Corection Protocol v.3 Iunie 2010

Correction Protocol for version 3

of application and supporting documents for “Extension and Rehabilitation of Water Supply and Wastewater Systems in Mureş County”

TA Number : Technical Assistance for project preparation in the drinking water and wastewater infrastructure in Mureş County

ISPA Measure No 2005 RO 16 P PA 001-03

Project : Extension and Rehabilitation of Water Supply and Wastewater Systems in Mureş County

Task : Revised version of application and supporting documents for “Extension and Rehabilitation of Water Supply

and Wastewater Systems in Mureş County”

Consultants : Eptisa România/ MVV Energie AG/RODECO

Status date : June 29, 2010

This protocol represent the additions and corrections requested from the Ministry of Environment to complete the documentation needed for the submission of the application for EC grant for the above indicated project under the Cohesion Fund.

Application Form To be fill in by the Consultant

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1. General comment

- Please make sure various documents (AF, FS, annexes, etc) which are part of the Financing Application have the same project title. The main concerns are raised by the local decisions for FS approval, land availability and

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EIA documents. It is not acceptable to have different titles for the same project.

2. B.2.4.1B.2.5

3 Please fill in the corresponding percentages for the specified codes.

3. General remark

5 By only comparing the cost of component 9 (Band-Panet) and 10 (Niraj valley), respectively €2.8 and €4.7 million, and the length of the trunks to be constructed, respectively 25 km and 33.1 km, and considering the topography of the two areas (fairly hilly for the former, flat for the latter), the cost of the second scheme seems high compared with the first one: +70% (while only 1/3 longer).

4. General remark

7 We would advise to provide 3 separate maps for the “trunk” component of the application in order to make the application more readable and to be able to easily identify the localities benefiting from the CF project (the Application indicates that the area covered by the project concern 41 localities, on top of the main municipalities and cities). The map provide in the AF p 7 is hardly readable.

5. Chapter B 17/Table B.4.1.8

The treatment capacity of the WWTP Sighisoara after completion of the project (2014) is ensured for 37.440 p.e., while, for the year 2014, it is provided a loading in the WWTP for 42.561 p.e. and, for the year 2018, for 41.913 p.e.This WWTP is undersized. Please explain.

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The treatment capacity of the WWTP Tarnaveni after completion of the project (2014) is ensured for 42.312 p.e. while, for the year 2014, it is provided a loading in the WWTP for 30.291 p.e. and, for the year 2018, for 29.713 p.e.This WWTP is oversized. Please explain.

6. Technical aspects

18 “As all agglomerations subject to this project have more than 10,000 p.e…..” (see Iernut agglomeration)Please revise the text.

7. 22 The extension and rehabilitation of the networks in Targu Mures include some 35 Km of pipes in total. Assuming an average pace of works of 30 m/day (which is normally achievable for this type of works) this result in some 1167 working days, which is a lot. As the works are subject to a single contract, please clarify whether they will be tendered on lots, or otherwise it will be extremely difficult, if not impossible, to observe the implementation period.The specific indicator investment costs per losses avoided should be compared to the cost of supplying of 1 m3 of water, in order to substantiate the rehabilitation efficiency. The same comment is also valid for the indicator investment cost per infiltration avoided, which should be compared to the cost of the collection and treatment of 1 m3 of

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wastewater. This is applicable to all water supply zones/agglomerations, otherwise, if the indicators are not benchmarked, they have no relevance.

8. AF, B.4.2 22-29 Please having in mind that when carrying out sludge disposal, the provisions of art. 7 of GD 349/2005 must be complied with

9. Component 3 and Component 7

25 It is stated that Sighisoara and Cristuru Secuiesc agglomerations have more than 10.000 p.e. Therefore, the reduction of the nutrients in WWTP’s /tertiary treatment is necessary. Please add the performance of this ongoing projects financed by BDCE.

10. Component 6

30 It is stated that Iernut agglomeration has less than 10.000 p.e. Therefore, the reduction of the nutrients in the WWTP is not necessary.’’At the same time, the new process must include an advanced biological treatment, where the nutrients are reduced below the required limits, and an improved sludge processing process.’’ Please revise the text.

11. 32 Rehabilitation of the trunk main Vorniceni-Sarmasu includes 41.6 km of pipes (entirely?), plus 3 pumping stations, plus 4 reservoirs. According to Consultant’s estimate (see table 1 on page 5 of the AF), these would cost 9.8 M €. This results in an average of 235 €/m, including everything. We estimate that this cost would cover 1 linear metre of 400 mm HDPE pipe.

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It would be useful to know the (range of) diameter(s) of the trunk main and what does the rehabilitation of the pumping stations and reservoir consist of. It is also recommended to have an indication (or reference) on unitary costs of each component subject to rehabilitation, as the indicator investment cost/losses avoided is high. Please clarify.

12. Component 9

34 It is stated that “both cities have already built complete distribution systems…” What is the overall condition of those? Do they fit to the design parameters of the infrastructure proposed in the CF project (i.e. flows, heads)? Are the materials suitable? Such information is necessary, as the risk that the newly created infrastructure will not operate in good condition, if the distribution network performance is poor, cannot be ignored. The per capita cost of this investment is 470 €. This is considerably high, therefore the affordability of this investment component is questionable, especially bearing in mind that the generated wastewater will have to be collected and treated, and the related investments will put an additional burden on the customers. Please clarify.

13. Component 10

35 The Consultant raised the issue of “the pollution of the zone, especially of the Niraj river”. This statement induces few problems: (1) is anything envisaged in relation with the control of this pollution? (2) what is the impact

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of such pollution on the quality of the envisaged water source for the proposed treatment works, and (3) the wastewater collection and treatment should be an immediate priority.Another matter of concern is that the system will depend on a single source, and as neither storage facilities, nor inter-connection to another system seem to have been envisaged, it is not clear what is going to happen in the case of an accidental pollution or failure of the intake/DWTP. Please clarify.

14. Component 10

35 ”Niraj Valley is one of the most densely populated areas in Transylvania[...]”.Please indicate the figure corresponding to this population density (per km2).Although no information is reported in this respect, do distribution networks already exist in localities in the Valley? What’s about wastewater? Chapter 4 (current situation and projections) is silent in this respect and information in annex 29 and annex X limited and not self explanatory (e.g. tables).Also, please explain on which basis were the different localities composing Niraj valley component chosen?

15. Component 10

35 Please provide a breakdown for the population within the different localities included in component 10 as it is not clear what “18.275 inhabitants (2014)” refers to.

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Please note that only 12 localities are mentioned in Annex 10, which reference is made to, with a total population not exceeding 8,500 inhabitants.Also please explain why the AF presents 30 localities instead?

16. B.4.2 37 Main physical indicators table – there are still some inconsistencies of the figures in the table with those provided in previous section (project component description):

- Catchment rehabilitation – no mention about this investment in project description;

- New trunk main – the correct value is 52,885 km (19,670 Band Panet + 33,125 Valea Nirajului), not 52,380 km, as mentioned in the table;

- New and rehabilitated pumping stations – there are at least 7 new DWPS (3 in Sighisoara, 1 in Ludus, 2 in Band Panet and 1 in Valea Nirajului) and 3 rehabilitated (Voiniceni, Campenita, Pogaceaua) – please revise the figures in the table; as well, please clarify the number of pumping stations (new and/or rehabilitated) in Targu Mures (it is stated “revamping of pumping stations”, not being clear how many);

- SCADA system – no SCADA system was mentioned in the description of project components;

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- New/rehabilitated waste water pumping stations – there are 17 new and 8 rehabilitated, according to the project component section, and not 22 new and 3 rehabilitated, as mentioned in the indicators table; please clarify which figure is correct;

- Please clarify what “connection – extended/rehabilitated network” means; no mention about this investment in the project description;

- Discharge pipe – no mention was done about this type of investment; please clarify!

As well, please ensure correlation of the whole list of indicators with those provided in other chapters of the AF (i.e. tables B.5.1.1 - B.5.1.9) or other documents (Feasibility Study, various annexes, local decisions for FS approval).

17. B.4.2

andChapter 1andChapter 9

page 37-38andpage 11andpage 19

Please correlate data from these chapters concerning the pumping stations for Tg.Mures.“The Northern II + III area pumping station located on 4 Verii St. is an over ground construction, the pumps being placed” ( chap.9), this clearly states one construction for 2 PS.

18. B.5.1. Current infrastruct

39 Although it is mentioned that one of the project objectives will “ - Reducing of the water losses in the project area by distribution

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ure endowment and impact of the project

network rehabilitation from a percentage 38% in 2008 to 26% in 2014. ”why do the water losses in the CBA increase in the second half of the projection period up to reach high level of losses: 50% in Reghin, 51% in Ludus notably? Please clarify.

19. B.5.1 61 and followings

Table B.5.1 – 23 – Performance indicators water supply:

- 2.4.7 (length of transmission main) – please clarify which is the correct value before and after the project;

20. Water abstraction

83 It is stated that “the water abstraction shall be entirely done through surface intake”. This statement is not correct in the case of the water supply systems which are further analysed, as in certain options, some systems are considered to be served by (a) new well field(s). Please clarify.

21. AF, section E

90 -91 This referred to provision of GD 349/2005 concerning the industrial waste landfills which have complied in terms of activity until July 16th 2009.The landfills listed in the “Sludge Management Option” are non-compliant municipal landfills which, in accordance with Annex 5 of GD 349/2009, have ceased their activity within the envisaged deadlines. Furthermore, the non-compliant landfill at Tarnaveni is under closure procedure.Please revise “Sludge Management Option”

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considering all of the above.22. AF,

section E90 -91 HG 349/2005, art.26, (3) refers to non-compliant

landfills not to “non-hazardous industrial waste” which is art.26, (2).

23. Options for Niraj Valley

92 In all options, only surface catchment and the associated treatment plants were considered. Please explain the reasons for which underground water sources were not analysed. The hydro geological survey is talking about “reduced potential aquifer and water quality potentially non-potable”, and in our opinion this possibility (i.e. use of drains for water abstraction and adequate treatment depending on the raw water quality) cannot be ignored.

24. D.1 102 Please fill in with complete dates in the following format dd/mm/yyyy.

25. AF, Section F.4.1

109 Please present in the text, as a summary, the status of the project sites in terms of NATURA 2000, including the distance from the each project component to the nearest NATURA 2000 sits.

26. E.2.2 115 Table with project benefits and costs – all the figures must be expressed with two decimal digits. The total percentage for each of the two (benefits and costs) should be 100%. Please correct accordingly.

27. E.2.4 116 New jobs created – please fill in the average duration of the jobs during the operational phase (12 * number of years of the operational phase)

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28. E.3.2 117 Sensitivity analysis- critical variables:Please clarify which are the financial and economic indicators which the variables tested refer to – only FRR and ERR are mentioned. FNPV and ENPV should be also specified.

29. F.3.2.3 125 - Please attach to Application Form the Screening Decisions in a distinct Annex.- Please attach to Application Form the EIA Summaries in a distinct Annex.

30. F.5 127 - The information related to Natura 2000 sites are related to the execution of works.

31. F.6 128 Please complete accordingly the percentage taking into account only the costs of the measures -additional measures apart of those included in legislation-) taken through the project to reduce and/or compensate negative environmental impacts and considered in the CBA. Please make also the corresponding link with F 5.

32. AF, Section F.6

128 Some of the presented measures are not mitigation measures (for example “solid waste collection and disposal” or “ecological toilets during the construction period”).The mitigation measures have to be more specific and the cost estimation has to be available.Please revise.

33. F.7 128 - According to the compliance with Accession

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Treaty, please add the necessary information, emphasizing the reach of the targets through the project (percentages and corresponding years) for the agglomerations from project area, considering both wastewater and drinking water. - Please explain how the project is consistent with Urban Waste Water Directive and Water Framework Directive. Please avoid the general information related to this issue and focus on the project components.- Regarding the reference to the accession Treaty, should distinguish the deadlines afferent to the treatment (2015) and to the collection (2013) for agglomerations above 10, 000 p.e.- Related to the special request of EC, please provide for each agglomeration the information on whether the project is coherent with the achievement of the environmental objectives set in the River Basin Management Plans/WFD (see the water permits and detail with relevant information regarding the discharge limits for N, P and BOD).

It is not necessary to attach the included tables; please provide only the relevant information taking into account the above requests.

34. I.4.3 141 Conclusions of JASPERS intervention – we recommend you to add the following

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paragraphs:

- The proposed project is coherent with the EU policies for environment and the Convergence objective; the project brings an important contribution to the Accession Treaty obligations of Romania in the field of environment.

- The proposed project is compliant with the SOP Environment document; social, institutional and economic contexts are well described, project objectives are defined; relevant options assessed.

- The Managing Authority should ensure that the co-financing funds are available in due time in order to avoid project bottlenecks during implementation.

35. Appendix I - It hasn’t been revised. The NATURA 2000 Declarations are the same.

Please attach the revised Natura 2000 Declarations; each of them must be followed by the new corresponding map.

36. Appendix I Are Voiniceni –Sarmaşu and Band –Pănet included in the Declaration ?If so, then “main trunk” should be also included within the works (not title of the project)

37. Appendix I Please replace the existing map in Appendix I with NATURA 2000 maps from Volume VI –

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EIA.Tirgu Mures Agglomeration: Voiniceni – Sarmas Main trunk rehabilitation seems to carry on in ROSCI0079 and ROSCI0100 sits.Sighisoara Agglomeration: Main trunk and water treatment plant rehabilitation seems to carry on in or nearest ROSPA0099 and ROSCI0186 sits.Iernut Agglomeration: The investments seem to carry on nearest ROSPA0041 and ROSCI0210 sits.In these cases, the information from NATURA 2000 Declaration is not correlated with the information from map attached. Please explain.

38. EIA Annexes

- Related to the additional EIA documents please attach to Application Form only the following distinct annexes: - Annex with “Summary of EIA procedure”: this annex must include only the timetables for EIA procedure - the documents named Annex 2, issued and signed by EPAs (the original documents); - Annex with the “Screening Decisions” (the original documents).Please clarify for Iernut if are Natura 2000 sites in the vicinity of agglomeration; in the screening decision are not relevant information. Please see Sighisoara for a good example.

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39. AF-Annex 2

59/Table 33and189/Table 137

Table 33: “Total investment” the value of 110,876,128 euro, as in table 137 “Total investment” 110,875,965 euro. Please correct.

40. Annex III - Done but please reintroduce in the Annex III the documents regulating the activity (“Notificare”).

Volume II : FS written part To be fill in by the Consultant

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41. Project Summary

16/Band -Panet trunk main

We draw attention again that a description of the actual status of the distribution systems in the villages is required. Option 3 has been eliminated, as only RO and membrane technologies were considered,, without any further explanation for this decision. In the absence of some raw water quality data, it is difficult to decide whether no other technologies could have been considered, i.e. activated carbon filtration, for odour, taste and chlorine removal. Please clarify.

42. Project Summary

17/Table 4

If only the investment cost/capita for the drinking water related investments reaches 430 €/capita, if we consider in addition the

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impact of the wastewater collection and treatment (as we understand that the local authorities undertook the responsibility of full compliance by 2013), we would expect that the overall investments will induce an affordability issue at the level of the local authorities. Please clarify.

43. Project Summary

23/New treatment plant and trunk main Miercurea Nirajului-Gheorghe Doja

From table 14, it results that there are a number of water supply and wastewater projects, which, if we understand correctly, are under preparation/ implementation (the Consultant to confirm). In this case, which are the water sources for certain localities, like Roteni, Acatari, Magherani, Vargata, Vadu, etc? Is it really correct that underground water cannot be used? On the other hand, which are the basis of the design for the for the WWTPs under these projects? Is the agglomeration concept observed? Are the design parameters in line with the design parameters in line with the design parameters in the CF project? The other problem is that the beneficiary population of the CF project is significantly reduced, if we take in consideration these projects. In this case, the per capita cost of the CF project will increase. Please clarify.

44.s

Project Summary

28 It is stated by the Consultant that “the Niraj river presents a set of negative characteristics, as risk of flooding and for attenuate it at County Council level a lot of

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reparative measures were taken, as the erecting a dam…” This raises a concern with regard to the technical solution proposed by the Consultant, as:- The flood risk seem to exist, therefore a

flood risk survey should be prepared, for the intake and the DWTP;

- As this seems to be flood scheme, it is not clear whether the necessary flow will be ensured at all times, for the water supply;

- Data on raw water quality from Niraj river should be provided, and also a brief description of the proposed processes in the DWTP.

These aspects need to be clarified in every detail.

45. Project Summary

Chap.1.5.1 and the following...and Annex B1

Please correlate the tables from chapter 1.5.1 and the following with the Annex B1 – Estimated population

46. Project Summary

77 Which system is analysed? In any case, it is unclear why the percent of NRW is going to sharply increase by 2014. Please clarify.

47. Project Summary

107/Table 80

It is not clear what the measurement units are. What is the meaning of “residual water volume”? Please clarify.

48. Project 109/ The volume is at 35% D.S. content? If yes,

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Summary Table 83 the density of the sludge should be something like 1.15 tonnes/m3, therefore the mass should be 16,307 tonnes, in the case of Targu Mures for 2014, for example. The D.S. content will be some 5,708 tonnes/year. Please clarify and check all the figures, as well as the others relevant tables in section 1.8.5.

49. Project Summary

Page 134/Table 110

Given the results of the sludge disposal option analysis, we do not understand the need to reach 92% D.S. content in the case of Targu Mures. Please clarify.

50. Project Summary

Page 156/Table 116

Is it coorect that in the case of Ludus the investment cost/length is less than 18 €/m and in the case of Iernut is 45 €/m? If the answer is yes, a justification for such low unit costs is necessary. The same comment is also valid for the similar indicators in table 119, for Sighisoara, Ludus, Iernut and Cristuru Secuiesc.

51. Project Summary

162/Table 125

It is difficult to understand why the unitary costs for Band-Panet are higher than those for Miercurea Nirajului, as in the case of Band-Panet the diameters are larger (with the highest proportion of 125 mm and 225 mm) and in the case of Miercurea Nirajului, the diameters vary between 110 and 225 mm, with a higher proportion of 225 mm, indeed. Is it due to the more difficult ground conditions and limited space for the pipe routes? Please clarify.

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52. Analysis of current situation and forecasts

109-/Table 117

By dividing the domestic component of the wastewater volume by the domestic component of the water demand, we have calculated a return ration to the sewerage of only 50%. Is this due to the rural nature of the Ludus agglomeration and low percentage of connection at present? Please clarify, as for an urban area (even for a rural one) this return ration is quite low. The same question is also valid for Iernut (60%).

53. Analysis of current situation and forecasts

227-232 Please consider providing additional information on Voiniceni-Samas, and-Panet and Niraj Valley components in respect of the existing situation of the water supply systems: despite the presence of sub-chapters in the table of content, there is no information for the last two components. And nothing is mentioned aid about wastewater.Please indicate, in particular, the current state of the situation in respect of existing water distribution network (and possible wastewater networks), existing customer connections and other relevant data.

54. Sludge Management

General request

In case of each WWTP from the project area it is necessary to detail the related proposed facilities for dewatering (including for 35%DS), disinfection and the necessary temporary storage capacities

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- To prove the availability for the landfilling, please correlate the data related to the capacity of the available landfills, including the temporary storage facilities (drying beds and the project facilities), and the total quantities (m3) of sludge from the corresponding relevant WWTPs estimated per year.

- In the sludge strategy must be included also information related to the management of residues from WWTP (sewage cleaning, grease, sand washing) – quantifying the corresponding volumes and loads.

- The relevant sludge treatment and disposal costs (including the operation cost, the treatment for the pathogens, dewatering and temporary storage or transport, etc). Please consider that the costs related to the Sludge Strategy must be included in CBA and summarise accordingly in the table 54, considering the selected option no. 4 (without incineration).

- It is necessary to send to EC a sound decision related to sludge disposal. This Decision, based on Sludge Strategy, should be approved by ROC and IDA.

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See the MoE models for agreements of relevant authorities and sanitation operator, and also for Beneficiary Decision.

For the final version of Sludge Disposal Strategy must consult EPA to include specific information in the relevant documents from EIA procedure.


17/Table 8

Which are the measurement units in the table? What does it mean “residual water volume” – is it the inlet flow in the WWTP? Please clarify. Same comment is also valid form table 12 on page 20-83.


19/6.6.2. Future sludge quantities

Please be more specific related to the temporary storage facilities. Please mention what kind of additional storage facilities are envisaged for each WWTP and their capacity (m3). It is necessary also to specify the capacity (m3) of the existing drying beds.For the total storage capacity of each WWTP from the project, please correlate the production of the sludge with the

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available capacities.57. Sludge

Management

21/6.7.2. Landfilling

According to HG 349/2005, art.26, (3) refers to non-compliant landfills not to “non-hazardous industrial waste” which is art.26, (2).

- Please clarify the relevance of the following statement: In accordance with the provisions of HG 349/2005 "the existing non-hazardous industrial waste landfills that comply until July 16, 2009 continues to operate until depletion of designed capacity." Please review GO 349/2005, taking into consideration the article no.26: “(3)Depozitele existente neconforme prevăzute în anexa nr. 5 sistează activitatea conform calendarului de sistare a activităţii prevăzut în anexă şi aplică prevederile legale de operare şi monitorizare în vederea închiderii sau aplică prevederile legale în vederea închiderii şi urmăririi postînchidere.”

- Please detail in the text the information for the new ecological landfill from Sanpaul, mentioning the real capacity and the real life period for disposal. Please contact the Consultant who prepared this project (the information from MP is not relevant; see also the page 28).

- The interruption year for Sighisoara is

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2019 or 2017? Please clarify with the same Consultant.

It is necessary to be revised the information presented for the landfilling having in view the specific conditions of this County and also the provisions of the legislation. Sound conclusion related this alternative should be assumed into the sludge strategy according to the responsibility of the Consultant.

In this respect it is necessary to delete the following considerations: “Management of sludge from the WWTPs for the period 2010-2013, will respect the decisions of local authorities and regional operator. In case that this short-term strategy (2010 - 2013) is not accepted by the AM, we are waiting instructions, to complete the strategy in a subsequent review of the documentation “


23/6.7.4.2 Reuse in forestry (reforestation)

Please consult the territorial Forestry Directorate to obtain the official and updated information related to the total area of the forestry.


32-83/Table 24

Please note that the table contains the quantities of sludge produced after the WWTPs rehabilitation, and not before.

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25/6.8. Strategic sludge disposal alternatives

Please include for the appropriate alternatives a clear conclusion related to the disposal of the sludge from the WWTPs from the project area, having in view the entire horizon of the strategy: short, medium and long term periods.


28/6.8.4. Investigation of the Disposal at Landfill

Please contact the Consultant who prepared this project related to the site of a new landfill at Sanpaul (the information from MP is not relevant).


28/6.9.Strategy proposed for Sludge Storage

- Table 19: Please clarify the included information for Cristuru – 35% DS before project and 25% after project. The information from the water company is not convincing; please take into consideration the real situation and revise accordingly.

- Table 26: Regarding the sludge from WTPs please consult EPA related to the selected 2 solutions for disposal: landfill and sewerage network, having in view the content of this type of sludge.


34-83/Table 27

Please note that if in the first row of the table the figures represent the D.S. content of the sludge, then the data is wrong, as the whole amount of sludge will have to be

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landfilled, not only its 35% D.S. content. Please check and revise accordingly. The same comment is also valid for the others disposal options.


35/Option Agriculture use

Please correlate the figures with those mentioned in chapter 6.8.1


42/6.9.3. Selected option

- Having in view that for the 2014-2039 all the sludge production from Targu Mures WWTP will be disposed at Sanpaul landfill, please revise the Table 27 considering the real capacity of the landfill (not from MP). Please be aware that the dewatering process in order to obtain minimum 35% DS requested for landfilling must be precisely proved. Please be aware that the dewatering process in order to obtain minimum 35% DS requested for landfilling must be precisely proved.

- Please detail the following information related to selected option (no. 4): “Short term period 2010 – 2013 the sludge is stored in current storage facilities.” Please explain for each WWTP what type of storage facilities are currently available for the corresponding quantities.

66. Sludge Managem

50/ 6.10.1.

Please correlate all the included information with those mentioned in Chapter 6.9.3 and

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ent Action plan for selected option implementation

6.10.

67. Option analysis

15/Voiniceni-Sarmasu trunk main

The option analysis for the trunk main rehabilitation does not make any sense, as it is obvious that an additional pumping station will induce additional costs, for both, investment and O&M. We would have expected to see a comparison between “do nothing” option and the rehabilitation of the trunk main and existing pumping stations. Please consider.

68. Option analysis

15/Panet-Band trunk main

Again, the option analysis is artificial. It is necessary to have an option analysis between the use of Targu Mures source, against local underground water sources, starting from a sound identification of the underground water potential yield and quality parameters and the associated costs for abstraction and treatment.

69. Option analysis

16/ Water treatment plant and trunkmain for Valea Nirajului

It is stated that “the only source of water for water supply in localities in the region Niraj Valley is the river Niraj”. On the other hand, in the Project Summary section (Page 23-2-7 table 14) it is noticed that there are a number of water supply projects, probably based on other sources. Please clarify.

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70. Option analysis

85/ WWTP rehabilitation – sludge line

As long as a 35% D.S. content of the sludge is required by the legislation in force for landfilling, we do not understand why the chemical conditioning of the sludge (lime use, “Kemi-Cond”, etc) was totally ignored in the option analysis. The use of chemicals to condition sludge for dewatering is economical because of the increased yields and greater flexibility obtained. On the other hand, the use of heat drying induces fire and explosion hazards. The prevention measures associated to this (venting systems, nitrogen padding, etc) are quite costly. Another problem is the air pollution (by fly ash) and odour control, which must be carefully considered. The Consultant must confirm whether these aspects have been taken in consideration in the Option Analysis and in the CBA. Please clarify, as from the brief description of Option 2, this does not seem to be the case.

71. Project presentation

9.1.1.1Targu Mures water supply zone

We have noticed that the new distribution pipes (see figure 1 on page 18-303) are of a branch type, in most of the cases. We draw attention that in a branch type network, only one path of supply reaching a demand node may cost less, but at the same time, will have low reliability. In such a case, if any of the pipelines fail, the subsequent demand node will not receive any water. However, in a loop type water distribution

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Req. No.

Chapter /Annex

Page/Para.


/PageComments

network, as the number of paths increases, the cost as well as the reliability increases. The comment is also valid for others supply zones, where applicable.

Volume III : FS - Annexes To be fill in by the Consultant

Req. Nr.

Chapter/

Annex

Page/Para.

Addition/Correction Requested

Chapter/Annex

Page/Para.

Comments

72. Hydro -geological Study

8.2 Reference is made to some hydro-geological studies, performed by different entities. We would have expected to see some yield and quality related information from these studies. It is also important to know when such studies were performed.

73.

Vol.II-Annex A

Annex A.2.7

Regarding the General Cost Breakdown for TAU’s (Annex A2.7) and the General Cost Breakdown in constant prices (Annex A2.4), the columns “with/without TVA in RON” and the official exchange rate published by the Romanian National Bank on the date when the estimate has been made must be added.

Annexes not presented as in the FS Guide.

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Volume IV: Cost Benefit Analysis To be fill in by the Consultant

Req. Nr.

Chapter/

Annex

Page/Para.

Addition/Correction Requested

Chapter/Annex

Page/Para.

Comments

74. General

As previously requested, please provide us with all the different files attached to the main model (Mures CBA.xlsx) that give detailed information on input data used in the main model (“Afordabilitate Mures.xlsx’ has not been provided for instance).

75. General Please explain why affordability limits, for the lowest deciles, are already exceeding the 4% threshold before the project starts: 4.23% as of 2009?

76. General As far as the specific water consumption is concerned, all the WSZ are supposed to average 80-85 lcd until 2019 (Niraj and Iernut below 70 lcd).Are there any explanations for these relatively low level of consumptions? If not, we believe that such levels could lead to some underestimations and ill design infrastructures.The value calculated should be checked and if confirmed some explanations provided to substantiate this unusual situation (compared with other Counties in Romania).

77. Model What does the WSA in the “Sales NOPro/Pro” worksheet refer to?

78. Model The connection profile does not seem realistic, not matching the technical part of the FS and procurement strategy. The treatment of Niraj, in particular, within the model is very unclear:

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around 1,300 new water connections are mentioned for the year 2012 (from none in 2011, those connections being out of the current CF application) and more than 6,000 additional connections (in connection with the current application) are forecasted in the following year.

How realistic are these figures in terms of works required? How are these new connections supposed to be financed?Please explain and clarify.

79. Model In relation with the above, some questions need to be clarified in relation with the Demand analysis component. Although we present specific questions related to the Niraj valley component in the following, similar questions and remarks can be raised for most of the WSZ and Agglomerations:

1. Why does the per capita per day consumption in Niraj remain below 70 lcd, before (low waste watercoverage) and after project (100% wastewater coverage)? Once wastewater services are in place, shouldn’t we expect an increase in per capita consumption? Please explain and clarify.

2. Why should the non-domestic consumption follow the same growth pattern as the domestic one? Aren’t institutions or companies, by and large, already supplied with water? Please explain.

3. Why should the non revenue water jump to 35% from 6% with the construction of new network? And why should there be a

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big jump in 2015 (from 25% to36%) in non revenue water? Please clarify.

4. While the number of consumers will be higher thanks to the project, the total billed volume of water in the Nopro scenario is often higher (while the current litre per capita consumption that is already quite low, around 70-80 lcd in most of the WSZ). Please clarify.

The level of non-revenue water taken into consideration does not seem consistent with the technical part of the FS and within the CBA itself: in all WSZ important increases have been projected in the second half of the projection period (up to 50% and 51% for Reghin and Ludus respectively). Please clarify and/or correct

80. Model In Targu Mures, why does the CBA model project a level of losses going down to 19% in 2014, keeping this level for the following 14 years, and then report increases reaching, at the end of the project period 27%(2039)? Please clarify and correlate with the FS.

81. 7.4.5 Supportability Analysis

107 This revised version of the CBA presents an affordability analysis and by doing so present a new situation far less problematic than in the previous one:- affordability limits are slightly exceeding 4% until 2019, but the magnitude of the affordability problem is less obvious compared with the previous version in which it ran until 2021, with some affordability peaks above or close to 6% between 2011-2014.

However, the main reason that explains this change is debatable. It is indeed based on the

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calculation of new per capita daily consumptions. While 75 lcd was previously used, as recommended by the CBA Guidelines, the Consultant has used a figure corresponding to 68% of the average county consumption level (75/110 lcd for 68%).

Unless such change is explained and substantiated by specific conditions or circumstances, we are of the opinion that this recalculation is not correct. The 75 lcd consumption level should be considered as a basic allowance: a minimum level of water enabling the satisfaction of basic needs under normal conditions (presence of both water and sewerage services). Indeed, in absence of running water, the United Nations reports that daily consumption levels of 20-50 litres are very common in most of the developing countries. Therefore, it is rather unlikely that individual consumption in Romania will fall below a level of 75 lcd and close to 60. This does not mean that this will never happen. There might be situations indeed in which the presence of alternative source of water for instance may lower the consumption from public network. But unless clear evidences are provided to explain such consumption low consumption levels, we recommend the use of 75 lcd.

The affordability analysis should be revised.82. 7.5.3

the Financial

110 The return of the project is supposed to worsen after the Community assistance: FRR/C -4.75% while -5.14% FRR/K. Please explain and/or check.

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indicators of the project

83. Demand analysis

The excel file showing demand data is missing and therefore the demand analysis couldn’t be properly checked.

84. Eligible/ ineligible costs

Please see the comments presented above on the Application Form section regarding the calculation of an ineligible part of the price adjustments, the total ineligible costs and the correlation between the tables reported in the Application form.

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Volume V: Institutional Analysis To be fill in by the Consultant

Req No

Chapter/

Annex

Page/Para.

Addition/Correction RequestedChapter/

Annex Page/Para.

Comments

85. Vol I Cap 11

14/11.4.2

RoC’ s shareholders table. Review Targu Mures’ s shares – 6.191.700 RON, the total value of the capital and the percentages of each shareholder

86. Vol I Cap 11

16/11.5.1.

RoC’ s shareholders table. Review the total value of the capital.

87. Vol I Cap 11

20-24 /11.5.2

Please update tables 7 – 15 with recent dates

88. Volume V

25/4.2.2

Review RoC’ s shareholders table

89. Volume V

44-48 /4.3.7.1-3

Please update tables 15-25 with recent dates

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Volume VI: EIA To be fill in by the Consultant

Req No

Chapter/

Annex

Page/Para.

Addition/Correction RequestedChapter/

Annex Page/Para.

Comments

90. General request

- Please include for each agglomerations only the following documents: the annexes 1 and 2 issued by EPA, all documents mentioned in the Annex 2 (signed by EPA) in the same order from this Annex, and also the revised Natura 2000 Declarations and the corresponding maps.The title of the major project is missing for all EIA documents!

Note: Please verify the status of the documents submitted in the table bellow.

Analiza InstitutionalaDocument Evaluat Corectie

/ConformareObservatii

Statut/Act Constitutiv ADI DA Conform POSHCL/HCJ infiintare/modificare Statut/Act Constitutiv ADI

DA/Lipsa

Conform POS Trebuie transmise si HCL/HCJ de modificare a Statutului si a Actului Constitutiv – Adaugat Act modificare Act Constitutiv ADI in Anexa 7Se vor transmite si HCL de modificare din noiembrie 2008

Certificat inregistrare ADI DA Conform POS

Act Constitutiv Operator Regional (OR) DA Conform POSHCL/HCJ infiintare/modificare Act Constitutiv OR DA/

LipsaConform POS Trebuie transmise si HCL/HCJ de modificare a

Actului Constitutiv – Adaugat act modificare OR in Anexa 7

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Va rog sa indicati paginileCertificat inregistrare OR DA Conform POS

Contractul Unic de Delegare a Gestiunii Serviciilor (CDMS)

DA Conform POS/ Neconform

Contractul este semnat si de UAT care nu sunt membre ale ADI - Bagaciu, Saulia, Petelea, Fanatnele, Apold, Craiesti, Avramesti, Silivasu de Campie, Urmenis –se impune introducerea lor in ADI - Adaugat Act modificare Act Constitutiv ADI in Anexa 7

HCL/HCJ aprobare CDMS DA Conform POS/ Neconforme

1.HCL neconforme Craciunesti, Corunca, Ernei, Livezeni, Madaras, Zau de Campie – nu aproba si delegarea gestiunii2. HCL Ibanesti – neconforma – art 5 eliminat3. Este necesara si punerea la dispozitie a HCL Targu Mures nr.98/2009Adaugat CDMS actualizat din 05.03.2010 in Anexa 7Au fost transmise doar HCJ Mures si Reghin

HCJ privind aprobarea Master Planului şi a listei de investiţii

DA Neconforma nu este aprobata si lista de investitii

HCJ privind aprobarea Studiului de fezabilitate şi a indicatorilor tehnico-economici ai proiectului

Lipsa Document ce va fi inaintat dupa aprobarea variantei draft a Aplicatiei.

Avizul Adunării Generale a Asociaţilor ADI privind aprobarea Studiului de fezabilitate şi a indicatorilor tehnico-economici ai proiectului


Avizul CTE al OR privind aprobarea Studiului de fezabilitate şi a indicatorilor tehnico-economici ai proiectului


HCJ/HCL-uri privind aprobarea cofinanţării proiectului (cheltuieli eligibile şi neeligibile)

Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.

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Planul anual de evoluţie a tarifelor (conform rezultatelor Analizei Cost-Beneficiu) aprobat de ADI


Dovezi privind privind proprietatea/posesia autorităţilor locale asupra terenurilor sau accesibilitatea acestora şi privind punerea terenurilor la dispoziţia proiectului - HCL

DA Conforme S-au inaintat HCL emise doar de Cristuru Secuiesc, Ludus, Sighisoara, Panet, CJ Mures, Miercurea Nirajului, Pasareni. Se va verifica daca sunt pentru toate investitiile care se vor realizaLipsa Tg Mures, Reghin, Tarnaveni, Iernut

Adeverinţă prin care se menţionează faptul că nu au fost depuse cereri de retrocedare, în conformitate cu legislaţia în vigoare şi că nu există litigii cu privire la stabilirea şi delimitarea proprietăţii

Da/Lipsa

Conforme/Neconforme

S-au inaintat adeverinte emise doar de Cristuru Secuiesc, Ludus, Sighisoara, Panet – care nu se coreleaza cu HCL in ceea ce priveste investitiile care vor fi efectuatePasareni si Iernut.

Declaraţie de Angajament a Beneficiarului (aprobată şi de ADI)


Declaraţie de Eligibilitate a Beneficiarului Lipsa Documente ce vor fi puse la dispozitie de catre beneficiar.

Scrisori de intenţie de la bănci comerciale/de investiţii privind interesul acestora de a cofinanţa proiectul, dacă este cazul

DA Conform POS

Constituire UIP DA Conform POS

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Corection Protocol v.3 Iunie 2010

Documents

Transcript of Corection Protocol v.3 Iunie 2010