Environmental Safeguard Framework Project Operations Manual...Industry, Mining and Energy (MIME),...

E687Volume 23

Royal Kingdom of Cambodia

Cambodia Provincial and Peri-Urban Water and Sanitation Project(PE073311-KH, PHRD Grant)

Ministry of Industry, Mining and Energy (MIME)Department of Potable Water Supplyd w Phnom Penh

and

Phnom Penh Water Supply Authority (PPWSA)Technical and Project DepartmentPhnom Penh

Environmental Safeguard Framework

Project Operations ManualVersion 1.2 (DRAFT)

Prepared with s upport from Frank Radstake, ConsultantContract for Environmental Assessment Consulting Services

January, 2003

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Provincial and Peri-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA / WB) Project Operations Manual

PREFACE

The present "Environmental Safeguard Framework", as part of the Project OperationsManual, describes the methodology and process to minimize adverse environmentalimpacts and to include proper mitigation measures for the Provincial and Peri-UrbanWater and Sanitation Project (PPUWSP), implemented by Department of Potable WaterSupply, Ministry of Industry, Mining and Energy (MIME), and the Phnom Penh WaterSupply Authority (PPWSA), Kingdom of Cambodia.

The manual is a toolkit for the borrower and/or consultants to prepare EnvironmentalAssessment (EA) reports, to safeguard appropriate environmental monitoring andmanagement, and to obtain the requirecl Environmental Clearances, following bothCambodian Regulations and World Bank guidelines. The various steps for conductingthe assessment are summarized in checklists and flowcharts. Additionally, the manualprovides technical considerations for the possible project components water supply,sanitation, drainage, and wastewater disposal and management.

All relevant Cambodian environmental regulations, World Bank Guidelines, andsupplementary documentation have been compiled on an annexed CD-Rom. Althoughcare has been taken to provide official and the most complete and/or up-to-datereferences, the author does not take any responsibility for the use and application of thecurrent documentation.

The Environmental Assessment activities are carried out under the general supervisionof Mr. Peng Navuth, Director, Department: of Potable Water Supply (DPWS), and Mr.Long Naro, Director, Technical and Project Department, PPWSA. Mr. Sin Vaidia, DeputyDirector DPWS, PPUWSP Project Manager, is responsible for the coordination and dailysupervision of the assignment. Mr. Cheav Channy, Deputy Chief of Technical Office,DPWS, and Mr. Ou Khua Vath, Project and Design Section, PPWSA, have beenassigned as direct counterpart for the technical implementation of the EnvironmentalAssessments.

The Environmental Assessment Consulting Services have been supported through aPHRD grant of the Japanese Government, with support of the Urban DevelopmentSector Unit, East Asia and Pacific Region of the World Bank.

The operations manual will be subject to review during the implementation of the project,and will be updated with experiences and recent findings of the projec t if appropriate.

Frank Radstake, Consultant'Environmental and Water Resources Management AdvisorE-mail: fradstake(caol.com

' Disclaimer: Findings and views expressed in this report are entirely those of the Consultant and should notbe attributed in any matter to the World Bank or to its affiliated organizations.

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TABLE OF CONTENTS

PREFACE

I INTRODUCTION ................................................. 1-1

1.1 PURPOSE OF THE MANUAL .................................................. 1-11.1.1 General ................................................... 1-11.1.2 Report outline ................................................... 1-2

1.2 NATIONAL LEGAL AND ADMINISTRATIVE FRAMEWORK . ................................................ 1-21.2.1 National Environmental Legislation .................... ............................... 1-21.2.2 Water quality standards ................................................... 1-31.2.3 Phnom Penh and the PPWSA ................................................... 1-51.2.4 Other related national regulations .................. ................................. 1-5

1.3 WORLD BANK EA REQUIREMENTS .................................................. 1-61.4 APPLIED PROJECT APPROACH ................................................. 1-6

1.4.1 EA Implementation Methodology ................................................... 1-61.4.2 Public consultation and participaiion ................................................... 1-8

2 DRINKING WATER SOURCES QUALITY IN CAMBODIA ................................................ 2-1

2.1 INTRODUCTION ................................................. 2-12.2 CURRENT STATUS ................................................. 2-12.3 CONCLUSIONS ................................................. 2-2

3 ENVIRONMENTAL STATUS OF SUB-PROJECT LOCATIONS ....................................... 3-1

3.1 GENERAL ......................... 3-13.2 MAIN FINDINGS ......................... 3-33.3 SUMMARY AND CONCLUSIONS ......................... 3-4

4 SCREENING PROCEDURES ......................... 4-1

4.1 RATIONAL ........................... 4-14.2 REPORTING PROCEDURES SMALLER SYSTEMS (<2000 CONNECTIONS) . .. 4-24.3 REPORTING PROCEDURES LARGER SYSTEMS (22000 CONNECTIONS) . .. 4-2

4.3.1 Process . 4-24.3.2 EA Report contents . 4-24.3.3 Drafting the Environmental Management Plan . 4-44.3.4 Conclusions and recommendations . 4-6

4.4 SUBMISSION AND FOLLOW-UP .. 4-74.5 PUBLIC CONSULTATION .. . 4-8

4.5.1 Documentation of the EA Process . 4-84.5.2 Proof of Social Acceptability . 4-8

4.6 MISCELLANEOUS .. 4-94.6.1 Arsenic Mitigation . 4-94.6.2 Sanitation . 4-10

5 INSTITUTIONAL ARRANGEMENTS . 5-1

5.1 RESPONSIBILITY FOR FRAMEWORK IMPLEMENTATION . 5-15.2 ENVIRONMENTAL ASSESSMENT . 5-15.3 COMPLIANCE MONITORING . 5-1

6 MAIN REFERENCES AND BACKGROUND DOCUMENTATION . 6-1

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LIST OF FIGURESFigure 1 - Schematic presentation of EA scheduling ..................................................... 1-7Figure 2 - Location map of current sub-project ............................................................. 3-1Figure 3 - Applied EA Process ................................................................. 4-1

LIST OF TABLESTable 1 - Main proposed drinking water quality standards ............................................ 1-3Table 2 - Cambodian and International effluent s tandards and guidelines ................... 1-4Table 3 - Receiving water quality standards ................................................................ 1-4Table 4 - Water Quality sampling results ( .... units ???) .2-2Table 5 - Summary of sub-p roject locations ................................. 3-2Table 6 - Summary matrix size versus of sub-project (number of towns) .......... ........... 3-3Table 7 - Summary of Will ingness to Connect .............................................................. 3-4Table 8 - Summary Matrix of Environmental Observations ........................................... 3-4Table 9 - Proposed Table of Contents ................................................................ 4-3Table 10 - Layout and example of an environment al Mitigation Plan (MiP) for a deep well

system ................................................................ 4-5Table 11 - Layout and example of an Envi ronmental Monitoring Plan (MoP) ................ 4-7Table 12 - Summary of Institutional Responsibilities for EA activities ........................... 5-1Table 13 - Checklist for assessment of environmental baseli ne conditions ......... .......... XVTable 14 - Guidelines for the minimum land acquisi tion for water sources protection. XVIITable 15 - Example of a summary matrix of Environmental Issues/Impacts ......... ....... XIXTable 16 - Example for guidelines for groundwater protection zones ........... ................ XXITable 17 - Potential impacts and mitigation rneasures related to the construction of

sewerage and drainage infrastructur e ................................................................ XXVITable 18 - General listing of wastewater treatment, disposal and sludge managem ent

technology (after WB EA Sourcebook) ............................................................. XXVIII

LIST OF ANNEXESAnnex A - Cambodian Envi ronmental Regulations (availabl e on attached CD-Rom) ....... IAnnex B -World Bank Environmental Guidelines (available on attached CD-Rom) ....... IIIAnnex C - OBA Instructions for compliance with E nvironmental Safeguards ................ VIIAnnex D - Environmental Safeguard Guidelines for Smaller W S System ....................... IXAnnex E - Supplementary Technical Guidelines ........................................................... XV

Annex E I - Assessment of Environmental B aseline Conditions .............. ..................... XVAnnex E 2 - General analysis and comparison of potential environmental impacts .... XVIIAnnex E 3 - Water Source Cons iderations ................................................................. XXAnnex E 4 - Sanitation and wastewater coll ection disposal ................ ........................ XXIIIAnnex E 5 - Improvement of storm drainage and wastewat er disposal ...................... XXXI

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Provincial and Pen-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA / WB) Project Operations Manual

LIST OF ABBREVIATIONS

BOD Biochemical Oxygen DemandCOD Chemical Oxygen DemandDBL Design-Build-Lease (contract)DPWS Department of Potable Water SupplyDPWT Department of Public Works and Transport (Municipality)EA Environmental AssessmentEEA Environmental Examination ApplicationEIA Environmental Impact AssessmentESF Environmental Safeguard F rameworkIEIA Initial Environmental Impact AssessmentJICA Japan International Cooperation AgencyLCPSS Low Cost Pilot Sewerage SystemLpcd Liters per capita per dayMg/I Milligrams per literMIME Ministry of Industry, Mines, and EnergyMiP Mitigation PlanMOA Memorandum of AgreementMoE Ministry of EnvironmentMoP Monitoring PlanMPP Municipality of Phnom PenhMWRAM Ministry of Water Resources and Meteo rologyMPWT Ministry of Public Works and TransportNGO Non Governmental OrganizationOM Operations ManualPCD Pollution Control Department (Ministry of Environment)PG Provincial GovernmentPO Project OwnerPPWSA Phnom Penh Water Supply A uthorityPPUWSP Provincial and Peri-Urban Water and Sani tation ProjectRGC Royal Government of CambodiaToR Terms of ReferenceTSS Total Suspended SolidsUNDP United Nations Development FProgramWB World BankWSS Water Supply and SanitationWTC Willingness To Connect

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1 INTRODUCTION

1.1 Purpose of the manual

1.1.1 General

The 'Provincial and Peri-Urban Water Supply and Sanitation' project is beingimplemented by the Department of Potable Water Supply (DPWS) of the Ministry ofIndustry, Mining and Energy (MIME), and the Phnom Penh Water Supply Authority(PPWSA), Kingdom of Cambodia.

The MIME component aims at financing water supply and sanitation projects targetingprovincial towns and district towns that express demand for improved services and low-income communities in urban centers. It finances investments that (i) respond to whatconsumers want and are willing to pay, (ii) facilitate and develop private sectorparticipation in financing, operating and maintaining constructed facilities, whiledesigning specific instruments that ensure inclusion of low income communities residingin the service areas.

The main objective of the PPWSA component is to ensure that consumers in rapidlygrowing peri-urban areas in Phnom Penh receive sustainable water supply. The projectwill finance water supply investment targeting peri-urban communities that expressdemand for the improved services, with special focus on low-income communities livingin these urbanized centers. As part of the project the RGC will develop financingmechanisms through which, low-income communities can participate as fully-fledgedpaying customers of piped water system. The second objective is to continue thesewerage program in Phnom Penh, incorporating in the sewerage systems newSangkats.

It is the responsibility of the borrower (i.e. the RGC through the Provincial Governments)to minimize adverse environmental impacts and to include proper mitigation measures,and to conduct an Environmental Assessment (EA), both required within the Cambodianregulations and the World Bank guidelines. Environmentally sound practices have to beincorporated into the project design, and possible negative impacts will have to bemitigated to acceptable levels.

The present volume of the Operations Manual describes the EA methodology andprocess. EA is the integrated process for the review of proposed businesses anddevelopment activities for their impacts on the environment, including ecological, socio-economic and cultural components. An EA complements the technical and economicfeasibility studies of a proposed project and/or activi ties.

The manual is a toolkit for the borrower and/or consultants to prepare the EA reports andto obtain required operating permits. The manual does not intend to provide full pre-prepared "blueprints"; as local assessments will always be required during each EApreparation.

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1.1.2 Report outline

Chapter 1 provides a general introduction to the Environmental Assessment process,including background information on institutional and regulatory developments in theenvironmental and the water sector in the Cambodia. Specific aspects like Arseniccontamination and a summary of the findings in the current project towns are given inChapters 2 and 3, respectively. Chapter 4 provides an overview of the formal proceduresto be applied for the preparation of the EA reports. including information on thepreparation of an Environmental Management Plan (EMP). Institutional, monitoring andfollow-up activities are provided in Chapter 5. Main references and additionalbackground materials are lis ted in Chapter 6.

1.2 National legal and administrative framework

1.2.1 National Environmental Legislation

Overall management of the environment lies with the Ministry of Environment (MoE),which was created in 1993. The MoE has wide responsibilities, which are spelled out inthe Law on Environmental Protection and Natural Resources Management. At theprovincial and city levels, there are corresponding Provincial/City EnvironmentDepartments. These local departments have the responsibility of enforcing theenvironmental legislation coming under the competence of the MoE. However, the dailyoperational functions of these departments would normally come under the direct controlof the provincial/city authorities.

The development of environmental legislation is one of the Cambodian Government'snational priorities. In November 1996, the Cambodian National Assembly passed theLaw on Environmental Protection and Natjral Resource Management (the frameworkLaw). The Law was prepared with technical and financial assistance from the UnitedNations Development Program (UNDP), the United Nations Environment Program(UNEP) and the United States Agency for International Development (USA ID).

The objectives of the framework Law are lo protect environmental quality through theprevention, reduction and control of pollution, to establish an Environmental ImpactAssessment (EIA) system, to ensure sustainable use of natural resources, to encouragepublic participation and to suppress acts which are harmful to the environment. Theframework Law calls for ElAs to be conducted for every private or public project, to bereviewed by the Ministry of Environment before submission to the Government for a finaldecision. All proposed and existing activities are to be covered under this requirement.Sub-decrees are antici pated to provide for the finer details of the system.

The Sub-decree on Environmental Impact Assessment Process, which was issued inDecember 1999, details specific procedures to be followed and the nature and size ofprojects which are required to submit ElAs. Furthermore, draft guidelines have beenprepared for the set-up and contents of the EIA reports). Although still in draft form, theywill be used as the basis for the EIA reports.

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Provincial and Per-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA / WB) Project Operations Manual

1.2.2 Water quality standards

Drinking Water Quality standardsNo official drinking water quality standards presently exist in Cambodia. The generalpractice is currently to apply the WHO guidelines wherever possibl e.

With support of the WHO, a proposal is being prepared by an inter-ministerial for theintroduction of new drinking water quality standards (see Table 1). It is not expected thatthe new water quality standards will officially be approved prior to the start of theprojects. The full set of proposed drinking water quality standards is included in Annex A.

Table 1 - Main proposed drinking water quality standardsPrinciple New Proposed Drinking Water WHO (updatedparameters quality standards 2nd edition)

Chloride [mg/I] 300 250Color [deg.] 10 TCU (True Color Unit) 15

Hardness 300 (as CaCo 3)

Iron 0.5 0.3

Manganese 0.5 0.1

pH 6.5 - 8.5 6.5 - 8.5

Odor Acceptable Unobject.Taste Acceptable Unobject.Turbidity [NTU] 5.0 5.0

Arsenic [mg/I] ()01* 0.01

Cadmium [mg/I] 0.01 0.003

Chromium [mg/l] 0.05 0.05

Cyanide [mg/I] 0.07 0.07Fluoride [mg/I] 1.5 1.5

Lead [mg/I] 0.01 0.01

Mercury [mg/I] (.001 0.001

Nitrate [mg/I] 50.0 50.0

Nitrite [mg/I] 3 3Selenium [mg/1] 0.01 0.01Total Coliform Zero Zero

E. Coliform Zero Zero

Note: Proposed interim Arsenic Maximum Allowable Concentration until June 2007: 0.01 - 0.05

The recommendations are especially important for the Arsenic level. It is generallyacknowledged that the WHO standard of lOpg/l would be unrealistic to apply currently,and that a (temporary) value of 50pg/l will be more appropriate for Cambodia.Accordingly, it is recommended to apply a maximum value of 50p/g for the design of thewater supply system for the Provincial towns. The PPWSA will apply the WHOguidelines, as is being done for the entire P WSA service area.

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Effluent Discharge standardsThe Ministry of Environment, through its Pollution Control Department (PCD), setseffluent discharge standards in Cambodia. The PCD obtained approval for acomprehensive set of wastewater discharge standards in April 1999 under the Sub-Decree on Water Pollution Control.

Table 2 summarizes the effluent standards for effluent discharge into a public waterarea. The complete sub-decree on water quality standards is included in Annex A. Thetable also provides a comparison with other regional or international effluent standards.

Table 2 - Cambodian and International effluent standards and guidelinesNo' Parameter Unit Discharge to Discharge to Thailand European World Bank

protected Public water (1996) - Union (1998) ....public water area and (1991)^--

area sewer2 pH - 6-9 5--9 55-9.0 - 6-93 BOD5(5 days Mg/l < 30 <80 < 20 < 25 < 50

at 20°C)4 COD Mg/A < 50 < 100 < 120 < 125 < 2505 Total Mg/l < 60 < 120 < 50 < 35 - 60 < 50

SuspendedSolids (TSS)

6 Total Mg/l < 1000 < 2000 < 3000 -

DissolvedSolids (TDS)

7 Grease and Mg/l < 5.0 < 15 < 5 mg/i - <10oil

8 Detergents Mg/l < 5.0 < 1510 Nitrate (NO3) Mg/I < 5.0 < 20 < 100 < 10-15 (s) -15 Phosphate Mg/ < 3.0 < 6.0 - < 1 - 2 (s) <2

(PO 4 )

34 Ammonia Mg/I < 5.0 < 7.0 - - <10(NH3)

^ From Sub-Decree on Water Pollution Control (Council of Ministers No. ANRK.BK -06 April 1999), Annex No 2Notification of the Pollution Control Committee, No. 3, B.E. 2539 (1996) dated August 20, B.E. 2539 (1996) issued

under Factory Act B.E.2535 (1996), Vol. 113, Part 75 D, dated September 17, B.E. 2539 (1996)EU, 1991 - Urban Waste Water Treatment (EU Directives 91/271/EEC & 98/15/EEC). (s) for sensitive (eutrophication)

areas only; upper limits applies to smaller systems (i.e. 10 000 - 100 000 population equivalents)WB, 1998 - Pollution Prevention and Abatement Handbook. General Environmental and Manufacturing guidelines

Receiving Water StandardsWater quality standards to be achieved in receiving waters are defined in the sub-decreeon Water Pollution Control (RGC, 1999).

Table 3 - Receiving water quality standardsRiver Lakes and Reservoirs

1 PH 6.5 - 8.5 6.5 - 8.52 BOD5 (5 days at 200C) Mg/I 1 -10 1 - 83 Suspended Solids Mg/I 25- 100 1 - 154 Dissolved Oxygen Mg/I 2.0 - 7.5 2.0 - 7.55 Coliform MPN/100ml < 5000 < 10006 Total Nitrogen mg/I No standard 0.1 - 0.67 Total Phosphorus mg/l No standard 0.005 - 0.05

Cambodia has no official bacteriological standards for effluents. In general, it seemsreasonable to link the treatment standards required to the planned and current quality of

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Provincial and Peri-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA I WB) Project Operations Manual

the receiving water. Policy should be to avoid causing deterioration of current waterquality and where possibl e to improve water quality.

1.2.3 Phnom Penh and the PPWSA

Phnom Penh Municipality (MPP) is the government body with overall responsibility forservice provision within the city. The Department of Public Works and Transport(DPWT), under the Ministry of Public Works and Transport (MPWT), is responsible forsewerage and drainage in the municipality. The PPWSA at present is responsible fordrinking water production and distributi on within the city of Phnom Penh.

The PPWSA have extensive experience with implementing major construction works inthe city of Phnom Penh and has elaborated regulations for contract implementation.Contract conditions, as approved by the World Bank, include various clauses related toenvironmental and social aspects to promote appropriate construction practices. Insummary, these include:* The contractor should comply with all laws in force in the country where the facilities

are installed and where the installat ion services are carried out (clause 9.4)* The employer should be responsible for acquiring and providing legal and physical

possession of the site and access hereto, and for providing possession of andaccess to all other areas reasonably required the proper execution of the contract,including all requisite rights of way (clause 10.2).

* The employer and the Contractor should establish site regulations setting out therules to be observed in the execution of the contract at the Site and shall comply withtherewith. The contractor shall prepare and submit to the employer, with a copy tothe project Manager, proposed site regulations for the employer's approval, whichapproval shall not be unreasonably withheld. Such site regulations shall include, butshall not be limited to, rules in respect to security, safety of the facilities, gate control,sanitation, medical care, and fire prevention (claus e 22.3).

* Site clearance in course of performance: In the course of carrying out the contract,the contractor shall keep the site reasonably free from all necessary obstruction,store or remove and surplus materials, clear away any wreckage, rubbish ortemporary works from the site, and remove any contractor's equipment no longerrequired for the execution of the contract (clause 22.6.1).

* Clearance of site after completion: after completion of all parts of the facilities, thecontractor shall clear away and remove all wreckage, rubbish and debris of any kindfrom the site, and shal I leave the site and facilities clean and safe (clause 22.6.2).

* Amongst others, the contractor shall held Third party liability insurance, workerscompensation, and employer Ii ability (clause 34).

1.2.4 Other related national regulations

ConstructionSection 10 of the Cambodian Code of Construction details the implementation of thenecessary procedures required for the protection of the Environment during theexecution of specific work activities. The Code has been prepared by the Ministry ofPublic Work and Transportation (M PWT).

The Sub-decree on Construction Licenses (No. 86, dated December 1997) requireproperty owners in cities to construct a septic tank for the treatment of domestic sanitary

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sewage from their building. The overflow from the septic tank should then be connectedto the 'sewerage' system.

1.3 World Bank EA requirements

World Bank procedures for environmental screening are described in the OperationalPolicy 4.01: Environmental Assessment (1999; Annex B of this manual). As the currentproject include major infrastructural works in Phnom Penh, the project has beenassigned to the Category A. This implies the requirement of the preparation of anenvironmental analysis or limited Environmental Assessment. Major environmentalissues to be addressed and mitigated include adverse impacts in terms of arseniccontamination, wastewater discharge, and draw down of groundwater (see Annex E ).

Special attention should be paid to public participation, possible involuntary resettlementand compensation for loss of income due to the development of the water supplysystems according to WB regulations (OD 4.30: Involuntary resettlement, see Annex B).Key issues include the necessary compensation for land acquisition and the possibledisplacement of people and resettlement. Details are given in the Operations manualson Public Participation and Economic Compensation prepared as separate Volumes.

As most of the necessary constructions for the water supply systems are small,resettlement and land acquisition are not major issues in the current project. However, if.applicable, the relevant measures have to be addressed and incorporated into the EAreports (see sections 4.2 and 4.3).

1.4 Applied Project Approach

1.4.1 EA Implementation Methodology

An 'Environmental Assessment Implementation Methodology' has been developedcombining both the Cambodian regulations and WB safeguard guidelines. As mentionedabove, the proposed methodology is principally based on and combines the regulationsand guidelines listed below:

Royal Government of * Sub-decree on Water Pollution (1999, No: 27.ANRK.BK)Cambodia * Sub-decree on Environmental Impact Assessment process (2001, No:

72.ANRK.BK)* Guideline for conducting Environmental Impact Assessment (EIA) report.

Draft only. Ministry of Environment.

World Bank Guidelines * World Bank guidelines on Environmental Assessment (OP and BP 4.01);a World Bank Guidelines on Involuntary Resettlement (OP and BP 4.12).

Details on the identification of EA requirements and necessary documentation to beprepared are given in Chapter 4. Additional references and background documentationare given in Annex E and Chapter 6.

Specific instructions for the OBA component are given in Annex C.

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The environmental assessment is closely coordinated with the other project preparationactivities (e.g. engineering design, economic analysis, and community consultation, seeFigure 1). The EA preparation should start simultaneously with the initial (engineering)assessment and pre-feasibility study in order to include all environmental aspects in tothe selection process and engineering design right from the beginning. The EApreparation and operating permit processing should be completed before the signing ofthe loan agreement.

Figure 1 - Schematic presentation of EA scheduling

ENGINEERING DESIGN PROJECT PHASES AND STEPS ENVIRONMENTAL ASSESSMENT

b Invitation and agreement on'participation'in the project

Inventory and evaluation of , Scoping and.Assessment ofexisting systems and water,-:. Environmnental baseline ..

reauirements conditions.-;.

- Pre-feasibility studies |, ; Analysis ofenvironmental |->~r ; --impacts and_drafting of EMP

\ I I, r t 8 J , } , //~~~~~~I" IVai

Approval of alternatives and tariffimplications

Public consultations and participatory'selection of final altemative -

b6 Dta`iled eng;neering desig an |- -,Finaizati6n-ofiEA+rieort arnd|fiaca anlyi I- ,-4; " ro - .... in, .'MoEapproya,--

-.WB appralsaland signing of loan,'_1 'agreements

Construction and operation of Compliance MonitoringWaler Sup'ply System

The main steps for the EA include:* (non-formal) Scoping meetings;* Inventory of the environmental baseline conditions;* Potential direct and indirect environmental impacts, including opportunities for

enhancement;* Systematic environmental comparison of alternative investments, sites,

technologies/designs, including all the significant adverse environmental impacts thatare anticipated.

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Provincial and Peri-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME I PPWSA / WB) Project Operations Manual

* Drafting of an Environmental Management Plan (EMP), including a mitigation andmonitoring plan;

* Community consultation and participatory selec tion of WS alternative;* Submission to and clearance of MoE and/or the World B ank;* EMP Compliance Monitoring.

Project preparation, including all environmental assessment activities, is coordinatedthrough the PMO of the PUWS. As a part of the whole feasibility study, the EA should bestarted at the project planning stage, or just after the proponent acquired the locationpermit. By starting the EA in the early stages of a project's cycle, it seeks to avoid costlydevelopment, caused by mistakes and unpredicted environmental damage s.

1.4.2 Public consultation and participation

Both the RGC and the WB emphasize the importance of public participation and requirea transparent EA process in gaining understanding and achieving social acceptability fora project or undertaking. Participation of the local authorities and population should besecured through regular community consultations during the entire EA process (similarto WB 'stakeholder workshops"). The goal of public participation is to enable citizens totake responsibility for environmental protection and management through activeinvolvement in decision making.

The community consultations must be sufficiently integrated into the process of theformulation and evaluation of technical alternatives. Therefore, it is recommended toinclude the public consultations on environmental issues during the multiple publichearings to be organized during t he technical assessment, feasibility study and design.

The consultation process should be documented and annexed to the EA report (seesection 4.5.1). Also, proof of social acceptability based on the results of the publicconsultations should be annexed to the E A report (see section 4.5.2).

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2 DRINKING WATER SOURCES QUALITY IN CAMBODIA

2.1 Introduction

In 2001, the Royal Government of Cambodia (i.e. MIME), with support from the WorldHealth Organization, completed an assessment of drinking water quality from sourcelocated throughout the country (MIME/WHO, 2001). The assessment, which wasconducted in thirteen of Cambodia's most densely populated provinces, focusedexclusively on testing the chemical quality of urban and rural water supplies. However, itis critical to note that the human health threat from bacteriological unsafe drinking wateris by far the most important water quality issue in Cambodia at present time.

The potential for naturally-occurring toxic chemicals to appear in groundwater wasamong the main concerns guiding the design of the 2001 assessment. Experiences inother portions of Asia where high concentrations of Arsenic and Fluoride have appearedin drinking water played a driving role. Consumption of elevated levels of Arsenic indrinking water over long periods of time has been associated with a variety of humanhealth problems, including skin lesion and abnormal pigmentation, cardiovascularproblems, and various forms of cancer.

2.2 Current status

The MIME/WHO assessment results indicated that the chemical quality of most urbanand rural drinking water sources was generally very good. No pesticides were detectedin any of the samples (which were screened for over 40 types of organochloride andorganophosphate compounds). Surface water sources were typically very low indissolved solids and of good quality (although not tested for bacteriological quality).Groundwater was generally also of good chemical quality, and did not have anydetectable levels of dissolved solids. Flowever, groundwater had higher levels ofdissolved solids. Iron, Manganese, sodium, chloride and other naturally-occurringelements are common constituents of groundwater. Most of these elements areharmless.

The most significant findings of the survey is that groundwater for certain areas inCambodia contain levels of chemicals that could pose concerns for human health. Themost important of these chemicals is Arsenic. Several water sources, both in rural andurban areas, were found to contain Arsenic concentrations above the WHO's guidelinevalue of 10 parts per million. The highest concentrations were detected in Kien Svay andTaKhm.

A few other chemicals of human health significance were detected in the study areas.These include Barium, Chromium, Fluoride, Lead, Manganese, Molybdenum, Nitrate,Nitrite, and Selenium. Of these, the most significant are likely Nitrate and Nitrate, as theywere detected at levels exceeding their respective WHO guideline value in severallocations.

The most prevalent concerns among consumers of groundwater were related to tasteand other aesthetic properties of water. Mainly Iron, Manganese, and Hardness cancause taste and odor problems, and can c reate problems for bathing and w ashing.

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During the feasibility studies for the first batch of sub-projects a water quality samplingprogram was conducted by MIME. A summary of the results of the sampling is given inTable 4.

....... .TO BE COMPLETED WITH FINAL RESULTS .

Table 4 - Water Quality sampling results (.... units ???)Water Tested Components

Town Source Tested pH EC TDS Fe NO3 Cl Hardn Asess

O' Smach Deep bore 46m 7.6 648 325 0.05 1 49 150 0

Bavet Deep bore 22-29m 4.85 28 13 0.02- 0.9- 49 25 00.33 1 5

Kandieng Reay Deep bore 24-36m 7.14 138 70 0.1 1.1 NT 50 0

Kraol Kou Deep bores 30-39m 6.56 100- 50- 0.12- 0.6- 56 100 0260 130 0.36 0.8

Kampong Chak Deep bore 36m 6.98 151 76 0.27 1.2 NT 25 0Boeung Deep bores 59-72m 6.00- 143- 80- 0.08- 1.1- 0-86 70-120 0Trakoun 7.73 1945 988 0.80 1.4Ph Thom + Ph Deep bores 17-33m 6.96 705 355 0.03 3.3 36 400 0TouchSrah Chik + Deep bores 30-40m 6.3- 40- 20- 0.1- 0.5- 0- 25-450 0-PaoyChar 8.4 1780 1115 1.0 18 290 <10Phsar Chub Deep bores 40-60m 5.64 44 22 0.37- 0.9 NT 40-80 0

0.66Thmor Pourk Deep bores-46-60m n/a n/a n/a 0.13 17 NT n/a 0

Neak Loeang + FS report summarizingdetails being prepared

Prek Khay KhaA& BPrasat Deep bore 53m 6.51 233 114 0.98 1.8 6 90 30

Svay Antor Deep bore 29m 6.59 249 125 0 1.5 NT 130 0

Prek Deep bore 47m 6.71 201 98 0.18 1.4 NT 80 0ChangkranChheu Kach Deep bore 35m 6.92 368 188 0.04 1.8 6 120 10

Roka Deep bores 21-33m 5.47 410 208 0.14 10.4 36 120 <10

Sala Lek Pram Deep bores 18-31m 7.3 400 200 <0.3 <0.1 24 150 0

Prey Khmer Deep bores 16 -35m 7.34 2'50- 140- 0.09- 0- 52- 50-250 01000 535 2.74 .002 183

Ponley Deep bores 27-38m 7.34 200- 98- 0.03- 0- 9- 120 0650+ 324 4.15 .002 18.5

Note: Bold values indicate samples exceeding proposed water quality standards.

2.3 Conclusions

The sampling data collected for the present project confirms the 2001 assessment thatcertain water quality parameters may need to be addressed, but no serious water qualityconstraints are to be expected. In selected towns the Iron, Manganese and Arseniccontent may be exceeding the official WHO guidelines values of lOpg/l, but it isexpected that standard aeration will be sufficient to provide drinking water of goodquality. Also high Hardness may require additional treatment in a selected number oftowns.

It should be noted that all water quality sampling programs are only generalassessments representative for limited areas only, but can not provide the final water

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quality to be found in a specific location. It will hence be necessary that any new well willalways be tested extensively before usage. If necessary, the design of the system willhave to modified to obtain acceptable water of an acceptable quality (see also section4.6.1: Arsenic Mitigation).

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3 ENVIRONMENTAL STATUS OF SUB-PROJECT LOCATIONS

3.1 General

The first batch of sub-project of the PPUWSP initially consisted of 5 Peri-urban areas, 23provincial towns, complemented with 6 back-up towns. After an initial assessment of thesuitability, feasibility, and environmental constraints to include the areas in the project, afinal listing for the first batch of project locations had been established (see Table 5 andFigure 2).

Figure 2 - Location map of current sub-project

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Table 5 - Summary of sub-project locationsCode Town Province District Current IEIA

Status reportMOI Kranhjung Prey Veng PostponedM02 Phsar Prum Krong Pailin Pailin PostponedM03 Samraong Odor Meanchey Samraong PostponedM04 Ou Smach Odor Meanchey Samraong Included YesM05 Anlong Vaeng Odor Meanchey Anlong Vaeng PostponedM06 Krong Kep Kampot Kampot PostponedM07 Bavet Svay Rieng Chantrea Included YesM08 Kandieng Reay Svay Rieng Svay Teab Included YesM09 Kraol Kou Svay Rieng Svay Chrum Included YesM1O Kampong Chak Svay Rieng Rumduol Included YesM11 Malai Banteay Malai Postponed

MeancheyM12 Boeung Trakunn Banteay Thma Pourk Included Yes

MeancheyM13 Phnom Thom / Phnom Banteay Mongkul Borei Included Yes

Touch MeancheyM14 Nimitt Banteay Ou Crov Postponed

MeancheyM15 Srah Chik/Poy Char Banteay Phnom Srok Included Yes

MeancheyM16 Phsar Chob Banteay Preah Netr Included Yes

Meanchey PreahM17 Thma Pourk Bantey Thma Pourk Included Yes

MeancheyM18 Neak Loeang/Preaek Khsay Prey Vieng Peam Ro Included Yes

KaM19 Prasat Prey Vieng Kampong Included Yes

TrabaekM20 Svay Antor Prey Vieng Prey Reang Included YesM21 Preaek Changkran Prey Vieng Sithor/Kandal Included YesM22 Chheu Kach Prey Vieng Ba Phn om Included YesM23 Roka Prey Vieng Pea Reang Included YesS02 Sala Lek Prim Kampong Kampong Included Yes

Chhnang ChhangS03 Prey Khmer Kampong Kampong Included Yes

Chhnang ChhangS04 Ponley Kampong Kampong Included Yes

Chhnang ChhangS04 Traeng Trayueng Kampong Speu Kampong Speu Back-upS05 Tram Khnar Kampong Speu Kampong Speu Back-upS06 Khsem Khsan Kampong Speu Kampong Speu Back-up

Phnom Penh Included Yes

Full environmental assessments have been carried out for all the participation sub-projects, parallel with the feasibility studies and community consultations. The findings ofthe activities for the first batch of towns have been a major input for the present ESF-OM.

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3.2 Main findings

.............. .TO BE COMPLETED WITH THE FINAL RESULTS .

Size of the sub-projectsA review of the sub-projects shows the relative large number of small sized sub-projects(Table 6).

Table 6 - Summary matrix size versus of sub-project (number of towns)Cost < Total

Size of System< 500 HH500- 1,000 HH1,000 - 2,000 HH> 2,000 HHTotal:

Environmental impacts

Arsenic

Sanitation

Public ConsultationsMIME, with support of the Engineering Consultant conducted a series of meetings andconsultations with the resident, Provincial Government Officials and local officials of thesub-project towns.

Overall, the project is perceived to be of great help to the community since it willsignificantly improve the quality of the drinking water supply and public health conditionsby reducing common cases of water borne diseases (diarrhea, gastroenteritis andparasitism). The project will further stimulate socio-economic growth through increase in

the number of commercial and economic activities thus adding revenue to thecommunity.

The results of the Willingness-to-Connect (WTC) is given in Table 7.

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Table 7 - Summary of Willingness to ConnectCode Town Province Forms Positive WTCM04 Ou Smach Odor MeancheyM07 Bavet Svay RiengM08 Kandieng Reay Svay RiengM09 Kraol Kou Svay RiengM10 Kampong Chak Svay RiengM12 Boeung Trakunn Banteay MeancheyM13 Phnom Thom / Phnom Touch Banteay MeancheyM15 Srah Chik/Poy Char Banteay MeancheyM16 Phsar Chob Banteay MeancheyM17 Thma Pourk Bantey MeancheyM18 Neak Loeang/Preaek Khsay Ka Prey ViengM19 Prasat Prey ViengM20 Svay Antor Prey ViengM21 Preaek Changkran Prey ViengM22 Chheu Kach Prey ViengM23 Roka Prey ViengS02 Sala Lek Prim Kampong ChhnangS03 Prey Khmer Kampong ChhnangS04 Ponley Kampong Chhnang

Phnom Penh

Institutional CapacityThe implementing capacity and resources of the Clients to carry out extensiveenvironmental assessments is admittedly lirnited. The classification of larger and smallersub-projects will significantly improve the effectiveness of the available resources. EAsummary reports can be prepared by the PMO staff itself, while some external supportmay be required for the larger sub- projects.

3.3 Summary and Conclusions

As the impacts for most of the smaller sub-projects are identical , are Impacts arerelatively similar

Table 8 - Summary Matrix of Environmental ObservationsSize of System Number of Towns Main Main identified Mitigation

infrastructure impacts measures500 HH

500- 1,000 HH1,000 - 2,000 HH> 2,000 HH

By limiting the

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4 SCREENING PROCEDURES

4.1 Rational

The substantive Environmental Assessment (EA) requirements for World Bank projects(i.e. OP 4.01: Environmental Assessment) are consistent with the 1996 Law onEnvironmental Protection and Natural Resource Management (the 'Framework law') andthe 1999 sub-degree on the EIA Process, to be implemented by the Ministry ofEnvironment (MoE) (see section 4.3.2). Environmental Safeguard Guidelines for theproject have been developed by MIME combining both the Cambodian regulations andWB guidelines. The methodology has been elaborated in an "Environmental SafeguardFramework", as part of the Project Operations Manual' (ESF-OM). A copy of the ESF-OM (hardcopy or CD-Rom, together with sarnple IEIAs, can be obtained from MIME.

Based on the mentioned MoE and WB documents, a flowchart showing the EIAprocedure to be applied has been prepared. For the present project, with MIME beingthe Project owner, the applied process is shown in Figure 3.

Figure 3 - Applied EA ProcessDetermination of Project EIA Requirements

< 2000 connectiols, PE,BpaVAapEAJlm'IflatiOf4 v Include EA In Batch -

jcsjojpeand size Summary Report

.i'',' Projecw >= 2000 connections:!*.8{{ ae<< l . Prepare Individual.,.* ' ,3 .IEIAJEIA Report

EIA Process for Proposed Project Approved by Project's Owner as Ministry and Institution

0 30 days * * 30 dayses

EPA'S EtA reportof Pr C.are

to1 < Rvsat IE MS] .App -:

RepoiltoMoE ElAre~~Mo

MOE Rviewg ELA Report_~ RevWIMlEIAIEIAo EIARRppon

ABBREtAIAONS.PO Pqd Oar,,A4oE M-,"odE,tEMP E ror.nlVd Mmg-Ie Plt.OeIA PAM E ,NM,r hv,cl AO.rerMeEM E-r ..WM d lAar.EEA E ,oorr/n -E. APPkI,tOI ,

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For new water supply systems 2 2,000 connections, a concise EnvironmentalAssessment (EA) will have to be prepared by the Project Owner, i.e. MIME/PPWSA orthe Contractor (OBA Component). This is consistent with the Cambodian Sub-decree onEnvironmental Impact Assessment Process. The Cambodian Environmental ImpactAssessment (EIA) reporting requirements for water supply projects start with 10,000users. The EIA sub-decree details specific procedures to be followed and lists the natureand size of projects which are required to submit Initial Environmental ImpactAssessment (IEIA) or ElAs reports.

4.2 Reporting Procedures Smaller systems (<2000 Connections)

For smaller systems (< 2000 connections), the Project Owner will have to includeEnvironmental Safeguard Guidelines into the Project design and operationarrangements, but will not be required to prepare an IEIA or seek formal permission fromthe Ministry of Environment. An 'environmental checklist' to be used for the smaller sub-projects, is included in Annex D. The checklist is based on the more elaborate Annex E- Supplementary Technical Guidelines.

An EA summary report will have to be prepared per batch of participating towns. MIMEand World Bank clearance for the project will be provided if the EnvironmentalSafeguard guidelines are sufficiently incorporated into the project des igns.

4.3 Reporting Procedures Larger Systems (22000 connections)

4.3.1 Process

For larger sub-projects, the Project Owner, will seek Environmental Clearance from theMinistry of Environment, who will subsequently notify MIME, being the ApprovingAgency, that construction of the project can proceed.

The first step in the EA process is the preparation of an Initial Environmental ImpactAssessment (IEIA), to be submitted by the Project Owner to the MoE, supplementedwith an Environmental Examination Application (EEA). Based on the review of the IEIA,the Project will either be approved, additional changes to the IEIA will have to be made,or a full scale EIA report will have to be prepared.

4.3.2 EA Report contents

The MoE has prepared draft guidelines for the set-up and contents of the EIA reports.Although still in draft form, they have been used as the basis for the IEIA reports.Combined with the World Bank recommendations, a layout of the EA reports is proposed(Table 9).

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Table 9 - Proposed Table of Contents

I PROJECT SUMMARY2 INTRODUCTION

2.1 BACKGROUND OF THE PROJECT2.2 ENVIRONMENTAL ASSESSMENT2.3 INSTITUTIONAL AND LEGAL FRAMEWORK

3 PURPOSE OF THE PROJECT3.1 OBJECTIVES

4 PROJECT DESCRIPTION4.1 SERVICE AREA4.2 SUMMARY OF INFRASTRUCTURE4.3 WATER QUALITY STANDARDS4.4 PROJECT PLANNING AND IMPLEMEN rA TION

5 DESCRIPTION OF ENVIRONMENTAL RESOURCES5.1 PHYSICAL RESOURCES5.2 ECOLOGICAL RESOURCES5.3 SOCIO-ECONOMICAL RESOURCES

6 PUBLIC PARTICIPATION6.1 INTRODUCTION6.2 CONSULTA TIONS WITH LOCAL GOVERNMENTS6.3 CONSULTATIONS WITH THE PROSPECTIVE USERS

7 ENVIRONMENTAL IMPACT ANALYSIS7.1 METHODOLOGY7.2 PRE-CONSTRUCTION CONSIDERATIC)NS7.3 ENVIRONMENTAL IMPACTS DURING PROJECT CONSTRUCTION7.4 ENVIRONMENTAL IMPACT DURING PROJECT OPERATION7.5 ENVIRONMENTAL IMPACTAFTER THE PROJECTABANDON OR CLOSURE STAGE7.6 SUMMARY OF SIGNIFICANT ENVIRONMENTAL IMPACT

8 ECONOMICAL ANALYSIS AND ENVIRONMENTAL VALUE9 ENVIRONMENTAL MANAGEMENT PLAN

9.1 INTRODUCTION9.2 ENVIRONMENTAL MITIGATION PLAN9.3 ENVIRONMENTAL MONITORING PLAN9.4 RESPONSIBILITIES

10 INSTITUTIONAL CAPACITY11 CONCLUSIONS AND SUGGESTIONS12 PRINCIPAL REFERENCES.

Annex I - List of EA preparersAnnex II -Accountability statement of project ownerAnnex III - Accountability statements of key EA report preparersAnnex IV - Process documentationAnnex V - Proof of social acceptabilityAnnex VI - Applied Water Quality Standards

The substantive contents of the EA report should cover all pos sible environmental issuesand mitigation measures to be taken, as agreed upon with the PG. As such, it should:

Identify all potential environmental issues/ impacts associated with the project typerelative to the ECA location;

* Identify all significant environmental impacts (SE Is);* Resolve all significant environmental impacts wi thin the scope of the EA report; and* Recommend additional studi es and/or an EIS to resolve outstanding issues/ impacts.

Annex E provides supplementary background information of various environmentalaspects of water supply and sanitation projects. General steps in the preparation of thesubstantive (technical) EA reports would refer to:* Inventory of the environmental baseline conditions (see Annex E 1);* Systematic environmental comparison of alternative investments, sites, technologies

and designs, including all the significant adverse environmental impacts that areanticipated (see sections Annex E 2 through Annex E 5);

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4.3.3 Drafting the Environmental Management Plan

GeneralThe EMP consists in principle of three main components:* An environmental Mitigation PI an (EMiP)* An environmental Monitoring Plan (EMoP);* Overview of the implementation arrangements.Both the Environmental Mitigation and the Mlonitoring plans can be presented in the formof a summary matrix.

Compliance reports on both the Mitigation and Monitoring plans will be prepared by thewater system operator/PG (see section 5.3) and subm itted to the PMO.

Environmental Mitigation PlanA project's environmental mitigation plan (MiP) consists of the set of measures to betaken during implementation and operation to eliminate, offset, or reduce adverseenvironmental impacts to acceptable levels. Limited mitigation2 plans alone suffice formany category B projects. The mitigation plan should include, if applicable, the followingitems:* Identification and summary of all the significant adverse environmental impacts that

are anticipated;* Brief description of each possible mitigation measure;* Institutional arrangements and the assignment of the various responsibilities for

carrying out the mitigation measures (e.g. responsibilities which involve operation,supervision, enforcement, monitoring of implementation, remedial action, reporting,and staff training).

In Table 10 an example of a proposed Environmental Mitigation Plan is presented.Examples of mitigation measures are given for the main environmental impacts listed inAnnex E 2 through Annex E 5. A sub-division in for the pre-construction, construction,and operation phase has to be included. When impacts are considered not significant,no mitigation measures are necessary.

The decision to proceed with a project, and the World Bank's decision to support it, will bein part predicated on the expectation that the mitigation plan will be executed effectively.Consequently, it is important to integrate the plan into the project's overall planning,design, budget, and implementation. Such integration should be achieved by establishingthe mitigation plan as an essential component of the project. This precaution ensures thatthe plan will receive funding and supervision along with the other investment components.

2 Full mitigation plans are essential elements for World Bank category A projects.

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Table 10 - Layout and example of an environmental Mitigation Plan (MiP) for adeep well systemPhase Mitigation measures Responsibility SchedulePre- . Lack of control of water source: Acquire land directly MIME, World Bank Prior to DBLconstruction around the well (or secure a possible purchase); Contracts

* Disturbance of land use and economic activities:Usage of public areas;

. Provision for proper compensation.

Construction . Disturbance of the land use due to drilling and Operator, with Continuousconstruction activities: Minimize impacts, Restore supervision of MIME duringdamages. consultant construction

* Loss of natural vegetation: Replanting of areas. phase.* Disturbance of stream channels, aquatic plant and

animal habitats:* Erosion and sedimentation control during construction.* Soil and water contamination (e.g. spilling of oil

products and other construction materials): Control(collection, disposal) of water.

* Hindrance (noise, air pollution, traffic, etc) due todrilling construction activities: Minimize hindrance tolocal population; Engage and provide labor for localpopulation; Usage of main roads when possible.

* Soil erosion and compaction: Proper runoff anderosion control through land protection and drainagechannels; Heavy traffic restrictions.

* Safety hazards: Application of proper safety andwaming Measures;

* Provision of temporary crossings and Bridges; Publicinformation campaign.

Operation . Increase of public health hazards due to increase of Operator, with To be determinedwastewater: Secure the construction of proper on-site supervision of MIME during feasibilitysanitary facilities (if lacking); Improve storm drainage study.system for sullage; Additional training of governmentstaff.

* Contamination of stream channels: Assure that inflowis relatively small compared to receiving riverdischarge; No routing of sewer lines directly in streamchannels.

* Water logging and salinization: Improve storm waterdrainage system.

* Contamination of the groundwater source: Acquireand fence a protection zone directly around the well;Regulate potential polluting activities in rechargezone; Monitor water level and groundwaterAbstraction.

* Lowered groundwater table: Calculate safe yield(abstraction); Assure/proof that other water users arenot affected.

* Reduction in artesian flow: Locate the well in an areawhere other water users are not affected.

* Increase of noise: Usage of electrical submersiblepumps; Construction of proper pumping house.

* Land subsidence: Space wells at larger distances;Avoid over-abstraction and consequent lowering ofgroundwater table.

Abandoning . Water availability: keep traditional water sourcesphase available.

Environmental Monitoring Plan

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Monitoring of environmental parameters and compliance to the EMP should be carriedout during both the construction and operational phase. A simple monitoring plan,developed according to the example in Table 11, should be discussed and formulatedwith the PG, including the following elements:* Activities/parameters to be monitored ("monitoring objectives");* Specific areas to be monitored;* Manner of monitoring;* Frequency and cost of monitoring; and* Institutional responsibilities for monitoring and data management.

The frequency and level of sophistication of the sampling depends in part on the size ofthe system and the nature of its treatment pr ocesses. Monitoring is expensive; it requireslaboratory facilities, equipment and technicians. Hence, as a general principle, include inthe monitoring plans only what is necessary for protecting the environment, managingthe system, and safeguarding its staff and equipment.

Implementation arrangementsThe proposed protection and enhancement measures in the environmental mitigationand monitoring plans should provide enough information on when and how themeasures at the various stages of the project should be implemented. However, incertain cases, additional information may be elaborated for the more important impactsor institutional constraints. For example:* Implementation schedule for measures that must be designed as part of the project,

showing phasing and coordination wit h overall project implementation plans;* Monitoring and reporting procedures tc (i) ensure early detection of conditions that

necessitate particular mitigation measures, and (ii) provide information on theprogress and results of the compliance monitoring;

* Integration into the total project cost tables of the cost estimates and sources offunds for both the initial investments and the recurring expenses for implementingthe mitigation and monitoring plan.

* Programs to strengthen environmental management capability in the PG/Operatorsmay include training/technical assistance programs, staff development, procurementof equipment and suppli es, and/or organizational changes.

4.3.4 Conclusions and recommendations

The conclusions and recommendations should brief and punctual, s ummarizing:* The list of resolved issues;* The list of partially resolved issues;* The new issues arising from the EA report that have been resolved.* Additional required studies.

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Provincial and Peri-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA / WB) Proiect Operations Manual

Table 11 - Layout and example of an Environmental Monitoring Plan (MoP)Phase Monitoring activities Responsibility ImplementationPre- . Land acquisition: Check if the required land MIME, World Bank Prior to DBL Contractconstruction has been purchased properly, or thal a

proper 'Deed of Sale" has been prepared.* Resettlement and Compensation: if

applicable, check if proper arrangementsare made and documented.

Construction . Hindrance to local population Noise, air Operator, with Continuous, throughpollution (odor, TSP, fume emissions), supervision of MIME regular constructionland damage, traffic. consultant supervision.

* EMP compliance of the contractors:Erosion control, vegetation protection, soiland water contamination.

* Safety precautions of contractors: Conformprofessional standards.

* Sanitary control: Proper construction of on-site facilities; Proper construction ofsullage drainage system.

Operation . Quality of distributed water: conform Operator, with Regular, according toofficial standard procedures (microbiology, supervision of MIME professional standards.standard parameters, arsenic, heavymetals)

* Groundwater resources: water level (2 Xper month (after pumping recovery period);operation of pumps (abstraction);

Abandoning . None.phase

4.4 Submission and Follow-up

For the smaller sub-projects, the PMO will submit the EA summary report to the World

Bank for its approval. The findings and recommendations of the EA Summary report will

be subject to regular project monitoring procedures (see section 5.3).

For the larger sub-projects, subject to the Cambodian EIA procedures, he project ownermust apply for an examination the EA report and pre-feasibility study by the MoE Afterfinalizing the full IEIA report. The request is formally submitted through an EnvironmentalExamination Application (EEA). The Ministry of Environment will examine and evaluate

the IEIA report within 30 working days, in collaborating with other lined Ministry-

Institutions.

If the IEIA report is considered appropriate for the proposed project, the MoE will give itsconsent to the project, or request the project owner to make some revisions and/orupdates. If the project is considered to have significant negative impacts on natural

resources, ecosystem, human health and public welfare, the Project's Owner must apply

for an examination the Full EIA Report and feasibility study to the MOE.

The Consent of the MoE with the EA report will allow the PO to proceed with the project.The Approval Maker Institutions will advise the PO to implement the Environmental

Management Plan of the project as described in EIA report, which has approved by the

MoE. Subsequently, the MoE will monitor and have the measure on project's owner to

comply the Environmental Management Plan during construction, operation, and

closure, the project as it is mentioning in the approved EIA report.

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The project owner (and operator) must implement the Environmental Management Plan

mentioning in the EA reports within 6 months from the date of announcement of the

Provincial-Urban Environmental Department, which has stated that EIA report is

application to this sub-decree.

4.5 Public Consultation

4.5.1 Documentation of the EA Process

Every EA required project proponent must publicly advertise his proposed project to the

public before finalizing the EA report. The EA process of scoping, public hearings and, if

applicable, dispute/conflict resolution (see section 4.5.2) has to be documented and

annexed to the EA report. The EA process documentation is a brief summary of the

applied methodology and act ivities, including:

* Representation of partici pants;

* The issues, concerns, and interests addressed;

* The sequence of significant activities undertaken or issues addressed;

* The process by which agreements or resolutions were arrived at;

* The stakeholders and key players who most actively participated, those who were

present but were quiet, those who w ere not represented;

* The outcome of the activity or undertaking.

The environmental analysis and participation will be fully integrated into the process of

the formulation and evaluation of technical alternatives. Accordingly, public consultationson environmental issues will be conducted during the multiple public hearings organized

during the technical assessment, feasibility study and design, and the documentedprocess of the overall public hearings and consultations will be used as the EA Process

documentation. Part of the EA process documentation may already have been included

in the EA report section on data collection.

4.5.2 Proof of Social Acceptability

Social acceptability is the result of a process that is mutually agreed upon by the

beneficiaries, the stakeholders and the proponent to ensure that the concerns of

stakeholders, including affected communities, are fully considered and/or resolved in the

decision-making process for granting or denying the issuance of an operating permit3.Social acceptability compels the consideration of a broad spectrum of environmental

factors. It also means the proponent is able to identify the relevant and valid issues andmatch them with corresponding mitigation/enhancement measures together with the

available resources to implement the measures and the corresponding agreements and

guarantees for the fulfill ment of such measures.

3Social acceptability can be achieved only if:* the decision is informed;* the process of decision-making is agreed upon through a democratic process;• the stakeholders have been empowered to decide for themselves; and* those who know about the project understand the risks and related responsibilities and accept them

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Evidence of social acceptability may be manifested, among others, through thefollowing:* Agreements with the affected communities on proposed mitigation and enhancement

measures duly recorded during public c onsultations;* Project endorsements/resoluti ons of community leaders/local governments;* Absence of oppositions during consultations;* Assurances/guarantees provided by the proponent addressing specific

issues/impacts raised by the s takeholders; and* Proof of public consultation/public participation in the EA report process.

Such proofs of social acceptability shall be duly documented and summarized togetherwith the EMP matrix.

The project proponent will also facilitate the resolution of possible conflicts that affectenvironmental quality. Iterative negotiation procedures shall be utilized until a consensusis arrived at in cases where there are outstanding disagreements, conflicts and outrightopposition to the project or certain elements of it. If after all measures to resolve conflictshave been exhausted and still no common agreement has been reached, then socialacceptability has not been achieved. Examples of proof include:* Memorandum of Understanding between the dis puting or conflicti ng parties;* Negotiated agreements on conflicts should be firmed up through a MOA between the

proponent, the Local governm ent, and legitimate stakeholders.* Resettlement and Compensation P Ian, if applicable;

Social Development Program (not necessary a full program, but it should containmeasures that should address socio-economic i mpacts).

4.6 Miscellaneous

4.6.1 Arsenic Mitigation

MIME is aware of the possible risks of higher Arsenic concentrations in wells to bedrilled in certain areas. The risk however is considered acceptable if appropriatemitigation measures are incorporated into the project design and preparation process. Itshould be noted that the 'Arsenic problem' generally applies to private shallow wells,where people have no choice in selection the location of the well, and have no resourcesto provide proper treatment. The PPUWSP will develop piped water supply systems,where the both the source and the treatment can relatively easily be adjusted accordingto the local conditions.

To deal with possible higher (or uncertain) concentrations of Arsenic in groundwater, theproject will apply the following mitigation measures:* Selection of the most suitabl e well locations, based on the findi ngs of a groundwater

investigation conducted during the feasibility study (geophysical survey, water qualitysampling program);

* Anticipation of water treatment facil ities (aeration) in project loc ations where higherArsenic concentration could be expectecl.

* Extensive water quality testing of al I new wells, as included in the D BL/OBA contract.* Allocation of a special budget for possible new well or additional water treatment

facilities after water testi ng of the actual completed w ells.

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4.6.2 Sanitation

Special attention will be given to onsite sanitation in areas with high groundwater tables,e.g. the Mekong Delta. As the regular septic tanks are not working properly in theseareas, the option of introducing alternative technologies and/or communal facilities(public toilets) will be discussed and investigated. At present, coverage of onsitesanitation facilities is still very low in Cambodia.

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5 INSTITUTIONAL ARRANGEMENTS

5.1 Responsibility for Framework Implementation

The Client (MIME/PPWSA) will be overall responsible for the proper implementation ofthe ESF, i.e. the preparation of the Environmental Assessment (section 5.2) andcompliance monitoring (section 5.3). The principal linkages and responsibilities of otheragencies/players are summarized in Table 12.

Project management will be the responsibility of two Project Management Offices(PMO), one in MIME for the provincial and district towns participating in the project, andone in PPWSA for the Phnom Penh peri-urban components. Consultants will beengaged to provide assistance during project preparation, and for supervising designand construction of the systems.

The daily supervision of the construction and operation of the MIME s ub-projects will becarried out by the Provincial Project Management Units (PMU). PMU staff will report tothe PMO.

5.2 Environmental Assessment

The PMOs will be responsible for that proper EAs are being carried out, either by thePMO (DBL sub-projects) or by the Contractor (OBA sub-projects). For the smaller sub-projects a summary report per batch of projects will be prepared (section 4.2), and a 'no-objection' from the World Bank obtained. For the larger sub-projects a separate IEIAreport will be prepared and approval from the MoE obtained (section 4.3).

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Table 12 - Summary of Institutional Responsibilities for EA activitiesAgency Principal project linkages Environmental Assessment Compliance MonitoringMIME/PPWSA PMOs Main linkage to MoE and WB-EASUR Prepare IEIA and summary reports for DBL Implements compliance monitoring -

sub-projects agreements.Obtain approval from MoE. Prepares compliance monitoring reports forPrepare Summary report on OBA sub- MoE and WB.projects.

Provincial PMUs Report to MIME PMO. Support the preparation of IEIA and EAsummary reports.

Ministry of Reviews and approves IEIA/EIA reports of Implements compliance monitoringEnvironment (MoE) Project Owners (MIME/PPWSA or OBA procedures: e.g. review of compliance

contractors) monitoring reports and field inspections.Provides clearance for operating permits toMIME

WB Operations Provides 'No-Objection Letters' to Secures and monitors proper Implements compliance monitoringDepartment (EASUR) MIME/PPWSA for sub-project implementation of ESF. procedures: e.g. review of compliance

implementation, after clearance from monitoring reports and field inspections.EASES

WB Environmental Provides Environmental Clearances for Reviews and approves IEIA/EIA and Implements compliance monitoringDepartment (EASES) (sub)-projects to EASUR Summary reports of Project Owners. procedures: e.g. review of compliance

(MIME/PPWSA or OBA contractors) monitoring reports and field inspections.Provides clearance for operating permits toMIME.

Supervision Support PMOs and PMUs. Supervises work of DBL and OBAConsultants contractors.

Support PMO/PMUs to prepare monitoringreports.

DBL Contractors Report directly to MIME-PMO Agreement with EA conditions in DBL Implement EA requirements.Contract. Prepare compliance monitoring reports and

submit to MIME.OBA Contractors Report directly to MIME-PMO Integrate ESF conditions into design and Implement EA requirements.

construction. Prepare compliance monitoring reports andPrepare and submit EIAI report to MoE (> submit to MoE and MIME.2000 HH)Obtain approval from MoE.

.MltMain text 5 *&/ersion 1.2, January 2003


5.3 Compliance Monitoring

General requirementsAll projects are subject to periodic compliance monitoring by the World Bank and theMoE (larger projects). The primary purpose of compliance monitoring is to ensure theimplementation of sound and standard environmental procedures as defined during theproject preparation. Specifically, it aims to:* Monitor project compliance with the conditions set in the operating permit;

Monitor compliance with the EMP and applicable laws, rules and regulations; andProvide a basis for timely decision-making and effective planning and managementof environmental measures through the monitoring of actual project impacts vis-a-visthe predicted impacts i n the EA.

The need for compliance monitoring is established at the time the Consent of the MoEand/or World Bank is issued, which will allow MIME to issue an operating permit. Thepermit sets the conditions for monitoring the activities to be monitored and themonitoring schedule. As a minimum requirement in compliance monitoring, the activitiesto be monitored by the PO should correspond to the conditions in the operating permitand EMP. In addition, the operating permit conditions may also require the proponent toundertake industry self-monitoring and submit the required reports.

General aspects to be covered in the Compliance Monitoring, as detailed in the EMP,includes:* Coverage of Monitoring;* Frequency of Monitoring;* Standard procedures/methods of monitoring (e.g. labeling, transport and handling of

samples) and laboratory analysis;* Selection of sampling stations;* Manpower requirements; and* Logistics.

The MoE letter of Consent issued pursuant to an IEIA/EIA report review also implies thepermission of the MoE to monitor proponent's compliance.

Internal implementation and monitoring of the EMPThe water supply system operator and the PG, with the assistance of PMO andconsultants, will monitor compliance with the operating permit and carry out the requisitedata collection during both the construction and operational phases. Monitoring reportsto be submitted to the MoE and the PMO wi 11 include:* Presentation of the collected data;* Discussion on the compliance or non-compliance to the E MP and operating permit;* Conclusions and recommendations.

The PMO is requested to summarize the finding of the quarterly monitoring reports andsubmit an annual compli ance report to the World Bank.

AlIPMain text 5-1 Version 1.2, January 2003


6 MAIN REFERENCES AND BACKGROUND DOCUMENTATION

CambodiaAtlas of Mineral Resources of the ES CAP Region, Volume 10, Cambodia, 1993.DILG/DBP - DBL Lease contract 'LGU Urban Water Supply and Sanitation project, The

Philippines.MIME/WB, 2001 - Regulatory Reform of the Water Supply and Sanitation Sector;

Cambodia Urban Water Supply. Draft final report, prepared by Fraser ThomasPartners and Sarin and Associates.

MIME/WHO, 2001 - Cambodia Drinking Water Quality Assessment. Prepared by PeterR. Feldman and Jan- Willem Rosenboom.

MOE - List of the Projects Require an IEIA or EIA; Annex of Sub-Decree No 72 ANRK.BK. Date 11 August, 1999.

MRD/JICA, 2001 - The study on Groundwater Development in Central Cambodia.Interim Report, prepared by Kokusai Kogyo Co., Ltd.

Parsons - DRAFT technical specifications for the OBA component of the 'Urban andPeri-Urban water supply project'.

Royal Government of Cambodia (1 996) - Law on Envi ronmental Protection and NaturalResource Management

Royal Government of Cambodia (1997) - Sub-decree of Construction License (No. 86)Royal Government of Cambodia (1 999) - Sub-decree on Water Pollution (No:

27.ANRK.BK)Royal Government of Cambodia (2 001) - Sub-decree on Environmental Impact

Assessment process. No: 72.ANRK.BKRoyal Government of Cambodia (-) - Guideline for conducting E nvironmental Impact

Assessment (EIA) report. Draft only. Ministry of Environment.

World Bank GuidelinesWorld Bank, 1991. Environmental Assessment Sourcebook; Volume l: Policies,

Procedures, and Cross-sectoral Issues. WB Technical Paper 139.World Bank, 1991. Environmental Assessment Sourcebook; Volume I: Sectoral

Guidelines. WB Technical Paper 140.World Bank, 1999. Operational Policy 4.01: Environmental Assessment.World Bank, 1999. Bank Procedures 4.01: Environmental Assessment.World Bank, 2001. Operational Directive 4.12: Involuntary Resettlement.World Bank, 2001. Bank Procedures 4.12: Involuntary Resettlement.World Bank, 2001. Operational Policy 7.50: Projects on International Waterways.

Internet SitesAsia-Pacific Centre for Environmental Law:

http://sunsite.nus.edu.sq/apcel/dbase/asean.html

.4lP-Main text 6-1 Version 1.2, January 2003


Annex A - Cambodian Environmental Regulations (available on attached CD-Rom)

General

General Constitution of the Kingdom of Cambodia (1993)

Law the Country planning. Urbanization and Construction (1994)

Ministry of Environment

Law on Environmental Protection and Natural Resource Management (1997)

Sub-decree on Environmental Impact Assessment process. No: 72.ANRK.BK (HTML or PDF file), includinga list of Projects subject to the EIA procedures (HTML or PDF file)

Guideline for conducting Environmental Impact Assessment (EIA) report. N° 49 BST.SSR Dated 9th March2000. Draft only. (HTML or PDF file)

Flowcharts for the EA process:

EIA Process for Proposed Project Approved by Royal Government of CDC

EIA Process for Proposed Project Approved by Proiect's Owner as Ministry and Institution

EIA Process for Proposed Project Approved by Provincial-Urban Authorities

Sub-decree on Water Pollution (No: 27.ANRK.BK) (HTML or PDF file)

Prakas (Declaration) on the Protection of Natural Areas (Ministry of Environment Declaration No. 1033)

Creation and Designation of Protected areas, 1993 (Kret No.

Ministry of Public Works and Transport

General specifications for construction activities:

Section 1: General Specification

Section 2: Earthworks and Allied Activities

Section 3: Subbase and Basecourse

Section 4: Bituminous Works

Section 5: Structures

Section 6: Drainage and Protection Works

Section 7: Ancillary Works

Section 8: Unexploded Ordnance

Section 9: Miscellaneous

Section 10: Day work

Annexes Version 1.2, January 2003


Miscellaneous

Preliminary Assessment of Cambodia's Environmental Law, prepared by Alan K.J. Tan, Faculty of Law,National University of Singapore (1998). Including:

Cambodian Primary Legislation

Cambodian Implementing Regulations

Country and regional perspectives on resource management in the Mekong River Basin

Annexes II Version 1.2, January 2003


Annex B - World Bank Environmental Guidelines (available on attached CD-Rom)

Environmental Assessment (from WB Operations manual)

Operational Policy

OP 4.01 (Environmental Assessment)Annex A (Definitions)Annex B (Content of an EA report for a Category A project)Annex C (Environmental Management Plan)

Bank Procedures

BP 4.01 (Environmental Assessment)Annex A (Environmental Data Sheet for Projects in the IBRD/IDA Lending Program)Annex B (Application of EA to Dam and Reservoir Projects)Annex C (Application of EA to Projects Involving Pest Management)

Involuntary resettlement

OP 4.12 Operational Policy + OP 4.12 Annexes

BP 4.12 Bank Procedures

Other safeguard policies

The World Bank's Safeguard Policies primary objective is to ensure that Bank operations do not causeadverse impacts and that they "do no harm." The ten safeguard policies are:

Environment

OP 4.04 - Natural Habitats + Annex ABP 4.04 - Natural Habitats Bank Procedures

Rural Development

OP 4.09 - Pest ManagementOP 4.36 - Forestrv + Annex AOP 4.37 - Safety of DamsBP 4.37 - Safety of Dams Bank Procedures + Annex A

Social Development

OP 4.11 - Management of Cultural PropertyOD 4.20 - Indigenous Peoples

International Law

OP 7.50 - Proiects on International Waterways + Bank ProceduresOP 7.60 - Proiects in Disputed Areas + Bank Procedures

Environmental Assessment Sourcebook

Below is the 1991 version of the EA sourcebook which is currently being revised and updated. TheSourcebook consists of three Volumes:

Volume I - Policies, Procedures & Cross Sectoral Issues (Chapters 1-7)

Volume II - Sectoral Guidelines (Chapters 8-9)

Annexes ill Version 1.2, January 2003


Volume III - Guidelines for Environmental Assessment of Energy and Industry Projects (Chapters 10)

Chapters:

1. The Environmental Review Process

2. Global and Cross-Sectoral Issues in Environmental Review

3. Social and Cultural Issues in Environmental Review

4. Economic Analysis of Proiects and Policies with Consideration of Environmental Costs and Benefits

5. Strengthening Local Capabilities and Institutions

6. Sector and Financial Intermediary Lending and Environmental Review

7. Community Involvement and the Role of Non-Governmental Organizations in EnvironmentalReview

8. Agriculture and Rural Development

9. Population. Health and Nutrition: Transportation: Urban Development: Water Supply and Sewerage

10. Energy and Industrv

Selected scanned parts:

Dams and Reservoirs

Irrigation and Drainage

Solid waste collection and disposal systems

Wastewater collection, treatment, reuse, and disposal systems

Updates

Chapter 1 Environmental Assessment: Process and components

Update No. 1: The World Bank and Environmental Assessment: An Overview

Update No. 2: Environmental Screening

Update No. 4: Sectoral Environmental Assessment

Update No. 14: Environmental Performance Monitoring and Supervision

Undate No. 15: Regional Environmental Assessment

Update No. 16: Challenges of Managing the EA Process

Update No. 17: Analysis of Alternatives in Environmental Assessment

Update No. 25: Environmental Management Plans

Chapter 2 Global and cross-sectoral issues in Environmental Assessment

Update No. 20: Biodiversity and Environmental Assessment

Update No. 7: Coastal Zone Management and Environmental Assessment

Update No. 10: International Agreements on Environment and Natural Resources

Annexes IV Version 1.2, January 2003


Chapter 3 Social and Cultural Issues in EA

Update No. 8: Cultural Heritage in Environmental Assessment

Update No. 18: Health Aspects of Environmental Assessment

Update No. 19: Assessing the Environmental Impact of Urban Development

Chapter 4 Economic Analysis of projects and policies with consideration of environmental costs andbenefits

Update No. 23: Economic Analysis and Environmental Assessment

Chapter 5 Strengthening local capacities and Institutions

Not yet available

Chapter 6 Sector investment, financial intermediaty and private sector operations

Update No. 6: Privatization and Environmental Assessment: Issues and Approaches

Update No. 24: Environmental Assessment of Social Fund Proiects

Chapter 7 Community involvement and the role of non-governmental organizations in EA

Update No. 5: Public Involvement in Environmental Assessment: Requirements, Opportunities andIssues

Chapter 8 Agriculture and rural development

Not yet available

Chapter 9 Population, Health and nutrition; Transportation; Urban development; Water supply andsewerage

Update No. 13: Guidelines for Marine Outfalls ancl Alternative Disposal and Reuse Options

Chapter 10 Energy and Industry

Update No. 12: Elimination of Ozone Depleting Substances

Update No. 22: Environmental Assessment of Mining Proiects

Chapter 11 Instruments and technologies in support of EA

Update No. 3: Geographic Information Systems for Environmental Assessment and Review

Update No. 9: Implementing Geographic Information Systems in Environmental Assessment

Update No. 11: Environmental Auditing

Update No. 21: Environmental Hazard and Risk Assessment

Other Off-line References

Principle Publications

The IMF/WB Pollution and Abatement Handbook (PDF version, DOC version)

Sourcebook on Participation (PDF files)

Electronic Learning Guidebook on Participatory Irrigation Management (not complete)

Annexes \/ Version 1.2, January 2003


GEF Operational progrHandbookams

International Waters

8. Waterbody-based Operational Program (Word97/ PDF)

9. Integrated Land and Water Multiple Focal Area Operational Program (Word97/ PDF)

10. Contaminant-Based Operational Program (_ord97/ PDF)

Publications of the Water And Sanitation Program (WSP)

Learning What Works A 20 Year Retrospective View on International Water and Sanitation Cooperation1978 1998

Effective Solid Waste Management With The Participation Of Waste Producers'

Urban Sewer Planning in Developing Countries and "The Neighborhood Deal": A Case Study ofSemarang. Indonesia

New Initiatives in Pollution Control (NIPC)

Informal regulation of industrial pollution in developing countries: Evidence from Indonesia

Program-Based Pollution Control Management: T he Indonesian PROKASIH Program (or a PDF file)

Controllinq Industrial Pollution: A new paradigm (or a DOC file)

Formal and informal regulation of Industrial Pollution: Comparative Evidence from Indonesia and the US(or a PDF files)

Environmental news in Argentina. Chile. Mexico and the Philippines

Impact of Financial Crisis on Industrial Growth and Environmental Performance in Indonesia

Pollution from Industrial Sources

Regulation in the Information age: Indonesian Public Information Program for EnvironmentalManagement

Going public on polluters in Indonesia: Bapedal's proper Prokasih Program

What is PROPER? Reoutational incentives for Pollution incentives for pollution contro. in Indonesia (or aPDF file)

Regulatory inspection, informal pressure and water pollution: A survey of Industrial plants in India

On-line WWW links

Environmental Department of the WB

World Bank homepage

Annexes VI Version 1.2, January 2003


Annex C - OBA Instructions for compliance with Environmental Safeguards

IntroductionThe Contractor will be responsible for complying with Environmental and Social

safeguards, as defined by the Government of Cambodia and the World Bank. Possible

environmental concerns will have to be addressed and mitigation measures to be

incorporated into the formulation and evaluation process of technical alternatives, and

hence into the project design, construction, and operation. Necessary environmental

mitigation measures will have to be included in the cost of the water to be provided.

The Project approach for securing compliance with Environmental Safeguards is based

on the following documentation:



Draft only. Ministry of Environment.* Draft Drinking Water Quality Standards (WHO)

World Bank Guidelines * Guidelines on Environmental Assessment (OP and BP 4.01);* Guidelines on Involuntary Resettlement (OP and BP 4.12);* Guidelines on Indigenous People (OD 4.20);* Guidelines on Natural Habitats (OP and BP 4.04).

Project MethodologyEnvironmental Project instructions and guidelines have been developed by MIME

combining both the Cambodian regulations and WB guidelines. The methodology has

been elaborated in an "Environmental Safeguard Framework", as part of the Project

Operations Manual' (ESF-OM), which is being applied for similar projects in Cambodia.

A copy of the ESF-OM (hardcopy or CD-Rom, together with sample IEIAs, can be

obtained from MIME.

MIME has agreed with the World Bank that for water supply systems > 2,000

connections, a concise Environmental Assessment (EA) for each of the participating

towns in the OBA Component will be prepared. This is consistent with the Cambodian

Sub-decree on Environmental Impact Assessment Process, which was issued in

December 1999. The Cambodian Environmental Impact Assessment (EIA) reporting

requirements for water supply projects start with 10,000 users. The sub-decree details

specific procedures to be followed and lists the nature and size of projects which are

required to submit Initial Environmental Impact Assessment (IEIA) or ElAs reports.

Larger WS system (> 2,000 connections)

The Contractor, being the Project Owner, will seek Environmental Clearance from the

Ministry of Environment, who will subsequently notify MIME, being the Approving

Agency, that construction of the project can proceed.

The first step in the EA process is the preparation of an IEIA, to be submitted by the

Project Owner to the MoE and MIME, supplemented with an Environmental Examination

Annexes VII Version 1.2, January 2003


Application (EEA). The preparation of the IEIAs should be carried out parallel to thefeasibility study and preliminary design. The IEIA will include an EnvironmentalManagement Plan (EMP), which will be an integrated part of the project design,appraisal and implementation. The findings and conclusions on the mitigation/monitoringactions to be taken will be summarized in an Environmental Mitigation Plan (EMiP), anEnvironmental Monitoring Plan (EMoP) and an overview of the implementationarrangements, defining the responsibi lities and timing.

Based on the review of the IEIA by MoE, the Project will either be approved, additionalchanges to the IEIA will have to be made, or a full scale EIA report will have to beprepared. Construction activities can only start after approval of the IEIA or EIA report bythe Ministry of Environment and MIME/WB.

Smaller WS systems (<2,000 con nections)For smaller systems (<2000 connections), the Contractor will have to includeEnvironmental Safeguard Guidelines into the Project design and operationarrangements, but will not be required to prepare an IEIA or seek formal permission fromthe Ministry of Environment. MIME and World Bank clearance for the project will beprovided if the Environmental Safeguard gulidelines are sufficiently incorporated into theproject designs.

Monitoring ArrangementsThe Contractor will have the overall responsibility for the proper implementation of theEnvironmental Management Plan (EMP) and/or Environmental Instructions. Upon thesigning of the OBA contract, the Contractor will proceed with the necessary steps for theenvironmentally sound construction and operation of the water supply system, asdefined in Contract. Project supervision by MIME and World Bank staff will be carried outto ensure compliance with Environmental and Social safeguards.

During the construction and Operation phase, the Contractor will be responsible forsecuring that proper measures are taken. The monitoring data will be well documentedand be available with the Contractor and MIME for consultation and inspection. TheContractor will inform MIME if violations occur, and appropriate actions will be taken.Moreover, MIME and World Bank staff will carry out control inspection during theirregular visits to the Provinces.

Brief monitoring reports will be submitted by the Contractor to MIME as part of theregular monitoring requirements, including: presentation of the collected data; discussionof the compliance and non-compliance to the EMP; and conclusions andrecommendations.

Regular monitoring reports will be submitted by MIME to the World Bank during theoperation phase. The environmental data will be available with the MIME and theContractor for consultation and inspection.

Annexes VilI Version 1.2, January 2003

Provincial and Peri-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME / PPWSA / WB) Proiect Operations Manual

Annex D - Environmental Safeguard Guidelines for Smaller WS System

IntroductionThe following Environmental Safeguard guidelines apply to the development of smallerpiped water supply systems with less then 2,000 connections. As many of the potentialEnvironmental Impacts are relatively standard for most of the smaller systems, simplifiedreporting procedures are applied to lower the transactions costs of project preparation.This is consistent with the Cambodian Sub-decree on Environmental ImpactAssessment Process, which was issued in December 1999. The CambodianEnvironmental Impact Assessment (EIA) reporting requirements for water supplyprojects start with 10,000 users.

Possible environmental concerns will have to be addressed and mitigation measures tobe incorporated into the formulation and evaluation process of technical alternatives, andhence into the project design, construction, and operation. Necessary environmentalmitigation measures will have to be included in the cost of the water to be provided.

The Project approach for securing compliance with Environmental Safeguards is basedon the following documentation:



Draft only. Ministry of Environment.* Draft Drinking Water Quality Standards (WHO)

World Bank Guidelines * Guidelines on Environmental Assessment (OP and BP 4.01);o Guidelines on Involuntary Resettlement (OP and BP 4.12);* Guidelines on Indigenous People (OD 4.20);* Guidelines on Natural Habitats (OP and BP 4.04).

Monitoring ArrangementsAll Sub-projects will be subject to regular monitoring procedures, as s pecified in theProject Operations Manual.

Annexes IX Version 1.2, January2003


Overview of general potential impacts and mitigation measures

Potential Negative Impact Possible Mitigation measures

Pre-construction PhaseLack of control of water source . Acquire land directly around the water source

Conflicting interests of water users * Check sufficient availability of water* Secure proper compensation arrangements

Land acquisition and resettlement . Usage of public grounds (e.g. roads, etc.)(see also below) . Provision of proper compensation

Disturbance of land use and * Usage of public owned areaseconomic activities (see also below) * Provision of proper compensation

Construction PhaseDisturbance of the land use * Minimize impacts and provide proper compensation for economic

losses* Restore

Los of natural vegetation * Replantinc of areas

Disturbance of stream channels, * Erosion/sedimentation control during constructionaquatic plant and animal habitats

Soil and water contamination * Control (collection, disposal) of waste

Hindrance (noise, air pollution, * Minimize hindrance to local populationtraffic, etc) due to construction * Engage and Provide labor for local populationactivities . Usage of main roads where possible.

Soil erosion and compaction . Proper runoff and erosion control through land protection anddrainage channels

* Heavy traffic restrictions

Safety hazards . Application of proper safety and waming measures* Provision of temporary crossings and bridges* Public information campaign

Operation PhaseIncrease of public health hazards * Secure the construction of proper on-site sanitary facilities if stilldue to increase of wastewater (see lacking;also below) e Construct on-site soakaways for waste water and sullage

* Maintain and/or improve storm water drainage system for sullage

Contamination of stream channels * Assure that inflow is relatively small compared to receiving riverdischarge

* No routinc of sewer lines directly in stream channels

Water logging and salinization * Maintain and/or improve storm water drainage system

Soil erosion o Proper runoff and erosion control through land protection anddrainage channels

Annexes X Version 1.2, January 2003


Potential impacts and mitigation measures related to the intake of surface water


Pre-construction PhaseSustainability of surface water * Analyze feasibility of acquiring land for intake and treatment plant;

* Assure that no people are negative affected by land acquisition,i.e. provide proper compensation for losses of land and income;

* Analyze feasibility of controlling upstream watershed (checkcurrent ancl planned development projects on logging, mining,agricultural development, road construction, etc.)

* Assure that no polluters are discharging upstream in the river.* Assure that no increase of potential polluters can be reasonably

expected.

Feasibility of treatment and sludge * Assure that treatment of surface water will provide safe drinkingdisposal. water quality;

* Assure that proper sludge disposal can be arranged.

Existing river contaminated * Assure quality of surface water can be properly treated forbacteriological quality, organic and inorganic components,pesticides, metals

Violation of minimum acceptable a Measure and analyze surface water dischargeflow

Construction PhaseDisturbance of stream channels, . Erosion/sedimentation control during constructionaquatic plant and animal habitats

Soil and water contamination by * Control (collection, disposal) of spillagespilling of construction products

Hindrance (noise, traffic, etc) due * Minimize hindrance to local populationto construction activities * Provide labor and engage local population in construction

activities.

Operation PhaseReduced surface water flow due to . Assure that intake is small compared to river dischargesurface water intake * Control for compliance to minimum acceptable flow

Reduction in or change of regime * Monitor and regulate development projects in the upstreamof surface water flow watershed (logging, mining, agricultural development, road

construction, etc.)

Temporary river pollution * Arrange for basic water quality monitoring upstream as an 'earlywarning' system

Production of sludge * Arrange for proper disposal facilities for sludge residue

Annexes Xl Version 1.2, January 2003


Potential impacts and mitigation measures related to the development of springs


Pre-Construction phaseSpring sustainability and protection * Acquire and fence land directly around the spring;(see also below!) * Assure that no people are negative affected by land acquisition,

i.e. provide proper compensation for losses of land and income;* Analyze feasibility of controlling upstream watersheda Assure that no potential pollution sources are present in upstream

watershed* Assurance/proof that other water users are not affected* Assess spring discharge and seasonal fluctuations

Conflicting interests of water users . Check current usage of spring water* Check sufficient availability of water* Secure proper compensation arrangements

Existing spring contaminated . Assure water quality on bacteriological quality, organic andinorganic components, pesticides, metals.

Construction phaseLos of natural vegetation * Replanting of areas

Soil and water contamination by * Control (collection, disposal) of spillagespilling of construction products

Hindrance (noise, traffic, etc) due * Minimize hindrance to local populationto construction activities . Provide labor and engage local population in construction

activities

Operation PhaseReduced surface water flow due to * Assure that spring discharge is relatively small compared tothe captation of springs receiving stream flow

Annexes XII Version 1.2, January2003

Provincial and Per-Urban Water and Sanitation Project Environmental Safeguard FrameworkRoyal Kingdom of Cambodia (MIME I PPWSA / WB) Project Operations Manual

Potential impacts and mitigation measures for the development of groundwaterPotential Negative Impact Possible Mitigation measures

Pre-construction PhaseSustainability and protection of * Analyze feasibility of acquiring land directly around the well;groundwater resources * Assure that no people are negative affected by land acquisition,

i.e. provide proper compensation for losses of land and income;Assure that no potential pollution sources are present in therecharge area

Conflicting interests of water users * Prediction of insignificant draw-down in surrounding wells (seebelow)

Existing groundwater contaminated * Check groundwater on organic and inorganic components, metals(Arsenic, Iron, Manganese!)

Construction PhaseDisturbance of the land surface . Minimize impacts and provide proper compensation for economicdue to drilling activities losses

Soil and water contamination by * Control (collection, disposal) of oil spillagespilling of oil products

Hindrance (noise, traffic, etc) due * Minimize hindrance to local populationto drilling activities * Provide labor and engage local population in drilling activities

Operation PhaseContamination of the groundwater * Acquire and fence a protection zone directly around the well;source . Regulate potential polluting activities in recharge zone;

* Monitor water quality (Arsenic), water level and groundwaterabstraction;

Lowered groundwater table * Calculate safe yield (abstraction)* Apply sufficient spacing between deep wells* Assure/proof that other water users are not affected

Reduction in artesian flow . Locate the well in an area where other water users are not(see also below) affected

Intrusion of saline water . Locate the well at sufficient distance from the sea* Determine and monitor draw-down and safe yield

Decreasing discharge of surface * Assure that quantity pumped is relatively limited compared towater streams stream discharge

Increase of noise * Usage of electrical submersible pumps* Construction of proper pumping house

Annexes XIII Version 1.2, January2003


Guidelines for the minimum land acquisition for water sources protectionWater Minimum land Minimum land RemarksSource acquisition requirements acquisition requirements

outside residential areas within residential areasSpring 20-50 m around the spring Not aclvisable Additional protection of the

box watershed is mandatory)

Deep well 10-20 m around the well 30-50m around the well Additional protection measuresfor the recharge area isrecommended (see section 0)

Surface water Size of the intake and Size of the intake and Extensive upstream waterintake treatment plant treatment plant quality monitoring will be

necessary to allow for control ofpolluters

Sludge 1000 - 2000 m2 Not acceptabledisposal

Example for guidelines for groundwater protection zonesDirect catchment area Protection area Remaining recharge

areaDelay time or distance 60 days and greater then 10 and 25 years or 2to well field 30 meter kilometer

Protection measures Protection against Protection against hardly Rules and act on soilpathogenic bacteria and degradable chemicals and groundwaterviruses, chemical protectionpollution sources

Admissible activities Only activities in relation Not admissible as a rule:to water supply . Transport and

storage ofdangerous goods

* Industries* Waste-sites* Building* Military activities* Intensive agricultural

and cattle breeding* Ground-sand or

limestone pits* Wastewater

Note: applies to porous permeable aquifers

Annexes XIV Version 1.2, January2003


Annex E - Supplementary Technical Guidelines

Annex E I - Assessm ent of Environmental Baseline Conditions

Data should be collected during field visits and desk studies. Because the required EAreport is not a full-scale assessment, information may come primarily from existingreports/studies supplemented by some field data and consultations with affectedstakeholders. A checklist of the most relevant issues is given in Table 13. A listing ofconsulted documents and reports should be included as an Annex.

Table 13 - Checklist for assessment of environmental baseline conditionsEnvironmental Conditions To be checkedCondition of watershed / catchment / * Check for adequacy of management and protectiongroundwater (GW) aquifer recharge * Identify existing or potential threats to quality and quantityarea (=sustainability) of source of supply

* Gather available data on past trend of water quality and yield

Levels and quality of shallow GW * Take samples and check for Fecal Coliform (FC), Nitrates,Iron and salinity

* Gather available data on trends of GW quality and yield

Surface drainage system including * Assess adequacy and proper functioningwater courses * Identify deficiencies, such as lack of drains, stagnant I

ponding water, clogged drains, undersized culverts andbridges

* Take water samples and check for FC and BOD* Assess demand for drainage improvements (through

consultation)

On-site sanitation systems * Determine percentage of coverage by type / category* Estimate percentage of systems functioning adequately* Estimate percentage of households without adequate systems* Assess demand for individual or community systems,

affordability and willingness-to-pay (through consultation)

Solid Waste Management . Assess general cleanliness of urban area* Check existing arrangements for garbage* Check availability of adequate disposal site, and disposal

procedures* Assess demand for improved garbage collection

Gather available public health statistics * Check for history of waterborne diseases* Outbreak of epidemics* Morbidity and mortality rates* Historic water quality data of existing water supply system (if

any)

Field visits should mainly focus on an initial field inspection of the concerned area andconsultations with the PG administration. Initial environmental concerns of both the PGadministration and the EA report preparer should be discussed and possible mitigationrequirements should be identi fied.

Annexes XV Version 1.2, January 2003


During the EA report preparation, a close cooperation with the Engineering Consultantwill be required. As the Engineering Consultant will carry out an extensive survey in thetowns, information will be obtained among others on socioeconomic conditions, publichealth, water resources, and sanitary conditions. These data should be incorporated inthe Environmental Assessment. Also, environmental issues and concerns will have to beincluded in the public consultations (see section 1.4.2), in the selection of alternatives(see Annex E 2), and discussed and agreed upon with the PGs (see 0).

An important step during the data collection is a (or multiple) 'Scoping' visit(s) to theMinistry of Environment. It is strongly advised to introduce the project to the governmentofficials at an early stage and discuss the range of actions to be undertaken andalternative and impacts to be examined.

Annexes XVI Version 1.2, January 2003


Annex E 2 - General analysis and comparison of potential environmental impacts

Prediction of general environmental impactsIn the WB Environmental Assessment Sourcebook no separate detailed section onenvironmental impacts of water supply development is included. As a reference onenvironmental impacts, the reader is referred to the Chapters on Land and WaterResources Management, Wastewater collection, Treatment, Reuse and Disposalsystem, and Oil and Gas pipelines.

A distinction is made between general environmental impacts, independent from theselected water source, and water source specific impacts. General impacts aredescribed in the current section. Impacts that are specifically related to the selection andusage of groundwater, springs, and surface water are elaborated in Annex E 3.However, it should be noted that the overviews may not be complete and additionalissues and impacts could be considered relevant.

Annex D summarizes in random order possible general impacts, including an overviewof possible mitigation measures. Selected issues on wastewater, land acquisition andcompensation are elaborated below. More detailed technical guidelines for the variousproject components are described in A nnex E 3 through Annex E 5.

Land acquisition, compensation and resettlementLand acquisition will be required for the protection of the immediate surroundings of thewater source, allowing only activities related to water supply. No official guidelines on thesize of protected areas around water sources exist yet in the Cambodia. Therefore,based on international experience, an estimate is made on the area to be acquired, bothfor location within and outside residential zones (Table 14). These estimates shouldprovide enough immediate protection against contamination of the drinking water sourcedue to accidents and improper land use. Specific additional protection requirements forgroundwater and spring sources are elaborated below .

Table 14 - Guidelines for the minimum land acquisition for water sourcesprotectionWater Source Minimum land acquisition Minimum land acquisition Remarks

requirements outside requirements withinresidential areas residential areas

Spring 20-50 m around the spring Not advisable Additional protection of thebox watershed is mandatory)

Deep well 10-20 m around the well 30-50m around the well Additional protection measuresfor the recharge area isrecommended (see section 0)

Surface water Size of the intake and Size of the intake and Extensive upstream waterintake treatment plant treatment plant quality monitoring will be

necessary to allow for control ofpolluters

Sludge 1000 - 2000 m2 Not acceptabledisposal

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The content and level of details for plans on land acquisition, compensation andresettlement to be incorporated into the EMPs will vary with circumstances and themagnitude of resettlement. If minor impacts or measures will be required, the purposeand size of the required land acquisition should be indicated. If major impacts ormeasures will be required, separate resettlements plans will be required according to theWB OD 4.30. Implementation of these requirements is further elaborated in the separatechapter of the Operations manual on Compensation and Resettl ement.

Comparison and selection of alternativesA first comparison of the main identified and feasible alternatives can be carried out inthe form of a summary matrix of alternatives (see Table 15). Such analysis brieflyindicates the main environmental issues and possible impacts of all the alternatives. Asub-division for the pre-construction, construction, and operation phase has to beincluded. To provide a complete comparison of possible environmental degradationand/or improvements, the "no-project" alternative should be included. This enables toinclude and highlight also positive impacts brought by the project.

Rating of impacts in the summary matrix will be generally qualitative only, as quantitativeanalyses will in most cases be beyond the scope of the EA report preparation. However,available quantitative/numerical data could be included in the matrix or furtherelaborated in the mitigation and monitoring plans.

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Table 15 - Example of a summary matrix of Environmental Issues/lmpactsPhase Environmental Parameter 'No 'With

Project' Project'Pre- Reliability of water availability +Construction

Reliability of water quality - +

Land acquisition and resettlement 0 0Disturbance of land use and economic activities. 0 0

Construction Disturbance of the land use 0 0

Loss of natural vegetation 0Disturbance of stream channels, aquatic plant and animal 0 0habitatsSoil and water contamination 0Hindrance (noise, air pollution, traffic, etc) due to 0construction activitiesSoil erosion and compaction 0

Employment 0 +

Operation Public Health +

Contamination of stream channels 0Water logging and salinization 0 0

Soil erosion 0 0

Land subsidence 0 0

Increase Land ValueEnhance Economic Activity

Leaend:- Significant negative environmental impact- Moderate negative environmental impact0 None or insignificant environmental impact+ Beneficial environmental impactn.a. Not applicable

Close cooperation with the other consultants should be maintained during the selectionprocess to obtain an acceptable compromise between social, economic/financial,technical and environmental criteria's. The goal of thi s "multi-criteria" selection process is

to balance development and environmental protection, not to consider them asconflicting problems only (i.e. 'trade-offs'). However, although environmentalconsiderations are not the only decisive factors for the selection, negative environmentalimpacts should receive ample attention and proper mitigation measures should besecured.

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Annex E 3 - Water Source Considerations

Development of groundwaterDeep groundwater wells are used in selected larger towns for piped water supply in theCambodia. In general, advantages of groundwater compared to springs and surfacewater include:* The reservoir character of groundwater enables better water resources management

and control;Lower vulnerability to water pollution (i.e. better protection of the water resources)Greaterflexibility in the selection of the well location.

Disadvantages of groundwater compared to springs include the pumping requirements,increasing the O&M cost, and reported problems with natural water quality. Especially involcanic areas (or volcanic sediments) the groundwater may have high iron and/ormanganese contents, requiring additional treatment.

In Annex D an overview is given of potential environmental impacts and possiblemitigation measures specifically related to the development of deeper groundwater. Thelisting, which may not be fully complete, is additional to and has to be combined with thedescribed general environme ntal impacts (see Annex E 2).

Well LicensingThe only current licensing requirement for groundwater abstraction has to be obtainedfrom the DPWS/MIME, linked to the operation of a water supply company.

New legislation is being prepared by the Ministry of Water Resources and Meteorology(MWRAM/SMEC, 2001). This new legislation would require obtaining a license also fromthe MWRAM. There will also be a fee charge for the amount of water abstracted, butfrom the present proposal the amount and rnechanisms are not yet clear.

The establishment of 'protection zones' for groundwater abstraction for drinking watersupply would be advisable for securing the quality of the groundwater. However, theestablishment and regulation of official groundwater protection zones is beyond thecapability of the PGs. Therefore, an adapted approach should be applied in the selectionof the location of a deep well:1. A first step in the selection process should be the determination of the groundwater

flow pattern. If clear indications of a dominant groundwater flow direction can bedetermined or suspected (e.g. on or near a mountain slope), the well should belocated upstream of the residenti al or other potential contamination sources.

2. If no prominent flow direction can be determined, general guidelines and commonsense should be applied in the selection of the location of the well(s). As an exampleof sound practices, Table 16 shows a system of guidelines as adapted from theguidelines in Germany and The Netherlands. The system applies to porouspermeable aquifers.

The introduction of groundwater protection zones could include the design of a propersimple monitoring network for existing and potential pollution sources, especially invulnerable areas. As it will be impossible to fully control or restrict potential pollutionactivities in the recharge area, monitoring can detect possible problems in advance andappropriate protection and/or rehabilitati on actions can be taken.

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Table 16 - Example for guidelines for groundwater protection zonesDirect catchment area Protection area Remaining recharge

areaDelay time or distance 60 days and greater then 10 and 25 years or 2to well field 30 meter kilometer

Protection measures Protection against Protection against hardly Rules and act on soilpathogenic bacteria and degradable chemicals and groundwaterviruses, chemical protectionpollution sources

Admissible activities Only activities in relation Not admissible as a rule:to water supply . Transport and

storage ofdangerous goods

* Industries* Waste-sites* Building* Military activities* Intensive agricultural

and cattle breeding* Ground-sand or

limestone pits* Wastewater

Note: applies to porous permeable aquifers

In areas where artesian wells for local water supply purposes are present, pumping ofdeep groundwater may reduce the discharge of the artesian wells. Therefore, thelocation of the well should be selected so that minimum effects are expected. If possiblenegative effects cannot be avoided, the issue should be addressed and clearly explainedduring the public consultations.

Intake of surface waterIt is expected that surface water may be Ei necessary water source for selected towns

participating in the project. Although surface water sources need extensive treatmentand high investment costs, and water availability may be subject to large seasonalfluctuations, surface water options may have to be cons idered if no other alternatives areavailable.

An overview of potential environmental impacts and possible mitigation measuresspecifically related to the construction of surface water intakes is given in Annex D. Thelisting, which may not be fully complete, is additional to and has to be combined with thedescribed general environme ntal impacts (see Annex E 2).

Water supply from the border river is not an appropriate water source for the currentproject. The World Bank 0 perational Policy (OP7.50) on International Waterways4 wouldrequire an extensive agreement between Ca mbodia and Thailand, whi ch seems to betoo uncertain for the present project:

4 Amongst others, this policy applies to any river, canal, lake, or similar body of water that forms a boundarybetween, or any river or body of surface water that flows through, two or more states.

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'Projects on intemational waterways may affect relations between the Bank andits borrowers and between states (whether members of the Bank or not). TheBank recognizes that the cooperation and goodwill of riparians is essential forthe efficient use and protection of the w aterway. Therefore, it attaches greatimportance to riparians 'making appropriate agreem ents or arrangem ents forthese purposes for the entire waterway or any part thereof.

Development of springsSpring development is often used for water supply because of their easy management

and low operational costs. In many cases water can be provided by gravity and only

limited treatment (chlorination) is required5 . However, a big disadvantage of the use of

springs is the lack of control of the water flow and quality, unlike for surface water and

groundwater. Discharge fluctuations, directly dependant on watershed conditions,

become critical external factors in the reliability and sustainability of the water supply

system (e.g. watershed protection, see below). Water exceeding the reservoir capacityoverflows and cannot be conserved. Therefore, an assessment of the discharge and

seasonal variation in flow is needed to confirm that the concerned spring is not directly

influenced by climatological changes (i.e. a "deep system").

An overview of potential environmental impacts and possible mitigation measuresspecifically related to the development of springs is given in Annex D. The listing, which

may not be fully complete, is additional to and has to be combined with the describedgeneral environmental impacts (see Annex E 2).

Protection of springs is a very critical issue. If the spring discharge diminishes, for

example due to upstream cutting of vegetation, water availability may becomeinsufficient and new water sources have to be developed. As often large investments are

required for tapping of springs (transmission pipelines), risks in developing and

exploitation of springs are relatively high. It is therefore of utmost importance toimplement and secure a very strict protec tion framework of the upstrea m watershed.

For securing the sustainability of the water source, it is not considered necessary that

the spring itself is directly located in the protected area. However, it should be confirmedand demonstrated in the EA report (e.g. by a map) that the main part of the rechargearea of the spring is located in the protected area, and no other potential pollution

source will have any effect on the quality of the spring.

5As a rule of thumb, if differences in water temperature occur during the day and night, the water quality issuspect.

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Annex E 4 - Sanitation and wastewater collection disposal

IntroductionImproving water supply requires addressing problems of increased amounts ofwastewater. As a rule of thumb, an estimated 80 to 90% of the delivered water supplywill has to be disposed of as wastewater6 . The provision of sanitary facilities to collectand dispose of human excreta poses a serious challenge to urban poor communitiesand to environmental sanitation planners of the government. Most urban centers in theCambodia rely on individual septic tank systems for the treatment and disposal ofwastewater from domestic and commercial buildings. However, the design for suchsystems is often inadequate. Facilities for land disposal of effluents from the septic tanksare generally absent. Hence the partially treated septic tank effluents flow directly intostorm drainage systems and other receiving bodies of water, thereby exacerbating analready grave pollution situation.

Where water quality problems are severe, as is the case in many densely populatedurban areas, individual wastewater projects may be executed as increments of long-termpollution control programs whose ultimate objectives realistically may take 10 to 20years or more to achieve. Water pollution control programs often include significantinstitution building and national water pollution control pol icy formulation components.

This section describes the relevant environmental aspects to consider for projectcomponents and mitigation/rehabil itation activities involving:* A general summary of potential environmental impacts;* A variety of small-scale on-site sanitation systems for rural and urban areas;* Although unlikely to be included, conduits for collection and conveyance of

wastewater, pumping stations, conventional and innovative treatment works,wastewater reclamation and reuse projects, ocean outfalls, wastewater treatment,and sludge management facil ities; and

* Urban storm water drainage projects (Annex E 5).

The overcrowding and lack of space in many urban poor communities pose a severeconstraint in improving toilet facilities, whether individual or public. The EA processshould ascertain the demand among residents for the facility, present to them therelevant technological options with their respective price tags. The selection betweenon-site and off-site facilities should be made by the communities based on feasiblechoices.

General overview of potential environmental impactsThe pollutants in municipal wastewater are suspended and dissolved solids consisting ofinorganic and organic matter, nutrients, oil and grease, toxic substances, and pathogeni cmicroorganisms. Urban storm water can contain the same pollutants, sometimes insurprisingly high concentrations. Human wastes that are not properly treated and aredisposed of at the point of origin or are collected and carried away pose risks of parasiticinfections (through direct contact with fecal material) and hepatitis and various

6 A distinction should be made between wastewater and waste from toilets (excreta faeces and urine) and sullage, thenon-toilet wastewater generated by a household (i.e. the wastewater from kitchen, bath and laundry, not containingexcreta).

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gastrointestinal diseases including cholera and typhoid (through contamination of watersupplies and food).

When wastewater is collected but not treated properly before disposal or reuse, thesame public health hazards exist at the point of discharge. If such discharge is toreceiving water, additional harmful effects will occur. For example, accumulated solidsmay impair habitat for aquatic and marine life; oxygen is depleted by decomposition oforganic material; and aquatic and marine organisms may be further harmed by toxicsubstances, which may spread to higher organisms through bioaccumulation in foodchains. If the discharge enters confined waters such as a lake or bay, its nutrient contentcan cause eutrophication, with nuisance plant growth, which can disrupt fisheries andrecreation. Solid waste generated in wastewater treatment (grit, screenings and primaryand secondary sludge) can poll ute soil and groundwater if not properly handled.

Wastewater projects are executed in order to prevent or alleviate the effects of thepollutants described above on the human and natural environments7. When properlycarried out, their overall environmental impact is positive. Direct impacts includeabatement of nuisances and public health hazards in the serviced area, improvement inreceiving water quality, and increases in the beneficial uses of receiving waters. Inaddition, installation of a wastewater collection and treatment system provides anopportunity for more effective control of industrial wastewater through pretreatment andconnection to public sewers and offers the potential for beneficial reuse of treatedeffluent and sludge. Indirect impacts include the provision of serviced sites fordevelopment, increased fishery productivity and revenues, increased tourist andrecreational activity and revenues, increased agricultural and silvicultural productivityand/or reduced chemical fertilizer requirements if treated effluent and sludge are reused,and reduced demands on other water sources as a result of effl uent reuse.

A number of these potential positive impacts lend themselves to measurement and thuscan be incorporated quantitatively into analyses of the costs and benefits of variousalternatives when planning wastewater projects. Human health benefits can bemeasured, for example, by estimating avoided costs in the form of health careexpenditures and lost workdays, which would result from poor sanitation. Reduceddrinking and industrial water treatment costs and increased fishery, tourism andrecreation revenues can serve as partial measures of the benefits of improved receivingwater quality. In a region where demand for housing is high, the benefits of providingserviced lots may be reflected in part by the cost differential between installing -theinfrastructure in advance or retrofitting unplanned communities.

Systems in which treated wastewater or sludge are reused may be more expensive toconstruct and operate than those in which the sludge is disposed of as a waste product.In evaluating alternatives involving reuse, however, it is important to include suchbenefits as increased water availability to support development in the region, theopportunity to diminish irrigation demands on potential public water supply sources,reduced need for chemical fertilizers, incremental improvements in crop and timberproduction, and low-cost means to re-vegetate marginal soils or reclaim them foragriculture or silvi-culture. These too can often be measured, most of them bycalculating avoided costs.

7Sub-decree on Water Pollution (No: 27.ANRK.BK) contains ambient water quality criteria categorized toprotect specific uses.

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Unless they are correctly planned, sited, designed, constructed, operated andmaintained, waste-water projects are likely to have a negative impact overall, failing toyield the full benefits for which the investment was made and adversely affecting otheraspects of the environment besides. The individual items listed are self-explanatory, forthe most part, and will not be discussed in detail in the text. However, there are severalcharacteristics common to many of the potential impacts and mitigating measures, whichshould be emphasized as special issues throughout project preparation, assessmentand implementation. These are:* The importance of sound and comprehensive was tewater system planning;. The fundamental dependence of wastewater projects on proper operation and

maintenance (and thus on strong insti tutional support for both);* Selection of appropriate technology;* The necessity for an effective industrial wastewater pretreatment program in any

municipal system serving industrial customers; and. The need to consider a number of potential socio-cultural impacts, which are

sometimes ignored in project preparation.

On-site sanitationPoor construction practices and disposal of the effluent and sludge of the septic tanksare main environmental concerns. Contamination of the surface (drainage) water posesa serious risk for public health. As the size and economic capacity of most target PGsmay not allow for an extensive sewerage system with treatment facilities, the selection oflow-cost on-site sanitary solutions is preferred. Appropriate technology options areavailable, whether water for flushing is available or not.

There are several possible options for addressing this problem, including improving thedesign of the septic tank system with the installation of soil absorption systems.Households discharging septic tank effluent (or other human wastewater effluent)directly into the storm drainage system may be required by the PG to add a properleaching field, leaching well or soak-away pit, preferably twin pits / fields to allow regularswitching and regeneration. Therefore, priority must be given by the PGs to address theproblem of discharge of partially treated effluent from septic tanks into the drainagesystem.

Some of these technologies were developed in the last two decades starting with theInternational Drinking Water Supply and Sanitation Decade of the 1980s. The well-triedsanitation alternatives that exist (e.g. pour-flush toilets) are not only cheaper thanconventional sewerage, but may also be able to deliver the same health benefits ifproperly installed and operated and offer the opportunity for community participation andreduce costs. However, it may be possible to modify these rural sanitation technologiesand try their appropriateness for the urban poor communities.

Off-site sanitationA summary of potential impacts and mitigation measures for the construction andoperation of off-site sewerage and drainage systems is provided in Table 17. Althoughthe Table focuses on sewerage and drainage systems, parts are general and can beapplied for on-site sanitation as well.

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Table 17 - Potential impacts and mitigation measures related to the constructionof sewerage and drainage infrastructurePHASE POTENTIAL IMPACT & RISKS POSSIBLE MITIGATION MEASURESPre- Dislocation of residents by * Assist with resettlementconstruction plant siting

Unplanned development * Coordinate installation of sewerage with land use planninginduced or facilitated by * Strengthen land use control regulation and institutionsinfrastructure * Integrate planning for infrastructure in urban development

projects

Regional solid waste * Incorporate sludge, excreta and septage in regional solid wastemanagement problems management planning and in wastewater system feasibilityexacerbated by sludge studies and technology selection

* Implement industrial waste pretreatment program

Loss of fisheries productivity * Evaluate importance of receiving water in local and regionalfisheries

* Implement mitigating measures for direct impacts

Reduction of tourist or * Give special attention to real or perceived nuisances andrecreational activity aesthetic impacts in selecting site and technology

* Implement mitigating measures for direct impacts

Construction Disturbance of stream * Do not route sewer lines in stream channelschannels, aquatic plant and * Require erosion/sedimentation controls during constructionanimal habitat, and spawningand nursing areas duringconstruction

Worker accidents during * Enforce adherence to safety proceduresconstruction and operation,especially in deep trenchingoperations.

Accidental destruction of * Include notification and protection procedures for culturalarchaeological sites during properties in construction contract documentsexcavation

Operation Alterations in watershed * Consider sub-regional and small community systems in water-hydrologic balance when short areas.wastewater is exported by * Take full advantage of opportunities for wastewatercollection in large upstream reclamation/reuse, especially in water-short areas.areas and dischargedownstream

Degradation of neighborhoods * Phase construction of collector systems and treatment works toor receiving water quality from avoid raw wastewater discharges.sewer overflows, treatment * Select appropriate technology.works bypasses, or treatment * Design for reliability, ease of maintenance.process failure. * Implement management and training recommendations,

monitoring program, and industrial waste pre-treatment program

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PHASE POTENTIAL IMPACT & RISKS POSSIBLE MITIGATION MEASURES

Degradation of receiving * Site and design treatment works and disposal or reuse systemswater quality despite normal on the basis of adequate data on the characteristics of thesystem operation wastewater and the assimilative capacity of the receiving water

body.* Use mathematical models for siting surface water discharges

and determining required level of treatment, and for siting anddesigning ocean outfalls.

* Take full advantage of appropriate land application alternatives,especially in water-short areas.

* Implement monitoring program and industrial waste pre-treatment program

Public health hazards in * Select appropriate technology.vicinity of discharges or reuse * Ensure pre-application treatment and operating guidelines forsites during normal operation land application and other water reuse systems are adequate toof system. safeguard health of humans and livestock.

* Restrict access to wastewater or sludge disposal sites wherehealth hazards are unavoidable.

Contamination at land * Site and design treatment works and disposal or reuse systemsapplication sites: on the basis of adequate data on the characteristics of the* soil and crops by toxic wastewater and land application site.

substances and * Implement monitoring program and effective industrial wastepathogens pre-treatment program (see text for guidelines).

* groundwater by toxic * Ensure pre-application treatment and operating guidelines forsubstances and nitrogen land application and other wastewater reuse systems are

adequate.

Failure to achieve desired * Establish realistic use objective and select water quality criteriabeneficial uses of receiving consistent with desired uses.waters despite normal system * Establish system performance standards by modeling or otheroperation. means which will result in meeting criteria.

Odors and noise from * Site treatment works only near compatible land uses.treatment process or sludge * Select appropriate technology.disposal operations. * Include odor control and low-noise equipment in design.

* Implement management and training recommendations

Emissions of volatile organic * Establish effective industrial waste pre-treatment program.compounds from treatmentprocess.

Soil, crop or groundwater * Incorporate sludge management in system feasibility studies,contamination and disease technology selection, design, staffing, training, budgeting andvector breeding or feeding at startup plan.sludge storage, reuse or * Implement effective industnal waste pretreatment program.disposal sites. * Ensure pre-application treatment and operating guidelines for

land application and other reuse or disposal systems areadequate to safeguard health of humans and livestock.

* Inspect for compliance with operating guidelines.

Worker accidents caused by * Emphasize safety education and training for system staff.gas accumulation in sewers * Implement effective industrial waste pretreatment program.and other confined spaces or . Provide appropriate safety equipment and monitoringby hazardous materials instruments.discharged into sewers. * Enforce adherence to safety procedures.

Serious public and worker * Incorporate safety provisions in design, operating procedures,health hazard from chlorine and training.accidents * Prepare contingency plan for accident response.

Nuisance and public health * Routinely insect sewers for illegal connections and obstructions.hazard from sewer overflows Clean sewers as necessary.and backups. * Provide monitoring system with alarms for pump station failure.

* Provide alternate power supply at critical pump stations.* Educate public to prevent disposal of solid waste in sewers.

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PHASE POTENTIAL IMPACT & RISKS POSSIBLE MITIGATION MEASURES

Failure to achieve public . Conduct sanitation and hygiene education programhealth improvement inserviced area

Perceived or actual nuisances . Iincorporate neighborhood improvements and useful publicand adverse aesthetic impacts facilities in projectin neighborhood of treatmentplant

Sewerage collectionGeneral off-site sewerage collection technologies, which could be considered, include:* individual holding tanks with truck collection* small-diameter gravity, pressure or vacuum sewers* shallow sewers* flat sewers* simplified sewerage systems* conventional gravity sewers and force mains* regional collection systems* community or sub-regional systems

The most environmentally sound alternative for the problem of discharging effluent ofseptic tanks that may be cost-effective and captures economies of scale is to connectindividual properties directly to a sewerage system for the collection, treatment anddisposal of the urban wastes. Especially if the center of a PG is relatively urbanized (i.e.higher population densities), the construction of a simplified sewerage system may berequired.

Wastewater treatment, disposal and manaaementA variety of siting and technological alternatives exists for wastewater collection,treatment and disposal, and sludge management. Several will be applicable in everysituation. A general summary of technologies is presented in Table 18.

Table 18 - General listing of wastewater treatment, disposal and sludgemanagement technology (after WB EA Sourcebook)WASTEWATER TREATM ENT WASTEWATER DISPOSAL SLUDGE MANAGEMENT

community on-site systems . reuse in agriculture, silviculture, . compostingoxidation ditches aquaculture, landscaping * co-composting with municipal

* stabilization ponds . reuse for groundwater recharge refuse* aerated lagoons . rapid infiltration * reuse in agriculture or silviculture* artificial wetlands (or constructed * underground injection * reclamation of marginal land for

wetlands) . reuse in industrial applications reforestation, cultivationl land treatment . ocean outfall . energy recovery (methanization)

* conventional biological treatment . surface water discharge . incinerationphysical-chemical treatment . night soil treatment plants . landfillpreliminary or primary treatment . ocean disposalwith ocean disposal

The concept of appropriate technology in wastewater systems has technical,institutional, social and economic dimensions. From a technical and institutional

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standpoint, selection of inappropriate technology has already been named as a primarycause of system failure. The wastewater environment is a hostile one for electronic,electrical and mechanical eqUipment. Maintenance is a never-ending process, and itrequires support - spare parts, laboratories, trained technicians, specialized technicalassistance, and adequate budgets. Even in developed countries, it is the simplersystems, selected and designed with maintenance in mind, which provide more reliableservice. In developing countries, where some of the ingredients for a successfulmaintenance program may be lacking, this should be the first consideration in choosingtreatment plant and pum ping station technology.

Level of treatment - the magnitude of pollutant removal a treatment process mustachieve -depends on the performance standards, which apply to the system. These areusually expressed as limitations on the concentrations of regulated substanc es permittedin the treated effluent. In the case of effluents, which are to be applied to crops orotherwise used on land, the standards are set to prevent crop and groundwatercontamination. National standards for effluent reuse may already exist; if they do not,they can be based on World Health Organization or World Bank guidelines or derivedfrom the standards of other countries in whi ch land application practiced.

Wastewater disDosalFor discharges to surface waters, the process of setting standards often begins withclassification of receiving waters based on the i ntended or desired uses. Receiving waterquality standards can then be established on the basis of the scientific literature toprovide for the uses in each classification. Classification of waters should be done withconsideration for what is economically and technically realistic; requiring drinking waterquality in a busy harbor, for instance, is not a sound use of pol lution control resources.

Ideally, effluent limitations for wastewater discharges should be determined by amathematical modeling process, which takes into account the existing quality and flowcharacteristics of the receiving water body. The maximum load of each pollutant whichcan be assimilated in each segment or zone under a specified statistical condition of dry-season stream flow (e.g., the minimum monthly flow in a five-year period) withoutcausing the standards to be violated can be calculated, and the load among alldischarges allocated. Such models require seasonal data on receiving water quality,volume and concentration of all discharges, and a long enough record of hydrologic datato show seasonal flow averages and permit calc ulation of the dry-season flow.

In practice, national effluent limitations are often established to correspond to the variousreceiving water classes, to simplify the process of preparing discharge permits orestablishing base/minimum levels of treatment. Modeling is reserved for situations inwhich adherence to those limits will not result in attainment of water quality standardsand more stringent requirements must be applied (or where projects are being plannedin countries without water quality or discharge regulations).

Limitations on discharges to marine waters are usually simpler; they focus on preventingdiscoloration of the water and pollution by oil and grease, floating debris, and bacteria (inshellfish harvesting and recreational waters). The major planning task is to identify anacceptable location for the submerged outfall, where the effluent will not degradesignificant water areas or contaminate shell lish beds and beaches.

Sludge management

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Wastewater treatment generates sludge and other solid waste, such as grit, and greasescreenings. Finding locations for waste dump or incineration, or outlets for recycling, isoften difficult. However, if solutions are not found, a portion of the pollutants removedfrom the wastewater will become pollutants of the land. Sludge management should bepart of wastewater system planning.

PlanninqIn many cases, it is cost-effective to construct treatment works in a modular fashion,adding additional capacity as the collector system is extended and new connections aremade. Phasing wastewater investments may be the only realistic way to make progresstoward ultimate water quality objectives in densely populated, highly polluted areas,where a single project would exhaust all resources available for public works andphysically disrupt the region. The level of treatment can be phased in a single project oras part of sector strategy. This approach is helpful when environmental improvement isurgently needed but local financial resources are limited or the scientific data todetermine exactly the extent of pollutant removal required has not been collected. It isimportant in any phased approach to reserve space for future expansion when acquiringsites and designing facilities.

Treatment facilities require land; siting them can lead to involuntary resettlement.Moreover, treatment and disposal works can cause nuisances in the immediate vicinity,at least occasionally. Often, the lands and neighborhoods selected are those of"vulnerable groups" who can least afford the costs of dislocation and whose livingenvironment is already impaired. Care should be taken to site treatment and disposalfacilities where odors or noise will not disturb residents or other users of the area, tomanage resettlement with sensitivity, and to include in the project mitigation planprovisions to mitigate or offset adverse impacts on the human environment. If theseconsiderations are not included in project planning, there is substantial risk of solvingone community's environmental problem by transferring it to another.

MonitoringThe frequency and level of sophistication of sampling depends in part on the size of thesystem and the nature of its treatment processes. Monitoring is expensive; it requireslaboratory facilities, equipment, and technicians. As a general principle, measure onlyparameters necessary for managing the system, safeguarding its staff and equipment,and protecting the environment (see also section 4.3.3: Environmental Monitoring Plan).

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Annex E 5 - Improvement of storm drainage and wastewater disposal

A problem in many slums and squatter settlements is the presence of stagnant waterthat becomes the breeding place of mosquitoes. Most of these areas are undevelopedlands, hence, the absence of internal drainage canals leading to the drainage mainsalong most city streets. The unplanned and uncontrolled construction of houses usuallyresults in difficulties in properly constructing drainage canals along straight lines withproper slopes.

During the rainy season, many of these areas are flooded after heavy rains. Theabsence of proper drainage results in very slow removal of trapped rainwater in low-lyingareas. In addition to rainwater, sullage and currently also the effluent from toilets andseptic tanks are household wastes that need to be conveyed out of the community toprevent the breeding of mosquitoes, flies and rats in the community.

In many communities (particularly in low-income areas) secondary and tertiary drainsare the responsibility of local residents. The unplanned nature of most slum and squattersettlements, in particular, has often affected the natural drainage of storm water andwastewater. The construction of neighborhood drains will be included in this sub-component.

Disposal of sullage could be implemented through a hydraulically well-designed stormwater drain or an on-site sullage soakaway 8 (simple 1-2m deep pit filled with rocks). Thestorm water drains should be able to carry the sullage flow also in dry weather periods.Especially in flat areas where natural drainage problems and water logging occur,emphasis should be given to regular cleaning and maintenance of the drainage system 9.

Discharge of sullage to marine environments is usually simpler then to surface waters.Main requirements include the discoloration of the water, and absence of pollution by oiland grease, floating debris, and bacteria (in shellfish and recreational waters).

As the environmental impacts are comparable or less then the impacts of theconstruction and operation of a sew erage system, the reader is referred to Table 17.

8Wherever possible, on-site solutions for sullage discharge are recommended, but the feasibility of this approach still hasto be tested.9 Drainage improvements within the project, if requested or considered necessary, are restricted to the storm waterdrainage system in the town. Flood protection is the responsibility of other Agencies, and should be addressed throughother appropriate channels.

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