or other natural habitats - are site specific, with only a few/if any, irreversible. This applies to the proposed sub-project in Sremska Mitrovica. Further details on classification of the Project, procedure of environmental screening and preparation of the EIA/EMP and other environmental safeguards instruments is available in the Project-specific ESMF2. Concerning World Bank OP/BP 4.11 PHYSICAL CULTURAL RESOURCES, the Sremska Mitrovica sub-project is classified as category B project, as it "will be located in, or in the vicinity of, a physical cultural resources site recognized by competent authorities of the borrower". This EMP identified the likely major physical cultural resources issues and proposes mitigation measures, as presented in Environmental Mitigation Plan in Section 6. Project Description The World Bank approved the project "Inclusive Early Childhood Education and Care" on 21 February 2017 with a total project cost of 50 MUSD to support the Government of the Republic of Serbia to improve access to quality Early Childhood Education and Care (ECEC) services, in particular for children from socially disadvantaged backgrounds. This Project is implemented through four main components:

Component 1: Expanding the supply of preschools spaces (approximately 34 MUSD). The objective of this component is to improve access to preschool services, particularly for disadvantaged children ages 3 to 5.5 years, by increasing the supply of spaces in high quality preschools. This component will finance approximately 17,000 new physical places in both urban and rural areas through a combination of new construction, extension of existing preschools, and repurposing or upgrading of other public buildings such as primary schools (or other buildings available in the municipality). Renovations and repurposing/upgrading will be prioritized in the first steps of project implementation to ensure fast increases in access, while new constructions will require more time. The refurbished and newly constructed environments will be conducive to child-centered education practices and will employ solutions that increase efficiency and flexibility. For all new and rehabilitated preschool institutions, the

2 ESMF document can be accessed here: http://www.mpn.gov.rs/wp-content/uploads/2016/11/ESMF-ENG-2.pdf

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component will also finance furniture, teaching-learning materials, equipment, and playgrounds. I. Municipalities will be identified and prioritized based on a proposed index (Municipality Eligible Index—MEI). The index is based on two dimensions (estimated preschool needs and social and economic characteristics of the municipality). In addition to all the new and upgraded preschools described above, this component would also finance up to five innovative centers to serve as model preschools for training and knowledge sharing purposes. This would be done either through new construction or through renovation of existing preschools that can demonstrate their potential to become such innovative centers. These preschool centers will be linked to teacher training institutions and will be used to share best practices in child-centered pedagogy (including as part of the roll-out of specific training activities under Component 2). They will be equipped as needed for optimal delivery of preschool services and for teacher training purposes. This component will also include training for local architects and engineers to promote efficiency and child-centered pedagogy in construction and renovation designs. Component 2 (with three sub-components): Strengthening the quality of preschool services (approximately USD 5 million). This component would finance activities aiming to build the foundation of a quality preschool system that is characterized by a holistic approach to supporting children’s physical, emotional, cognitive development and wellbeing. Component 3 (with three sub-components): Supporting young children and families (approximately USD 9 million). This sub-component would contribute towards creating effective learning environments that successfully nurture children’s wellbeing and holistic development and thereby maximize their gains from preschool attendance, including in the new or upgraded preschools supported as part of Component 1 but also more broadly. Component 4 (with two Sub-components): Project management, technical assistance, and monitoring and evaluation (approximately USD 2 million).

Activities under the Component 1 of the ECEC Project, including the sub-project in Sremska Mitrovica, are the most likely to create adverse environmental impacts during construction on new sites and/or reconstruction of existing facilities. If negative environmental effects cannot be avoided, mitigation measures, as presented in this EMP, should be applied and monitored during site selection and all subsequent stages of Project planning and implementation. It is less likely that any environmental effects will be effectuated during preparation and implementation of Project components 2 and 3.

3. APPROACH AND METHODOLOGY The Environmental Consultant developed and agreed with the developing site-specific EMPs to include the following:

• Primary data collection and analysis o Interviews and meetings with key stakeholders o Meetings with national and local decision makers o Interviews with other stakeholders relevant for the implementation of the project,

• Mapping and analysis of secondary data through a desk study concenring other publicly available information such as relevant legislation, regulations and standrads of the Republic of Serbia, including data on the location of the proposed sub-project.

The methodology is entirely consistent with ESMF document developed for the Project, as presented above. A written confirmation or a statement from the World Bank, if the EMP deviates from it (and where, in case it deviates) is needed.

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Primary data made available to the consultant are listed in the exhaustive list below:

• Design and technical documentation for Construction Permit, • Construction permit, • Property register database

The primary and secondary data were supplemented by one site visit, field verification and a walk over survey performed on 7 August 2018. Data collection and review activities undertaken by the Environmental Consultant have followed the developed methodology and for the scope of the assignment was deemed to be sufficient. Based on data available the sub-project and its particulars were assessed by using the EA form as provided in ESMFD and presented in Section 5. Information on location and type of works of the proposed sub-project were provided by authorized representatives of PIU and MOESTD. Identification and prioritization were of sub-projects were not part of the scope of this EMP and remain sole and exclusive covenants of PIU and MOESTD.

4. SUB-PROJECT DESCRIPTION

Broader Location

The proposed sub-project is planned to be implemented under Component 1 of ECEC project. It will provide for a significant expansion of pre-school spaces in the preschool facility "Pčelica" located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica. Sremska Mitrovica is a city and the administrative center of the Srem District in the autonomous province of Vojvodina, Republic of Serbia. It is situated on the left bank of the Sava river. As of 2011, the city has a total population of 37,751 inhabitants, while the city administrative area has a population of 79,940 inhabitants. The city of Sremska Mitrovica includes the town of Mačvanska Mitrovica, and several villages. Villages on the northern bank of the river Sava are Bešenovački Prnjavor, Bešenovo, Bosut, Čalma, Divoš, Grgurevci, Jarak, Kuzmin, Laćarak, Ležimir, Manđelos, Martinci, Sremska Rača, Stara Bingula, Šašinci, Šišatovac, Šuljam and Veliki Radinci. Villages on the southern bank of the river Sava, in the region of Mačva, are Noćaj, Radenković, Ravnje, Salaš Noćajski, Zasavica I and Zasavica II. According to the 2011 national census results, the city administrative area has a population of 79,940 inhabitants. Concerning ethnic diversity, most of the settlements in the city have an ethnic Serb majority. Ethnically mixed settlement with relative Serbian majority is Stara Bingula. The main concentration of ethnic minorities is in the urban area of the city. Climate of Sremska Mitrovica is humid continental climate (Köppen-Geiger climate classification)3. The area where Sremska Mitrovica is located is dominated by riverine wetlands, arable areas and flooded forests. This area belongs to the Black Sea catchment area and contains one protected site Zasavica, designated as a Ramsar Site (No.1783), Important Plant Area, Important Bird Area (RS008), and Prime Butterfly Area (40). According to the IUCN management categories, it is a Habitat and Species Management Area, category IV4. 3 Geiger, Rudolf (1961). Überarbeitete Neuausgabe von Geiger, R.: Köppen-Geiger / Klima der Erde. (Wandkarte 1:16 Mill.) – Klett-Perthes, Gotha. 4 The fifth national report to the United Nations Convention on Biological Diversity. 2014. https://www.cbd.int/doc/world/rs/rs-nr-05-en.pdf

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Site Description

The sub-project is located in Laćarak, Skolska street 1, in the broader area of Sremska Mitrovica, in the cadastral land plot no. 1032. The land plot in question has an area of 2509 m2, and is registered in the Cadaster of immovable properties as public property with title registered in the name of City Sremska Mitrovica in accordance with the law. The existing facility is constructed in the 1970's. The aerial view of the land plot is presented in Figure 1. This land plot and adjacent land plot no. 1031 are placed under the previous protection categorized as "Conglomeration of a memorial character". The land plot adjacent to the site of the proposed sub-project is registered as property of the Serbian Orthodox Church and contains the church of Saint Archangel Michael, registered and protected as a cultural monument of great importance.

Figure 1. The aerial view of the land plot1032 for this sub-project. Planned Interventions

Currently, the site of this sub-project contains an existing kindergarten facility, with the capacity that does not meet the needs of this pre-school institution (photograph of the existing facility are presented in Figure 2). The building is located along the construction line parallel to the street, measuring approximately 43.5x14.5m, with a gross surface area of 532 m2. Within the facility there are six classrooms for children, sanitary facilities, a small kitchen and a room for education and other staff. There is one underground fuel tank and one underground septic tank in close proximity to the existing building. Both of these tanks are currently out of use, decommissioned and are not visibly marked, as presented in figures 3 to 5. Both tanks are in relatively poor condition and it is not known if they leak. The exact volume of both tanks is not known. The contents of both tanks was not checked. The building has only ground floor and is constructed of pre-fabricated gypsum elements on the inside (divisive walls), asbestos panels on the facade and the roof constructed of asbestos-containing corrugated elements (photos of these elements are presented Figures 6 to 10).

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Figure 2. The existing kindergarten facility (front view) and the adjacent churchyard (photo S. Susic)

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Figure 3. Approximate position of decommissioned fuel and septic tanks (position of the fuel tank indicated with a red square and of the septic tank with a blue square).

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Figure 4. Decommissioned septic tank in the yard of the facility (photo S. Susic)

Figure 5. Decommissioned heating fuel tank in the yard of the facility (photo S. Susic)

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Figure 6. Asbestos containing roof sheets (photo S. Susic)

Figure 7. Heating pipes exposing a cross-section of an internal wall in the existing facility (photo S. Susic)

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Figure 8. Chipped samples of an internal wall in the existing facility (photo S. Susic)

Figure 9. Air-conditioning shaft exposing a cross-section of an internal wall in the existing facility (gypsum, carton, paint) (photo S. Susic)

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Figure 10. A ventilation shaft with a cross-section of a facade insulation panel containing asbestos (photo S. Susic)

According to the official Project for Building Permit, drafted by Quiddita d.o.o., Belgrade and dated to December 2015 formally provided to the environmental consultant by the ECEC PIU staff, the existing building is planned to be demolished at a certain future stage. It is presumed that facility users (children) would be re-located in this case to other ECD facilities in Sremska Mitrovica during the works. However, based on the information received from the PIU staff at the meeting held in MoESDT on 1 August 2018, this sub-project envisages reconstruction of the existing facility and construction of a new ECD facility in its immediate proximity. No detailed plans or documentation on reconstruction of the existing facility have been provided by PIU or MOESTD during the preparation of this EMP. According to the presented information, demolition of the existing infrastructure will not be conduceted and the existing building will be reconstructed and connected to the new building (as presented in Figure 11). The conceptual solution for the new facility foresees a new kindergarten facility with a ground floor and one additional floor. The new building is located in parallel with the existing one, along the construction line in the northwest part of the plot. In this way, the southeast orientation of the children's rooms are turned to the inner courtyard. With the existing facility, the object is physically connected with a closed corridor that connects the existing building with the dining room and has exits to the yard. In this way, minimal intervention on the existing kindergarten facility was achieved, and a fusionary connection between the old and the new part was achieved. This EMP considers the renovation of the existing facility and construction fot new facility as the planned intervention for this sub-project.

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Figure 11. Rendered appearance of the new and old facilities on site.

Relevant Considerations

The location of the proposed sub-project currently possesses major infrastructure connections: drinking water, fire hydrants, waste collection and disposal service; electric lighting installation; telephone installations and city’s gas pipeline. Since the construction site is located in the existing and operational urbanized area, the environmental impacts during execution of construction works will be limited to the ones which are common to all construction activities – air, dust and noise pollution, vibrations and local soil and possibly groundwater disturbance. Most of the negative impacts will be felt only temporarily (during the execution of works) and will be limited in scope. As this EMP considers the renovation of the existing facility and construction fot new facility as the planned intervention for this sub-project, it is assumed that the functioning structural elements of the existing facility will be kept and that the existing facility will be fully reconstructed. This processes, is expected to generate different waste streams, that should be dealt with as presented in the subsequent sections of this EMP, but it is expected that certain waste streams will contain ACM that will be removed from the existing facility. These will have to be disposed in line with relevant national regulation and ECEC ESMF. In addition, the decomissioned septic tank and fuel tank found on the site, will have to be checked for their contents. In case either of them is found not be empty and dry, their contents should be checked for presences of hazardous chemicals/materials. In case either tank is found to be empty and dry it can bre moved and/or permanently sealed and left in the ground. In case that either tank contains liquids or other materials contaminated with hazardous chemicals/materials, their contents should be treated according to the Waste Management Plan to be developed for this sub-project and the relevant national legislation. In case that contents of either of the tanks is found not to be contaminated with hazardous chemicals/materials, the contents should be pumped out and removed and tanks permanently sealed and left in the ground or removed from the ground. However, application of sound engineering practices and proper site and contract control will contribute to minimize or avoid negative impacts altogether. In order to avoid, prevent or mitigate

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the potential occupational and community health and safety risks, potential environmental impacts on air quality, underground waters, noise disturbance, waste generation and management (particularly waste streams containing asbestos), sound demolition/construction practices implementing several mitigation measures is proposed within the following Environmental Mitigation Plan - EMP (Section 5 of this EMP). In this regard, it is important to ensure maximum protection of facility users during the reconstruction and construction works on site, by implementing adequate measures, such as closing and not using the existing faciity during the renovation and construction works, and/or ensuring that the site of the new facility is fully fenced with solid fence panels, and separate transport and access routes created for the children using the existing facility and new construction site/workers. The main responsibility for implementation of EMP-related measures lays on the Contractor/Sub-contractor, who needs to take into account and applies on daily basis all proposed preventive and mitigation measures. The Site Supervisor needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor/Sub-contractor, and issue corrective instructions and/or orders, if necessary. The main inspection responsibility is, according to national legislation, given to the municipal staff (Environmental Inspector and Communal Inspector) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP). PIU within MOESTD will also coordinate the overall working plan related to this sub/project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks. During the operational phase, when the facilities envisaged in this sub-project are reconstructed and constructed/completed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment).

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5. ENVIRONMENTAL MANAGEMENT RESPONSIBILITIES For each potential impact the EMP identifies proposed mitigation measure(s) and parties responsible for implementing those measures5, i.e.:

• Executing agencies responsible for delivering the action. For this specific sub-project, the contractor/investor will ensure that all necessary agreements and permits are obtained from relevant national and local authorities before the construction works have started.

• Construction contractors will take the responsibility for physical implementation of mitigation measures provided under the EMP during the construction phases according to the Bank’s policies and relevant Serbian legislation.

• The designated supervisory body responsible for supervising the works (performed by the contractor) to ensure that they execute the mitigation measures as planned. Designated supervisory bodies (companies, individual consultants) will be responsible for supervising the timely, proper and reliable implementation of works and measures identified in this EMP, according to the risk mitigation table presented below.

• ECEC PIU holds management responsibility to MOESTD and WB concerning the implementation of this EMP.

• The Contractor will prepare its compliance reports in respect to EMP as Quarterly Progress Reports and submit these to the designated supervision body, that in turn provides these to the investor and ECEC PIU, as described in Sections 9 of this document. The same applies to the Environmental Monitoring and Supervision Contractors for their part of mitigation and environmental monitoring activities. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation6.

• ECEC PIU shall provide semi-annual reports to MOESTD and WB regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed.

6. CLAUSES FOR ENVIRONMENTALLY SOUND CIVIL WORKS CONTRACTS Most environmental impacts during the re-construction/construction phase will be possibly mitigated by including appropriate clauses into the civil works contracts. Construction and other civil works contracts have to include this EMP with its Environmental Mitigation Plan and Environmental Monitoring Plan and at least, the following, in a form to be fully binding to the contractor(s):

• Compliance with national environmental laws and standards; • Compliance with World Bank Operational Policies; • Adequate disposal of construction and excavation wastes; • Reasonable restoration of landscape in construction sites after works completion, in line with

the relevant design documents (such as the design for the surrounding areas); • Occupational safety and health (consultants and contractors working on this sub-project will

be required to adhere to all applicable laws and regulations controlling workplace health and safety).

7. IMPLEMENTATION ARRANGEMENTS 5 The World Bank during supervision missions may request randomly to check if such permits are issued and are valid as well as if the EMP mitigation and monitoring aspects are implemented on the ground during the construction phases according to the Bank’s policies and relevant Serbian legislation. 6 A provisional table of contents for this report is provided in Annex

21

Project management functions, including monitoring of the implementation of this EMP, and day to day operations are be the responsibility of the ECEC Project Implementation Unit (PIU) and MOESTD. For the purpose of this sub-project, the MOESTD is considered to be the financing body while the municipal administration is considered as the investor. The financing body and the investor will sign a contract outlining mutual obligations, that will contain basic information and guidance on preserving the environment, as presented in this EMP. The financing body and the investor sign the contract for performance of works, after a tendering procedure, with the contractor. The designated supervisory body responsible for supervision of works performed by the contractor, will be selected after a tendering procedure and will sign the relevant contract with the investor.

ECEC PIU and MOESTD will also coordinate the overall working plan related to this sub-project, its construction schedules, implementation progress and implementation of proposed measures for avoidance and/or minimization of environmental, health and safety risks.

During the operational phase, when the facilities envisaged in this sub-project are constructed and operational, the main activity related to environmental protection will be related to preparation of the Fire Protection Plan and Plan for Regular and Preventive Maintenance of the object (sewer and water supply systems, heating devices, equipment) in accordance with the relevant legislation in the Republic of Serbia.

8. MONITORING ARRANGEMENTS

ECEC project will be monitored by MOESTD and the PIU. Information and data collected at each of the implementation agencies will be fed into overall monitoring and evaluation framework. MOESTD will oversee M&E activities regularly through project reports, evaluate results achieved and guide the implementing agencies on corrective management actions.

The main responsibility for implementation of EMP-related measures lays with the contractor, who needs to take into account and apply on a daily basis all proposed preventive and mitigation measures. The designated supervisory body needs to perform the supervision on the practical implementation of the mitigation measures by the Contractor, and issue corrective instructions and/or orders, if necessary, in conjunction with the investor and ECEC PIU. The main inspection responsibility is, according to national legislation, given to the municipal staff (environmental Inspectors, communal inspectors, health and safety inspectors, building inspectors) that will be involved in monitoring the implementation of the mitigation measures and proposed Monitoring Plan (Section 6 of this EMP), in accordance with the relevant legislation in Serbia. The Contractor is obliged to perform all activities defined within the Environmental Monitoring Plan of this EMP for which the Contractor is contracted. The designated supervisory body is responsible to monitor all construction activities, including environmental protection during project implementation. The Monitoring plan for this sub-project should be drafted against the bidding documents and it should include, at least:

• Environmental issue to be monitored and the means of verification • Specific areas, locations and parameters to be monitored; • Applicable standards and criteria; • Duration • Institutional responsibilities for monitoring and supervision • Reporting

The draft Monitoring plan is presented in Chapter 13. of this document.

22

9. REPORTING ARRANGEMENTS The reporting procedure for this sub-project will be done in four tiers, as described below. Tier 1. Contractor to Supervisor The Contractor will prepare its compliance reports in respect to implementation of this EMP as EMP Quarterly Progress Reports and submit these to the designated supervisory body. These reports will be submitted in both Serbian and English languages, in hard copy and electronic versions. These reports will document the implemented environmental mitigation and protection measures, together with prescribed monitoring activities carried out during that quarter’s reporting period. The Contractor will take care of the quality of the environment according to the mitigation and monitoring plan, which are parts of this EMP. Each Contractor is obliged to produce and deliver to the designated supervisory body a mid-term Environmental Report covering all project activities during half-way period of project implementation. Tier 2. Supervisor to Investor The designated supervisory body will submit EMP Quarterly Progress Reports and the mid-term Environmental Report to the investor (municipality). Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the designated supervisory body will forward these reports to the investor (municipality) not later than 3 working days after the intial submission of the reports by the contrctor. Tier 3. Investor to ECEC PIU/MoESTD The investor (municipality) will submit EMP Quarterly Progress Reports and and the mid-term Environmental Report to ECEC PIU/MoESTD. Based on the agreement signed between the financing body (MoESDT), the investor (municipality) and the contractor, the investor will forward these reports to ECEC PIU not later than 3 working days after the intial submission of the reports by the contrctor. Tier 4. ECEC PIU to WB ECEC PIU shall provide at least semi-annual reports to MOESTD and WB, as layed out in the Project Operations Manual and Project Apppraisal Document, regarding the status of implementation of mitigation measures by contractors, additional mitigation measures that may need to be implemented, incidents of non-compliance with applicable environmental permits, complaints received from local residents, NGOs and how these were addressed. Monitoring and compliance in accordance with ESMF and this site-specific EMP, during project implementation will be undertaken by ECEC PIU (environmental specialist), and reported in writing to the Bank at least once during the lifetime of this sub-project. Specific Provisions on Reporting For all reporting tiers presented above, in case of any kind of accident or endangerment of environment happens and/or in case of health and safety related incidents, including but not limited to serious injury at work, loss of limb or death due to site related activities, reporting to ECEC PIU and WB will be immediate. This reporting will be done from Tier 1 to Tier 4 immediately and in its totality not exceeding 24 hours following the incident. The Contractor has the final responsibility for reporting and addressing the incidents to the designated supervisory body and the relevant authorities of the Republic of Serbia. ECEC PIU has the final responsibility for reporting and addressing the incidents to WB.

23

10. Environmental Impact Assessment Report

Evaluation of impact – reconstruction of the existing facility and construction of a new facility Environment

Type

of

impa

ct

Posi

tive

or

nega

tive

Mag

nitu

de o

f im

pact

Exte

nt/l

ocat

ion

whe

re

impa

ct

occu

rs

Tim

ing

whe

n im

pact

oc

curs

Dur

atio

n of

im

pact

Reve

rsib

le/i

rre

vers

ible

Like

lihoo

d of

im

pact

Sign

ifica

nce

Physical/Natural Environment Groundwater pollution from leakage from

underground fuel tanks negative local on site during

extraction of underground fuel tanks

long irreversible unlikely major

Landscape and visual environment

disruption of existing landscape and visual environment

negative local on site operational phase

long potentially irreversible

unlikely minor

Existing or future land use none Water and energy resources

none

Public hazardous elements Air quality Generation of emissions from

mobile sources of CO2, NOx, PAH, SO2 and suspended particulates (PM10, PM2.5). Generation of airborne due to dismantling of the equipment, excavation, vehicle movement and handling with materials, particularly around the construction site.

negative local on site reconstruction/construction phase

long reversible unlikely minor

Water quality Possible impacts on due to contamination from spillage of vehicle fuel, motor oils, lubricants and improper dismantling of boilers and fuel reservoirs



Soil pollution none Waste Environmental and health effects

due to inappropriate waste management of various waste streams


long irreversible/reversible

certain significant

24

Noise and vibrations Construction activities and traffic related noise and vibrations due to machinery and vehicles used for transportation of construction materials, transportation of workers, and transportation of waste



Biodiversity (flora and fauna)

none

Physical Cultural Resources Protected cultural sites Possible disturbance by noise and

vibrations due to removal of a fuel tank, if applicable, located on the land plot containing a protected cultural building (church of St. Michael)

negative local on site reconstruction phase

short reversible unlikely minor

25

11. ENVIRONMENTAL MITIGATION PLAN General Provisions

Potential Environmental Impact

Impact scale Proposed mitigation measures Responsibility

Activity: Design activities Possible adverse environmental, health and safety impacts due to poor design and planning

Local/ short term/unlikely to happen/ major significance

• Relevant permits must obtained prior to any construction/re-construction works (Information about the location, Location Permit (including an extract from the cadastral register of underground installations is issued by the Republic Geodetic Bureau, Department of Real Estate Cadaster); Approval of the location and the project documentation for fire protection (issued by the Serbian Ministry of Internal Affairs, Department for Emergency Situations) and Water Management permit, especially if the new facility is located near the riverbed, (issued by Public Enterprise “Srbijavode”), Construction Permit and Utilization permit for projects of constructing new facilities and reconstruction of the existing ones regardless;

• In addition to addressing the requirements of the Mitigation Plan, the following additional documents will be produced during the design phase:

• Site Organization Plan: to incorporate environmental, health and safety protection measures that meet legal requirements (including the measures defined in this EMP), particularly taking into account transportation routes that should minimize adverse effects to nearby communities.

• Soil Management Plan detailing measures to be undertaken to minimize effects of wind and water erosion on stockpiles, measures to minimize loss of fertility of topsoil, timeframes, haul routes and disposal site;

• Waste and Wastewater Management Plan. All construction waste materials including drums, lumber, sand and gravel, cement bags etc. are to be suitably disposed of. If these cannot be recovered for scrap value these materials should be taken to an approved landfill sites for safe disposal. The Plan should cover all aspects of waste management, including implementation of practice standards such as reduce, re-use and recycle. It should specify final disposal alignments for all waste and demonstrate compliance to national legislation and best practice procedures on waste management. The Plan will, as a minimum, include details of temporary waste storage, waste transfer and pre-treatment prior to final disposal or recycling. Licensed/approved facilities for solid and liquid waste disposal must be used and a duty of care and chain of custody for all waste leaving the site will be followed. This plan needs to be updated by the Contractor (and approved by the Supervisor) within 30 days from the start of the

• Investor • Contractor

26

Contract. Inadequate application of EMP due to weak linkages of EMP with other contract documents

Local/ short term/likely to happen/ major significance

• This EMP is to become integral part of the bid and contract documents. It is the Contractor’s obligation to cost the implementation of the environmental mitigation measures in his overall cost. The Contractor will be required to provide a short statement that confirms that EMP conditions have been costed into the bid price.

• PIU • Contractor • Supervisor

Activity: Civil Works – General Provisions Possible adverse environmental, health and safety impacts due to absence or non-observance of relevant procedures

Local/ short term/likely to happen/ major significance

The Supervisor will be required to confirm that the following documents have been prepared by the Contractors: • Waste Management Plan, as desrbied in detail below. • Sewage management plan for provision of sanitary latrines and proper sewage

collection and disposal system to prevent pollution of watercourses during the execution of civil works. This plan needs to be updated by the Contractor (and approved by the Supervisor) within 30 days from the start of the Contract.

• Oil and fuel storage management plan. The Contractor’s Plan should cover all procedures for storage, transportation and usage of oils and fuels, refueling of machinery and procedures for minimizing the risk of ground and water contamination. All oils and fuels will be required to be stored within secondary containment of 110 % capacity and all spillages shall be cleaned up immediately. Re-fueling vehicles will carry Spill Kits to enable spillages to be cleaned up as soon as possible.

• Emergency response plan. The Contractor’s Plan should contain procedures for emergency response in the event of accidents or major incidents, in order to safeguard people, property and environmental resources. Details of the spill response equipment to be provided on site are to be specified.

• Noise Reduction Plan – all equipment is licensed and approved in accordance with EU standards. This applies to all machinery, vehicles and construction sites where noise and vibration may affect susceptible receptors. The contractor will be responsible for ensuring that noise and vibration does not affect the adjacent communities, in accordance with the Law on Noise Protection.

• Rehabilitation Plan: Rehabilitation of construction sites and removal of contractor‘s facilities following successful completion of construction activities. This includes removal of all waste materials, machinery and any contaminated soil, if any. The contractor will develop a plan for handover, removal of all plant, vehicles and machinery to ensure that no unserviceable items are left on the construction site, in accordance with the Law on Waste Management and Law on Environmental Protection.

• Grievances Plan: detailing the means by which local people and other project affected persons can raise grievances arising from the rehabilitation process and

• Contractor • Supervisor • MoESTD/ECEC project

staff (concenring grievance redress plan)

27

how these will be addressed (e.g., through dialogues, consultations, etc.),as presented in ESMFD and sections of this EMP dealing with social issues ;

• Health and Safety Plan: Contractor will be required to identify potential hazards and proposed relevant mitigation measures, including, provisions for emergency responses. This plan will ensure, at least, the following: • Provision for a safe work environment and provide safety measures and

protective equipment to all workers, including hand, head, eye and ear protection and safety footwear.

• Provision or first aid facilities on-site and employ a trained first aid person, in accordance with the Law on Safety and Health at Work.

• Supplies of potable water, toilets and wash water to the workers. • Keep the site free of drugs and alcohol. • Contractor is responsible to ensure workers are properly trained and

certified to use the equipment • Contractor is insured against accidents. • Contractor has qualified and experienced persons (at least one staff with an

environmental or technical degree and at least 2 years of relevant professional experience in conducting similar tasks) on the Contractor‘s team who will be responsible for implementation of the environmental compliance requirements as stated in this EMP;

• Contractor (and its sub-contractors) will comply with Republic of Serbia national laws and Lender requirements.

Waste generation Possible adverse environmental and health effects could occur due to inappropriate waste management of various waste streams

Local/ short term/certain to happen/ high significance

• Preparation of Waste Management Plan for expected waste streams during the decommissioning and construction phases and its approval, within 28 days from the reception of the Letter of Acceptance by the selected contractor. This Plan must be reviewed and approved by the site supervisor.

• • Identify hazardous and non-hazardous waste and separate them at the

demolition/construction site; • The majority of waste is expected to be classified under the Waste Chapter 17

“Construction and demolition wastes” with the waste code 17 01 – Waste from concrete, bricks, 17 09 04 – Mixed waste from construction site including glass from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it is possible, transport to the final deposition site);

• Small quantities of glue, paint, packaging waste from paint, glue and solvents, aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company);

• Contractor • Supervisor

28

• Contract with company for waste collection and transportation should be signed for collection and transportation of waste including old windows and doors;

• The materials should be covered during the transportation to avoid waste dispersion;

• On-site open incineration of construction waste is prohibited.

Sub-project Specific Provisions

Activity: Reconstruction of the existing facility OH&S issues Possible adverse health impacts on workers, facility users and general population in the community due to:

• Location of facility in an urban area

• Possible injury to people and facility users due to ongoing works

• Non - compliance with local community safety regulations



• The construction site needs to be fully fenced using hard fencing panels not shorter than 2m, gated and information signs containing basic information on this sub-project, including accessibility of grievance mechanisms should be placed on the construction and maintained during the civil works;

• The area of the existing facility that is expected to be used by children during the construction works should be fenced using hard fencing panels not shorter than 2m in the form of an inner fence, within the perimeter of the outer construction site;

• Traffic to and from the construction site, must be regulated in such a way to ensure minimal disturbance to the daily routine of facility users, facility staff, parents and the local community. Access and other roads on the construction site should not cross the roads and/or paths used by facility users, facility staff, parents and the local community in their daily routines. If this can not be avoided, traffic on such roads should be organized outside of the busiest hours locally.;

• Protection of pedestrians, general population and facility users and access of non-authorized personnel to the construction site, will be achieved as above;

• For construction workers - legally prescribed health and safety measures should be applied: a) use of appropriate protective clothing and equipment (masks against dust, wooden fragments and fibers, and safety harnesses for work at heights etc; b) Maintain a good level of personal hygiene; c) Health protection-first aid kits and medical service on sites need to be provided during the works;

• Old windows and doors should be temporary placed in an area/space that prevents access of unauthorized persons on site within the perimeter of the outer fence;

• Follow relevant safety guidelines contained in the Law on Waste Management of Republic of Serbia for the storage, transport, and distribution of hazardous materials to minimize the potential for misuse, spills, and accidental human exposure;

• Perform regular maintenance of vehicles to minimize potentially serious accidents caused by equipment malfunction or premature failure;


29

• Organize 24-hour security service on the construction site; • Use labeling and placarding (external signs on transport vehicles); • Cleaning routines of facilities should be increased to address extra dust and dirt

created by demolition/construction works. • Ensure that none of the facility users, parents and facility staff are rmoved from

the facility during the reconstruction works; • If possible, start and end construction activities during the usual adequate

season. • Old windows and doors should be stored temporary in a separate room on the

site or if this is not possible outside of the facility, covered and labeled “not to open/uncover” until final disposal.

• Contractor • Facility staff

Water and soil pollution Possible environmental impact on the underground water could occur due to ground contamination from spillage of materials such as vehicle fuel, motor oils and lubricants

Local/ short term/medium significance/low probability

• Possible hazardous waste (motor oils, vehicle fuels, lubricants) should be collected separately and authorized company should be sub-contracted to transport and finally dispose hazardous waste.




• Identify hazardous and non-hazardous waste and separate them at the demolition/reconstruction site;

• The majority of waste is expected to be classified under the Waste Chapter 17 “Construction and demolition/reconstruction wastes” with the waste code 17 01 – Waste from concrete, bricks, 17 09 04 – Mixed waste from construction site including glass from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it is possible, transport to the final deposition site);

• Small quantities of glue, paint, packaging waste from paint, glue and solvents, aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company);



• On-site open incineration of construction waste is prohibited.


Removal of the asbestos containing construction elements Possible adverse health impacts

Local/ short term/major impact on facility site

• Post signs indicating” ASBESTOS REMOVAL – NO ADMITTANCE” should be placed on construction site;

• Restrict access to the removal area to those people directly involved in asbestos removal, site supervisor and municipal inspectors;

• Contractor • Supervisor • Facility staff

30

to the workers, facility users, students and general public as a result of emissions of asbestos fibers and dust during the removal of asbestos sheets, their transport and final disposal

• Roof and facade elements of the existing facility should be demolished during non-working days to decrease health risks to facility users;

• Install barrier tapes and warning signs in proximity to facilities; • All construction workers must wear personal protective equipment (full body

covering including the head, water proof foot and hand protection and eye protection, dust mask with special HEPA filters);

• Maintain a good level of personal hygiene (facility for washing hands and face should be made available and needs to be used by each employee when leaving the work area, all protective clothing and equipment shall work in the work area, footwear is to be kept in the construction area until works are completed;

• Health protection-first aid kits and medical service on sites need to be provided during construction works;

• No smoking, drinking or eating is allowed inside the construction area; • Surrounding area should be kept clean, without ACM waste disposed there. ACM

waste (roof sheets, side wall panels, pipes) need to be collected, packaged and immediately removed from facility site.

• If possible start and end demolition/reconstruction activities during summer months or during absence of facility users and staff.

ACM Waste management Possible adverse environmental impacts and health effects could occur due to inappropriate handling of asbestos-containing waste

Local/ short term/major impact

• Persons in charge of removal of ACM construction elements, such as roof sheets and facade panels should be trained on appropriate techniques for safe dismantling of ACM to minimize health risks, as prescribed in the Regulation on preventive measures for safe ad healthy work during exposure to asbestos (OGRS 108/15), particularly concerning the utilization of protective equipment, maintenance of protective equipment, regular health monitoring of workers involved in ACM handling, applying for relevant permits, if applicable, and procedures for handling, transportation and final disposal of ACM by certified contractor(s);�

• Identification of asbestos containing materials – waste as a hazardous waste should be executed;

• ACM waste need to be classified as a hazardous waste under the Waste Chapter 17 “Construction and demolition/reconstruction wastes” with the waste code 17 06 05* – Construction material containing asbestos in accordance with relevant national legislation;�

• ACM waste should be placed in polyethylene bags or other containers of at least 0.15 mm thickness, that ensure the receptacle/container are hermetically sealed;

• Printed asbestos warning labels must appear on the outer surface of the container/bag warning that it is an “asbestos waste”;�

• Breaking of ACM roof sheets and facade panels into smaller pieces to fit into containers/bags is forbidden. Roof sheets and facade panels should be handled very carefully and removed in one piece, aiming not to be broken because during

31

the break the asbestos fibers and dust appear and pose a health risk. In case of deformation and/or breakage the above provisions apply. Techniques for safe handling and transportation are numerous, e.g. using wrapping materials and ensuring they are hermetically sealed or using larger solid containers with thickness exceeding 0.15 mm, provided they have ensure hermetic seal (Article 7, point 4, of the Regulation on preventive measures for safe ad healthy work during exposure to asbestos (Official Gazette of the Republic of Serbia, 108/15);

• Avoid temporary storage of roof sheets and side wall panels within the facility, but it is necessary, precautionary measures should be applied – the ACM waste should be stored in a designated area with posted signage and/or caution tape to eliminate any possible access or damage;

• Contract with the company for asbestos-containing waste collection and transportation should be signed for collection and transportation of asbestos-containing waste;

• Following the removal of asbestos waste all surfaces in the facility need to be dusted with a damp cloth or vacuumed with a HEPA filter;

• Workers who perform clean up should wear protective clothes as those who perform dismantling of roof sheets, side wall panels or pipes;

• Contract with relevant landfill or other utility should be signed for final disposal of asbestos containing roof sheets, side wall panels and pipes;

• Asbestos-containing waste should be disposed at the special area for disposal of that type of waste (responsibility of relevant landfill or other chosen utility) at the chosen landfill.

Improper dismantling of fuel and septic tanks

• Heating fuel tank and the septic tank should be checked for their contents and the contents identified.

• In case that heating fuel tank and/or the septic tank contain hazardous substances, the tanks must be emptied by pumps, as relevant, and removed in a manner to minimize environmental risks, also following provisions on protecting the physical cultural resources.

• In case that the heating fuel tank and the septic tank are empty and do not contain any hazardous materials, they also may be be permanently sealed and left in the ground or removed.

• Dismantling of tanks must be done by trained persons in order to avoid potential effects of oil spills on soil, which would contaminate the underground water and fully in line with the Law on Waste Management (OGRS 36/09 and 88/10).


Noise pollution Demolition/reconstructionand reconstruction activities and traffic will cause noise and vibrations due to machinery and

Local/ short term/medium significance/certain to happen

• Construction works should not be permitted during nights, the operations on site should be restricted to the period 7.00 AM -7.00 PM. Bearing in mind the above relevant OH&S measures, alterations of this schedule can be made exclusively on a case by case basis, subject to approval of the investor and ECEC PIU;�

• The level of noise should not exceed national limited values for residential areas

• Contractor • Supervisor • Local communal and

environmental inspectors

32

vehicles used for transportation of construction materials, transportation of workers, and transportation of waste produce in decommissioning and construction phase

in open spaces, i.e. 55 dB during the day and evening and 45 dB during the night; • Excessively noisy vehicles should not be operated until corrective measures are

taken, taking into account maximum noise levels (55 dB during the day and evening and 45 dB during the night).

Air pollution Demolition/reconstructionand reconstruction activties will generate emissions from mobile sources (vehicles and construction machinery) of CO2, NOx, PAH, SO2 and suspended particulates (PM10, PM2.5). Airborne dust will be caused by dismantling of the equipment, excavation, vehicle movement and handling with materials, particularly around the construction site.

Local/Short term/low significance/ certain to happen

• Usage of protective masks for the workers; • Vehicles and construction machinery will be required to be properly maintained

and to comply with relevant emission standards; • Conduct regular maintenance of vehicles and construction machinery in order to

reduce leakages of engine oils, emissions and dispersion of pollution; • Vehicle loads have to be covered to prevent emission of dust;� • Construction site, transportation routes and materials handling sites should be

water-sprayed on dry and windy days;� • Construction materials should be stored adequately to minimize dust

generation;� • Open incineration of debris will not be permitted; • Restriction of the vehicle speed within the construction location.



Physical Cultural Resources Possible disturbance by noise and vibrations due to removal of a fuel tank located on the land plot containing a protected cultural building (church of St. Michael), if applicable

Local/Short term/low significance/unlikely

• Consent from the relevant administrative authority to perform works on the grounds containing a protected cultural monument and consent from the owner of the affected land plot containing a protected cultural monument, should be obtained;

• Equipment used should be fitted with appropriate noise reduction devices;� • The level of noise should not exceed national limited values for (depends on the

area of protection where works take place); • Install barrier tapes and warning signs in proximity to facilities;

• Contractor • Supervisor • Local communal

inspectors

Activity: Construction of the new facility OH&S issues Possible adverse health impacts on workers, facility users and general population in the community due to:

• Location of facility in an urban area

• Possible injury to people and facility users due to ongoing works


• The construction site needs to be fully fenced using hard fencing panels not shorter than 2m, gated and information signs containing basic information on this sub-project, including accessibility of grievance mechanisms should be placed on the construction and maintained during the civil works;

• The area of the existing facility that is expected to be used by children during the construction works should be fenced using hard fencing panels not shorter than 2m in the form of an inner fence, within the perimeter of the outer construction site;

• Traffic to and from the construction site, must be regulated in such a way to ensure minimal disturbance to the daily routine of facility users, facility staff, parents and the local community. Access and other roads on the construction


33



site should not cross the roads and/or paths used by facility users, facility staff, parents and the local community in their daily routines. If this can not be avoided, traffic on such roads should be organized outside of the busiest hours locally.;

• Protection of pedestrians, general population and facility users and access of non-authorized personnel to the construction site, will be acheieved as above;

• For construction workers - legally prescribed health and safety measures should be applied: a) use of appropriate protective clothing and equipment (masks against dust, wooden fragments and fibers, and safety harnesses for work at heights etc; b) Maintain a good level of personal hygiene; c) Health protection-first aid kits and medical service on sites need to be provided during the works;

• Old windows and doors should be temporary placed in an area/space that prevents access of unauthorized persons on site within the perimeter of the outer fence;

• Follow relevant safety guidelines contained in the Law on Waste Management of Republic of Serbia for the storage, transport, and distribution of hazardous materials to minimize the potential for misuse, spills, and accidental human exposure;

• Perform regular maintenance of vehicles to minimize potentially serious accidents caused by equipment malfunction or premature failure;

• Organize 24-hour security service on the construction site; • Use labeling and placarding (external signs on transport vehicles); • Cleaning routines of facilities should be increased to address extra dust and dirt

created by demolition/construction works. • If possible, start and end construction activities during the usual adequate

season. Water and soil pollution Possible environmental impact on the underground water could occur due to ground contamination from spillage of materials such as vehicle fuel, motor oils and lubricants

Local/ short term/medium significance/low probability

• Possible hazardous waste (motor oils, vehicle fuels, lubricants) should be collected separately and authorized company should be sub-contracted to transport and finally dispose hazardous waste.




• Identify hazardous and non-hazardous waste and separate them at the demolition/construction site;

• The majority of waste is expected to be classified under the Waste Chapter 17 “Construction and demolition wastes” with the waste code 17 01 – Waste from concrete, bricks, 17 09 04 – Mixed waste from construction site including glass from old windows and manage in accordance with national waste legislation for inert waste (separation at the spot, collection and temporary storage, re-use if it


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is possible, transport to the final deposition site); • Small quantities of glue, paint, packaging waste from paint, glue and solvents,

aluminum profiles, screws and other construction material could be found after the finalization of the project and managed in accordance with national hazardous waste legislation (collection of hazardous materials, label as hazardous waste and give to the authorized company);



• On-site open incineration of construction waste is prohibited. Noise pollution Construction activities and traffic will cause noise and vibrations due to machinery and vehicles used for transportation of construction materials, transportation of workers, and transportation of waste produce in decommissioning and construction phase

Local/ short term/medium significance/certain to happen

• Construction works should not be permitted during nights, the operations on site should be restricted to the period 7.00 AM -7.00 PM. Bearing in mind the above relevant OH&S measures, alterations of this schedule can be made exclusively on a case by case basis, subject to approval of the investor and ECEC PIU;�

• The level of noise should not exceed national limited values for residential areas in open spaces, i.e. 55 dB during the day and evening and 45 dB during the night;

• Excessively noisy vehicles should not be operated until corrective measures are taken, taking into account maximum noise levels (55 dB during the day and evening and 45 dB during the night).



Air pollution Construction activities will generate emissions from mobile sources (vehicles and construction machinery) of CO2, NOx, PAH, SO2 and suspended particulates (PM10, PM2.5). Airborne dust will be caused by dismantling of the equipment, excavation, vehicle movement and handling with materials, particularly around the construction site.

Local/Short term/low significance/ certain to happen

• Usage of protective masks for the workers; • Vehicles and construction machinery will be required to be properly maintained

and to comply with relevant emission standards; • Conduct regular maintenance of vehicles and construction machinery in order to

reduce leakages of engine oils, emissions and dispersion of pollution; • Vehicle loads have to be covered to prevent emission of dust;� • Construction site, transportation routes and materials handling sites should be

water-sprayed on dry and windy days;� • Construction materials should be stored adequately to minimize dust

generation;� • Open incineration of debris will not be permitted; • Restriction of the vehicle speed within the construction location.



Operational phase of the Project

No environmental risks are expected. Positive impact (more space for facility users, new sport facilities, energy efficiency

Local/ short term/major at the location of facilities

• Fire prevention Plan should be prepared addressing fire risks and ignition sources, as well as measures needed to limit fast fire and smoke development.

• Prevention Maintenance Plan for regular and preventive maintenance should be prepared to ensure proper operation of all infrastructure components of the

• Facility staff

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and energy savings, reduction of GHG emissions) is expected with construction of the new facilities.

facility (sewer system, storm-water system, water supply system, heating devices);

• Procedure for keeping records should be established in order to ensure proper storage of all technical documentation.

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12. ENVIRONMENTAL MONITORING PLAN

Which parameter is to be monitored?

Where is the parameter to be monitored?

How is the parameter to be monitored?

When is the parameter to be monitored (frequency of measurement)?

Why is the parameter to be monitored?

Responsibility

Activity: Design activities Status of necessary permits and plans (Site Organization Plan, Soil Management Plan, Waste and wastewater management plan, Sewage management plan, Oil and fuel storage management plan, Emergency response plan, Noise reduction plan, Rehabilitation Plan, Grievances plan, Health and Safety Plan) Inclusion of EMP provisions in contracts

On facility site Review of the necessary permits, Plans and contracts with the contractors

Before the start of construction works

To ensure full compliance with regulations of the Republic of Serbia and the lender To ensure full application of EMP by the Contractor and ensure efficient linkages of EMP with other contract documents

Investor Contractor-Bidder Design engineers/Architects ECEC PIU staff

Activity: Civil Works – General Provisions Completion and implementation of relevant procedures

On facility site Review of plans and contracts with the contractors

Before the start of construction works

To minimize the risk of adverse environmental, health and safety impacts due to absence or non-observance of relevant procedures

Contractor - Bidder /Supervisor

Project activity: Demolition of the existing facility and construction of the new facility

Community safety regulations and protection measures applied

In vicinity of facility sites

Visual checks At beginning of works and every working day until closure of works

To ensure minimization of health and safety risks - mechanical injuries to members of local community - especially from broken glass, wooden windows and doors and spikes. Special attention should be given to removal of the asbestos containing roof sheets

Contractor - Bidder /Supervisor/ Municipal staff: Communal and Environmental Inspector/ Facility staff

Fire Protection Plan Before the start of facility operation

Review of the Plan

At the beginning of facility operation

To ensure that all fire protection measures are implemented

Municipal staff: Communal and Environmental Inspector

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The OH&S protection measures applied for workers at facility sites

On facility site Visual checks Every working day until closure of works

To minimize risks related to occupational health and safety of workers using, particularly those handling asbestos containing wall panels


Avoid and minimize safety and health risks for facility users and staff

In facility and immediate surroundings

Visual checks At the beginning of demolition works and continuously every working day

To avoid injuries of facility users and staff from falling objects (fragments of windows, doors, broken glass and inhalation of asbestos fibers or dust)


Waste Management Plan for all generated waste streams

On facility site Review the document - Waste Management Plan

Before demolition activities start

To ensure minimization of waste generation and appropriate disposal

Contractor - Bidder/Supervisor/ Municipal staff (Communal and Environmental Inspector

Existence of fragments of glass, dust generated during the demolition Generation of different types of waste

In facility Visual checks For broken glass immediately/For dust generation every day after completion of work for inert waste every on 2 days

To avoid and minimize injuries and dust inhalation


Level of dust - fine particulate matter

On facility site Visual monitoring On sunny dry days only (once a week at the peak working hour)

To avoid and minimize airborne dust accumulation and minimize health risks for facility users and staff, as well as local residents.

Contractor - Bidder and authorized company for dust measurements

Collection, transportation and storage of hazardous waste (if any generated)

In temporary storage facility

Review the transportation list and conditions at the storage facility

Before transportation of hazardous waste (if any generated)

To improve waste management practices at municipality and national level.

Authorized contractor for collection and transportation of hazardous waste (if any generated) subcontracted by the Contractor- Bidder/ Environmental inspector

Noise from construction works

On facility site Auditory monitoring of noise and noted of complaints from local residents

On regular basis during works, in accordance with national legislation

To monitor if noise levels are above or below the accepted noise levels for that particular area

Contractor - Bidder Authorized Company for performing noise level measurements sub-contracted by the Contractor – Bidder/ Environmental Inspector to collect noise level measurements

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Exposure to noise from vehicles, machines, mechanization and other equipment

On facility site Review noise level technical specifications for vehicle used, mechanization and equipment for their usage outside

Before beginning of works (first day) for all vehicles and equipment

To protect the workers against exposure to loud noise taking into account the technical specifications of the equipment and time duration of the work outside

Contractor - Bidder Supervisor Environmental Inspector /Inspector for communal works

Physical Cultural Resources Disturbance by noise and vibrations due to removal of a fuel tank located on the land plot containing a protected cultural building (church of St. Michael)

On facility site Visual checks and interviews

During and after the dismantling of the fuel tank

Presence of excessive dust, cracks caused by vibrations and disturbance in appearance of the land plot containing the protected cultural building.

Contractor - Bidder Supervisor Local communal inspector

Project activity: Demolition of construction elements containing asbestos Primary selection of waste streams at facility sites

On facility sites Review documentation - identification of waste types according to national waste categorization lists

At beginning of works To separate hazardous (packaging for glue, paint, solvents, insulation and other material) from non-hazardous waste To separate inert from biodegradable waste

Contractor - Bidder Supervisor/ Municipal staff: Communal and Environmental Inspector

Identification of asbestos-containing waste, appropriate packaging and labeling

On facility sites Review documentation - identification of waste types according to national waste categorization lists

At beginning of works Asbestos containing (ACM) waste is hazardous waste with adverse environmental and health impacts

Contractor - Bidder Supervisor/ Municipal staff: Communal and Environmental Inspector

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Temporary storage of removed windows and doors with appropriately labelled and covered Temporary storage of removed asbestos containing roof sheets and piped, appropriately labelled and packed

In separate rooms/basement of facilities or in their close proximity

Visual checks On daily basis To minimize injuries and adverse environmental and health impacts

Contractor-bidder Facility staff

Collection, transportation and final disposal of wooden windows and doors

On facility sites and in their vicinity

Visual monitoring and reviewing transportation logs

After the collection and transportation of waste from old wooden windows and doors by public communal utilities

Not to leave waste on facility sites to avoid environmental and health impacts to the facility users

Contractor - Bidder who needs to sign the contract with licensed company for collection, transportation and disposal of waste

Contract with authorized transporter of asbestos containing waste should be signed Contract with the chosen landfill should be signed as well for acceptance and final disposal of asbestos-containing waste

Before works start

Review contracts During collection and transportation of removed roof covers and pipes Before final disposal of removed sheets and pipes

To ensure that asbestos-containing waste will be treated according to national legislation, international conventions and best available practices

Contractor - Bidder who needs to sign contract with licensed company for acceptance and final disposal of asbestos-containing waste. Chosen landfill must hold a license for acceptance and final disposal of asbestos waste issued by the relevant Ministry.

Annual Report on transportation and disposal of waste

Local self- government administration

Review of documentation - Identification waste list

After completing collection, transportation, temporary disposal and final disposal of different types of waste, including asbestos-containing waste

To improve waste management and hazardous waste management at local and national level

Mayor of municipality

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Project activity: Operational phase of facility Drinking water quality Before starting

operation of piping in facilities, tap water should be sampled and analyzed by the authorized and accredited laboratories

Laboratory equipment for physical- chemical and microbiological water quality analysis

Before starting facility operation

To ensure distribution of high quality drinking water facility users and to minimize health risks of waterborne diseases

Municipal staff Facility staff Institute for public health

Fire Protection Plan Before starting facility operation

Review Plan At beginning of facility operation

To ensure that all fire protection measures are implemented

Municipal staff: Communal and Environmental Inspector Facility staff

Plan for regular and preventive maintenance of facilities

Before starting facility operation

Review Plan At beginning of facility operation

Municipal staff: Communal and Environmental Inspector Facility staff

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13. REPORT ON PUBLIC CONSULTATIONS The disclosure of this EMP document started on 25 February 2019, when ECEC PIU and the City of Sremska Mitrovica announced the invitation for Public Consultations for the public, bodies and organizations interested in this EMP document. Public and other interested parties and organizations were invited to participate in process of public consultation on this draft EMP document. Insight into the ESMF document was ensured by the following:

• Placing the draft document in Serbian language on the following Internet address: o http://www.sremskamitrovica.rs/admin_area/kcfinder/upload/files/javnakosult1_.p

df • Inviting all interested parties to review the EMP document and attend public consultations by

placing an hard copy of the invitation on the notice board of the City of Syrmaks Mitrovica on 25 February 2019.

• Ensuring access to a hardcopy of the document at the premises of the municipal administration building of the City of Sremska Mitrovica (address: Svetog Dimitrija Street 13, Sremska Mitrovica).

Disclosure of this EMP document finished by organizing public consultations and presentation of this EMP document that were held in the premises of the City of Sremska Mitrovica on 5 March 2019, from 11:00 AM to 12:00 midday. Up to the said date when the disclosure process was concluded, no complains, suggestions or any other form of communication concerning the draft EMP document had been received in any form and through any of the communication means.

There were 8 attendees present at the public consultation meeting, and these were the following:

1. Zorica Žigić, interested citizen 2. Petar Ranisavić, staff of City of Sremska Mitrovica 3. Vera Jakšić, interested citizen 4. Jovana Karastanković, interested citizen 5. Slavoljub Erdeljan, interested citizen 6. Milan Dimitrijević, staff of City of Sremska Mitrovica 7. Momčilo Gajić, ECEC PIU staff 8. Srdjan Sušić, ECEC PIU environmental specialist

The meeting started according to schedule at 11:00 AM. EMP document was presented in detail to the interested attendees by Srdjan Sušić. During the public consultations, there were several questions, comments and remarks in regards to environmental protection issues, presented below of which all of them were addressed immediately:

1. Question: To whom the designated supervisory body (page 10, section 7) is responsible in this sub-project? It should be made clearer that the designated supervisory body has to operate according to the relevant Serbian regulations.

Answer: Monitoring of the implementation of this EMP is discussed in details in Chapters 9 and 10. At the time of completion of this EMP, monitoring and reporting lines were defined as presented in the current document. In the following months, agreement between MOESTD and WB on the final outline of the reporting lines was reached. This outline was explained at the Public Consultations and will be changed in the final version of the EMP document accordingly.

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Action: Introduce the new agreed reporting outline to the text of this EMP.

2. Question: The currently valid Construction Permit, issued by the City of Sremska Mitrovica to the City administration for infrastructure and administration on 25 November 2016 (number: ROP-SMI-26564-CPI-3/2016) is going to be altered in the coming days/weeks, upon the request for alterations by the City administration for infrastructure and administration. The new Construction Permit is expected to state that the existing kindergarten facility will not be demolished, but rather reconstructed. All other issues are expected to remain unchanged.

Answer: The current EMP is based on the pertinent information collected from the currently valid Construction Permit and information received from ECEC PIU staff. The works and actions to be taken during the implementation of this sub-project are reflected in the current EMP, and fully encompass the expected alterations in the new Construction Permit.

3. Question: What are the planned measures to be taken by the contractor in order to ensure safety of the facility users during reconstruction and construction works? This issue should be covered in more detail in the current EMP. One of the potential solutions would be not to limit the working hours on the construction site only outside of the working hours of the existing facility, but to allow flexibility of the operational schedule, based on the individual daily needs. It was suggested that the facility users should be moved out of the facility during the reconstruction works on the existing building and re-assigned to other similar neighboring facilities. During the construction phase of the new building, the construction site has to be physically separated from the rest of the perimeter of the facility, with hard paneling of at least 2m height. Access roads to the construction sites in both cases (reconstruction of the existing building and construction of the new one) should not disturb the daily routine of the facility and pose additional risks to its users.

Answer: The relevant provisions of the current EMP will be changed to respond to these requests. Action: Amend the current EMP to reflect the presented requests.

4. Question: What does the lighting of the construction site mean? Can it be ensured that this lighting does not produce excessive pollution by light?

Answer: The usual general practice in Serbia that does not cause excessive pollution by light, prescribed in the current EMP, is suggested to be applied.

5. Question: According to the current Serbian legislation, it is not the designer who is responsible for obtaining all necessary permits, but the investor. Can this be changed in the current EMP?

Answer: The relevant provisions of the current EMP will be changed to respond to this request.

Action: Amend the current EMP to reflect the presented request.

6. Question: In addition to Question 3, it should be ensured that the operating hours for the construction site remain flexible and not only from 7 AM to 7 PM. This is because a need might arise to work during the night when temperatures are expected to be lower, rendering the operation conditions, e.g. for works with fresh concrete, more favorable.


Action: Amend the current EMP to reflect the presented requests.

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7. Question: The provision on necessary training of the facility staff by municipal authorities on relevant administrative procedures should be removed.



8. Question: The provision for measuring the concentration of dust particles in the air and the level of noise on the construction site should be removed. Works envisaged for this sub-project are of smaller scope and are not expected to cause significant increase of dust particles in the air or excessive levels of noise on the construction site.

Answer: The relevant provisions of the current EMP will be changed to respond to this request, with the addition that the measurements concerning dust concentration and levels of noise should be performed only in case when repeated complains in this regard have been formally lodged with the project, based on the project Grievance Mechanism.


The Public Consultations meeting ended at 12:00 midday, local time. Copies of internet announcements, copy of the newspaper advertisement, copy of the list of participants of public consultations and photos from the Public Consultations meeting are presented in Annex 2.

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14. ANNEXES

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Annex 1. NATIONAL ENVIRONMENTAL LEGAL and ENVIRONMENTAL IMPACT ASSESSMENT FRAMEWORKS Environmental protection in Republic of Serbia is regulated by several national and municipal laws and by-laws. The main legal documents are the following:

• Constitution of Serbia (“Official Gazette of RS” No. 98/06). • National Strategy for Sustainable Development (“Official Gazette of RS” No. 72/09, 81/09) • Law on Environmental Protection (“Official Gazette of RS” No. 135/04, 36/09, 43/2011,

14/2016) • Law on Environmental Impact Assessment (“Official Gazette of RS” No. 135/04) • The Law on Waste Management (“Official Gazette of RS” No. 36/09, 88/2010, 14/2016) • The Law on Protection against Environmental Noise (“Official Gazette of RS” No. 36/09, 88/10) • Law on Water (“Official Gazette of RS” No. 30/10, 93/12) • Law on Occupational Safety and Health (“Official Gazette of RS” No. 101/05, 91/2015) • Law on Planning and Construction (“Official Gazette of RS” No. 72/09, 81/09, 64/2010,

24/2011, 121/2012, 42/2013, 50/2013, 98/2013, 132/2014, 145/2014) • Law on Nature Protection, (“Official Gazette of RS” No. 36/09, 88/2010, 91/2010, 14/2016) • Law on Strategic EIA (“Official Gazette of RS” No. 135/2004, 88/2010) • Law on Forest (“Official Gazette of RS”, 30/2010, 93/2012 and 89/2015), • Law on Air Protection (“Official Gazette of RS”, 36/09, 10/2013) • Agricultural Land Law (“Official Gazette of RS” No. 62/06, 65/2008, 41/2009, 112/2015))

Regulations related to EIA procedure include the following:

• Law on EIA (Official Gazette of the Republic of Serbia No.135/2004, 36/2009); • Law on Environmental Protection (“Official Gazette of RS”, No. 135/04, 36/09, 43/2011,

14/2016); • Decree that prescribes list (I) of projects for which an impact assessment is mandatory and list

(II) of projects for which an impact assessment may be required (Official Gazette of the Republic of Serbia No. 114/2008);

• Law on Ratification of the Convention on Environmental Impact Assessment in a Transboundary Context (Espoo Convention)- („Official Gazette of the Republic of Serbia“, No. 102 /07);

• Law on Ratification of the Aarhus Convention („Official Gazette of the Republic of Serbia“, No. 38/09)

• Law on Free Access to Information of Public Importance, („Official Gazette of the Republic of Serbia“, No. 120/04, 54/07, 104/09 and 36/10);

• Law on Planning and Construction ("Official Gazette of RS", No. 72/09, 132/14 and 145/14). • In 2005, the following areas have been regulated through by-laws („Official Gazette of the

Republic of Serbia“, No. 69/05): o Rulebook on public insight, presentation and public discussion about the study; o Rulebook on the work of the expert commission in assessment of the study; o Rulebook on the content of application for determining screening and on the content

of application for determining scope of the EIA study; o Rulebook on the content of the EIA study and on the content of appearance, manner

of keeping public register regarding the act decisions about the EIA; o Rulebook on manner of keeping public register regarding the act decisions about the

EIA. • Rulebook on the contents of requests for the necessity of Impact Assessment and on the

contents of requests for specification of scope and contents of the EIA Study (“Official Gazette of RS” No. 69/05)

• Rulebook on the contents of the EIA Study (“Official Gazette of RS” No. 69/05)

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• Rulebook on the procedure of public inspection, presentation and public consultation about the EIA Study (“Official Gazette of RS” No. 69/05)

• Rulebook on the work of the Technical Committee for the EIA Study (“Official Gazette of RS” No. 69/05)

• Regulations on permitted noise level in the environment (“Official Gazette of RS” No. 72/10) • Decree on establishing classification of water bodies (“Official Gazette of SRS” No. 5/68) • Regulations on hazardous pollutants in waters (“Official Gazette of SRS” No. 31/82)

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Annex 2. Public consultations related documents

Photo from the start of the Public Consultations held on 5 March 2019.

Photo of the orginal List of Participants

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Additional photo of the orginal List of Participants

Photo of the Invitation notice for the Public Consultations held on 5 March 2019.

Environmental Management Plan for sub-project in SREMSKA ... · to the site of the proposed...

Documents

Transcript of Environmental Management Plan for sub-project in SREMSKA ... · to the site of the proposed...