REG: Improving the Implementation of Environmental ... · 3.5 Main Findings Revaled during the Documents Review and Site Visits 80 3.6 Non-Compliances and Recommendations 80 4. CWUW

Technical Assistance Consultant’s Report

This consultant’s report does not necessarily reflect the views of ADB or the Government concerned, and ADB and the Government cannot be held liable for its contents.

Project Number: 43333-012 July 2014

REG: Improving the Implementation of Environmental Safeguards in Central and West Asia

Environmental Safeguards Training Consultant and Third Party Auditor - Armenia, Azerbaijan and Georgia

Armenia Country Report

Prepared by” Eco Spectri” Ltd. (Georgia)

For Asian Development Bank

ASIAN DEVELOPMENT BANK ECO-“PECTRI LTD.

ASIAN DEVELOPMENT BANK

RETA 7548: Improving of Environmental Safeguards in Central and

West Asia

IDC: Environmental Safeguards Training Consultant and Third Party

Auditor - Armenia, Azerbaijan and Georgia

ARMENIA COUNTRY REPORT

Prepared by “Eco-Spectri” Ltd. (Georgia)

For Asian Development Bank

July, 2014

RETA 7548: Improving of Environmental Safeguards in Central and West Asia


2

TA-7548 REG: IMPROVING THE IMPLEMENTATION OF

ENVIRONMENTAL SAFEGUARDS IN CENTRAL AND WEST ASIA

ARMENIA COUNTRY REPORT

For consideration:

Asian Development Bank

6 ADB Avenue, Mandaluong City, Metro Manila, Philippines

Prepared by:

Ltd. “Eco-Spectri” 7 Chavchavadze Ave. Tbilisi 0179,

Georgia www.eco-spectri.ge



3

TABLE OF CONTENTS

TABLE OF CONTENTS 3 ABBREVIATIONS 5

EXECUTIVE SUMMARY 7 I.

TRAININGS CONDUCTED IN ARMENIA 18

1.1 Training Needs 18

1.2 Purpose and Objectives of the Training Course 18

1.3 Scope and Content of the Trainings 18

1.4 Training Methodology and Preparation 19 1.5 Review of Documentation 20 1.6 Preparation of Training Materials 20

1.7 Preparatory Activities 20 1.8 Project Implementation Team Composition and Detailed Tasks 22

1.9 Training Assessment & Evaluation 22 1.10 Execution of the Trainings and Observations 22 1.11 Staff Trained 22 1.12 Main Observations and Conclusions 27

1.13 Main Findings and Recommendations 34

II. ENVIRONMENTAL AUDITS CONDUCTED IN ARMENIA 36

1. CWPF 45230-001: WOMEN ENTERPRENEURSHIP SUPPORT PROJECT 36

1.1 Brief Project Description (CWPF - 45230-001) 36 1.2 Project Status 36 1.3 Institutional Aspects on Environmental Safeguards Implementation 36 1.4 Project Document Analysis 39 1.5 Meeting with the German - Armenian Fund (GAF) 41 1.6 Main Findings and Recommendations 41

2. CWEW 424117-023: SUSTAINABLE URBAN DEVEOPMENT INVESTMENT PROGRAM, PROJECT 1, TENDER 1 - CONSRUCTION/REHABILITATION OF ARSHAKUYATS STREET

43

2.1 Brief Project Information 43 2.2 Institutional Aspects on Environmental Safeguards Implementation 44 2.3 Project Document Analysis 46 2.4 Project Site Audit 52 2.5 General Findings and Recommendations 59

3. CWTC 42145-023, 42145-033: NORTH–SOUTH ROAD CORRIDOR INVESTMENT

PROGRAM – TRANCHE 1 AND TRANCHE 2: YEREVAN-ASHTARAK, YEREVAN-ARARAT AND ASHTARAK-TALIN

65



4

3.1 Brief Information on the project (42145-023; 42145-033) 65 3.2 Institutional Aspects on Environmental Safeguards Implementation 66 3.3 Project Document Analysis 68 3.4 Project Site Audit 73 3.5 Main Findings Revaled during the Documents Review and Site Visits 80 3.6 Non-Compliances and Recommendations 80

4. CWUW 45299-001: WATER SUPPLY AND SANITATION SECTOR PROJECT – PHASE 2

83

4.1 Brief Information on the Project 83 4.2 Institutional Aspects on Environmental Safeguards Implementation 84

4.3 Project Document Analysis 85 4.4 Project Site Audit 90 4.5 Main Findings Revealed During the Documents Review and Site Visits 98 4.6 Non-Compliances and Recommendations 100

APPENDIXES 102

Appendix 1. Environmental Safeguards Compliance Monitoring Checklist for the Construction/Rehabilitation of Arshakunyats Street Project

102

Appendix 2: Environmental Safeguards Compliance Monitoring Checklist For North–South Road Corridor Investment Program

107

Appendix 3. Environmental Safeguards Compliance Monitoring Checklist For Water Supply and Sanitation Sector Project

111



5

ABBREVIATIONS

ADB Asian Development Bank

ARMRM Armenian Resident Mission

AWSC Armenia Water Sewerage Company

CWRD Central and West Asia Department

EA Executive Agency

EIA Environmental Impact Assessment

EIAF Environmental Impact Assessment Framework

EMP Environmental Management Plan

ES Environmental Safeguards

ESMS Environmental and Social Management System

GAF German Armenian Fund

IA Implementation Agency

IEE Initial Environmental Examination

IFC International Financial Corporation

LA Loan Agreement

LLC Limited Liability Company

MES Monitoring and Evaluation Specialist

“NSRP” PMU SNCO

“North-South road Corridor Investment Program PMU” SNCO

OJSC Open Joint Stock Company

PAM Project Administration Manual

PIU Project Implementation Unit



6

PMCSC Project Management and Construction Supervision Consultant

PMU Project Management Unit

PPTA Project Preparation Technical Assistance

PPMU Project Preparation and Management Unit

RETA Regional Technical Assistance

SE Safety Engineering

SEMP Site-Specific Environmental Management Plan

SEPE Social and Environmental Protection Expert

SIEE Summary Initial Environmental Examination

SME DNC Small and Medium Entrepreneurship Development National Center

SPS Safeguard Policy Statement

SS Safeguard Specialist

SUDIP Sustainable Urban Development Investment Program

TA Technical Assistance

YM Yerevan Municipality

YMPIU Yerevan Municipality Project Implementation Unit



7

EXECUTIVE SUMMARY

1. ADB helps developing member countries (DMCs) to strengthen their safeguard systems and

develop their capacity to address environmental and social issues in development projects.

Since the approval of the Safeguard Policy Statement (SPS) in 2009, ADB has been providing

technical assistance to help strengthen the legal and institutional framework for effectively

implementing safeguards.

2. Work undertaken by ADB's Central and West Asia Department (CWRD) highlighted a number

of deficiencies preventing effective implementation of environmental safeguards. Foremost

among the challenges is insufficient capacity in executing agencies to prepare, implement, and

monitor the implementation of EMPs. The lack of effective implementation means that there is a

credible risk that projects are not in compliance with the SPS.

3. Under the TA of ADB, it was decided that a number of environmental service providers will be

trained to deliver the training course in each country and will do so through an on-call basis.

This approach will ensure that the type and content of training is consistent across all projects,

providing a more cost effective approach by avoiding the costs of international consultants,

developing an in-country training capability, providing an opportunity to undertake refresher

training, and it will also allow contractors to commission the same training, at their cost.

4. In scope of the project three training courses - Training of Trainers (ToT) in Improving of

Environmental Safeguards in Central and West Asia have been delivered in Kazakhstan,

Georgia and Pakistan in 2012. 33 Trainers from 6 firms undergone development of tracking

system training of third party auditors on effective environmental management and monitoring

during the job training. The trainings were based on the Environmental Safeguards Training

course developed by the ADB.

5. Few companies have been selected on tender basis to conduct on-the-job trainings and

environmental audits in 10 countries of Central and West Asia: Afghanistan, Armenia,

Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Pakistan, Tajikistan, Turkmenistan, and

Uzbekistan. In the countries of Caucasus region - Armenia, Azerbaijan and Georgia the project

is accomplished by “ECO-SPECTRI” LTD (Georgia). At the first stage, 4 trainings were conducted in Tbilisi, Georgia, 4 Trainings in – Baku, Azerbaijan and 4 trainings – in Yerevan,

Armenia for PIUs, Supervising Consultant and Construction Contractor.

6. At the second stage, the “Eco-Spectri’ Ltd. (the Consultant) conducted Environmental Audits

of ADB funded projects in Georgia in the framework of Regional Technical Assistance (RETA)

“Improving the Implementation of Environmental Safeguards in Central and West Asia”. At

present, 18 projects are implemented by three PIUs, in particular: Armenia Water Sewerage

Company (PIU), North-South Road Corridor Investment Program (PMU) and Municipality of



8

Yerevan. At this stage it is not decided how many sub-projects will be implemented in scope of

“Women Entrepreneurship Support Project” by the German - Armenian Fund.

7. The Environmental Audit was conducted after 9 months of training activities held for

Executing/Implementing Agencies’ (EA/IA), Project Management Unit/Project Implementation

Units (PMU/PIU)’s, Supervision Consultants, and Contractors involved in implementing ADB

funded projects. During the training activities, all participants were informed about approach and

steps to be taken during the Environmental Audit. In addition, a list of documents, which would

be reviewed during the Environmental Audit, was included into the training materials distributed

among participants.

8. The main goal of the Environmental Audit was an assessment of execution of environmental

safeguards during the project preparation and implementation stages as well as development of

recommendations for EA, PMUs/PIUs and ADB to improve environmental performance of the

projects based on findings revealed during the Environmental Audit. Generally, the

Environmental Audit consisted of two parts: (i) review of institutional and regulatory bases of

EA/IAs established for safeguards implementation; and (ii) assessment of Site Environmental

Management Plans (SEMP) implementation by Contractors at the construction sites.

9. As the module of trainings covered new approaches to be considered both, by the

Construction Contractor and other Project-implementing organizations, it was decided to

organize the Environmental Audits for the Project owner, Supervising Company and

Construction Contractor. The environmental audit was conducted by using the questionnaire

developed by the Asian Development Bank.

10. As a first part of Environmental Audit, the following project documents were reviewed to

check if environmental requirements are included: Loan/Project Agreements, Project

Administration manual, Bidding Documents, Contracts between Project

Management/Implementation Units (PMU/PIU) and Supervision Consultant/Contractors. In

addition, the results of environmental monitoring, which needs to be conducted by

Contractor/PMU/Supervision Consultant per concerned requirements indicated in each

Environmental Management Plan (EMP) and PMU/PIU’s working papers related to environmental performance were observed.

11. In order to assess Site-Specific Environmental Management Plan (SEMP) or EMP

implementation, a joint team comprised from representatives of the Consultant, PIUs,

Supervision Consultant, and Contractors visited construction camps and sites of all projects.

During those visits, sites with on-going and recently completed project activities were observed.

12. The following paragraphs and chapters give a detailed description of the summary of non-

compliances fixed with the trainings and environmental audits held in Azerbaijan, and relevant

conclusions and recommendations.



9

Summary of Findings, Non-Compliances, and Recommendations of Conducted Trainings

in Armenia

13. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU

representatives, 4 of them being the representatives of the Construction Contractor, 2 of them

being the representatives of the Supervising Consulting Company and 3 of them being the

representatives of RM of ADB. The rest 6 attendees were representatives of national banks

under the “Women Entrepreneurship Support Project”. 9 months after the trainings, 4 people

(21%) having taken the training, did not work in their previous positions, being either retired, or

moved to other positions with the same office (in short, they are not concerned with the

environmental issues any more).

14. In the course of the trainings, the participants stated about the problems hampering meeting

the environmental requirements. In the participants’ opinion, the problems existing in the country associated with the environmental protection are as follows: (a) Lack of correct state attitude

towards the environmental problems, due to which the contractor does not regard environmental

issues seriously; (b) Environmental specialist is not involved in the review of the tender

proposal; (c) There is no real mechanisms for PIU for penalization of the construction contractor

for non-compliances.

15. The results of the survey to evaluate the degree of mastering the training materials were

satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (14 %) made 1

mistake each, 16 of them (86 %). made 2 mistakes each.


satisfactory. The results of the survey to evaluate the degree of mastering the training materials

were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (12.5%)

made 1 mistake each, 15 of them (62.5%) made 2 mistakes each and 6 of them (25%) made 3

mistakes each.

17. The training evaluation questionnaires did not identify the respondents. As Table 9 shows,

the absolute majority of the participants are content both, with the developed training module

and method of delivery.

18. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship

Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the

same view, and the trainings desirable by them were about: (a) Preparation of environmental

documents and their implementation; and (b) Description of entire monitoring process.



10

19. Unfortunately, there were no international environmental specialists of a supervising

company of either project attending the trainings.

Summary of Findings, Non-Compliances, and Recommendations of Conducted

Environmental Audits in Armenia

Findings:

20. There are 18 ongoing projects on the territory of Armenia financed by the ADB, and there

are 3 PIUs engaged in their realization: Armenia Water Sewerage Company, North-South Road

Corridor Investment Program PMU and Municipality of Yerevan. At present, 18 projects are

implemented by three PIUs, in particular: Armenia Water Sewerage Company (PIU), North-

South Road Corridor Investment Program (PMU) and Municipality of Yerevan. At this stage it is

not decided how many sub-projects will be implemented in scope of “Women Entrepreneurship

Support Project” by the German - Armenian Fund;

21. The Loan Agreements prepared under the projects envisage the obligation of the authority

of the Republic of Armenia to realize the project in line with the ADB safeguard policies and

requirements of the environmental legislation of Armenia;

22. The FAM/PAM developed within the scope of the projects gives the necessity of fulfillment

of environmental requirements in different degree. The FAM developed within the scope of the

NSRP project gives a detailed description of the qualification necessary for the environmental

specialists and their rights and obligations, as well as all major requirements to be considered

by any organization engaged in the project. The FAM/PAM developed within the scope of other

projects gives fewer details related to the environmental requirements;

23. In each PIU, besides German-Armenian Fund, Environmental Unit is created or

environmental specialist is hired with relevant qualification. The obligations of environmental

specialist of GAF are performed by the Head of PFIs Audit Division;

24. International Supervision Consultant Company is hired under the North - South Road

Program (NSRP) and Sustainable Urban Development Investment Program (SUDIP) projects.

Local Supervision Consultant is hired under the “Water Supply and Sanitation Sector Project”;

25. No environmental specialist of PIU is engaged in tender evaluation committee. Only under

the (SUDIP) an environmental specialist was included in the bid evaluation committee. The

mentioned specialist had been invited from American University of Armenia.

26. All companies engaged in the realization of NSRP and SUDIP projects are staffed both, with

local and international environmental specialists of relevant qualification. Only the PIU

implementing the Water Supply and Sanitation Sector Project and Consultant/Supervision

Company are staffed with local environmental specialists. As for the construction contractors,



11

within the scope of the said project, they (the construction contractors) have not employed

qualified environmental specialists (the bidding documents do not give such a requirement).

27. The Baseline Analyzes ate accomplished within the scope of projects NSRP and SUDIP.

The Framework Initial Environmental Examination Report developed within the scope of Water

Supply and Sanitation Sector Project immediately gives the requirements for not accomplishing

such measurements (“No new baseline monitoring is required”, Clouse VIII – “Framework Environmental Management Plan”);

28. EMP is updated within the scope of NSRP and Water Supply and Sanitation Sector Project.

As for SUDIP, the EMP is not updated within its scope. There is also SEMP within the scope of

NSRP project by using the new methods of risk assessment developed by the Bank. There are

some inaccuracies fixed with the risk assessment methods;

29. Within the scope of NSRP and SUDIP projects, all planned monitoring are being

accomplished. The said monitoring are accomplished by the environmental specialist of both,

Construction Contractor and Consulting Company and PIU. There are no daily monitoring

envisaged by the EMP accomplished by an environmental specialist of Construction Contractor

within the scope of Water Supply and Sanitation Sector Project;

30. All planned environmental reports are developed and submitted within the scope of all

projects. The environmental data contained in the Monthly Progress Report within the scope of

Water Supply and Sanitation Sector Project is developed by the environmental specialist of the

Consulting Company. As per the requirement, the Progress Report is drafted by the

Construction Contractor and is submitted to the Consulting Supervision Company. But in this

case, it looks like the monthly environmental reports envisaged by the progress reports are

drafted by the Consulting Company to be submitted to itself;

31. The environmental trainings were conducted to the Construction Contractor within the scope

of NSRP. No environmental trainings were held within the scope of other projects despite the

fact that the documents for all of them (IEE and EMP) envisage such a requirement quite

strictly;

32. Within the scope of all projects, there are agreements drafted with the local authority and

relevant organizations concerning the following issues: disposal of inert and municipal waste,

use of borrow pits (if the company has its own borrow pits), removal of sewage silt, etc.

33. Within the scope of NSRP and SUDIP projects, the books of complaints are available on the

construction site. There is no book of complaints found at any construction site of the three sub-

projects within the scope of Water Supply and Sanitation Sector Project;

34. In scope of the NSRP there are permanent meetings held with the locals to consider the

environmental issues interesting to the population, who are under the project impact. This action

can be considered as good practice for other ongoing projects (in Armenia and other countries).



12

Within the scope of other projects, the results of environmental monitoring and audits are not

informed to the local population. However, it should be considered that no such requirement is

envisaged officially by any document;

Non-Compliances: 35. In scope of the project NSRP the inert waste is disposed on the existing topsoil. The

developed inert waste disposal plan does not envisage the removal of the topsoil on the territory

where the inert waste is to be placed. In fact, according to the developed plan, the topsoil on the

territory where the inert waste is to be disposed is to be totally destroyed;

36. In scope of the project NSRP there is a violation of standards at the territory of topsoil

disposal, in particular the height of the temporarily disposed topsoil significantly exceeds

permissible standards;

37. In scope of the Water Supply and Sanitation Sector Project neither of the Construction

Companies have an environmental specialist on staff. Consequently, within the scope of any

project, no daily inspections are conducted and no relevant records are made by the employees

of the Construction Contractor;

38. In scope of the Water Supply and Sanitation Sector Project the Consultant/Supervising

Company has not provided any training related with the environmental issues. It is necessary in

scope of the mentioned projects, because none of the Construction Contractor does not have

environmental specialist on staff.

Recommendations: 39. One of the documents developed under the project by ADB (Loan agreement, PAM/FAM)

shall necessarily contain the detailed description of the following environmental requirements:

(a) the rights and obligations of the environmental specialists of all organizations engaged in the

implementation of the project, (b) the need for the environmental specialist’s participation in the evaluation of the bid proposals and assessment criteria, (c) reporting and terms (regularity) of

reporting, (d) categories of non-compliance and sanctions for the failure to meet the

environmental requirements, (e) the requirement for the need to include all the above-listed

clauses in the biding documents and contract.

40. After the loan agreement is approved, PIU and/or the environmental specialist of the

consultant company shall be engaged in all following phases of the project implementation

(drafting the project detailed design, developing and assessing the tender bids, concluding the

agreement with the construction contractor);

41. The bid proposal developed within the scope of the Water Supply and Sanitation Sector

Project shall envisage the requirement for the Construction Contractor to hire a qualified



13

environmental specialist. Despite the fact that the project, under the Framework Initial

Environmental Examination Report developed within the scope of the project, has no great

impact, the said project belongs to category “B” and its scales are quite large covering 110

settled areas.

42. As practice evidences, despite the fact that in all cases, the bidding proposal is enclosed by

EIA or IEE and the obligation to meet the environmental requirements is specified by the terms

of the tender, most construction contractors do not read it, but they draft the project cost

estimate based on the list presented in the “Scope of Works”. It is necessary for the PIU and/or consulting company in the “Scope of Works” to give the detailed description of the necessary actions to be accomplished to meet the environmental requirements;

43. The positions of the professional safety and health specialist and environmental specialist

are desirable not to be occupied by the same person. If following the financial and technical

conditions of the project this seems necessary, the specialist is better to be an environmentalist

rather than the professional safety and health specialist (Water Supply and Sanitation Sector

Project);

44. An environmental inspection checklist is to be developed and records during the

environmental inspection are to be made. All relevant records must be kept on the construction

site. During the audit, the environmental specialist was given the sample daily or weekly

questionnaire and was explained the principles of filling it in (Water Supply and Sanitation

Sector Project);

45. Book of Complaints should be prepared and maintained on the site Water Supply and

Sanitation Sector Project);

46. A module of the environmental training is to be developed by the environmental specialist of

the Consulting Company and the training shall first of all be given to environmental specialist of

the Construction Contractor Water Supply and Sanitation Sector Project and SUDIP);

47. Under the ADB guidelines, the IEE document is developed and approved before the detailed

design is developed. Consequently, all negative environmental impacts of the project

implementation phase cannot be identified at this stage. It is clear that the EMP developed

within its limits cannot give all necessary mitigation measures. Consequently, the Construction

Contractor must update and not copy existents EMP (SUDIP);

48. SEMP does not envisage all the new requirements developed by the Asian Development

Bank. In addition, there are some inaccuracies fixed with the risk assessment methods and

using the requirements making it obviously necessary to update the documents (NSRP);



14

49. The results of the environmental monitoring are to be distributed among the project affected

settlements (in the language familiar to them). The reports of the environmental monitoring are

possible to hand over to the local NGOs (if any), local authorities, informal associations,

religious organizations, etc (SUDIP and Water Supply and Sanitation Sector Project);

50. Based on the Environmental Audit findings, the Consultant has developed a summarized

table of recommendations for the each reviewed sub-project. The table provides data on

implementer and timing when recommendations should be applied during the project cycle

(Table 1).

Table 1: Recommendations Matrix

# Recommendation Responsible/Actions Implementation

Terms

1. The loan agreements concluded within the scope of the project, PAM, IEE, bidding proposal, contract and other relevant documents must give the environmental requirements in greater details.

ADB - gives the environmental requirements in greater details in PAM. Construction/Supervision Consultant - gives the environmental requirements in greater details in IEE/EIA.

During preparation of relevant Documents – PAM, IEE and EIA.

2. It is necessary to update EMP. Construction Contractor: EMP should be updated on the basis of detailed design.

Within one month after receiving the Environmental Audit Report.

3. Monthly progress reports and quarterly environmental reports should be provided to all stakeholders, including local media

Construction Contractor: Disseminates monthly and quarterly reports prepared under the project among all interested stakeholders including media representatives.

Within one week after receiving the Environmental Audit Report to elaborate procedure for disseminating of monthly and quarterly reports among the local population.

4. All environmental specialists engaged in the project shall take the training developed within the scope of RETA project.

Consultant Company: prepares training module on the basis of the trainings conducted under the RETA program and conducts trainings for Construction Company employess including every

Within one week after receiving the Environmental Audit Report



15

new hired employees. 5. Place 0.24 m3 waste containrs wihin

the territory of construction site for collection of municipal waste.

Construction Contractor: Placement of 0.24 m3 waste containrs wihin the territory of construction site.

Within one week after receiving the Environmental Audit Report.

6. SEMP should be updated.

Construction Company: Risk assessment table is to be improved, assessment methodology has to be in compliance with ADB requirements.


7. Inert Waste Management Plan has to be updated.

Construction Company: Updates Inert Waste Management Plan in accordance with the presented recommendations.


8. Construction Contractor shall have environmental specialist on staff.

Consultant Contractor: Includes in bidding document requirement for the Contractor to hire a qualified environmental specialist on staff.

During the preparation stage of the bidding documents for the next sub-projects.

9. Armenia Water Sewerage Company shall hire at least two more environmental specialists.

PIU - Armenia Water Sewerage Company: Announces tender for hiring of two additional environmental experts within the PIU under the project.


51. The Consultant has prepared Environmental Audit Reports for all 3 projects and shared with to each PMU/PIUs for review and comments. Based on the comments provided by PIUs, the Consultant incorporated necessary clarifications into the final version of Environmental Audit Reports.

52. Following the above-mentioned, the present Country Environmental Audit Report considers

9 sub-projects. Brief information on implementation status of audited projects is presented in

Table 2.



16

Table 2: Brief Information on Implementation Status of ADB Funded Projects in Armenia

4. CWTC 42145-023: South Road Corridor Investment Program, Tranche 1: Yerevan-Ashtarak and Yerevan-Ararat

PIU: North-South Road Corridor Investment Program PMU; Construction Company: Corsan–Corviam Construction S.A Consultant Supervision: Safege S.A. Eptisa JV

Ashtarak-Yerevan-Talin

95% 1. The construction works are almost

completed and restoration works

are in progress.

5. CWTC 42145-033: South Road Corridor Investment Program, Tranche 2: Ashtarak-Talin

PIU: North-South Road Corridor Investment Program PMU; Construction Company: Corsan–Corviam Construction S.A Consultant Supervision:

Ashtarak - Talin 55% 2. The construction works are in

progress.

3. .

# Project Identification Project Implementation team (PIU, Construction

Company, Consultant Company)

Project Location Project Status (Project

Implementation Percentage)

Remarks

1. CWPF - 45230-001: Women Entrepreneurship Support Project

PIU: German -Armenian Fund (GAF)

Armenia 0% The project has not been started yet.

2. Tranche 1 - Tender 1: Construction/Rehabilitation of Arshakunyats Street

PIU: Municipality of Yerevan; Consultant Company: EGIS International; Consultant Company: Vahagn and Samvel LLC

Yerevan 8%

3.

Tranche 1 - Tender 2: Construction/Rehabilitation of New Shirak Street-Artashat Highway

PIU: Municipality of Yerevan; Consultant Company: EGIS International; Construction Company: EGIS International Consultant Company: not selected yet.

Yerevan 0 % A construction contractor has not been selected yet.



17

Safege S.A. Eptisa JV

6. CWTC 42145-043: South Road Corridor Investment Program, Tranche 3: Talin-Gyumri

PIU: North-South road Corridor Investment Program PMU; Construction Company: Corsan–Corviam Construction S.A Consultant Supervision: Safege S.A. Eptisa JV

Talin-Gyumri 0% No construction actions have been started yet. A tender to identify a Construction Contractor is announced.

7. Improvement of Water Supply Systems in Vedi and Ararat Towns and Banavan GMF, Ararat, Volketap Villages.

PIU: Armenia Water Sewerage Company Construction Company: Ararat-Chanshin LLS - Artezia LLS Consultant Supervision: JV of HGSN LLS and JINS LLS

Vedi and Ararat towns

81% 4.

8. Improvement of Water Supply Systems in Hrazdan Town, Qaghsi Village.

PIU: Armenia Water Sewerage Company Construction Company: LLS&Ashotsg LLS Consultant Supervision: JV of HGSN LLS and JINS LLS

Hrazdan town 78% 5.

9. Improvement of Water Supply Systems in Metsavan, Sarchapet and Lernahovit Villages and Reconstruction of Hovdra External Water Main.

PIU: Armenia Water Sewerage Company Construction Company: Agat 777 LLS Consultant Supervition: JV of HGSN LLS and JINS LLS

Metsavan, Sarchapet and Lernahovit villages

70% 6.



18

I. TRAININGS CONDUCTED IN ARMENIA

1.1 Training needs

53. The ADB Safeguard Policy Statement (SPS 2009) contains a revealing paragraph that

discusses the environmental management of previous projects.

54. Three major reasons why projects fail to effectively implement environmental safeguards

requirements are:

Poorly prepared EMPs that do not provide enough details for the environmental staff of

PIUs to know what measures to implement on the ground;

Lack of direction of guidelines from ADB as to what is required and when, and

Poorly prepared tenders and contracts that do not provide that not provide adequate

environmental management requirements.

55. There is thus a need to train project staff in how to implement environmental requirements,

understand what should be done, when and by whom; have the ability to incorporate

environmental management requirements into tender and contract documents and have the

ability to prepare and assess a site-specific environmental management plan (SEMP) so that

construction workers can have a clear picture of what is required on the ground.

1.2 Purpose and Objectives of the training course

56. Purpose of the training is to strengthen the environmental management and monitoring capability of the executive agency and project implementing organizations, as well as construction contractor and supervision consultant in the region through on the job trainings.

57. The objectives of on-the-job trainings are thus to ensure that the PIU, contractor companies and consultants environmental staff responsible for preparation, adoption and implementation of EMP/SEMP. 1.3 Scope and Content of the trainings

58. According to the contract between Asian Development Bank and Ltd. “Eco-Spectri” (The Consultant), the Consultant commenced the services on 5th of June, 2013. Training schedule for

Georgia has been prepared by Ltd. “Eco-Spectri” and agreed with ADB.

59. It was envisaged to conduct 4 on-the-job trainings in Yerevan, Armenia of executive agency

staff, project supervision consultant and contractors in environmental management, monitoring

and reporting based on the Environmental Safeguards Training course developed by ADB as

per the schedule detailed in Table 3 below.



19

Table 3: Training Schedules for Armenia

# Executive Agency/PIU Dates of Training

1. North-South Road Corridor Investment Program 10-11 September, 2013

2. “Armenian Water & Sewerage” CSJC 12-13 September, 2013

3. Sustainable Urban Development Investment Program 16-17 September, 2013

4. Women Entrepreneurship Support Project 18-19 September, 2013

60. The duration of each training was 2 days. Each day of the training lasted from 9:00

o’clock/am – till 6:00 o’clock/pm. The Training program consisted of 12 modules including

national case study and exercises. The following modules considered during the training were

as follows:

Module 1 - Introduction

Module 2 - ADB’s Relationship with Partners

Module 3 - Environmental Specialist/Roles and Responsibilities

Module 4 - Loans, Tenders and Contracts

Module 5 - Bid Evaluation

Module 6 - Introduction to Risk Assessment

Module 7 - Construction Impacts & Mitigations

Module 8 - Case study (particular cases for relevant sectors)

Module 9 - Environmental Monitoring

Module 10 - Reporting

Module 11 - Inspection and Audit

Module 12 - Final Exercise, Questions and Lahore Case Study/SEMP Group Training Exercise

61. The following knowledge products has been already prepared by ADB for on-the-job

training: (i) environmental management inserts for the PAMs that cover the different lending

modalities; (ii) guidelines on drafting environmental management clauses for tender documents

and contracts; (iii) handbook on Environmental Mitigation Measures for Construction; and (iv)

handbook on Environmental Management for Construction sites.

1.4 Training Methodology and Preparation

62. Project implementation team has decided to conduct the trainings in the conference room

rented for this special purpose, outside the PIU’s offices to avoid the frequent movement (absence) from the side of the training participants, which may negatively affect the training

quality.



20

63. The trainings involved a lot of advance preparations and were highly participatory. It

included case studies for relevant sectors, focus group discussions, group presentations and

on-the-job trainings during environmental audits on sites. The Consultant team assessed the

participants at the end of the training course to evaluate their understanding of the subject

matter using questionnaires prepared by ADB and Consultant. At the end of each training, each

participant completed a questionnaire to evaluate the content, and the conduct of the training.

64. It was determined that the quantity of training attendees should not exceed 10 participants.

Project focus group consisted of: Executive agency, PIU and supervision company. The

environmental specialists of the construction contractor were provided with on-the-job training

during the audit time at the project site.

1.5 Review of Documentation

65. As part of the advance preparation, the following documents were reviewed by the

Consultant: i) ADB’s Safeguard Policy Statement (SPS 2009); ii) ADB Strategy 2020; iii)

Environmental Impact Assessments of relevant projects; iv) Training module – Environmental

Safeguards Information Kit; v) Environmental management inserts for the PAMs that cover the

different lending modalities; vi) Guidelines on drafting environmental management clauses for

tender documents and contracts; vii) Handbook on Environmental Mitigation Measures for

Construction; viii) Handbook on Environmental Management for Construction sites.

1.6 Preparation of Training Materials

66. Training materials, questionnaires, practical exercises, etc were prepared in line with the

documents reviewed. Project implementation team has prepared English-Russian (for Armenia)

power point presentations based on the training modules and training materials provided by

ADB. The following materials have been also translated into Russian for Armenia: 1.

Environmental Safeguard Compliance Monitoring Checklist; 2. PIU tools and Templates for

EMP Supervision; 3; Training Course Effectiveness Questionnaire.

67. At the end of each training course an exercise was carried out to ensure that the participants

understood the concepts & could implement them. The exercises covered all the aspects of the

training.

68. Hands on practical exercises were conducted with the teams in preparing Site Specific

Environmental Management Plan (SEMP).

1.7 Preparatory Activities

69. Contact persons from Executing and Implementing Agencies of the relevant projects have

been identified from the very beginning:



21

1. Ministry of Transport & Communication: N. Sargsyan; E-mail: [email protected]

2. Armenian Water Sewerage Company: Patric Lorin; E-mail: [email protected]

3. Yerevan Municipality. Nora Martirosyan; E-mail: [email protected]

4. The German-Armenian Fund: Ishkhan V. Karapetyan; E-mail: [email protected]

70. Lists of ongoing projects in Armenia have already been provided by the ADB (see table 4 below).

Table 4: List of Ongoing Projects in Armenia

Country Div Project No.

Loan/Grant

No.

Project Name Project

Team

Milestone Dates Category

PTL Approval Effectivity Closing Env.

ARM CWPF 45230-001

L2922/2923

Women

Entrepreneurship

Support Project

A. Schou-

Zibell

25-Oct-

12

31-

Dec-17

FI

ARM

CWTC 42145-023

L2561

North-South Road

Corridor Investment

Prog - Tranche 1

P.

Seneviratne

6-Oct-09 24-Feb-

10

30-Jun-

14

B

CWTC 42145-033

L2729

North-South Road

Corridor Investment

Prog - Tranche 2

P.

Seneviratne

21-Dec-

10

18-Jul-11 30-Jun-

15

A

CWTC 42145-043

L2993

North-South Road

Corridor Investment

Prog - Tranche 3

P.

Seneviratne

12-Mar-

13

NYE 30-Jun-

17

A

ARM CWUW 42417-023

L2752

Sustainable Urban

Development

Investment Program,

Tranche 1

C. Llorens 9-May-

11

19-Jul-11 30-Jun-

16

B

ARM CWUW 45299-001

L2860

Water Supply and

Sanitation Sector

Project-Phase 2

(Additional Financing)

C. Llorens 12-Apr-

12

14-Sep-

12

31-Oct-

17

B

71. Cost estimate of the scheduled trainings in Armenia was prepared and submitted for

approval to the ADB on 20 of August, 2013.

mailto:[email protected]






22

1.8 Project Implementation Team Composition and Detailed Tasks

72. Project implementation team was mobilized in a couple of days after contract signing. No

changes have been made to the project implementation team and all persons mentioned in

tender proposal are involved in project implementation.

73. The detailed tasks of the experts involved in the trainings in Armenia are the following:

Irakli Kaviladze - Environment Specialist (Team Leader)

- Lead the assignment/work

- Finalize the reports for submission to ADB

- Oversee the timely implementation of the assignment/work

- Conduct on the job training on Environmental Safeguards, Monitoring and Reporting for - Executing Agencies, relevant government agencies, supervision consultants, and contractors

Keti Dgebuadze - Environmental Auditor – International

- Assist in the conduct on the job training on Environmental Safeguards, Monitoring and Reporting for Executing Agencies, relevant government agencies, supervision consultants, and contractors

- Prepare training report

1.9 Training Assessment & Evaluation

74. At the end of each training, all participants completed a questionnaire to evaluate the

content, and the conduct of the trainings. This was aimed at giving feedback on the relevance of

the training, adequacy of the training content in addressing the training needs, competence of

the trainers in impacting knowledge and knowledge transfer.

1.10 Execution of the Trainings and Observations

75. The on-job trainings scheduled for the PIU -“German-Armenian Fund”, PIU - Erevan Municipality, PMU - North-South Road Corridor Investment Program and PMU - Armenia Water Sewerage Company were conducted during the period of September, 2013 in the conference room of “Ani Plaza” Hotel located at #19 Sayat Nova Avenue, Yerevan, 1500 Armenia.

1.11 Staff Trained

76. The participants trained were selected based on their functional responsibilities in line with

the scope of the training program. Table 5 below shows summary of staff trained of relevant

PIUs (“Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor



23

Investment Program” - State Non-Commercial Organization (PIU), Sustainable Urban

Development Investment Program” (PIU), “Women Entrepreneurship Support Project”), Supervising Companies and Construction Contractors.

Table 5: Summary of total number of staff trained in Armenia

# Name Work Place Position Tel/Mob E-mail

I. Armenian Water & Sewerage Company” CJSC (PIU)

1. Alice Savadyan “Armenian Water & Sewerage Company” CJSC (PIU)

Environmental and

Social Impact

Specialist

091

204215

[email protected]

2. Zara Khachatryan JINJ Ltd. Social Specialist 091

343578

[email protected]

3.

Arevik Havsepyan JINJ Ltd. Environmental

Specialist

091

539202

[email protected]

4.

Mkrtchyan Nazik HGSHN Ltd. Environmental

Specialist

093

969908

[email protected]

5. Kristine Sahakyan “SOS MM” Ltd. Environmental

Specialist

091

529317

[email protected]

II. “North-South Road Corridor Investment Program” State Non-Commercial Organization (PIU)

1. Armine Yedigaryan “North-South Road

Corridor Investment

Program” State Non-

Commercial Organization

(PIU)

Social Safeguard

and Environment

Officer

095 111364 [email protected]

m

2. Gevarg Afyan “North-South Road

Corridor Investment



(PIU)

Environmental

Specialist


3. Viktor Bakhtamyan “Corsan-Corviam

Construction” S.A. Environmental

Specialist

095 111046 vbakhtamyan@isoluxcorsa

n.com

4. Sos Yedigeryan “North-South Road

Corridor Investment


Social Relation

Specialist

095 111045 samirkhanyan@isoluxcorsa

n.com















24

77. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU

representatives, 4 of them being the representatives of the Construction Contractor, 2 of them

being the representatives of the Supervising Consulting Company and 3 of them being the

representatives of RM of ADB. The rest 6 attendees were the representatives of national banks

under the “Women Entrepreneurship Support Project”. 9 months after the trainings, 4 people

(21%) having taken the training, did not work in their previous positions, being either retired, or

moved to other positions with the same office (in short, they are not concerned with the

environmental issues any more).

78. Summary of training photos of the participants in Armenia is provided in Table 6 below.


(PIU)

III. Sustainable Urban Development Investment Program” (PIU)

1. Ruzanna Voskanyan “SUDIP” (PIU) Environmental

Specialist

+374940830

88

ruzanna.voskanyan@yerev

an.am

2. Edita Vardgesyan SUDIP–PMIC

(Supervising Company)

Environmental

Specialist

+374936060

17

[email protected]

IV. “Women Entrepreneurship Support Project”

1. Georgi Davtyan “ACBA Credit Agricale Bank”

Credit Specialist 055909808 [email protected]

2. Hasmik Yegoryan “ARARAT BANK” Environmental

Management Specialist


3. Marine Badalyan “ARMECONOMBANK” OJSC

Senior Specialist,

Ecologist

055191219 [email protected]

4. Arusiak Gasparyan German-Armenian Fund Auditor (091)

484536

[email protected]

5. Satenik Ghevondyan German-Armenian Fund Auditor (091)

537132

[email protected]

6. Manuk Petrosyan “CARD AgroCredit “UCO

Senior Loan Officer 093 115599 [email protected]

7. Nina Avetisyan Armenia Resident

Mission,

Asian Development

Bank

Senior Project Assistant

(374 10)

546371 ext.

102

[email protected]

8. Gohar Tadevosyan Armenia Resident

Mission,

Asian Development

Bank

Resettlement Specialist (374 10)

546371

[email protected]













25

Table 6: Summary of Training Photos in Armenia

“Armenian Water & Sewerage Company” CJSC (PIU)

“North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU)



26

Sustainable Urban Development Investment Program” (PIU)

“Women Entrepreneurship Support Project”



27

1.12 Main Observations and Conclusions

79. This section highlights the main observations made during the training execution.

80. The involvement of the attendees into the training process was conducted thrice to check

their opinion and the level of comprehension of the material, namely: (i) once through inquiry,

(ii) once through filling in a questionnaire and (iii) once – through discussion of an example.

(i) Inquiry:

81. As it has been mentioned in the “Training Needs” chapter, ADB identified the three impeding reasons why the quality of meeting the environmental requirements of the bank is lower than

needed. Despite the already made conclusions of the bank, the attendees were asked if they

see any reasons why the environmental requirements are not met at a needed level by the

contractor. The reasons named both by project implementing agencies (PIUs) and consultant

companies were mainly identical and are given in the Table 7 below:



28

Table 7: Summary of the results of inquiry in Armenia

# PIUs I. “Armenian Water & Sewerage Company” CJSC - (PIU)

1. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously;

2. Environmental specialist is not involved in the review of the tender proposal. As the representatives of the company explained, they had repeatedly appealed to the management explaining that environmental specialist should be included in the tender evaluation commission, but their claim was rejected because facilitation of environmental information separately is not required by the RFP, namely, inclusion of CV of environmental specialist is not mandatory, while the environmental expenses are part of the construction expenses in the budget. Consequently, the management of the company thinks that there are no criteria according to which the tender proposal is evaluated in environmental terms;

3. The construction contractor, as a rule, uses CVs of strong respectively expensive specialists, but after being awarded with tender hires environmental specialists with relatively low qualification;

4.

Construction contractor does not employ qualified ecologists. The functions of ecologists are exercised by engineers;

5. There is no real mechanisms for PIU for penalization of the construction contractor for non-compliances.

II. “North-South Road Corridor Investment Program” - (PIU) 1. Lack of correct state attitude towards the environmental problems, due to which the

contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal; 3. The construction contractor, as a rule, uses CVs of strong respectively expensive specialists,

but after being awarded with tender hires environmental specialists with relatively low qualification;


III. Sustainable Urban Development Investment Program”- (PIU)

1. There is a lack of environmental specialists throught the country, this speciality is less prestigious in the country;

2. Lack of correct state attitude towards the environmental problems, due to which the contractor does not regard environmental issues seriously;

3. Environmental specialist is not involved in the review of the tender proposal.


IV. “Women Entrepreneurship Support Project” 1. Lack of correct state attitude towards the environmental problems, due to which the

contractor does not regard environmental issues seriously; 2. Environmental specialist is not involved in the review of the tender proposal; 3. There is no real mechanisms for PIU for penalization of the construction contractor for non-

compliances.



29

82. Among the problems named by the training participants of different PIUs, there were the

problems common to all organizations and problems typical to the organization engaged in

some or other project. 100% of the attendants explain the low quality of meeting the

environmental requirements by two major reasons, in particular:

1. Lack of correct state attitude towards the environmental problems, due to which the

contractor does not regard environmental issues seriously;

2. Environmental specialist is not involved in the review of the tender proposal;

3. There is no real mechanisms for PIU for penalization of the construction contractor for non- compliances.

83. 50 to 75% of the attendants think that:

1. Environmental specialist of PIU or Environmental Unit (EA) is not involved in the preparation of the tender proposal, hence, environmental requirements are not distinctively and clearly determined in the proposal.

84. As Consultat revealed, the main reasons of above-mentioned problems are: poor national

environmental legislation and incomplete ADB guidelines. None of the documents give the

detailed description of the rights and obligations of the PIU or EA environmental team or

environmental specialist within the scope of the project. The detailed information delivered by us

at the trainings about the rights and obligations of the PIU environmental specialist for the

management of the project implementing organization, is not considered as an obligation, and

unless the relevant requirements are fixed under the guidelines of the ADB or Project

Administration Manual, they will be always ignored by the management of the organizations.

85. Recommendation: A very good example was given in Georgia within the scope of project:

“Urban Services Improvement Investment Program”, Tranche 1 and Tranche 2, implemented by UWSGC, as PAM was updated and all the requirements communicated to the training

participants at the trainings were given in details in the newly developed document.

(ii) Filling of the Questionnaires

86. Training attendees were provided with questionnaires on the second day of training. The

questionnaire was prepared by ADB based upon the new attitudes, which were explained and

discussed during the training course.

87. The attendees had the right to use the provided material for answering the questions. They

also could consult with one another, which influenced the result, because except for some

cases all of them made the same mistakes. However, it should be noted that majority of the

answers were correct.

88. The results of the questionnaires answered by training attendees of “Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor Investment Program” - State



30

Non-Commercial Organization (PIU), Sustainable Urban Development Investment Program” (PIU) and “Women Entrepreneurship Support Project”, are given in Table 8 (“+” – correct

answer; “-“ – wrong answer).

Table 8: Summary of the results of the answers of training participants in Armenia

Name of Participant 1 2 3 4 5 6 7 8 9 10

“Armenian Water & Sewerage Company” CJSC (PIU)

Alice Savadyan + + + + + + + - + -

Zara Khachatryan + + - + + + + + + -

Arevik Havsepyan + + - + + + + + + -

Mkrtchyan Nazik + + - + + + + + + -

Kristine Sahakyan + + - + + + + + + -

“North-South Road Corridor Investment Program” - State Non-Commercial

Organization (PIU)

Armine Yedigaryan - + + + + + + - + +

Gevarg Afyan - + + - + + + + + +

Viktor Bakhtamyan - + + - + + + + + +

Sos Yedigeryan + + + - + + + + + +

Sustainable Urban Development Investment Program” (PIU)

Ruzanna Voskanyan

+ + + + + - + + - +

Edita Vardgesyan

+ + + + + - + + + +

“Women Entrepreneurship Support Project”

Georgi Davtyan + + - + + + + + + -

Hasmik Yegoryan + + - + + + + + + -

Marine Badalyan + + - + + + + + + -

Arusiak Gasparyan + + - + + + + + + -

Satenik Ghevondyan + + - + + + + + + -

Manuk Petrosyan + + - + + + + + + -

Nina Avetisian + + + + + + + + + -

Gohar Tadevosian + + + - + + + + + -


satisfactory. The results of the survey to evaluate the degree of mastering the training materials



31

were satisfactory. Neither of them could answer all 10 questions correctly. 3 of them (14 %)

made 1 mistake each, 16 of them (86 %) made 2 mistakes each. The best results were fixed

with PIU representatives having vast work experience in the field of environmental protection

with state organizations or in the private sector.

(iii) Practical Exercises

90. The evaluation of environmental impact risks and implementation of mitigation measures

were discussed based on the different practical examples by training participants of “Armenian Water & Sewerage Company” CJSC (PIU), “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU), Sustainable Urban Development Investment

Program” (PIU) and “Women Entrepreneurship Support Project”, namely: construction process of

one section of the rehabilitation project of “North-South Road Corridor Investment Program”” - by

“Armenian Water & Sewerage Company” CJSC (PIU) participants; construction process of one

section of the rehabilitation project of “North-South Road Corridor Investment Program” by

“North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU)

participants; One section of the rehabilitation project of “Argavand Highway to Shirak Street

Upgrade“ by Urban infrastructure and Sustainable City Development Program” by Sustainable

Urban Development Investment Program” (PIU) participants and after the consultation with the

group “North-South Road Corridor Investment Project” was taken as a practical example by

“Women Entrepreneurship Support Project” participants, thus, as of today none of the projects

were not defined to be financed under the mentioned program. The working groups prepared,

identified and assessed environmental risks for the mentioned projects and planned respective

mitigation measures.

91. The participants of the training having many years of experience in the environmental field

were mainly active during the answering process of the training. The mentioned participants

were the representatives of PIUs.

92. After the training the training participants were provided with the training effectiveness

assessment questionnaire. The summary of answers to the questionnaire is given in Table 9. In

addition, the attendees were asked which type of training they would like to attend in the future in

the end of the questionnaire.

Table 9: Summary of answers to the questionnaire in Armenia

# Question Answer Comment

Yes No

1 Did this course achieve the education

objectives?

19



32

2 Did the training course meet your expectation? 19

3 Was the classroom environment conductive

the learning?

19

4 Was the instructional method effective? 19

#

Question Points Quantity

of

attendees

5 Please rate (1-5)1 quality of training content 5 18

4 1

6 Please rate quality of information delivery? 5 18

4 1

7 Please rate quality of clarity and usefulness of

visual?

5 16

4 3

8 Please rate quality of opportunity to ask

questions?

5 16/ 1 no

answer

4 2

9 Please rate quality of opportunity to hands-of

training?

5 15

4 3

3 1

93. The training evaluation questionnaires did not identify the respondents. As Table 9 shows,

the absolute majority of the participants are content both, with the developed training module

and method of delivery.

94. The training participants listed the topics for trainings they desired to attend in the future

(see Table 10):

1 5 point is - excellent, 2 point is – bed.



33

Table 10: Summary of list of topics for future trainings in Armenia

# PIUs I. “Armenian Water & Sewerage Company” CJSC (PIU)

1. Training related with the preparation and implementation of Environmental Monitoring Plan (EMP);

2. To discuss our project in more detail and review respective examples; 3. More detailed criteria in risk assessment; 4. Training in ecological audit and monitoring; 5. Facilitation of the same training for the construction contractor environmental expert and

training in environmental audit and inspection.

II. “North-South Road Corridor Investment Program” - State Non-Commercial Organization (PIU)

1. Training related with management of construction wastes; 2. ADB guidelines related with classification of construction wastes; 3. ADB environmental guidelines; 4. Preparation of Environmental Impact Assessment (EIA). III. Sustainable Urban Development Investment Program” (PIU) 1. Both participants required to conduct training in Professional Health & Safety. IV. “Women Entrepreneurship Support Project”

1. All of training participants requested to conduct training for them in environmental audit and report writing.

95. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship

Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the

same view, and the trainings desirable by them were about: (a) Preparation of environmental

documents and their implementation; and (b) Description of entire monitoring process.

Main Observations:

96. This section highlights the main observations made during the trainings execution for PIUs in Armenia. The summary of following observations is listed below (see Table 11).

Table 11: Summary of main observations in Armenia

# PIUs

I. “Armenian Water & Sewerage Company” CJSC (PIU)

1. Environmental specialist of fairly good qualification is employed in PIU;

2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working



34

experience in respective state or private entities; 3. The construction contractor does not have an environmental specialist as a member of

staff.

II. “North-South Road Corridor Investment Program” - State Non-Commercial Organization

(PIU)

1. Special division is established within the Project Implementing Unit (PIU) comprising two professional environmental specialists with a good experience and a resettlement specialist;

2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working experience in respective state or private entities;

3. Moreover, the team of the construction contractor employs two environmental specialists with satisfactory qualification and experience;

4. Only the local environmental specialists of the consulting company did not attend the training from the environmental team involved in the implementation of the mentioned project. As we found out the specialist will attend trainings to be held on September 16-17 proceeding from the fact that the specialist also participates in Sustainable Urban Development Investment Program.

III. Sustainable Urban Development Investment Program” (PIU) 1. Environmental specialists of fairly good qualification is employed in Supervising Company

as well as in PIU;

2. They were very active during training and proceeding from the practical example and filled in questionnaire. The level of comprehension of the material by the attendees was satisfactory. It is especially true for the participants having many years of working experience in respective state or private entities;

IV. “Women Entrepreneurship Support Project”

1. Most of the training participants did not have experience in preparation and implementation of environmental documentation. Representatives of German-Armenian Fund as well as bank sector were mainly from procurement and audit devisions with relevant qualification;

2. It should be mentioned that projects planned to be financed under the above-mentioned program have less environmental risks;

3. It is desirable to hire one environmental specialist at German-Armenian Fund.

1.13 Main Findings and Recommendations

97. Based on the conducted trainings the Consultant revealed the following general findings:

I. All over Armenia, the trainings were attended by 19 persons, with 5 of them being PIU

representatives, 4 of them being the representatives of the Construction Contractor, 2 of

them being the representatives of the Supervising Consulting Company and 3 of them

being the representatives of RM of ADB. The rest 6 attendees were the representatives

of national banks under the “Women Entrepreneurship Support Project”. 9 months after

the trainings, 4 people (21%) having taken the training, did not work in their previous



35

positions, being either retired, or moved to other positions with the same office (in short,

they are not concerned with the environmental issues any more);

II. The results of the survey to evaluate the degree of mastering the training materials were

satisfactory. The results of the survey to evaluate the degree of mastering the training

materials were satisfactory. Neither of them could answer all 10 questions correctly. 3 of

them (14 %) made 1 mistake each, 16 of them (86 %). made 2 mistakes each;

III. The training evaluation questionnaires did not identify the respondents. As Table 9 shows, the absolute majority of the participants are content both, with the developed training module and method of delivery;

IV. As Table 10 shows, the answers to the question “What kind of training would you like to attend in the future?” much differ and they mostly come from the problems arising with each project. For instance, 6 representatives of national banks under the “Women Entrepreneurship Support Project” asked for the training related to the “Environmental Audit and Report Writing”. However, two representatives under the “Sustainable Urban Development Investment Program” required training related to the “Professional Health & Safety” issues. Some people had the same view, and the trainings desirable by them were about: (a) Preparation of environmental documents and their implementation; and (b) Description of entire monitoring process.

98. Based on the findings observed during the trainings the Consultant elaborated the following Recommendations:

For Asian Development Bank:

I. The new requirements developed within the scope of the training are to be shown in the documents developed by the ADB within the scope of the project (Loan Agreement, FAM or PAM), or such requirements should be added to Safeguard Policy Statement developed by the ADB in 2009 as an annex.

For Project Implementation Units (PIUs):

I. The environmental specialists of all the companies engaged in all new projects shall be

given the training developed by the ADB. The said trainings are to be attended by the

international environmental specialists as well engaged in the implementation of the

project. The first part of the trainings should be also attended by the employees of the

Procurement Department;

II. All new environmental specialists engaged in the implementation of the project are to be given training “Environmental Safeguards Requirements” under the projects financed by ADB within the limits of the RETA Project.



36

II. ENVIRONMENTAL AUDITS CONDUCTED IN ARMENIA

1. CWPF 45230-001 WOMEN ENTERPRENEURSHIP SUPPORT PROJECT

1.1 Brief Project Description (CWPF - 45230-001)

99. The proposed Women’s Entrepreneurship Support Sector Development Program is a sector development program which comprises an integrated approach to enable women entrepreneurs and micro, small and medium-sized enterprises (MSMEs) in Armenia to play a greater role in economic development. The program has two components: (i) a policy-based loan to help fund budget allocations to strengthen the business environment and the Small and Medium Entrepreneurship Development National Center (SME DNC) and its support for women entrepreneurs and MSMEs; and (ii) a financial intermediation loan to enable participating financial institutions (PFIs) to provide medium-term local currency loans to MSMEs, of which at least 50% are women’s MSMEs. The program is supported by capacity development TA to improve the entrepreneurial capacity of women and to increase the capacity of the SME DNC, the project management unit of the German-Armenian Fund (PMU GAF) and PFIs to provide support for women entrepreneurship. The program period is 2013-2017. The program’s impact will be women benefitting from increased economic opportunities. The program’s outcome will be an improved enabling environment for women entrepreneurs. 100. The policy-based loan will have four outputs: (i) improved institutional framework supports women entrepreneurs and MSMEs, (ii) improved capacity of women entrepreneurs and MSMEs, (iii) improved access to finance by women entrepreneurs and MSMEs, and (iv) improved business environment supports MSMEs.

1.2 Project Status

101. At the given stage, the project implementation has not started yet. There is a Loan

Agreement between the Asian Development Bank and Republic of Armenia concluded within

the scope of the project. In addition, the ADB has concluded individual loan agreements with all

national banks engaged in the project. There is a document titled “Project Administration Manual” (PAM) developed within the scope of the project. In addition, the document titled “Recommendations of President” was developed by the ADB within the scope of the project.

1.3 Institutional Aspects on Environmental Safeguards Implementation

102. On July 27, 1998, the Governments of the Federal Republic of Germany and the Republic

of Armenia executed an Agreement on Financial Co-operation. On this basis, KfW and the

Central Bank of Armenia (CBA) entered into a long-term loan agreement for a loan in the

amount of DM 6 million on September 25, 1998. Under the Agreement an apex fund was

created: German-Armenian Fund (GAF). Eight months after the inter-governmental agreement

was signed, in March 1999 the project began its operations.



37

103. The main objective of the activity of Project Manamgement Unit - GAF is the implementation and management of the loan programs of the "German-Armenian Fund" in accordance with the loan agreements and the separate agreements forming an integral part of them concluded between the Central Bank of the Republic of Armenia and the KfW Development Bank (KfW Bank) belonging to the KfW-Bankengruppe the promotional bank of the Federal Republic of Germany within the framework of the intergovernmental agreements between the governments of the Republic of Armenia and the Federal Republic of Germany.

104. GAF-MSME program has been implemented since 1999, GAF-RE and GAF-HF were launched in 2006, and GAF-CGF was launched by the GAF in 2007 and closed in 2010. During the last few months of 2008 the RA Government and the World Bank joined the PMU GAF as new donor organizations with new loan programs. The program: "Support to Small and Medium Enterprises" financed by the RA Government was launched in December 2008, GAF-WB/AFSME financed by the World Bank and GAF-RF financed by the RA Government have been implemented since 2009. In 2012 GAF is planning to initiate new "Agricultural Finance" Program under the funding of KfW and RA Government.

105. The project implementing organizations are: Ministry of Finance, Ministry of Economy and

Central Bank of Armenia through the PIU German-Armenian Fund (GAF).

106. The responsibilities of the Ministry of Finance of Armenia are the following: Act as

executing agency for the program; Provide overall policy direction and guidance; Facilitate

cooperation and coordination among the government agencies involved in the program;

Responsible for executing the Guarantee Agreement between Armenia and ADB for the FIL;

107. The responsibilities of the Ministry of Economy are the following: Act as implementing

agency for the policy-based loan and technical assistance grant; Implement and monitor timely

achievement of the conditions in the policy-based loan’s policy matrix; Submit annual progress

reports on achievement of performance targets and indicators in the program design and

monitoring framework; Prepare a program completion report for the policy- based loan and

submit to ADB within 6 months after program closing date;

108. The responsibilities of the German-Armenian Fund are the following: Act as the borrower

and implementing agency under the FIL; Execute subsidiary loan agreements with PFIs; The

PMU GAF under the CBA shall: Act as oversight body for overall implementation and monitoring

of the FIL; Facilitate coordination between ADB and PFIs; Monitor compliance of the PFIs to the

subsidiary loan agreement and the project agreement conditions, including compliance to the

sub borrower selection criteria and sub loan features; Conduct initial screening of sub loan

applications that are above the sub loan free limit; Manage the project imprest account and

ensure timely transfer of the FIL proceeds to the PFIs; Submit to ADB annual audited financial

statements that include an audit management letter and an audit opinion on the use of loan

proceeds, and on the imprest fund and SOE procedures; Submit to ADB consolidated quarterly

progress report using the format in Attachment 1 within 30 days from the end of each quarter;



38

Prepare a project completion report for the FIL and submit to ADB within 6 months after

program closing date.

109. The following national banks will be engaged in the first phase of the project

implementation: ACBA-Credit Agricole Bank, CARD AgroCredit UCO, Araratbank,

Armeconombank. The list of the national banks engaged in the second phase of the project will

be specified at the project implementation stage (see Figure 1).

Figure 1: Program Organization Structure



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1.4 Project Document Analysis

A) Loan Agreement Between ABD and Republic of Armenia

110. Loan Agreement dated 25 January 2013 between Republic of Armenia ("Borrower") and

Asian Development Bank ("ADB") says nothing about the obligation to meet the environmental

requirements. As for the requirement for monitoring at the stage of the project implementation,

the reference in the document states as follows: „The Borrower shall carry out review of the

Program with the participation of ADB in accordance with the review procedures described in

the Project Administration Manual for the Program“ (Paragraph 6 - “Monitoring and Review” pp-

16).

111. Though, it should be mentioned that PAM developed within the scope of the project gives a detailed description of the environmental obligations to be performed by the organizations engaged in the project.

B) Loan Agreement between ADB and Central Bank of the Republic of Armenia

112. Loan Agreement dated 25 Jenuary 2013 between Central Bank of the Republic of

Armenia ("Borrower") and Asian Development Bank ("ADB"). The obligation to meet the

environmental requirements is given in schedule 3 - “Execution of Project Financial Matters”, paragraph 10 - “Environment”, according which: „The Borrower shall cause the PFIs to ensure

that the preparation, design, construction, implementation, operation and decommissioning of

each Qualified Subproject comply with (a) all applicable laws and regulations of the Guarantor

relating to environment, health, and safety; (b) the ESMS; and (c) all measures and

requirements set forth in the respective IEE and EMP, and any corrective or preventative

actions set forth in a Safeguards Monitoring Report“.

113. The said agreement also envisages the monitoring and reporting obligations of

Participating Financial Institutions (PFI).

C) Loan Agreement between ADB and ACBA-Credit-Agricol Bank

114. Loan Agreement dated 25 January 2013 between ACBA-Credit-Agricol Bank ("Borrower")

and Asian Development Bank ("ADB"). Neither does the developed document state about the

obligation to meet the environmental requirements, but the main body of the document

envisages the following obligation only: „ACBA-Credit-Agricol Bank shall promptly and

effectively exercise its rights in relation to each Qualified Subproject in accordance with the

standards of a prudent lender and in such manner as to protect the interests of the Borrower,

ACBA-Credit-Agricol Bank and ADB (Section 2.05) “.



40

D) Loan Agreement between ADB and Ararat Bank

115. Loan Agreement dated 25 January 2013 between Ararat bank ("Borrower") and Asian

Development Bank ("ADB"). Neither does the developed document state about the obligation to

meet the environmental requirements, but the main body of the document envisages the

following obligation only: „Ararat bank shall promptly and effectively exercise its rights in relation

to each Qualified Subproject in accordance with the standards of a prudent lender and in such

manner as to protect the interests of the Borrower, ACBA-Credit-Agricol Bank and ADB (Section

2.05) “.

E) Project Administration Manual (PAM)

116. In October of 2013, the Project Administration Manual (PAM) was developed within the

scope of the „Women Entrepreneurship Support Project“. The necessity for meeting the

requirements envisaged by the said document is given by the Loan Agreement. The necessity

for meeting the requirements of the ADB SPS of 2009 for the companies engaged in the project

is given in the IX Chapter of the said document. The document also envisages the criteria used

in the financing process of the projects. The projects belonging to Category A in an

environmental respect, according to the environmental classification developed by the ADB, will

not be financed.

117. Next to the necessity for meeting the requirements of the national environmental

legislation, the document fixes the necessity for meeting the requirements of the ADB

Safeguard Policy Statement of 2009: „Safeguards due diligence has been carried out according

to ADB SPS requirements for FIs. The assessed PFIs selected shall have staff capacity and

established ESMSs. PMU GAF and the PFIs should ensure that the needed improvement in the

safeguards categorization, screening and review procedures, social inclusion and performance

monitoring and reporting to process category B projects (for environmental safeguards) are

incorporated into the PFI’s ESMS” (Article IX “Safeguards”, Paragraph 6).

118. The document is enclosed by „Environmental and Social Management System“guidelines

as annex (Annex IV). The given Annex provides a detailed description of a) Environmental and

Social Management Policy and Applicable Requirements (b) Environmental and Social

Management Procedures (d) Organizational Responsibilities, Resources, and Capacity

developed by the ADB.

F) Report and Recommendation of the President to the Board of Directors

119. The said document within the scope of the project was developed in October of 2012. The

document has a special chapter dedicated to the environmental issues, according which: “The policy-based loan will not trigger safeguard policies and is categorized C for environment,

involuntary resettlement, and indigenous peoples. The FIL is categorized as financial

intermediation for environment and indigenous peoples, and financial intermediation (treated as



41

C) with respect to involuntary resettlement. Subprojects categorized A for environment and

indigenous peoples or having involuntary resettlement impacts will not be eligible for financing

under this program. Activities included in ADB’s Prohibited Investment Activities List are excluded. Each PFI will implement an ESMS acceptable to ADB to ensure proposals for

subprojects are screened for environmental and social impacts and (if applicable) mitigating

measures are in place. Each PFI is required to designate at least one staff member to be

responsible for implementation of its ESMS” (IV.Due Diligence, asticle D. Safeguards).

1.5 Meeting with the German - Armenian Fund (GAF)

120. The meeting at the office of German- Armenian Fund with Head of PFIs Audit Division -

David Mikayelian (Figures 2, 3) was held on April 27, 2014.

Figures 2 and 3: Meeting at GAF office

121. As it became clear during the meeting, the implementation of the said project has not

started yet, but the preparatory period has started. There are 4 national banks of Armenia

engaged in the project with relevant agreements concluded with all of them.

122. There is a PIU established within the scope of the project, and no environmental specialist

is hired yet. At this stage, Mr. David Mikayelian, Head of the Audit Service, performs the duties

of an environmental specialist.

123. As for the national banks engaged in the project, they have the specialists with relevant

qualification on staff.

1.6 Main Findings and Recommendations

124. Based on the projects documents review the Consultant (Audit Team) revealed the

following general findings:



42

I. The project implementation has not started yet, but the preparatory works are in

progress;

II. The training developed by the ADB within the scope of RETA 7548 was taken by 2

employees of German-Armenian Fund. The training was also attended by environmental

specialists of all four National Banks;

III. The German-Armenian Fund (GAF), as the project implementer, has vast experience in

implementing similar projects. Under the financing of various international financial

institutions and state budget, the GAF has implemented more than one similar project:

(a) "Support to small and medium enterprises" (GAF-MSME-Government) program

(financed by the RA Government) (b) "Access to finance for small and medium

enterprises" (GAF-WB/AFSME) program (financed by the World Bank) (c) "Economy

stabilization lending" (GAF-RF) program (financed by the RA Government);

IV. Within the scope of the said project, the projects belonging to Category A in an

environmental respect will not be financed;

V. The project implementing body has no environmental specialist on staff, and such

specialist’s rights are enjoyed and obligations are performed by the head of the audit service;

VI. The Project Administration Manual (PAM) developed within the scope of the project

gives quite a detailed description of all environmental requirements and mechanisms to

meet the requirements to be met by the organizations engaged in the project.

125. Based on the above-mentioned findings the Consultant made the following

recommendations:

I. The Project Implementing Organization - GAF has to employ an environmental specialist

with the relevant qualification;

II. The environmental specialist of PIU shall be engaged in all phases of the project

development, including the development of bidding documents, evaluation of the bidding

proposal, monitoring and audit of the course of the project, as well as in the process of

the Final Environmental Monitoring Report;

III. The bidding documents and contracts particularly, should repeat the environmental

requirements and ways to meet them envisaged by the PAM developed within the scope

of the project.



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2. CWTC 42417-023: SUSTAINABLE URBAN DEVEOPMENT INVESTMENT PROGRAM,

PROJECT 1, TENDER 1 - CONSRUCTION/REHABILITATION OF ARSHAKUYATS STREET

2.1 Brief Information on the Project

126. The Arshakunyats Avenue road project under the Sustainable Urban Development Investment Program (SUDIP) is financed through the multitranche financing facility (MFF) of the Asian Development Bank (ADB). The investment program will be implemented over a period of 9 Years. 127. The Project falls within component A and has been divided into two separate construction tenders: Tender 1, the widening of Arshakunyats street on approximately 1.3km; Tender 2, the construction of a link from Argavand Highway to Shirak Street, the construction of New Shirak Street, and the widening of Artashat Highway.The Arshakunyats Avenue project site is located in Yerevan’s Shengavit district, approximately 6km south-west of the City centre of Armenia’s capital (refer to Site location plan on the following page). Arshakunyats Avenue connects with Artashat Highway via the new Shirak Street. The 1.3 km length of Arshakunyats Avenue connects with Artashat Highway (M-2) to New Shirak Street (Figure 4).

Figure 4: Location of Arshakunyats Avenue, Tender 1



44

128. The Works comprises the widening of Arshakunyats Avenue over approximately 1.3 km

long, from dual 2 lanes to dual 3 or 4 lane carriageways with central reservation. The Works

include (but is not limited to) the following: Diversion of exiting utilities including water supply,

electricity and trolley line power supply; Site clearance and demolition of existing structures

within the proposed expropriation limits; Demolition and reconstruction of existing carriageway;

The construction of a new carriageway to cater for traffic in one direction; Associated drainage

works; Ancillary works including lighting, signs and markings; Demolition and reconstruction of

boundary wall and checkpoint to Department of Defense institute; and Temporary Works

including traffic management works and maintenance of access. Construction will be

undertaken over a period of 10 months.


129. Yerevan Municipality is implementing the Asian Development Bank (ADB) funded project -

„Sustainable Urban Development Investment Program“. Within the IA, the Yerevan

Municipality Project Implementation Unit (YMPIU) will be responsible for day-to-day

management of this project. It is headed by a full-time Project Director. The YMPIU includes the

following specialists: Institutional, Technical, Financial, Monitoring and Evaluation,

Legal/Contract administration, Procurement, Resettlement, Environment, Communication and

public relations, assistant/translator. Responsibilities of the YMPIU include: preparing and

updating procurement plan; tendering, evaluating bids and awarding works; contracting

administration; managing the DESC; supervision; quality control; obtaining copies of the

approvals and permits from relevant agencies; inspectingthe Contractor’s implementation of mitigation measures as specified in the EMP; prepareing and submiting semi-annual

environmental reports regularly to the EA for ADB; responding to emergencies and notifying the

relevant authorities within reasonable times.

130. A Management Board of the Sustainable Urban Development Investment Program

(SUDIP) is chaired by the Prime Minister. It is comprised of the Minister of Economy, Minister of

Finance, Minister of Territorial Administration, Minister of Justice, Minister of Transport and

Communications, Mayor of Yerevan, and representatives of the Central Bank, the Real Estate

Cadastre Agency, and Yerevan Municipality PIU. The Management Board has been set up to

follow up the implementation of the Program. The Management Board is meeting every month.

131. The Executing Agency (EA) of the SUDIP is the Ministry of Economy (MOE). The EA will

oversee the implementation of the Program and the disbursement of the loan.

132. Implementing Agency (IA) for the services is the Municipality of Yerevan (The Client)

which will be responsible for the overall technical supervision and execution of the Projects. The

Municipality also has the responsibility for waste management services that include organization

of waste collection, assigning dump sites for construction waste.



45

133. Detailed Engineering and Construction Supervision Consultant’s (DESC) key

responsibilities include: update or prepare the final Environmental Impact Assessment (EIA) or

Initial Environment Examination (IEE) as applicable), along with the relevant Environment

Management and Monitoring Plan (EMP), and other documents as required; submit the updated

EIA, EMP and EARF for the MOE, MTA, or YM and ADB’s review and approval; conduct the

necessary consultations in compliance with the Environment Assessment and Review

Framework (EARF) approved in 2010 between ADB and the Government of Armenia; and

apply for and get a positive environmental expertise conclusion from the Environmental

Expertise of the RA Ministry of Nature Protection for the EIA/IEE report and EMP as prescribed

by the Armenian legislation (including, agreement on route with the RA Ministry of Culture,

etc.). During construction the key tasks of the DESC will include also supervision and monitoring

of construction activities of the project including the implementation of the Site Specific EMP.

134. The Contractors’ key responsibilities are listed below but are not limited to the following:

update the EMP as a working construction document based on the EIA and the EMP report,

update the EMP during the construction when needed and obtain the DESC approval of the

updated part; hire the services of an Environment Specialist as defined in the tender document;

implement the EMP as a special part of the contract, particular conditions; coordinate with the

DESC for the implementation of the various components of the EMP including monitoring; in

cases of emergencies and accidents or extraordinary situations notify the DESC and the

relevant emergency authorities; obtain permits and approvals from relevant agencies and

provides copies to DESC; and report on EMP.

Figure 5: Institutional Chart of the Environmental Safeguards Arrangement



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2.3 Project Document Analysis A) Loan Agreement, Facility Administration Manual (FAM)

135. According to Schedule 5 - “Execution of Project and Operation of Project Facilities; Financial Matters”, clause 2 - “Environment” of the Loan Agreement # 2752-ARM (19 May,

2011) between Republic of Armenia ("Borrower") and Asian Development Bank ("ADB"),

„…The Borrower shall ensure that the preparation, design, construction, implementation,

operation and decommissioning of each Subproject comply with (a) all applicable laws and

regulations of the Borrower relating to environment, health, and safety; (b) the Environmental

Safeguards; (c) the EARF; and (d) all measures and requirements set forth in the respective

IEE and EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring

Report“.

137. The same document includes those environmental requirements that are necessary to be

included at the preparation of the bids (Schedule 5: “Safeguards – Related Provisions in Bidding

Documents and Works Contracts”, pp-17). The same annex (Schedule 5: “Safeguards Monitoring and Reporting”, pp -18) includes all the requirements related to the process of the

monitoring and reporting on the above-mentioned project, these are: (a) “Submit semi-annual

Safeguards Monitoring Reports to ADB and disclose relevant information from such reports to

affected persons promptly upon submission.

138. On May 19, 2011 a contract was concluded between the ADB and Yerevan Municipality.

According to Section 2.04 of the contract: „Yerevan shall carry out the Project in accordance with plans, design standards, specifications, work schedules and construction methods

acceptable to ADB“.

139. In March of 2011, the Asian Development Bank developed and approved Facility

Administration Manual (FAM). The mentioned document (Clause VII “Safeguards”, article A –

“Environment”) sets forth the requirements that are mandatory at the project implementation

stage, these requirements are: “Tranche 1 classified as environmental category B under ADB's

Safeguard Policy Statement, 2009. The environmental assessment and review and framework

(EARF) is detailed in RRP Linked document 11 and will be updated before every PFR signing.

The initial environmental examinations (IEE) are detailed in RRP Linked document 10 and will

be updated every 6 months if necessary. The Environmental Management and Monitoring Plan

will be updated during detailed engineering design and incorporated in bidding documents and

civil works contracts“.

140. The Loan Agreement and FAM also gives the requirements for conducting permanent

environmental audits and for regular reporting. In whole the environmental requirements in Loan

Agreement and FAM are reflected satisfactorily.



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B) Bidding Documents

B.1) Supervision Consultant

141. The tender to select the Consulting Firms for Detailed Engineering, Management and

Supervision of The Construction of Two Road Links of The Yerevan Western Ring Road

announced on 23 January 2012.

142. The obligations on the environmental safeguards implementation are included in the

bidding documents in Section 5 – “Terms of Reference”, clause C - “Scope of Work and Detailed Terms of Reference”, sub clause f - „Preparation of Environment Documents” which set

forth the requirements that are mandatory for the Supervision Consultant at the project

implementation stage, these requirements are: „The Consultant will review the preliminary

design prepared and will update the environmental assessment in accordance with ADB’s SPS

2009 and the Environment Assessment Review Framework (EARF) agreed between the

Government of Armenia and ADB. The key responsibilities of the Consultant will be: (i) update

or prepare the final IEE or Environmental Impact Assessment (EIA) as applicable, along with

the relevant EMP, and other documents as required, (ii) submit the updated IEE, EIA, EMP and

EARF for the YM, YDPIU and PMIC’s review and approval, (iii) conduct with the PMIC the

necessary consultations in compliance with the Environment Assessment and Review

Framework (EARF) approved in 2010 between ADB and the Government of Armenia; (iv) assist

the PMIC and YM in getting required approvals for the IEE or EIA and EMP as prescribed by the

Armenian legislation (v) assist the PMIC in the implementation of the Site Specific EMP.

143. The mentioned document also includes (Section 5 – Terms of Reference, clause C “Scope of Work and Detailed Terms of Reference” sub clause f- „Staffing Requirements“) requirement related to the involvement of international and local experts in the project. Under the first

tranche, at the project construction stage, according to the requirement, one international

environmental specialist should be involved in the supervising consulting company for 1 month,

as well as a local environmental specialist – for 4 months, and under the second tranche,

respectively, international environmental specialist should be involved for 3 months and a local

specialist – for 4 months.

B.2) Construction Contractor

144. The tender to select the Construction Contractor (2752 - ARM (MFF)) of Sustainable Urban

Development Investment Program, Tranche 1 - announced on 28 September 2013. An EPM

documents were attached to the tender documentation as an annex 1. The obligation of the

contractor to meet the requirements of the document as well as contractor’s reporting responsibility are given in part 8 of the tender documentation - „Specific Provisions“, stating: “The Contractor shall comply with (i) all applicable environmental laws and regulations

of the Republic of Armenia; (ii) Asian Development Bank’s environmental safeguards; (iii) all measures and requirements relevant to the Contractor set forth in the EIA and EMP. The EMP



48

updated by Contractor and (iv) any corrective or preventative actions set out in the safeguards

monitoring reports that the Employer will prepare from time to time to monitor the

implementation of and compliance with environmental management plan, resettlement plan, and

indigenous people plan (as applicable). The Contractor shall allocate the budget required to

ensure such measures, requirements and actions“.

C) Bidding Proposals

C.1) Consultant/Supervision Company – EGIS International

145. The technical part of the bid submitted by the consulting company has the entire chapter

(Clause 4B.2 5) dedicated to the obligations about the fulfillment of environmental requirements.

In addition to other commitments the consulting company has taken the following key

obligations in the environmental field, in particular: “review and update the existing IEE report in

accordance with ADB SPS (2009); carry out field visits in order to gain first-hand knowledge of

existing environmental conditions; estimate the costs of the proposed environmental mitigation

measures and of the implementation of the EMP’s for Task 1 and Task 3; prepare a detailed

EMP and monitor the implementation of mitigation measures and the impact of the proposed

works during construction; update the archeological statues carried out for preparation of the

project”.

146. The presented proposal includes CVs of international as well as local environmental

specialists, as well as the schedule of involvement of the mentioned specialists in the project.

D) Evaluation of Bids

147. Project Implementing Unit (PIU) environmental specialist is not involved in the bids evaluation process. There is no official requirement to have an environmental specialist in the bid evaluation committee. In spite of this, under the mentioned project an environmental specialist was included in the bid evaluation committee. The mentioned specialist had been invited from American University of Armenia. No special criteria had been developed for the evaluation of bids in terms of environmental issues.

148. Recommendation:

149. For ADB: In one of the documents developed under the project (Loan Agreement, PAM/FAM) the requirement about the involvement of environmental specialist in the bid evaluation committee shall be stipulated.

150. For PIU: The following criteria developed by ADB are desirable to use for the evaluation of environmental aspects of the tender bid (for example: Does the bid address the findings of the EIA; Does the bidder have sufficient resources to implement the EMP; Is the bidder qualified; Is the bidder proactively addressing environmental issues, including waste management; Does the bidder have a past history of significant environmental compliance/or noncompliance).



49

E) Contracts

E.1) Contract with EGIS International (Consulting Company)

151. The contract for consultancy services was concluded with EGIS International on

September 4, 2012. The activities to be accomplished by the contractor are given in Appendix

A. The contract contains all those requirements that were included in the Bidding Document.

152. Furthermore, the requirement about having international and local environmental

specialists and the schedule of their involvement has been fully transferred from the bidding

documents into the contract.

E.2) Contract with Construction Contractor - Vahagn and Samvel LLC

153. Agreement with local Company Vahagn and Samvel LLC“was concluded on December

10, 2013. The necessity of the fulfillment of environmental requirements is stipulated in the

contract part: „Particular Conditions of Contract“, Clouse F - “Safeguard Provisions”, stating that: “The Contractor shall comply with (i) all applicable environmental laws and regulations of the Republic of Armenia; (ii) Asian Development Bank’s environmental safeguards; (iii) all measures and requirements relevant to the Contractor set forth in the EIA, EMP, the EMP updated by

Contractor and the resettlement plan and (iv) any corrective or preventative actions set out in

the safeguards monitoring reports that the Employer will prepare from time to time to monitor

the implementation of and compliance with EMP, RAP, and indigenous people plan (as

applicable). The Contractor shall allocate the budget required to ensure that such measures,

requirements and actions”.

154. The contract has the following annexes: Appendix 1: Ref DTO 101144 – 06 Environmental

Impact Assessment with Annex 5 - Environmental Management Plan.

155. Recommendation: The contract with the construction company was concluded in

December, 2013. By now the training developed by the ADB under RETA: 7548 has already

been held. Training materials contained quite detailed overview of all those requirements

inclusion of which in the construction company contract would better underline the necessity of

fulfillment of all environmental requirements. The contract also does not envisage the

determination of the levels of inconsistency by the ADB in case of the failure to fulfill

environmental requirements and the imposition of a fine per each level.

F) Preparation of Pre-Construction Documents

156. According to the IEE prepared under the project (IEE, Clouse - I.1.Mitigation): “During the Mobilization period, the Contractor submits for approval by the DESC the updated EMP that will

include: Occupational Health and Safety Plan; Public Consultation and Communications Plan;

Vegetation Clearing Plan; Utilities Protection and Relocation Plan; Environmental Protection

Plan; Construction Work Camps Plan; Site Management Plan (Quarry and borrow pit, dumping



50

sites, concrete batching and asphalt plants); Traffic and Access Management Plan; Emergency

Response Plan; Waste and Material Disposal Plan; Site Reinstatement, Landscaping, and

Revegetation Plan”.

157. The construction contractor has developed EMP and submitted to the PIU for approval.

The presented document contains all environmental management plans required under the IEE.

158. Recommendation: In fact, the EMP has not been updated, the construction contractor has

simply copied and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at

the stage of the design of the mentioned document, when a detailed project design has not

been developed. EMP is updated prior to the commencement of construction, when project

detailed design is in place. Respectively, a contractor has to also elaborate specific activities to

meet environmental requirements. For example, the following mitigation measure: „Obtain all the permits for waste disposal and dispose only in permitted sites“, that is acceptable for an IEE as a planned mitigation activity. EMP prepared by construction contractor under the project

should not have this requirement copied as a requirement; rather, the document shall contain

the outcome of the fulfillment of this requirement. Hence, the EMP should contain a permit

issued by a relevant agency about the disposal of waste, as well as the description as to how,

when and who will collect, transport and dispose the waste.

159. During the audit of a construction site Construction Contractor, based on the Consultant’s request, has provided the contract with the City Municipality about the disposal of waste.

Further, it has verbally described to the Consultant the way and the frequency of the collection

and removal of the mentioned waste from the construction site. Effectively, the construction

contractor had stipulated everything that had to be included in the EMP for this concrete case. It

was only the mentioned documentation and procedure that were not included in the EMP

document.

G) Monitoring, Reporting and Trainings

160. The environmental monitoring and reporting of the construction contractor as well as of PIU

is done within the terms specified by the agreement.

161. Investigations of baseline quality have been carried out during the environmental

assessment study, during April 2012, in accordance with the Contract in four points of two

sections along the Arshakunyats Street, in Yerevan, measurements of noise and vibration levels

were taken. The measurements have been taken by Sergey Karapetyan, Head of Sanitary-

Hygienic Department of “Disease Control & Prevention Center” CJSC, M. of HC, RA and by Moses Yeritsyan, an engineer of the same department. In taking measurements first-class

OKTAVA 110A MAXIMA sound level meter produced in 2009 was used. Every year including

12.11.2012 it was calibrated by the National Institute of Metrology of Ministry of Economics, RA,

which has been entitled to carry out activities of the kind.



51

162. At the construction stage Construction Contractor’s environmental specialist is performing the inspection of the construction site on a weekly basis. Relevant checklist has been developed

and the records are entered. The records are stored at the construction site.

163. The environmental specialist of the Roads Department also undertakes monthly

monitoring, inter alia studying the degree of correction of the facts of non-compliance.

164. According to the requirement Construction Company should „Provide community leaders and local newspapers with notices on project progress and anticipated issues“ (Source of

request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue

(Tender 1), Annex 5, pp-7).

165. Recommendation: Monthly progress reports and quarterly environmental reports should

be provided to all stakeholders, including local media.

166. As has been mentioned, the project implementation has commenced recently, respectively,

quarterly environmental reports have not been presented yet. As for the bi-annual reports two

such reports have been prepared under the project and sent to the ADB. Both reports are

approved.

167. PIU and PMIC ESs participated in the ADB training session held on 16 - 17 September 2013, under the Regional Technical Assistance RETA: “Improving the Implementation of Environmental Safeguards in Central and West Asia”. The aim of the training was to provide knowledge of ADB environmental safeguard requirements during project implementation strengthen the environmental management and monitoring capability of PIU and PMIC. Unfortunately, the construction contractor had not been identified as of the day of the training and their representative did not attend the mentioned training. Further, consulting company environmental specialist who attended the training is no longer involved in the implementation of the mentioned project.

168. Recommendation: All environmental specialists engaged in the project shall take the training developed within the scope of RETA project.

169. A number of environmental trainings are required according to the IEE document developed as part of the project, these trainings are: (a) training to all staff on Health, Safety and Environment (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-3); (b) training program on waste management for Contractor’s Personnel (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-18); (c) Job-specific training for workers with responsibility for activities that could have adverse impacts on the environment or humans (e.g., PAH) (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1), Annex 5, pp-5); (d) Health risks and prevention.

170. Recommendation: It is not mentioned in IEE document when the above-mentioned trainings should be conducted for he employees of the Consruction Contractor. Despite of this, it



52

is desirable to conduct all the mentioned trainings from the beginning of the project, duration of which is 10 months.

2.4 Project Site Audit

171. Site visits were organized on 29.04.2013. A meeting with the environmental specialists and technical staff was organized (Figures 6, 7). The environmental audit was conducted by using the questionnaire developed by the Asian Development Bank (see Appendix 1).

Figures 6 and 7: Meeting with PIU

172. The environmental plans developed and relevant records drafted by the contractor were considered and evaluated during the meeting. These were the documents the construction contractor was responsible to develop under the agreement.

A) Construction Site

173. As has been mentioned above the project has been launched recently and at currently street expansion works in the first section of the project territory are underway; the expansion works include the removal of the existing asphalt cover, replacement of old infrastructure (mainly old underground systems) and the dismantlement of the existing walls and building new walls in order to expand the street.

174. The safety requirements are fully met at the construction site, the construction site is

enclosed adequately and a person is standing on each side regulating the movement of the

vehicles entering and exiting the site (Figures 8, 9, 10 and 11).



53

Figures 8 and 9: The man regulating the traffic

Figure 10: The man regulating the traffic Figure 11: The warning signs

175. At one location a secondary road links to the project site, while at another place the project

blocks the enterprise entrance gate (Figures 12, 13). According to the developed project

alternative options to solve the mentioned problem have not been identified. Respectively,

currently both the enterprise entrance and the section linking with the secondary road are open.

Motor vehicles that use the above-mentioned secondary road or are entering the enterprise has

to cross the construction site, which is associated with additional risks.



54

Figure 12: The entry of the secondary road Figure 13: The entry to the enterprise

176. As can be seen from the pictures the warning signs have not been installed in the

mentioned sections. The problem is quite severe in terms of safety. As can be seen from Figure

13 pedestrian employees of the enterprise use the mentioned entrance as well, and they have

to pass the construction site involuntarily.

177. Recommendation: Several alternative recommendations can be considered:

1. Identify or organize temporary access road to the factory that will enable the transport

and especially the employees to enter the factory territory without crossing the

construction site;

2. The construction company to identify an individual who will regulate the mentioned

problem and warn not only the vehicles and employees that appear on the construction

site about the expected threat but will also halt the operation of construction equipment

in case of the entry of every vehicle or individual to the construction site.

3. It is desirable that the factory employees undergo special training in safety issues.

178. As mentioned, with the purpose of expanding the road the existing walls were being

dismantled and the new walls are built. Although the walls are not very high construction

workers still had to use the scaffolds. The construction workers use self-made scaffolds that are

not acceptable in terms of safety or stability.



55

Figure 14: Self-made scaffolds

179. Recommendation: Although the height on which the workers are working is not

considered as the working on height according to international standards (height of 2 meters

and below) the construction contractor has to use more solid and safe scaffolds.

B) Dust

180. It was not dry and sunny weather on the day of the audit; respectively, the formation of

dust was not observed at the time of the movement of construction equipment. The company

had implemented a number of activities for the reduction of dust. Specifically, the sections of the

construction site where earth works had been planned had a cellophane protective wall around

them that will significantly reduce the area of the spread of emerged dust (Figures 15 and 16).

Figures 15 and 16: Walls protecting against dust around the construction sites.

181. Furthermore, as they have explained to the Consultant on dry and hot weather special

equipment will work on the site. This equipment will water the construction site with certain

frequency based on necessity. As can be seen from the pictures the construction site borders



56

one of the central roads of the city, respectively, there is a high risk that the soil reaches the city

area through the tires of the vehicles, which will be additional source for deriving dust, leave

along the pollution of the city. The soil adhered to the tiers of construction equipment may also

be carried by those vehicles that are involuntarily crossing the construction site in order to reach

the enterprise territory or home.

Figures 17 and 18: Construction site continues the road

182. Recommendation: The best method of removing soil from car tiers is washing the tires.

Although in this specific case this method may not be effective since in addition to the

construction equipment, as has been mentioned the vehicles destined to the enterprise as well

as those of local residents appear on the construction site. The number of the vehicles of local

residents will not be insignificant. Due to understandable reasons one cannot force private

vehicles to stop to wash tires at every entry or exit of the construction site. In the mentioned

case the most effective way will be the installation of simple structures shown on Figure 19 or

simply pour medium gravel (Figure 20).

Figure 19 and 20: Simple ways of removal of soil attached to vehicle tires



57

C) Construction Waste

183. Main waste derived at this stage as a result of performance of ongoing works is: a)

removed asphalt; b) soil; c) existing old pipes, d) household waste.

184. It should be mentioned that the construction site looked quite clean. Save minor and

insignificant exceptions we did not see any waste disposed without control. The construction

company has a contract with the relevant municipal office on the disposal of removed asphalt

and soil. According to the contract the mentioned waste are disposed at a specifically

designated location. Until the removal from the construction site the mentioned waste are

placed on a temporary basis at the locations where they are produced (Figure 21 and 22).

Figures 21 and 22: Removed asphalt is placed temporarily on the construction site

185. Dysfunctional metal pipes are collected at their locations (Figure 23), later they are taken

and warehoused in specifically designated places (Figure 24), following which they are given to

the contractor.

Figure 23: Removed old pipes Figure 24: Warehoused metal pipes



58

186. As has been mentioned the Consultant has not observed the facts of placing the

mentioned waste without control. If the existing pipes contain asbestos they are not removed.

187. Recommendation: As the Consultant has been told that they remove metal pipes (waste)

frequently. Still, it is desirable to use sheltered place for temporary storage of metal waste in

order to avoid their contact with rain water.

188. Municipal waste produced on the construction territory is collected on a daily basis by a

construction contractor. First they are placed in relevant bags and at the end of the day the city

cleaning service removes and takes the waste to the municipal dumpsite (Figure 25).

Figure 25: Municipal waste stored temporarily

189. Recommendation: It is necessary to place 0.24 m3 waste containrs wihin the territory of

construction site for collection of waste creating, which will be a pre-condition to avoid contact of

the insects and stray dogs with the waste.

E) Construction Camp

190. At this stage of project implementation the construction company had not set up own

construction camp. According to the contract a Military Aviation Institution located adjacent to

the construction territory had allocated a well-organized territory to the contractor.

191. A cafeteria and lavatory are located on the mentioned territory (Figures 26 and 27), they

are linked to the relevant municipal network. The location for storing equipment is also allocated

on the territory of the institution. Construction equipment is fueled at a petrol station located

opposite the construction site (Figure 28).



59

Figure 26: Kitchen Figure 27: Toilet

Figure 25: Petrol Station

D) Book of Complaints

192. The site with ongoing construction works had the Book of Complaints and Suggestions.

According to the PIU and Contractor, there were no complaints received from the citizens.

2.5 General Findings and Recommendations

193. Based on the project documents review and conducted site visits the Consultant (Audit

Team) revealed the following general findings:

I. Project implementation has been commenced recently. A PIU has been established

by the Yerevan Municipality and the environmental specialist is included within the

PIU. Both the construction company and a consulting/supervisor company have

hired qualified environmental specialists;



60

II. Project Implementing Unit (PIU) environmental specialist is not involved in the bids

evaluation process. There is no official requirement to have an environmental

specialist in the bid evaluation committee. Besides that, under the mentioned project

an environmental specialist was included in the bid evaluation committee. The

mentioned specialist had been invited from American University of Armenia;

III. The contract with the construction company was concluded in December, 2013. By

now the training developed by the ADB under RETA: 7548 has already been held.

Training materials contained quite detailed overview of all those requirements which

inclusion of which in the construction company contract would better underline the

necessity of fulfillment of all environmental requirements. The contract also does not

envisage the determination of the levels of inconsistency by the ADB in case of the

failure to fulfill environmental requirements and the imposition of a fine per each level;

IV. A number of environmental trainings are required according to the IEE document

developed as part of the project, these trainings are:

Provide training to all staff on Health, Safety and Environment (Source of request:

IEE. Table 1: Environmental Management Plan: Mitigation. Arshakunyats Avenue

(Tender 1), Annex 5, pp-3);

Organize a training program on waste management for Contractor’s Personnel (Source of request: IEE. Table 1: Environmental Management Plan: Mitigation.

Arshakunyats Avenue (Tender 1), Annex 5, pp-18);

Job-specific training for workers with responsibility for activities that could have

adverse impacts on the environment or humans (e.g., PAH) (Source of request:


(Tender 1), Annex 5, pp-5);

Health risks and prevention. Training should include information and education

on sexually transmitted diseases and HIV/AIDS for construction workers as part

of the health and safety program at campsites (Source of request: IEE. Table 1:

Environmental Management Plan: Mitigation. Arshakunyats Avenue (Tender 1),

Annex 5, pp-5);

Ensure that the ERT receives emergency response training (Source of request:


(Tender 1), Annex 5, pp-17).

V. In fact, the EMP has not been updated, the construction contractor has simply copied

and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at

the stage of the design of the mentioned document, when a detailed project design

has not been developed. EMP is updated prior to the commencement of

construction, when project detailed design is in place. Respectively, a contractor has

to also elaborate specific activities to meet environmental requirements. For example,

the following mitigation measure: „Obtain all the permits for waste disposal and dispose only in permitted sites“, that is acceptable for an IEE as a planned mitigation



61

activity. EMP prepared by construction contractor under the project should not have

this requirement copied as a requirement; rather, the document shall contain the

outcome of the fulfillment of this requirement. Hence, the EMP should contain a

permit issued by a relevant agency about the disposal of waste, as well as the

description as to how, when and who will collect, transport and dispose the waste;

VI. According to the requirement a construction company should: „Provide community leaders and local newspapers with notices on project progress and anticipated

issues“(Source of request: IEE. Table 1: Environmental Management Plan: Mitigation.

Arshakunyats Avenue (Tender 1), Annex 5, pp-7);

VII. According to the IEE document prepared under the project a number of

environmental trainings should be provided, the delivery of these trainings has not

yet commenced under the project;

VIII. At one location a secondary road links to the project site, while at another place the

project blocks the enterprise entrance gate. According to the developed project

alternative options to solve the mentioned problem have not been identified.

Respectively, currently both the enterprise entrance and the section linking with the

secondary road are open. Motor vehicles that use the above-mentioned secondary

road or are entering the enterprise have to cross the construction site, which is

associated with additional risks;

IX. With the purpose of expanding the road the existing walls were being dismantled and

the new walls are built. Although the walls are not very high construction workers

still had to use the scaffolds. The construction workers use self-made scaffolds that

are not acceptable in terms of safety or stability;

X. The construction site looked quite clean. Other than very few and minor exceptions

the Consultant did not see waste placed without control;

XI. At this stage of project implementation the construction company had not set up own

construction camp. According to the contract a Military Aviation Institution located

adjacent to the construction territory had allocated a well-organized territory to the

contractor;

XII. The site with ongoing construction works had the Book of Complaints and

Suggestions. According to the PIU and Contractor, there were no complaints

received from the citizens.

194. Along with the above-mentioned findings the Consultant made the following recommendations:

I. For ADB: In one of the documents developed under the project (Loan agreement,

PAM/FAM) the requirement about the involvement of environmental specialist in the bid

evaluation committee shall be stipulated;

II. For PIU: The criteria developed by ADB are desirable to use for the evaluation of

environmental aspects of the tender bid;



62

III. The contract with the construction company was concluded in December, 2013. By now

the training developed by the ADB under RETA: 7548 has already been held. Training

materials contained quite detailed overview of all those requirements which inclusion in

the construction company contract would better underline the necessity of fulfillment of

all environmental requirements. The contract also does not envisage the determination

of the levels of inconsistency by the ADB in case of the failure to fulfill environmental

requirements and the imposition of a fine per each level;

IV. In fact, the EMP has not been updated, the construction contractor has simply copied

and pasted mitigation measures provided in the IEE in the “updated” EMP document. The requirements set forth in the IEE as mitigation measures are acceptable only at the

stage of the design of the mentioned document, when a detailed project design has not

been developed. EMP is updated prior to the commencement of construction, when

project detailed design is in place. Respectively, a contractor has to also elaborate

specific activities to meet environmental requirements. For example, the following

mitigation measure: „Obtain all the permits for waste disposal and dispose only in

permitted sites“, that is acceptable for an IEE as a planned mitigation activity. EMP prepared by construction contractor under the project should not have this requirement

copied as a requirement; rather, the document shall contain the outcome of the

fulfillment of this requirement. Hence, the EMP should contain a permit issued by a

relevant agency about the disposal of waste, as well as the description as to how, when

and who will collect, transport and dispose the waste;

V. According the IEE request: “Monthly progress reports and quarterly environmental

reports should be provided to all stakeholders, including local media” VI. A;ll environmental specialists engaged in the project shall take the training developed

within the scope of RETA project;

VII. It is not mentioned in IEE document when the mentioned trainings should be conducted

(finding iv) for he employees of the Consruction Contractor. Despite of this, it is desirable

to conduct all the mentioned trainings from the beginning of the project, duration of

which is 10 months;

VIII. (For finding viii) Several alternative recommendations can be considered:

Identify or organize temporary access road to the factory that will enable the

transport and especially the employees to enter the factory territory without

crossing the construction site;

The construction company to identify an individual who will regulate the

mentioned problem and warn not only the vehicles and employees that appear

on the construction site about the expected threat but will also halt the operation

of construction equipment in case of the entry of every vehicle or individual to the

construction site.



63

It is desirable that the factory employees undergo special training in safety

issues.

IX. Although the height on which the workers are working is not considered as the working

on height according to international standards (height of 2 meters and below) the

construction contractor has to use more solid and safe scaffolds;

X. The best method of removing soil from car tiers is washing the tires. Although in this

specific case this method may not be effective since in addition to the construction

equipment, as has been mentioned the vehicles destined to the enterprise as well as

those of local residents appear on the construction site. The number of the vehicles of

local residents will not be insignificant. Due to understandable reasons one cannot force

private vehicles to stop to wash tires at every entry or exit of the construction site. In the

mentioned case the most effective way will be the installation of simple structures or

simply pour medium gravel;

XI. As the Consultant has been told that they remove metal pipes (waste) frequently. Still, it

is desirable to use sheltered place for temporary storage of waste metal in order to avoid

their contact with rain water;

XII. It is necessary to place 0.24 m3 waste containrs wihin the territory of construction site for

collection of waste creating, which will be a pre-condition to avoid contact of the insects

and stray dogs with the waste;

195. More detailed recommendations with indication of the entities responsible for their

implementation as well as the terms of recommendations implementation are provided in the

Table 12.


# Recommendation Responsible/Action Implementation Terms

1. The loan agreements

concluded within the scope of

the project, PAM, IEE, bidding

proposal, contract and other

relevant documents must give

the environmental

requirements in greater

details.

ADB - gives the

environmental requirements

in greater details in PAM.

Construction/Supervision

Consultant - gives the


in greater details in

IEE/EIA.

During preparation of relevant

Documents – PAM, IEE and

EIA.

2. It is necessary to update

EMP.

Construction Contractor:

EMP should be updated on

Within one month after

receiving the Environmental



64

the basis of detailed design. Audit Report.

3. Monthly progress reports and

quarterly environmental

reports should be provided to

all stakeholders, including

local media


Disseminates monthly and

quarterly reports prepared

under the project among all

interested stakeholders

including media

representatives.

Within one week after


Audit Report to elaborate

procedure for disseminating

of monthly and quarterly

reports among the local

population.

4. All environmental specialists

engaged in the project shall

take the training developed

within the scope of RETA

project

Consultant Company:

prepares training module on

the basis of the trainings

conducted under the RETA

program and conducts

trainings for Construction

Company employess

including every new hired

employees.



Audit Report

5. Place 0.24 m3 waste

containrs wihin the territory of

construction site for collection

of municipal waste.


Placement of 0.24 m3 waste

containrs wihin the territory

of construction site.



Audit Report.



65

3. CWTC 42145-023; 42145-033: NORTH–SOUTH ROAD CORRIDOR INVESTMENT

PROGRAM – TRANCHE 1 AND TRANCHE 2: YEREVAN-ASHTARAK, YEREVAN-ARARAT

AND ASHTARAK-TALIN

3.1 Brief Information on the project (42145-023; 42145-033)

196. The RA has selected the Bavra-Yerevan-Agarak route as the north-south road corridor to be rehabilitated, reconstructed and expanded and has appointed the “North-South Road Corridor Investment Program PMU” SNCO (“NSRP” PMU SNCO) of the Ministry of Transport and Communications (MOTC) to co-ordinate the work. The Program is funded by the Asian Development Bank (ADB) under a multi-tranche funding facility (MFF). The MFF is designed to rehabilitate and upgrade national north-south roads to form a new, upgrade and expanded North-South highway. The main objective is to widen the existing 2-lane roads (often in poor condition) to become 4-lane divided roads along existing alignments wherever possible or to construct new alternate 2-lane roads where a single 4-lane road would not be feasible. 197. Tranche 1 Project is to improve two road sections of the North-South Corridor, namely, the M-1 section of road north from Yerevan to Ashtarak from km 18+370 to km 29+773 (Section 3 in the contract with Contractor) and the M-2 section of road south from Yerevan to Ararat from km 9+312 to km 47+400. The Tranche 2 Project starts at km 29+600 in Ashtarak and ends at km 71+500 close to Talin (Section 1 in the contract with Contractor). Two bypasses will be constructed in Agarak starting at km 29+934 to km 32+600, and in Ujan from km 36+600 to km 40+300. The Project will also have a new road alignment (8.95 kilometres) at Katnagbyur starting from km 59+950 to km 68+900 that will be located on the left side of the existing highway to join the existing alignment in Talin.

Figure 26: Project Area



66


198. The Executing Agency (EA) is the Ministry of Transport and Communication (MOTC).

The MOTC set up a North-South Road Corridor Investment Project Implementation Unit

SNCO. The Project Management Unit is implementing day-to-day management of project

execution including, among other things, (i) monitoring the progress of Project implementation;

(ii) preparing withdrawal applications and Project progress reports; (iii) maintaining Project

accounts and completing financial records for auditing the Project; and (iv) carrying out

procurement, including advance contracting activities. The PMU includes a Social and

Environmental Unit whose responsibilities include the management of all environmental aspects

of the project.

199. The Project Management Consultant is providing Technical Assistance to the PMU in the

management and reporting of the project. Environmental Safeguards Unit of the PMC is

responsible for supervising the construction works in relation to environmental and

archaeological impact and, in particular, for supervising and reporting on the Contractor’s performance in the implementation of the EMP.

200. Contractor is implementing construction works. Contractor’s Environmental Unit is

responsible for implementation of the EMP, monitoring of the construction activities and

reporting.

201. During the reporting period the PMU Social and Environmental Safeguards Unit

consists of: Social Safeguards and Environmental Officer; Social Safeguards Specialist and

Environmental Specialist:

- Ms. Armine Yedigaryan - Social Safeguards and Environmental Officer, is responsible

for environmental, resettlement and social management of the project;

- Mss. Sona Poghosyan - Social Safeguards Specialist is responsible for the compliance

of the project to ADB’s Safeguard Policy and RA Legislation; - Mr. Gevorg Afyan - Environmental Specialist is responsible for the compliance of the

project to ADB’s Environmental Policy and RA Legislation.

202. Presently the PMU Environmental Safeguard Unit consists of:

- Ms. Edita Vardgesyan, the National Environmental Specialist (NES), manages the unit

after the departure of the International Environmental Specialist. Allocation of the NES

came to an end and was renewed in October 2013;

- Mr. Boris Gasparyan, the National Archaeological Specialist, is responsible for the

consultancy on archaeological issues in Tranche 2, compliance of the construction

activities to the Armenian archaeological related legislation and inspection visits to the

borrow pit, dumping and concrete plant sites with archaeological evaluation purposes;



67

- Mr. Charles Adamson, the International Environmental Specialist (IES) is responsible for

the provision of consultation on international best practices on environmental safeguards.

His recent input was from 26 April 2014 to 22 May 2014;

203. The Contractor’s Environmental Unit is staffed by four people:

- The Quality and Environmental Manager - Mr. Javier Gomez Moreno, the Quality and

Environmental Manager, commenced work in Jan 2014 replacing the former manager;

- Mr. Viktor Bakhtamyan, the Environmental Specialist, is responsible for the assistance to

the Quality and Environmental Manager as a local counterpart;

- Mr. Sos Amirkhanyan, the Social Relation Specialist, is responsible for the compliance of

the Contractor’s activities to social part of the ADB Safeguard Policy Statement; - Mrs. Patricia Ortega Gonzalez, Health and Safety Manager, replaced Ana Maria Del

Hoyo Figaredo and commenced work in March 2014. She is responsible for the

compliance of the Contractor’s activities to health and safety part of the ADB Safeguard Policy Statement.

Figure 27: Institutional Chart of the Environmental Safeguards Arrangement



68

3.3 Project Document Analysis A) Loan Agreement (Tranch 1)

204. According to the obligation to meet the environmental requirements given in schedule 5,

clause 14 of the Loan Agreement # 2561 - ARM(SF) (October 12, 2009) between Armenia

("Borrower") and Asian Development Bank ("ADB"), „…The Borrower shall ensure that the

Project is designed, carried out, maintained, and monitored in compliance with (a) all applicable

environmental laws and regulations; (b) ADB’s Environment Policy (2002); and (c) the EMP,

including the mitigation measures and monitoring requirements arising from the implementation

of the IEE. The Borrower shall also cause ARD to ensure that: (y) Works contractors’ specifications include requirements to comply with the environmental mitigation measures

contained in the IEE and EMP, and (z) Works contractors are supervised to ensure compliance

with the requirements of the IEE and EMP“.

205. The said loan agreement was concluded in 2009, when the Asian Development Bank

Safeguard Policy Statement (SPS 2009) was not put to action. Consequently, the said

agreement contains a requirement for meeting the 2002 environmental safeguard policy. Within

the limits of the project, in 2013, the FAM was drafted, which covered the first tranche of the

project as well. Under the new FAM, the “North–South Road Corridor Investment Program” of the project (including Tranche 1) shall be accomplished in line with the requirements of ADB

SPS (2009).

B) Loan Agreement (Tranche 2)

206. According to the obligation to meet the environmental requirements given in schedule 5,

clause 2 “Environment” of the Loan Agreement # 2729-ARM (May 30, 2011) between Armenia

("Borrower") and Asian Development Bank ("ADB"), „…The Borrower shall also ensure that the

design, construction, and operation of the Project are in accordance with the environmental

safeguards and requirements set forth in the ADB’s Safeguards Policy Statement (2009) and the Borrower’s environmental laws and regulations. The Borrower shall ensure that potential

adverse environmental impacts arising from the Project are minimized by implementing all the

mitigation measures presented in EIA and EMP. The Borrower shall further ensure that (i)

during construction, the contractor has primary responsibility for implementing the EMP and

mitigation measures, and MOTC has access to sufficient resources to ensure that all

environmental management provisions are included in the relevant contract; (ii) MOTC monitors

and records the implementation of the EMP; (iii) MOTC, with the assistance of the project

management consultants, prepares semiannual environmental monitoring reports, satisfactory

to ADB, and submits such to ADB, within 3 months of the end of each half of the calendar year,

from the start of project implementation and until the Project completion“.



69

C) Facility Administration Manual (Tranche 1, 2 and 3)

207. In January of 2013, the “Facility Administration Manual” (FAM) was developed by the ADB

within the scope of project „North–South Road Corridor Investment Program“ covering all three

tranches of the project. The document gives a detailed description of all environmental

requirements to be met by all organizations engaged in the project. The document is attached

by ToR (Annex 2) giving a detailed description of the qualification necessary for environmental

specialists and their rights and obligations, and Appendix 3 gives a detailed description of all

major requirements to be considered by any organization engaged in the project.

D) Bidding Documents

208. On April 29, 2014, a meeting was held at the office of the project implementing company,

where the according o the requirement of the Consultant the bidding documents and contracts

were presented (Figures 28 and 29).

Figures 28, 29: Meeting with North-South Road Corridor Investment Program PMU

E) Contract with Supervition Company (Safege S.A. Eptisa JV)

209. An agreement with the supervision company „Safege S.A. and Eptisa JV“ was concluded

on May 18, 2012. Out of environmental requirements, the agreement includes the following

issues: Appendix A – “Description of services”, Clause B – “Scope of Consulting Services” –

(a) to hold permanent project monitoring to identify the compliance of the Safeguards with the

IEE/EIA, EMP and EARF, (b) to draft monthly and quarterly progress reports, (c) to document

any environmental non-compliance and inform MOTC and ADB of them, (d) to develop the

training module and hold the trainings about the safety issues. Clause F – “PMC Team Composition” gives the qualification requirements of the environmental specialists (education, experience, skills and training). Clause G – sub-chapter “Tasks and Responsibilities of Each Team Member” describes the rights and obligations of the local and international environmental

specialists; Appendix B gives the engagement schedule of the international and national



70

environmental specialists in the project, with 12 months (4 months at home and 8 months on

site) for the national sp and 12 months (12 months on site) for the international expert.

F) Bidding Documents (Construction Contractor)

210. Within the scope of Tranche 1 and 2 of the „North–South Road Corridor Investment

Program“ a tender for the Construction Contractor was announced in August 19, 2011.

211. The obligations on the environmental safeguards implementation are included in the

bidding documents in the following sections: Section 7 - General Conditions of Contract, Sub-

Clouse 4.18; Section 8 - Particular Conditions of Contract, Sub-Clouse 4.21 “Progress Reports”; and Part II Volume 2b - Special Technical Specifications for Sections 2 and 3. Sub Clouse

101.16. The said sub-chapter gives a detailed description of the obligations the Contractor will

have to perform at the project implementation stage. In addition, sub-chapter 101.44.3

„Protection of the Environment“envisages the requirements for necessary measurements to

control the qualitative indicators of the environment.

212. The bidding documents have the EIA documents developed within the scope of all three

sub-projects attached as annexes.

G) Contract with Construction Company (Corsan Corviam Construction, S.A)

213. The contract with Construction Company - Corsan Corviam Construction, S.A was

concluded on April 27, 2012. The necessity for meeting the environmental requirements under

the contract concluded with the Construction Contractor is more superficial than it is in the

Bidding Document. The environmental issues under the contract are limited to several

sentences only, in particular: Part A – Particular Conditions of the Contract, Sub-Clouse 4.1

“Contractor general obligations”, states: “The contractor shall comply with requirements of the national and ADB’s SPS (2009) to the extent applicable”. Also, Part A – “Particular Conditions

of the Contract”, Sub-Clouse 4.18 “Protection of Environment”, states: “The Contractor shall take all reasonable steps to protect the environment (both on and off the Site) and to limit

damage and nuisance to people and property resulting from pollution, noise and other results of

his operations. The Contractor shall ensure that emissions, surface discharges and effluent from

the Contractor’s activities shall not exceed the values stated in the Specification or prescribed

by applicable Laws”.

214. The Contract concluded with the Construction Contractor (Particular Conditions of the

Contract) does not show the obligation of the Contractor to accomplish the mitigation measures

and monitoring plan under EIA/IEE and EMP. In addition, the Contract fails to give the sanctions

for the failure to meet the environmental requirements.



71

215. Recommendation: The Contract concluded with the Construction Contractor (Particular

Conditions of the Contract) shall envisage the obligation to accomplish the mitigation measures

and monitoring plan under EIA/IEE and EMP.

H) Evaluation of Bids

216. No environmental specialist is engaged in the evaluation of the submitted tender

proposals.

217. Recommendation: After the loan agreement is approved, PIU and/or the environmental

specialist of the consultant company shall be engaged in all following phases of the project

implementation (drafting the project detailed design, developing and assessing the tender bids,

concluding the agreement with the construction contractor).

I) Preparation of Pre-Construction Documents

218. As already mentioned, there is one EIA and two IEEs developed within the scope of the

project. Under the requirements of these documents, the Construction Contractor had to

develop a number of environmental plans and submit them to the PIU for approval.

219. The Construction Contractor developed the environmental management plans listed below:

Waste Management Plan; Site Management Plans For Borrow-Pits And Dump Sites; Traffic

Management Plan; Concrete Plant Site Development Plan; Site Protection and Stabilisation –

Site Work Plan; Emergency response Plan; Community Consultation and Communications

Plan; Site Clearing, Flora and Fauna Plan; Dust, Noise And Vibration - Mitigation Measures;

Physical Cultural Resources Plan for introducing the Archaeological Issues along km 59.400 –

km 71.500 (Tr. 2, Ashtarak-Talin) of the “North-South Road Corridor” Investment Program.

220. All the plans were developed and submitted to the PIU for approval by the Construction

Contractor, and all of the said plans were submitted during the audit.

221. The Construction Contractor also developed SEMP and submitted it to the PMC for

approval. One of the components of this plan is risk assessment table developed for all sections

of the project.

222. Recommendation: The risk assessment table, according to the ADB methods, cannot use

‘zero’ (0), as the minimal point is ‘one’ (1) (0 was used for assessment in document „Topsoil Stockpile Site In Davtashen community (Davtashen 3“); 5 points in graph „Likelihood“ are used

to assess the activities, which are planned and realized in fact every day. „Likelihood“ of „Spillages during transportation“ cannot be evaluated by ‘5’ point. A vehicle with permanent oil

or fuel leakage must be removed from the project (Davtashen -1 Dumping Site).



72

K) Monitoring, Reporting and Trainings

223. The environmental monitoring and reporting of the construction contractor as well as of PIU

is done within the terms specified by the agreement.

224. A daily checklist is developed by the Construction Contractor and agreed with the

Consultant, which is used by the Construction Company when inspecting the project sites. The

given checklist consists of 89 questions and is quite detailed.

225. On his turn, the environmental specialist of the supervising company holds monitoring twice a month, while PIU undertakes monitoring once a month.

226. The Construction Contractor develops monthly environmental reports to be submitted to

the consultant. The report gives quite a detailed description of all the activities in the field of

environmental protection to be accomplished by the construction consultant during the month.

227. An International Consultant Company - Eptisa JV hired by for construction supervision

South Road Corridor Investment Program, undertakes environmental monitoring of project

progress and submits quarterly Environmental Monitoring Report to North-South road Corridor

Investment Program PMU.

228. The Bi-Annual Report 2 developed on the request of the North-South Road Corridor

Investment Program PMU. The presented report was drafted in line with the requirements of

Asian Development Bank. All the above-listed reports are available both, on the construction

site and at the head office of the North-South Road Corridor Investment Program PMU. As for

the Bi-Annual Reports, which ARS North-South Road Corridor Investment Program PMU

submits to the ADB, they are available on the ADB web-site.

229. The companies engaged in the project hold frequent meetings with the local population to

acquaint them with the course of the project, monitoring results and accomplished mitigation

measures.

230. On March 04, 2014 Public Consultation (PC) was held in the Administrative Centre of

Shamiram and Aruch communities. During the PCs different environmental, social and safety

issues were discussed related to the construction and further maintenance works of the

carriageway (41.9 km, PK29+600 – PK71+500) of Ashtarak-Talin M1 road section.

231. A training schedule is developed within the scope of the project. There are records about

the trainings available. As per Consultant requirement, we were presented the list of the

trainings held in March of 2014 and relevant records.

2

The reports are placed on the ADB web-site.



73

232. On March 20, 21, 2013 Environmental Team of “Corsan Corviam Construction” S.A. organized and implemented emergency plan and safety, environmental and HIV course

training for the workers of “Hormigones y Morteros Serrano” Armenian Branch, “Dental Import” LLC, “Arpa Sevan” OJSC, “Mirada” LLC, “Nivecotrans” LLC subcontractors, and “Corsan Corviam Construction” S.A. During the different courses constructions workers were informed

about possible negative environmental impacts as well as their mitigation measures. A number

of participants of the training were 70.


233. The Consultant conducted construction site environmental audit on April 30, 2014 in

presence of representatives from PMU and Contractor. The first meeting to get acquainted with

environmental documents available on the site was held at the office of the Construction

Contractor (Figures 30 and 31).

Figures 30 and 31: Meeting with project implementation team

234. The environmental audit of project site was conducted by using the questionnaire

developed by the Asian Development Bank (see Appendix 2).

A) Book of Complaints

235. There is a book of complaints compiled by the company and it is kept at the construction

camp. The book of complaints includes some complaints filed at the stage of construction, but

neither of them is associated with the environmental issues (Figures 32, 33).



74

Figures 32, 33: Book of Complaints

B) Baseline Analyzes

236. The relevant analyses to assess the baseline data of the environment were held during the

preparation of EIA, in particular:

Air Quality - Measurements were taken from 9 June 2010 to 16 June 2010. Specialists

from Armecomonitoring (SNCO - under the MNP) were engaged to obtain and analyze

air quality samples at all communities with potential receptors located no more than 250

m from the highway. Sulphur dioxide (SO2) and nitrogen dioxide (NO2) concentrations

were measured in receptors representative of the 6 communities close to the highway;

Noise - Representative receptors of the 6 communities that are within 250 m of the

existing or planned highway are affected by noise from traffic and potentially, from

construction activities. Noise measurements were taken at all 6 locations between 4 and

10 June 2010;

Water Quality - Specialists from Armecomonitoring were engaged to obtain and analyze

physical chemical and biological water quality samples of all 7 streams that are crossed

by the existing and new highway and the samples were analyzed in Armecomonitoring’s laboratory;

237. At the construction stage Contractor implements monthly monitoring for the following

components: (i) Dust monitoring, (ii) Noise monitoring, (iii) Vibration monitoring, (iv) Water

quality monitoring.



75

C) Business Yard

238. The Construction Company has no construction camp, where the workers can live. Most of

the workers are locals and go to the construction site from their homes. As for the non-local staff

engaged in the project, there are buildings hired for them. Along the project line, the

Construction Contractor has opened two business yards. Besides accommodating the concrete

plants on the given territory, the business yards are used for some other purposes by the

Construction Contractor.

239. The workers dine at the dining halls adjacent to the project line. The same dining halls are

used by the workers for sanitary purposes.

240. If there are no dining halls near the working sites, the construction company takes the

workers to the nearest dining hall during the break. At the same time, the bio-toilets are being

installed in the construction site. During the audit, the said bio-toilets were located on the

territory of the business yard (Figures 34 and 35).

Figures 34, 35: Bio-toilets located on the territory of the business yard

241. There are concrete plants located on the territory of the business yard owned by the

Construction Contractor. Under the legislation of Armenia, the operation of a concrete plant

needs no EIA document.

242. The plants are built with concrete foundations and have drainage system and

sedimentation basins (Figures 36 and 37).



76

Figures 36, 37: Concrete plans located on the territory of business yard

243. The business yard is also used to dispose inert waste in it. The inert waste is disposed in

the specially allotted area (Figures 38, 39 and 40).

Figure 38: Concrete Plant Figure 39: Metal Waste

244. There are plastic containers placed in the business yard for separated collection of the

municipal waste.

Figure 40: Plastic Containers Figure 41: Concrete Waste



77

245. There is a vehicle tire washing area arranged at the entrance of the business yards and in

line with the environmental requirements, it is located on a concrete pillow, has a drainage

system and sedimentation basin (Figures 42 and 43).

Figures 42, 43: Vehicle tire washing area

246. There is no fueling station in the area. The construction techniques are fuelled at the

fueling stations located the adjacent to the construction corridor.

D) Borrow Pits

247. The Construction Contractor has not opened its own borrow pits. The contractor uses the

existing borrow pits. At present, the Construction Contractor has concluded an agreement on

raw materials supply with 6 companies owning the borrow pits. These companies are:

1. “AAB Project” LLC.- with the permit issued on 20.10.2012 (valid until 25.07.2036)

2. “Khochar” LLC – with the permit issued on 20.11.2003 (valid until 20.11.2034)

3. “Macdzavan” LLC – with the permit issued on 22.03.2012 (valid until 24.07.2028)

4. “Nairi CHSHSH” OSSC – with the permit issued on 20.10.2012 (valid until 24.12.2032)

5. “Stavn Lord” LLC – with the permit issued on 01.09.2012 (valid until 16.07.2032)

6. “TNA-SHIN-ASHOT” LLC - with the permit issued on 03.09.2012 (valid until 21.07.2022)

248. All companies have a license to mine the construction materials.

D) Site Inspection

249. During the audit, the drainage systems were installed at some locations of the construction site. The safety requirements were fully observed on the construction site (Figures 44 and 45).



78

Figures 44, 45: Installation of drainage systems

250. There was no dust or noise on the site and there were no uncontrolled waste or spills fixed.

E) Inert Waste

251. In the environmental respect, one of the major problems during the construction was

disposal of the inert waste (see Figure 46).

252. The construction company has a relevant permit to dispose the inert waste adjacent to the

project site. There are inert waste management plans developed for all such sites. All the

mentioned permits and management plans are kept at the construction camp.

Figure 46: Disposal of inert waste

F) Non-Compliance # 1:

253. Existing situation: Figure 25 shows that the inert waste is disposed on the existing

topsoil. The developed inert waste disposal plan does not envisage the removal of the topsoil on



79

the territory where the inert waste is to be placed. In fact, according to the developed plan, the

topsoil on the territory where the inert waste is to be disposed is to be totally destroyed.

254. Corrective action: The existing inert waste disposal plans should be updated. Before the

onset of placement of the inert materials, the topsoil must be removed in the allotted area and

stored in the adjacent area. After the inert waste is placed, the stored topsoil should be used to

restore the territory.

F) Temporal disposal of the topsoil

255. Under the project, the topsoil will be removed on the construction site and placed temporarily. After the completion of the project, the stored topsoil should be used for the restoration works.

256. The company has an agreement concluded with the local authority about temporal disposal

of the topsoil. There are some areas allotted for the temporal disposal of the topsoil, and there

are relevant agreements concluded and relevant plans developed for every area.

G) Non-Compliance # 2:

257. Existing situation: As Figures 47 and 48 shows, the height of the topsoil disposed in the

allotted area varies from 3 to 5 m.

258. Requirement: The height of the disposed topsoil must not exceed 2.5 m. (Technical

Specification 1002 TOPSOIL, Part II Volume 2a, and Special Technical Specifications).

Figures 47, 48: Temporarily disposed topsoil

259. There was an extra meeting held with the management of the Construction Contractor in

connection to this issue. The Consultant asked the Construction Contractor for two months to

develop the corrective actions and accomplish relevant activities.



80

3.5 Main Findings Revaled during the Documents Review and Site Visits

260. Based on the projects documents review and conducted site visits the Consultant (Audit


I. The Loan Agreement envisages the obligation of the authority of the Republic of

Armenia to realize the project in line with the ADB safety requirements and requirements

of the environmental legislation of Armenia. The FAM developed within the scope of the

project gives a detailed description of the qualification necessary for the environmental

specialists and their rights and obligations, as well as all major requirements to be

considered by any organization engaged in the project;

II. The Contract concluded with the Construction Contractor (Particular Conditions of the

Contract) does not show the obligation of the Contractor to accomplish the mitigation

measures and monitoring plan under EIA/IEE and EMP. In addition, the contract fails to

give the sanctions for the failure to meet the environmental requirements;

III. All the companies engaged in the project are staffed with high-quality international and

local environmental specialists;

IV. All needed environmental documents are developed within the scope of the project. The

project is permanently inspected, monitored and audited by both, construction and

supervision consultant company and environmental specialist of PIU;

V. There is a book of complaints kept at the construction camp, containing the complaints

of the local people. Neither complaint is about the environmental issues;

VI. There are permanent meetings held with the locals to consider the environmental issues

interesting to the population, who are under the project impact. This action must be

considered as good practice for other ongoing projects (in Armenia and other countries);

VII. The basic analyses were accomplished within the scope of the project, and monthly

analyses envisaged by the EIA are accomplished permanently to assess the baseline

data of the environment (air, water, noise). The results of the analyses are available at

the construction camp;

VIII. There are agreements concluded with the local authority about the disposal of inert

waste and temporal disposal of the topsoil;

IX. A number of legislative requirements are violated during the disposal of inert waste and

temporal disposal of the topsoil.

3.6 Non-compliances and Recommendations

261. Along with the above-mentioned findings the Consultant fixed the following general non-

compliances and made the following recommendations:



81

Non-Compliances:

I. The inert waste is disposed on the existing topsoil. The developed inert waste disposal

plan does not envisage the removal of the topsoil on the territory where the inert waste is

to be placed. In fact, according to the developed plan, the topsoil on the territory where

the inert waste is to be disposed is to be totally destroyed;

II. There is a violation of standards at the territory of topsoil disposal, in particular the height

of the temporarily disposed topsoil significantly exceeds permissible standards.

Recommendations:

I. The Contract concluded with the Construction Contractor (Particular Conditions of the

Contract) shall envisage the obligation to accomplish the mitigation measures and

monitoring plan under EIA/IEE and EMP;

II. After the loan agreement is approved, PIU and/or the environmental specialist of the

consultant company shall be engaged in all following phases of the project

implementation (drafting the project detailed design, developing and assessing the

tender bids, concluding the agreement with the construction contractor);

III. The risk assessment table, according to the ADB methods, cannot use ‘zero’ (0), as the minimal point is ‘one’ (1) (“0” was used for assessment in document „Topsoil Stockpile Site In Davtashen community (Davtashen 3“);

IV. 5 points in graph „Likelihood“ is used to assess the activities, which are planned and

realized in fact every day. „Likelihood“ of „Spillages during transportation“ cannot be

evaluated by ‘5’ point. A vehicle with permanent oil or fuel leakage must be removed

from the project (Davtashen -1 Dumping Site);

V. The inert waste management plans shall be permanently updated. Before the onset of

placement of the inert materials, the topsoil should be removed in the allotted area and

stored in the adjacent area. After the inert waste is disposed, the stored topsoil should

be used to restore the territory;

VI. Aiming at eliminating the violation of the standards of disposal on the territory of

temporal placement of the topsoil, the corrective actions shall be developed and

implemented.



Table 13.



82




concluded within the scope

of the project, PAM, IEE,

bidding proposal, contract

and other relevant

documents must give the


in greater details.

ADB - gives the







IEE/EIA.



EIA.

2. SEMP should be updated.

Construction Company:

Risk assessment table is to

be improved, assessment

methodology has to be in

compliance with ADB

requirements.



Audit Report.

3. Inert Waste Management

Plan has to be updated.


Updates Inert Waste

Management Plan in

accordance with the

presented

recommendations.



Audit Report.

4. Corrective actions related to

the topsoil disposal have to

be elaborated and

implemented.


Elaborates and implements

corrective actions related to

the topsoil disposal.

Within two months after


Audit Report.



83

4. CWUW 45299-001: WATER SUPPLY AND SANITATION SECTOR PROJECT – PHASE 2

4.1 Brief Information on the project

263. Water supply infrastructure in Armenia dates back to the Soviet era and has suffered from lack of investment since the collapse of the Soviet Union. The systems were constructed using cast iron and steel components and are now well past their normal life. Corrosion of pipelines result in water losses of up to 90% in some cases, e.g. Vayq, with the result that water supplies have to be turned off for extensive parts of the day. 265. Water is extracted from some sources that cannot provide the required quantities year round. Abstraction from new or supplementary sources is required to provide year-round water supply. Within many reasonably sized towns the citizens collect water from stand pipes or from bulk tankers as water supply does not reach their homes. A Phase 1 program of works has already been implemented with ADB funding, along with parallel projects under the auspices of other IFIs. These projects were limited by the capacity for implementing the works, and hence in many cases the Phase 1 works form the foundation for Phase 2 and future works that will realize the benefits in the context of the overall program. 266. The proposed Project will be implemented in 18 towns and 92 villages throughout Armenia, distributed through the territory, excluding Yeravan Gyumri and Vanadzor Cities. The objective of the project is improved public health and environment for households and other consumers in 18 towns and 92 small villages through safe and reliable water supply. The project is grouped into ten sub-projects, clustered around these following towns: Vedi & Ararat; Ecmiatsin; Artik; Alaverdi, Tashir & Stepanavan; Gavar & Martuni; Noyemberan & Berd; Kapan & Meghri; Veyq & Jermuk; Talin; Hrazdan & Tsahkadzor. The location of these named centers is shown in Figure 1.

Figure 49: Project Area



84


267. The Executing Agency (EA) is the State Committee for Water Economy (SCWE). Roles

and Responsibilities of the SCWE are: i) Responsible for oversight and administration; ii) Hold

monthly meetings with AWSC to review progress; iii) Convene regular meetings in consultation

with the Company Board of Directors and AWSC; iv) Facilitate the approval procedures within

the Government.

268. The Implementing Agency is Armenia Water Sewerage Company. The Project

Management Unit is implementing day-to-day management of project execution including,

among other things: (i) Oversee accounting and auditing; (ii) Oversee implementation and

management; (iii) Secure technical and environmental approvals for all civil works prior to

bidding; (iv) Ensure compliance with covenants; (iv) Invite bids, evaluate and prepare bid

evaluation reports for ADB‟s approval: (v) Award contracts; (vi) Oversee contractor’s works (vii) Prepare and submit quarterly progress reports.

269. The Project Management Consultant is providing Technical Assistance to the PMU in the

management and reporting of the project. Environmental Safeguards Specialist of the PMC is

responsible for supervising the construction works in relation to environmental impact and, in

particular, for supervising and reporting on the Contractor’s performance in the implementation

of the EMP.

270. Contractor is implementing construction works. Contractor’s Environmental Unit is

responsible for implementation of the EMP, monitoring of the construction activities and

reporting.

Figure 50: Institutional chart of the environmental safeguards arrangement within the project



85

4.3 Project Document Analysis A) Loan Agreement & Project Administration Manual (PAM)

271. According to the obligation to meet the environmental requirements given in schedule 5

“Execution of Project; Financial Matters”, clause 6 of the Loan Agreement # 2860-ARM (may 2

12, 2012) between Armenia ("Borrower") and Asian Development Bank ("ADB"), “…The Borrower shall ensure and shall cause AWSC to ensure that the preparation, design,

construction, implementation, operation and decommissioning of the Project and all Project

facilities comply with (a) all applicable laws and regulations of the Borrower relating to

environment, health and safety; (b) the Environmental Safeguards; and (c) all measures and

requirements set forth in the IEE, the EMP, and any corrective or preventative actions set forth

in a Safeguards Monitoring Report.”

272. In addition, the Loan Agreement contains the safety requirements, both for the need for

permanent monitoring and reporting and including the safeguard issues in the Bidding

Documents and contracts.

273. In February of 2012, within the scope of the project, the ADB developed and approved

PAM. Part B of the document: “Capacity Building and Public Awareness Campaign” gives the

rights and obligations of the environmental specialist of PIU, which are as follows: “The

Environmental Specialist will carry out the initial environmental examination (IEE) of all

subprojects in accordance with ADB SPS (2009), and Armenia Environmental Guidelines, and

accordingly prepare the EMPs to monitor the sub-projects both at the design and

implementation stages. The environmental mitigation and monitoring measures should ensure

that (a) any adverse environmental impacts are minimized by the mitigating measures and

monitoring program detailed in the environmental management plan (EMP) in the IEE; (b)

implementation of the EMP and any violation of environmental standards are reported to ADB

(c) EMP is incorporated in the bidding documents. The Specialist will also be responsible for the

safeguards issues during construction and EMP’s proper implementation”. In article B -

“Monitoring”, AWSC will undertake the monitoring of safeguard covenants compliance to be

included in the quarterly project progress report and submitted to ADB.

B) Bidding Documents

274. On April 29, 2014, a meeting was held at the office of the project implementing company,

where the audit team members were presented the tender documents and contracts required by

the Consultant.

275. The Bidding Document was submitted by the Supervision Consulting Company in July of

2012. The document contains quite a thorough description of the obligations of the

environmental specialist (Chapter 4.2.2.9. “Environmental Protection”). However, there are a



86

number of obligations, which are not clear for the specialist working for the Consulting

Company.

276. According to the submitted Bid Proposal the environmental specialist should carry out

Environmental Impact Assessment process, for which the specialist should study the ADB’s environmental assessment procedures – Initial Environmental Assessment (2002),

Environmental Policy (2002), Environmental Assessment Guidelines (2003). The specialist also

should study existing Armenian laws regulated environmental impacts regulated environmental

impacts of the works implemented for water supply and wastewater systems improvement”.

277. As the documents drafted within the scope of all projects state, the realization of the given

project will cause a minimum impact on the environment. Despite this, following the scales of

the project (the project is to be accomplished in 110 settled areas and it engages 14

construction companies), the environmental specialist of the Consulting Company shall have

quite good experience, background and skills within the scope of the project. His obligation is to

explain and consult others, not to learn himself, particularly, the basic international or national

legislative base.

C) Contract with Supervision Company

278. The contract with Supervising Company - JV of HGSN LLS and JINS LLS (Armenia) was

concluded on December 26, 2012. Neither “General Condition of the Contract”, nor “Special Conditions” of the Contract gives the environmental obligations of the Consultant. The

environmental obligations are given in Annex A: “Description of Servicies”. The given chapter is totally copied from the Bidding Documents.The different chapters of Annex A give the following

obligations of the environmental specialist of the Consulting Company: (iii) conducting Initial

Environmental Examination IEE; (vii) developing of the Environmental Management Plan (EMP)

for the each sub-project (Annex a, Part A “Design and construction supervision of the civil

works”); Preparation of IEE as a basis for the future development of the EMP in DD phase

(Annex A, Brief Description of the consultant activities); The consultant shall exercise control

over implementation of environmental impact mitigating and safety measures including in EMP

and present information thereon in the separate semiannual safeguard monitoring reports

(Annex A, Brief Description of the consultant activities); The consultant shall prepare and submit

IEE and EMP reports (Annex B “reporting Requirements”).

279. Within the scope of the contract, annex C “Personnel Schedule” also gives the schedule of

the environmental specialist’s engagement in the project, making 36 months.

D) Construction Contractors

280. There are 14 tenders announced and the same number of contracts concluded with the

Construction Contractors within the scope of project “Water Supply and Sanitation Sector

Project”. The obligations to meet the environmental requirements are the same in all 14



87

Bidding Documents, as well as in the Bid Proposal of the winning construction company and all

contracts are found in the same chapters. The only difference lies in the dates of declaring the

tender and terms of submitting the Bid Proposals and concluding the contract.

281. As already mentioned, based on the agreement with the ADB, the site audit within the

scope of the project was accomplished for three sub-projects. Table 14 shows the statistics for

the three sub-projects.

Table 14: Statistics for three sub-projects

# Project name Winner Construction Company

Date

of

ten

der

an

no

un

cem

en

t

Date

of

su

bm

issio

n

of

bid

p

rop

osals

Co

ntr

act

co

nclu

sio

n

date

1. Improvement of water supply systems in Vedi and Ararat towns and Banavan GMF, Ararat, Volketap Villagies.

Ararat-Chanshin LLS - Artezia LLS

24 May, 2013

9 July, 2013

21 August, 2013

2. Improvement of water supply systems in Hrazdan town, Qaghsi village.

LLS & Ashotsg LLS 28 May, 2013

9 July, 2013

11 October, 2013

3. Improvement of water supply systems in Metsavan, Sarchapet and Lernahovit villages and reconstruction of Hovdra external water main.

Agat 777 LLS 26 August, 2013

7 October, 2013

26 November, 2013

D.1) Bidding Documents for Construction Contractor

282. The Bidding Documents of all sub-projects envisage the obligation to meet the

environmental requirements by the Construction Contractor. According to Chapter 8 - “Special Conditions of the Contract” – GCC 63 “Safeguards”: “The Contractor shall: (a) comply with the measures relevant to the contractor set in the Initial Environmental Examination (IEE),

Environmental Management Plan (EMP) and any applicable Resettlement Plan (RP), and any

corrective or preventative actions set forth in a Safeguards Monitoring Report;(b) make available

a budget for all such environmental and social measures; (c) provide the Employer with a

written notice any unanticipated environmental or resettlement risk or impacts that arise during

construction that were not considered in the IEE, EMP and RP; (d) adequately record the

condition of roads, agricultural land and other infrastructure prior to starting to transport

materials and construction; and (e) reinstate pathways, other local infrastructure, and

agricultural land to at least their pre-project condition upon the completion of construction”.

283. The Bidding Documents are annexed by EMP (Section 6 – “Works Requirement –



88

Environmental Management Plan”). This document is drafted by the environmental specialist of

the Consulting Company based on the detailed design.

284. The Bidding Documents: Section 3 – “Evaluation and Qualification Criteria”, Clause - 2.5,

“Personnel” give the qualification requirements for the specialists engaged in the project. The

document contains no requirement for the Construction Contractor to hire an environmental

specialist on staff.

D.2) Bid Proposals of Construction Companies

285. All Bid Proposals submitted by the winning Construction Company repeat (in fact, word by

word) (Clause - “Environmental Protection”) the obligation given in the Bidding Document to

meet the environmental requirements as the one undertaking by them.

286. None of the Construction Contractors have included an environmental specialist on the

Personnel.

D.3) Contracts with Construction Companies

287. All the contracts concluded with the Construction Contractors are annexed by EMP

developed within the scope of all sub-projects. In addition, all contracts give the obligation of the

Construction Contractor to meet the environmental requirements. The wording of this

requirement is identical for all contracts. In fact, the wording about the obligation to meet the

environmental requirements by the Construction Contractor is identical in all documents

associated with the Construction Contractor (Bidding Documents, Bid proposal and Contract)

(See Chapter D.1 for the wording).

E) Evaluation of Bids

288. No environmental specialist is engaged in the evaluation of the submitted tender

proposals.

289. Recommendation: After the loan agreement is approved, PIU and/or the environmental

specialist of the consultant company shall be engaged in all following phases of the project

implementation (drafting the project detailed design, developing and assessing the tender bids,

concluding the agreement with the construction contractor).

I) Preparation of Pre-Construction Documents

290. As already mentioned, within the scope of the project, there was one EIA document

(Framework Initial Environmental Examination Report) developed in January of 2012.

Consequently, the environmental management plans, which are necessary to develop before

the realization of the project, are the same for all projects.



89

291. The only document to be developed before the onset of the project is EMP. There are

EMPs developed based on the detailed designs within the scope of all sub-projects. The

developed documents are also annexed to the contracts concluded with the Construction

Contractor within the scope of each sub-project.

F) Monitoring, Reporting and Trainings

292. Requirement: As already mentioned, the EMPs are developed within the scope of all

projects. A part of this document is a monitoring table giving quite a detailed description of the

Construction Contractor’s obligations of ensuring daily environmental monitoring. The said

document also contains a checklist to be used by the environmental specialist during the

environmental monitoring. For example, the relevant requirement in the contract concluded

within the scope of the first sub-project is given in annex J – “Environmental Manajement Plan”, Clause 8 – “Intuitional framework of Environmental management”, according which: “NGSN Ltd and JINJ Ltd Joint venture will also implement control of implementation of mitigation measures

during the construction. The environmental specialist shall make visits to control the EMP and

SSEMP implementation and assess the situation according the Mitigation compliance &

inspection monitoring form”.

293. The existing situation: None of the Construction Contractors have a qualified

environmental specialist on staff. Consequently, no qualified daily inspections of the sites are

accomplished and no relevant records are made by the employees of the Construction

Contractor.

294. Corrective actions: The Construction Contractor shall hire an environmental specialist on

the basic staff, or some Company employee shall be charged with the duties of an

environmental specialist. The Construction Contractor shall have a designated person, who will

be officially responsible for the environmental issues.

295. The project monitoring is accomplished by an environmental specialist of the Consulting

Company at least once a month. The said specialist uses the checklist developed within the

scope of the project.

296. Reporting within the scope of the project is done by the following organization with the

following regularity: monthly progress reports are drafted by the Construction Contractor and

submitted to the Consulting Supervision Company. As per the existing requirements, this

document shall also cover the environmental issues. As none of the companies have an

environmental specialist, the environmental reports are drafted by the environmental specialist

of the Consulting Company.

297. Recommendation: The Construction Contractor shall hire an environmental specialist on

the basic staff, or some Company employee shall be charged with the duties of an



90

environmental specialist. It will be the obligation of such a specialist to draft the monthly

environmental reports and submit them to the Consultant.

298. A Consultant Company - JV of HGSN LLS and JINS LLS hired in scope of Water Supply

and Sanitation Sector Project undertake environmental monitoring of project progress and

submit quarterly Environmental Monitoring Report to Armenia Water Sewerage Company.

299. The Bi-Annual Report3 developed by Armenia Water Sewerage Company. The presented

report was drafted in line with the requirements of Asian Development Bank. All the above-listed

reports are available both, on the construction site and at the head office of the Armenia Water

Sewerage Company. As for the Bi-Annual Reports, which Armenia Water Sewerage Company

submits to the ADB, they are available on the ADB web-site.

300. The proper specialists of the Construction Contractors have not been given the trainings

about the environmental issues.

L) Non-Compliance #1:

301. Requirement: “The mitigation measures above will be strengthened and supported by the delivery of compulsory training for successful Construction Contract bidders. This training has

been prepared to educate the Contractors‟ Personnel on the implementation of the mitigation

measures of the EMP and on relevant good construction practices” (Framework Initial Environmental Examination Report, Clouse D - Mitigation Measures, sub clause 7 - Community

and Worker Safety).

302. Existing Situation: The Consulting/Supervision Company has not been given the

trainings related with the environmental issues.

303. Corrective Actions: The Consulting Company shall develop the module of environmental

trainings, as well as schedule of trainings and shall start organizing the trainings without delay.


304. The Consultant conducted construction site environmental audit on May 2-3, 2014 in

presence of representatives from PMU and Contractors. As already mentioned, the site audits

were organized only within the scope of three sub-projects. Within the scope of all three sub-

projects, the water-supply and water drainage pipes were replaced and connected to the

residential houses.

3

The reports are placed on the ADB web-site.



91

305. The work schedules were identical for all sub-projects. The trenches were excavated along

50 to 150 m distance, the pipes were laid and trenches filled. Then, the construction activities

were accomplished along the next section with the same works done with it.

A) Improvement of water supply systems in Vedi and Ararat towns and Banavan GMF,

Ararat, Volketap Villagies

A.1) Baseline Analyzes

306. According to the Framework Initial Environmental Examination Report elaborated under

the Project: “No new baseline monitoring is required” (Clouse VIII – “Framework Environmental Management Plan”). In addition, the EMPs developed within the scope of all projects say that

the noise level is to be measured only in case there is a complaint.

A.2) Business Yard

307. The Construction Contractor has no construction camp for the workers to live in. Most of

the workers are locals and go to the construction site from their homes. As for the non-local staff

engaged in the project, there are buildings hired for them. Along the project line, the

Construction Contractor has opened a business yard. Besides accommodating the concrete

plants on the given territory, the business yards are used for some other purposes by the

Construction Contractor. As there are 10 to 12 workers working at every construction site, and

not all of them are locals, they dine at the nearest dining hall during the break.

308. There is a concrete plant in the business yard (the area of the business yard is 7 ha)

(Figures 51, 52) owned by the Construction Contractor. Under the legislation of Armenia, the

operation of a concrete plant needs no EIA document to develop. There is also office buildings,

crushing plant and oil station located within the territory (Figures 53, 54).

Figures 51 and 52: Concrete Plant within the territory of business yard



92

Figure 53: Crushing Plant Figure 54: Crushing Plant

309. There is also a fueling station for the construction techniques on the territory of the

business yard. The station is not located over the concrete pillow and it seems that no

secondary container is used during the fueling operations (Figure 55, 56). Consequently, there

are spilt fuel spots seen in the area.

Figure 55: Fueling Station Figure 56: Construction Techniques Park

310. The Construction Company owns a sand quarry, which is located in the riverbed. There is

the proper license issued to the quarry allowing the company to mine the sand only for some

months during the year. As for the rest of the year, as the license states, the quarry is filled in

with the inert material transported by the river, i.e. in a natural way (Figures 57 and 58).



93

Figures 57, 58: Sand Borrow Pits

A.3) Site Inspection

311. During the audit, the water-supply pipes were being replaced on the construction site. The

construction activities were accomplished along the areas under strong anthropogenic impact

(Figures 59 and 60). The soil excavated from the trenches was placed in the adjacent area.

The soil was disposed by meeting the relevant requirements. This soil is used to fill in the

trenches and the excess soil is placed in the areas specially designated under the agreement

with the local authority as inert waste.

Figures 59, 60: Site Inspection

312. The water-supply pipes were also being replaced and wells were being installed in the

streets of the city of Vedi. The construction soil was fenced with relevant tapes and proper

warning signs were in place (Figures 61, 62). There were design works accomplished in the city

streets.



94

Figures 61, 62: Design works accomplished in the city streets

313. The connection of the water-supply pipes to the houses was accomplished within the

scope of the project, and the relevant trenches were filled in with the soil (Figures 63, 64).

Laying new asphalt over the road sections damaged due to the project is planned in the near

future.

Figures 63, 64: Trenches filled with soil

A.4) Noise and Dust

314. Following the methods of the project realization, the ground works on one site are

accomplished for at most two weeks. Consequently, the impact with dust and noise following

the construction activities is short.



95

B) Improvement of Water Supply Systems in Hrazdan Town, Qaghsi Village

315. In April 2014, a meeting with the representative of the Construction Contractor was held at

the construction site (Figures 65, 66).

Figures 65, 66: Meeting at construction site

316. As already mentioned, the construction activities within the scope of all sub-projects were

accomplished along short sections (50-150 m). The methods to replace the water-supply pipes

by the Construction Contractor in the city of Hrazdan were the same as in any other cases.

There was a trench of an approximately 150 m length with the pipes being laid in it (Figures 67,

68).

Figures 67, 68: Construction Site

317. There was no topsoil in the project area, where the trenches were excavated.

Consequently, the excavated soil is being placed along the trenches. The soil placed



96

temporarily is used to fill in the trenches. As the photos show, the construction site is fenced

with warning tapes and the workers are duly equipped.

B.1) Business Yard

318. The business yard of the Construction Contractor is located in the former industrial area in

the city. This area was under impact for years. There is a park for the construction techniques

(Figure 69), fueling station (Figure 70) and storage area and area for temporal storage of waste

on the said territory (Figures 71, 72).

Figure 69: Construction Techniques Park Figure 70: Fueling Station

Figure 71: Storage Area Figure 72: Waste Disposal Area

319. Like with other sub-projects, the major problem in this sub-project is the absence of the

relevant documents evidenced as follows: (a) the environmental specialist of the Construction

Contractor fails to accomplish daily monitoring and has no checklists accordingly, (b) there is no



97

book of complaints on the construction site, and (c) the monthly environmental reports are

drafted by the PIU environmental specialist instead of the environmental specialist of the

Construction Contractor.

C) Improvement of Water Supply Systems in Metsavan, Sarchapet and lernahovit Villages

and Reconstruction of Hovdra External Water Main

320. The meeting with the Construction Contractor’s team was held at the construction object. The length of the construction object did not exceed 100 m this time, too (Figures 73, 74).

Figures 73, 74: Meeting with Construction Contractor

321. The methods of construction were identical to those with the two former sub-projects. The

soil gained during the excavation of trenches is disposed in the adjacent area and used to fill in

the trenches after the pipes were laid in the trenches. Any excess ground was placed in the

areas specially designated by the local authority. The relevant agreement is available on the

construction site.

C.1) Business Yard

322. The business yard of the Construction Contractor is located in the former industrial area in

the city. The Construction Contractor uses the mentioned territory for temporary disposal of

construction materials, construction techniques and non-hazardous waste (Figures 75, 76, 77,

78).



98

Figures 75, 76: Business Yard

Figures 77, 78: Business Yard

323. Like with the two former subprojects, the major problem in this sub-project is the absence

of the relevant environmental documents leading to the absence of the environmental specialist

with the relevant qualification at the Construction Contractor.

4.5 Main Findings Revaled during the Documents Review and Site Visits

324. Based on the projects documents review and conducted site visits the Consultant (Audit


I. The Loan Agreement envisages the obligation of the authority of the Republic of

Armenia to realize the project in line with the ADB safeguard policies and requirements

of the environmental legislation of Armenia;

II. The Contract concluded with the Construction Contractor (Particular Conditions of the

Contract) does not show the obligation of the Contractor to accomplish the mitigation



99

measures and monitoring plan under EIA/IEE and EMP, as well as the sanctions

envisaged by the given document for the failure to meet the environmental requirements;

III. None of the documents drafted within the scope of the project contains a requirement for

the Construction Contractor to hire an environmental specialist. Consequently, the

majority of the construction companies within the scope of the 14 sub-projects have no

environmental specialists;

IV. For each sub-project, the environmental specialist of the Consulting Company has

developed an EMP document based on the detailed design, which is enclosed to the

contract concluded with the Construction Contractor as an annex;

V. Within the scope of all three projects, which were audited, the Construction Contractor,

despite the requirements in place, fails to accomplish the daily environmental monitoring

envisaged by EMP;

VI. The only qualified environmental specialist engaged in the project permanently

undertaking the environmental monitoring within the scope of all 14 projects, is the

environmental specialist of the Consulting Company. If considering that at the given

stage, the construction works within the scope of the project are being accomplished in

about 50 m from the settled area, one environmental specialist is not sufficient indeed to

conduct a thorough environmental monitoring. Even more so when the number of sub-

projects will reach 120 as the project is fully launched;

VII. The Framework Initial Environmental Examination Report of every sub-project contains

the requirement for providing the trainings in the field of environmental protection to the

Construction Contractor. The said requirement is not met within the scope of any of the

sub-projects;

VIII. The EMP developed for every project contains the form of the book of complaints as an

annex. Despite this, no book of complaints was found at any of the construction sites

audited;

IX. Within the scope of all projects, there are agreements for disposal of the inert waste

concluded with the local authorities. There is also an agreement about the supply of the

construction materials concluded with the licensed quarries. Only one Construction

Contractor owns a borrow pit and concrete plant;

X. All construction sites look clean and are duly fenced. The workers wore relevant

uniforms (PPE). Within the scope of all three sub-projects audited, no violations of the

environmental requirements during the construction were fixed;

XI. As a conclusion, the Consultant may say that the major environmental problems within

the scope of Water Supply and Sanitation Sector Project are associated with the lack

of the environmental specialists of the companies engaged in the said project. There are

only two qualified environmental specialists actively engaged in the development and

realization of 110 sub-projects.



100

4.6 Non-Compliances and Recommendations

325. Along with the above-mentioned findings the Consultant fixed the following general non-

compliances and made the following recommendations:

Non-Compliances:

I. Neither of the Construction Companies have an environmental specialist on staff.

Consequently, within the scope of any project, no daily inspections are conducted and

no relevant records are made by the employees of the Construction Contractor;

II. The Consultant/Supervising Company has not provided any training related with the

environmental issues.

Recommendations:

I. The Construction Contractor shall hire an environmental specialist within the basic staff,

or some Company employee shall be charged with the duties of an environmental

specialist. The Construction Contractor shall have a designated person, who will be

officially responsible for the environmental issues;

II. When developing the Bidding Documents for the Construction Contractor within the

scope of the following sub-projects, the document (chapter “Personnel” in particular) shall contain the requirement for the Contractor to hire a qualified environmental

specialist on staff;

III. Armenia Water Sewerage Company shall hire at least two more environmental

specialists;

IV. After the loan agreement is approved, PIU and/or the environmental specialist of the

consultant company shall be engaged in all following phases of the project

implementation (drafting the project detailed design, developing and assessing the

tender bids, concluding the agreement with the construction contractor);

V. The Supervision Consulting Company shall develop the module of environmental

trainings, as well as schedule of trainings and should start organizing the trainings

without delay;



Table 15.



101




concluded within the scope

of the project, PAM, IEE,

bidding proposal, contract

and other relevant

documents must give the


in greater details.

ADB - gives the







IEE/EIA.



EIA.

2. Construction Contractor shall

have environmental


Consultant Contractor:

Includes in bidding

document requirement for

the Contractor to hire a

qualified environmental


During the preparation stage

of the bidding documents for

the next sub-projects.

3. Armenia Water Sewerage

Company shall hire at least

two more environmental

specialists.

PIU - Armenia Water

Sewerage Company:

Announces tender for hiring

of two additional

environmental experts

within the PIU under the

project.



Audit Report.



102

APPENDIXES:

Appendix 1. Environmental Safeguards Compliance Monitoring Checklist for the

Construction/Rehabilitation of Arshakunyats Street Project

Country safeguard review

Country : Armenia

Audit Date :

Project Data

Project Name:

Project Progress (%) : 100%

Environmental Safeguards Categorization A B C

X

Overall Status of Compliance

Not compliant – Remedial action

& monitoring required

X

Mostly compliant - Minor

remedial action & monitoring

required

Fully compliant

A. Safeguards Loan/Grant Covenants

Item No. Covenant Status of Compliance



103

B. Environmental Management Planning (Preconstruction)

Item Status4

(Y/N)

Follow up

required

(Y/N)

Comments/Actions required

Environment Unit (EU) established

within Project Implementation Unit

(PIU )

Y Y An Environmental and Social

Safeguards Unit was established within

Project Implementation Unit.

Environmental recording system

established in EU

Y Y Environmental issues reported

regularly in the monthly reports by the

Contractor and to be commented on by

the environmental specialist.

In addition, PIU Ecologist conducts

monthly visits to the construction site

for seeing whether it is complied with

the requirements on environment

protection. The survey is conducted

with the station ecologist with PIU.

Baseline monitoring completed Y N Within the framework of EIA, which

was prepared in June-July 2009,

baseline environmental monitoring was

conducted.

EMP design requirements included

in design brief. (Evidence that EU

has checked design brief in this

regard)

Y N EMP design requirements included in

design brief. There is no evidence that

ES has checked design brief in this

regard.

EMP requirements included in

tender documents

Y N An EIA and EPM documents were

attached to the tender documentation

as an annex. The obligation of the

contractor to meet the requirements of

the document as well as contractor’s reporting responsibility are given in

part B of the tender documentation-

„Specific Provisions“.

4 Documentary evidence of each item to be maintained in EU’s environmental recording system and made available

for audit.



104

Part of the tender documentation “Bill of Quantities” does not give thorough

budget necessary to meet the

environmental requirements under the

EIA document

EU involvement in bid evaluation Y N Project Implementing Unit (PIU)

environmental specialist is not involved

in the bids evaluation process. Besides

that, under the mentioned project an

environmental specialist was included

in the bid evaluation committee. The

mentioned specialist had been invited

from - American University of Armenia.

Contractor’s SEMP(s) reviewed and approved by PIU prior to

contractor commencing work.

Y Y SEMP document developed, needs

further elaboration and update.

C. Construction Environmental Management Compliance (to be completed as relevant)

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required

Monitoring data as per EMP monitoring

plan requirements.5

Y Y The continuous monitoring of the SEMP implementation was carried out.

Unanticipated environmental impacts

identified and assessed and options to

address them evaluated.

N Y Unanticipated environmental

impacts are not identified.

Significant EHS incidents reported. N Y Cases of serious violations

of environmental

requirements were not

found.

EMP reviewed and updated Y Y EMP is reviewed and

updated (see

5 To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”



105

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required

recommendations).

Site inspection records ( Mitigation

Compliance & Inspection Monitoring

Forms)

Y Y The Contractor’s field inspectors performed daily

site visits to the project sites.

YM Environmental team

visited on project sites

minimum once a weak.

Environmental Consultant

performed weakly site

inspections.

Site inspection non-compliance

notifications and corrective action requests.

Y Y No one noncompliance fixed

yet.

Complaints log. Y Y There is Compliance Books

on sites

Environmental safeguard compliance

included in project progress reports

Y Y Contractors prepare monthly

reports, which contain

monitoring form on

implementation of EMP in

project.

Training/Capacity building activities

undertaken as per EMP requirements.

(Training records)

N Y Required trainings are not

conducted yet

Overall current status of project

EMP/SEMP implementation

(All mitigation measures identified in

approved SEMP(s) to be itemized and

evaluated as per implementation status)

Y Y Contractors prepare monthly

reports, which contain

monitoring form on

implementation of EMP in

project.

Six monthly Environmental Monitoring

Reports submitted to ADB and posted on

ADB website

Y Y Bi-Annual Reports, which

YM submits to the ADB, they

are available on the ADB

web-site.



106

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required

Monitoring reports disclosed to local

communities and relevant government

agencies6

N Y All the above-listed reports

are available both, on the

construction site and at the

head office YM. As for the

Bi-Annual Reports, which

YM submits to the ADB,

they are available on the

ADB web-site.

Final post construction Audit Report

completed

N Y Project is under

development activities.

6 Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general

perception of project impacts



107

Appendix 2: Environmental Safeguards Compliance Monitoring Checklist For North–South Road Corridor Investment Program


Country : Armenia

Audit Date :

Project Data

Project Name: North–South Road Corridor Investment Program

Project Progress (%): 40%


X




X



required

Fully compliant

D. Safeguards Loan/Grant Covenants


schedule 5,

clause 2

Implementation of environmental requirements

included in the IEE.

Yes



108

E. Environmental Management Planning (Preconstruction)

Item Status7

(Y/N)

Follow up

required

(Y/N)




(PIU )

N Y Within PMU the Environmental Unit (EU) was established.


established in EU

Y Y The system of the environmental

activity documentation was established

in PMU. Engineering Consultant

prepares the monthly environmentall

reports for PMU on the project

progress, containing information on the


implementation. Documentation is also

maintained on the results of the

monitoring carried out by the PMU

M&E Specialist and submitted in form

of internal memo to the Project

Manager, after that the relevant actions

are taken against Contractors, if

necessary.

Baseline monitoring completed Y Y The basic monitoring of environmental

conditions was accomplished. Such

requirements had been included in the

EIA documents and it was

responsibility of constructor company.




regard)




regard.


tender documents

Y N The requirements of EMP observance

were included in the bidding

documents, the EMP itself was

included in the bidding documents as

7 Documentary evidence of each item to be maintained in EU’s environmental recording system and made available

for audit.



109

the Annex 1.

EU involvement in bid evaluation N Y There is no ecologist in the bidding

board composition.

Contractor’s SEMP(s) reviewed

and approved by PIU prior to


Y Y The contractor has submitted updated

EMP, which now includes the issues

identified in the project detailed design.

SEMP was prepared by Construction

Contractor.

F. Construction Environmental Management Compliance (to be completed as relevant)

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required


plan requirements.8

Y Y Analyzes required by IEE

are done by Construction

Contractor.






Significant EHS incidents reported. N Y There are no records.

EMP reviewed and updated Y Y The contractor has

submitted updated EMP,

which now includes the

issues identified in the

project detailed design.



Forms)

Y Y 7. There is quite a detailed questionnaires developed, which are used during the weekly inspections. There are relevant filled-in questionnaires on the construction site.

8 To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”



110

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required



Y Y 8. Any fixed non-compliance is officially registered and the contractor develops relevant corrective actions. All non-compliances and realized corrective actions are shown in the monthly reports.

9. Complaints log. Y Y Complaints book is placed at

construction site.



N Y The contractor drafts the

monthly reports about the

environmental issues on

their own.



(Training records)

Y Y 10. The trainings are held permanently and there are relevant records.


EMP/SEMP implementation

(All mitigation measures identified in

approved SEMP(s) to be itemized and

evaluated as per implementation status)

Y/N Y 11. There are some problems with placing the inert materials and topsoil. In all other fields, all developed mitigation measures are undertaken.



ADB website

Y Y 12. Semi-annual reports are permanently submitted to the bank and they are available on the ADB web-site.



agencies9

Y Y 13. The environmental specialists of all organizations engaged in the project actively cooperate with the local population. In this respect, the actions accomplished within the scope of the project can be considered as a good example not only for

9 Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general

perception of project impacts



111

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required

Armenia, but for other countries as well.


completed

N Y The final environmental

audits have not been

accomplished.



112

APPENDIXES:

Appendix 3. Environmental Safeguards Compliance Monitoring Checklist For Water

Supply and Sanitation Sector Project


Country : Armenia

Audit Date :

Project Data

Project Name: Water Supply and Sanitation Sector Project


X




X



required

Fully compliant

A. Safeguards Loan/Grant Covenants


schedule 5,

clause 2

Implementation of environmental

requirements included in the IEE.

Yes



113

B. Environmental Management Planning (Preconstruction)

Item Status10

(Y/N)

Follow up

required

(Y/N)




(PIU )

Y Y One environmental specialist was hired within the PMU under the Project.


established in EU

Y/N Y The system of the environmental

activity documentation was established

in PMU. In fact, there are no records

about the environmental problems

developed by the Construction

Contractor. Documentation maintained on the

results of the monitoring carried out by

the PMU M&E Specialist and

submitted in form of internal memo to

the Project Manager, after that the

relevant actions are taken against

Contractors, if necessary.

Baseline monitoring completed Y Y According to the Framework Initial

Environmental Examination Report

prepared under the Project: “No new

baseline monitoring is required”

(Clouse VIII – “Framework Environmental Management Plan”).




regard)




regard.


tender documents

Y N The requirements of EMP observance

were included in the bidding

documents, the EMP itself was

included in the bidding documents and

contract.

10

Documentary evidence of each item to be maintained in EU’s environmental recording system and made available for audit.



114

EU involvement in bid evaluation N Y There is no ecologist in the bidding

board composition.

Contractor’s SEMP(s) reviewed and approved by PIU prior to


Y Y The PIU has submitted updated EMP,

which now includes the issues

identified in the project detailed design.

C. Construction Environmental Management Compliance (to be completed as relevant)

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required


plan requirements.11

N Y Under the monitoring plan of

EMP, the responsibility for

organizing the monitoring is

the obligation of the

Construction Contractor. The

Construction Contractor

does not organize

environmental monitoring.

The environmental

monitoring is done by the

PIU environmental specialist

instead.






Significant EHS incidents reported. N Y There are no records.

EMP reviewed and updated Y Y The environmental specialist

of PIU has submitted

updated EMP, which now

includes the issues identified

in the project detailed

design.



Forms)

N Y Quite detailed checklists are

prepared. The mentioned

checklists are the part of the

Contract. Anyway,

11

To be recorded in appropriate format as per “Tools and Templates for EMP Supervision”



115

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required

Construction Contractor

does not use the mentioned

checklists. The mentioned

checklists are used by the

environmental specialist of

PIU.



Y Y Non-compliance is fixed

officially and corrective

actions are elaborated.

All non-compliances and

implemented corrective

actions are included in

monthly environmental

reports.

Complaints log. N Y The Complaints Book is not

kept at construction site.



Y Y Construction Contractor

does not prepare monthly

environmental monitoring

reports. The mentioned

reports are prepared by the

environmental specialist of

PIU.



(Training records)

N Y None of the trainings were

conducted.


EMP/SEMP implementation (All mitigation

measures identified in approved SEMP(s)

to be itemized and evaluated as per

implementation status)

Y/N Y The majority of mitigation

measures are implemented.



ADB website

Y Y Bi-annual reports are

submitted to the ADB

permanently. They can be

find at ADB web-site.



116

Item Status

(Y/N)

Follow up

required (Y/N)

Comments/Actions

required



agencies12

N Y Dissemination of monitoring

results among local

population is not

implemented.


completed

N Y The final environmental

audits have not been

accomplished.

12

Auditor to consult with project affected people (PAPs) to get their feedback on the monitoring report or general perception of project impacts