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Medium-Voltage Sub-Transmission Expansion Sector Project (RRP CAM 42361)

Draft Environmental Assessment Review Framework

The views expressed herein are those of the consultant and do not necessarily represent those of ADB’s members, Board of Directors, Management, or staff, and may be preliminary in nature.

Project Number: 42361 September 2012

Kingdom of Cambodia: Medium-Voltage Sub-Transmission Expansion Sector Project

Prepared by: Electricite du Cambodge Royal Government of Cambodia

This environmental assessment review framework is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

Kingdom of Cambodia: Medium-Voltage Sub-transmission Expansion Sector Project Draft Environmental Assessment Review Framework

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Currency Equivalents

(National Bank of Cambodia official exchange rate as of June 2012)

Currency Unit - Riel (KHR) KHR 1.00 = US$ 0.000246 US$ 1.00 = 4,065 KHR

ABBREVIATIONS

ADB Asian Development Bank AP Affected Person APL Angkor Protected Landscape ASEAN Association of Southeast Asian Nations CDM Clean development mechanism CEMP Construction Environmental Management Plan CITES Convention on International Trade in Endangered Species CMAA Cambodian Mine Action and Victim Assistance Authority EA Executing Agency EAC Electricity Authority of Cambodia EARF Environmental Assessment Review Framework EDC Electricité du Cambodge EIA Environmental Impact Assessment EMP Environmental Management Plan EMoP Environmental Monitoring Plan FGD Focus Group Discussion GMS Greater Mekong Sub-region GNI Gross National Income GRM Grievance Redress Mechanism IA Implementing Agency IEE Initial Environmental Examination IEIA Initial Environmental Impact Assessment LAB Lead Acid Battery MAPU Mine Action Planning Unit MEF Ministry of Economy and Finance MIME Ministry of Mines and Energy MOE Ministry of Environment OFID OPEC Fund for International Development PCB polychlorinated biphenyl PIC Project Implementation Consultant PPA Power Purchase Agreement REA Rapid Environmental Assessment REE Rural Electrification Enterprise RGC Royal Government of Cambodia RP Resettlement Plan SEDP Socio-economic Development Plan


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The views expressed herein are those of the consultant and do not necessarily represent those of ADB’s members, Board of Directors, Management, or staff, and may be preliminary in nature.

SEPRO

Social, Environmental and Public Relations Office, EDC

SPS Safeguard Policy Statement (of ADB, June 2009) TSBR Tonle Sap Biosphere Reserve ULAB Used Lead Acid Battery UXO Unexploded Ordinance

ELECTRICAL TERMINOLOGY

V (Volt) Unit of voltage kV (kilovolt) 1,000 volts kVA (kilovolt-ampere) 1,000 VA MVA (Megavolt-ampere) 1,000 kVA High Voltage (HV) Voltage level exceeding 35 kV Medium Voltage (MV) Voltage level exceeding 0.6 kV and less than 35 kV Low Voltage (LV) Voltage level less than 0.6 kV HV Transmission System 500 kV (Planned), 230 kV, 115 kV lines MV Sub-transmission System 22 kV lines supplying distribution substations LV Distribution 400/230 V distribution and service lines Grid Substation Substation with primary voltage of 230 kV or 115 kV Distribution Substation Substation with primary voltage of 22 kV and secondary voltage of 400/230 V cct.km circuit kilometers


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CONTENTS

I. INTRODUCTION 1

A. Project Overview 1

B. Purpose of the Environmental Assessment and Review Framework 1

II. DESCRIPTION OF SUB-PROJECTS 1

III. LEGAL FRAMEWORK AND INSTITUTIONAL CAPACITY 10

A. Legal and Institutional Framework of Cambodia 10

B. EDC Capacity Assessment 15

IV. ENVIRONMENTAL ASSESSMENT PROCESS 15

A. Screening and Categorization – Defined Subprojects 15

B. Screening and Categorization –Subprojects Developed During Implementation 16

C. Anticipated Environmental Impacts 17

D. Preparation of Subproject Environmental Assessments 18

E. Ministry of Environment Approval 19

F. Mine and UXO Clearance 19

G. Revision of Subproject Environmental Assessment during Construction 20

V. INFORMATION DISCLOSURE CONSULTATION AND PARTICIPATION 21

A. Consultation Activities Undertaken 21

B. Additional Planned Disclosure and Consultation Activities 21

VI. GRIEVANCE REDRESS MECHANISM 22

A. Introduction 22

B. Type of Grievances 22

C. Grievance Resolution Process 22

D. Grievance Follow-up 24

E. Confidentiality and Anonymity 24

VII. INSTITUTIONAL ARRANGEMENTS AND RESPONSIBILITIES 26

A. Project Implementation Arrangements 26

B. Environmental Assessment Preparation 26

C. Support to EDC 26

VIII. MONITORING AND REPORTING 27

A. Environmental Monitoring 27

B. Reporting 27

APPENDICES 28

APPENDIX 1: RAPID ENVIRONMENTAL ASSESSMENT (REA) CHECKLIST

APPENDIX 2: ENVIRONMENTAL ASSESSMENT OUTLINE


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APPENDIX 3: MINE/UXO MAPS AND CLEARING COST ESTIMATE

CAM: Rural Electrification Project Initial Environmental Examination Report

I. INTRODUCTION

A. Project Overview

1. The project will contribute to increasing access to grid-electricity in Cambodia. The outcome of the project is expanded supply of reliable and cost-effective grid-electricity in Kampong Thom, Kampong Cham, Siem Reap, Kandal and Banteay Meanchey province. The project has three components: (1) Expanded Medium Voltage Sub-Transmission Network; (2) Project Implementation Support; and (3) Improved Operational Effectiveness and Efficiency of EDC. This document relates primarily to components 1 and 2 above. The project is being implemented using a sector approach.

B. Purpose of the Environmental Assessment and Review Framework

2. An Initial Environmental Examination (IEE) has been prepared for the three core sub-projects in Kampong Thom, Kampong Cham and Siem Reap province that have been fully appraised under the project. The preparation of IEEs for additional sub-projects in Kandal and Banteay Meanchey province will be guided by the Environmental Assessment and Review Framework (EARF).

II. DESCRIPTION OF SUB-PROJECTS

1. Project Scope and Location

3. The 22 kV sub-transmission lines will be connected from grid-substations in provincial towns to the existing and new low-voltage distribution and service lines owned and operated by private rural electricity enterprises (REEs). 4. EDC will own, operate and maintain the 22 kV lines installed under the project. The ownership and the responsibility for operating and managing the low-voltage distribution network will remain with the respective REEs and EDC will supply electricity to REEs under a Power Purchase Agreement (PPA). 5. The project will finance the construction of 2,110 kilometer (km) of new 3 phase 22 kV overhead sub-transmission lines including short lengths of 22 kV underground cable, the installation of 22 kV/0.4 kV distribution transformers, advanced electronic metering for all distribution transformers, auto reclosing circuit breakers and automatic voltage regulators to improve reliability and voltage performance.

6. The following three subprojects have been fully appraised:

i) Subproject 1: 625 circuit-kilometer (cct-km) in Kampong Thom Province

ii) Subproject 2: 184 cct-km in Kampong Cham Province

iii) Subproject 3: 866 cct-km in Siem Reap Province

7. The following subprojects will be fully appraised during implementation:

i) Subproject 4: 263 cct-km in Kandal Province

ii) Subproject 5: 173 cc-km in Banteay Meanchey Province


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2. Technical Components

8. The technical components of the sub-transmission lines include:

Up to 2,110 km of concrete pole mounted single circuit (3 phase) sub-transmission lines (all five subprojects).

Concrete poles stand approximately 10 m high and are spaced approximately 60 m apart (Figures 2.6 and 2.7).

22/0.4 kV transformers will be mounted on poles at appropriate locations.

Cross arms and insulators on poles to support 3 phase conductors.

3. Construction Activities

9. All sub-transmission lines will be installed along the road reserve of existing national, provincial or commune roads. Road reserve requirements for various road categories are described in Section II.B.4.

10. Construction activities will be confined to small-scale works involving transporting poles to the road side, erection of poles, stringing of conductors and erection of pole mounted transformers where required. These sequential activities will be primarily manual activities involving small teams with minimal use of mechanical equipment. No excavation will be required other than auguring holes for the pole footings. Some trimming of roadside trees may be required to ensure appropriate safety clearances for the power lines.


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Figure 1.1: Sector Project Components


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Figure 2.1: Proposed 22 kV Sub-transmission Alignment in Kampong Thom and Kampong Cham Provinces, Subproject 1 and 2


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Figure 2.2: Proposed 22 kV Sub-transmission Alignment in Siem Reap Province, Subproject 3


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Figure 2.3: Tentative 22 kV Alignment in Banteay Meanchey Province, Subproject 5


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Figure 2.4: Tentative 22 kV Alignment in Kandal Province, Subproject 4


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Figure 2.5: Cross-section of 22 kV sub-transmission line

Figure 2.6: Typical sub-transmission line pole with transformer, constructed under the World Bank-funded Rural Electrification and Transmission Project (RETP) in 2005


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11. Poles will be sequentially placed along the verge of road corridors prior to hole auguring and erection using a truck mounted crane. Other construction materials, equipment and transformers will be stored at EDC’s depots and transported to the construction site as required.

12. Worker requirements are modest. At any one time at each work site during construction there will be a maximum of up to six people, and it is anticipated that there will no more than two work teams per subproject. Access to the sites is very good, and there will be no worker camps.

4. Safety Clearances

13. Minimum safety clearances for the construction and maintenance of MV and LV lines are defined in the Electricity Authority of Cambodia (EAC) General Requirements and are summarized in Table 2.1. These clearances will be strictly maintained.

Table 2.1: MV and LV Clearances

Location Minimum Clearance (meters)

MV LV

Clearances above ground,

Across roads

Across railway tracks

Along roads

Other places

8.0 8.0

6.5

6.5 6.5 5.5 5.0

Bare Covered Insulated

MV LV MV LV MV LV

Clearances to buildings,

Vertically

Where a person may climb

Horizontally

3.0 3.0 3.0

Bare

conductor not

permitted

2.5 1.5 1.5

2.0 1.2 1.2

1.2 0.5 0.5

1.0 1.4 0.4

Clearance to trees and vegetation 2.0 No contact

No contact

No contact

No contact

No contact

Source: General Requirements of Electric Power Technical Standards of the Kingdom of Cambodia, Issued by the Ministry of Industry, Mine and Energy in Accordance with the Electricity Law of the Kingdom of Cambodia (2004, amended 2007).

5. Operational Activities

14. During operation periodic (annual) maintenance and checking will be undertaken by provincial EDC technical staff. This will involve one or two people for very short (hours) periods of time. Under normal operating conditions such activities will not require the use of powered mechanical equipment other than a transport vehicle to the site.


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III. LEGAL FRAMEWORK AND INSTITUTIONAL CAPACITY

A. Legal and Institutional Framework of Cambodia

15. Key environmental related laws of Cambodia relevant to the Project are summarized below.

1. Environment Law

16. The Law on Environmental Protection and Natural Resources Management (No: NS/RKM/1296/36) was enacted in 1996 and is the main law for protection of the environment in Cambodia. Article 6 of the law requires that environmental impact assessment (EIA) be undertaken for proposed projects with the Ministry of Environment designated as the authority to review EIAs prior to submission to the Government for approval.

17. The Sub-Decree on Environmental Impact Assessment Process (Sub- Decree 72, 11 August 1999) supports the Law on Environmental Protection and Natural Resources and sets out institutional responsibilities, impact assessment requirements and the procedures for undertaking the environmental assessment process. The annex to the sub-decree lists all projects (public or private) for which environmental assessment is required. Sub-transmission, transmission and rural electrification projects are not included in the list of projects requiring environmental assessment.

18. However, the Protected Area Law (No. NS/RKM/0208/007) of in 2008 requires that environmental and social impact assessment is required for all proposals and investments for development within or adjacent to a protected area boundary where a protected area is defined as: i) national parks; ii) wildlife sanctuaries; iii) protected landscapes; iv) multiple use areas; v) Ramsar sites; vi) biosphere reserves; vii) natural heritage sites; and viii) marine parks.

19. Some sub-transmission lines proposed under this Project traverse the Angkor Protected Landscape (APL) and the transition zone of the Tonle Sap Biosphere Reserve (TSBR), and it is within this legal context that EDC is required to undertake an environmental impact assessment. Other than for the proposed alignments in these areas, EDC is legally exempt from undertaking any type of environmental assessment for the rural electrification Project.

20. The RGC environmental assessment process is illustrated in Figure 2.7. The Project owner must conduct an Initial Environmental Impact Assessment (IEIA – equivalent to an ADB IEE)) and apply to MoE for review of the IEIA report. This includes payment of a fee to cover costs of the review and a contribution to the Environmental Endowment Fund of the Law on Environmental Protection and Natural Resources (the fees are not specified). EDC intends to submit this IEE report, with a summary translated into Khmer, to MoE for review and forwards a copy to the project approval Ministry (Ministry of Industry Mines and Energy). In the case of the Project where the potential impacts will be minimal, submission of an IEIA (or IEE equivalent) is anticipated to be sufficient to obtain RGC approval without the need for undertaking a separate EIA. However, based on current regulations, 22 kV sub-transmission lines do not require submission of an IEIA nor clearance from the Ministry of Environment.

21. Sub Decree No. 72 11 August 1999 specifies that findings and recommendations on the IEIA (IEE) will be provided within 30 work days from the date of receipt of the report otherwise the report will be deemed to have complied with the Decree.


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22. Public consultation is required as part of the RGC IEIA and EIA requirements and is equivalent in nature and scope to that of the ADB.

Figure 2.7: EIA Process in Cambodia

2. Other Regulations with Environmental Implications for Rural Electrification

23. Sub-transmission lines of and associated low voltage lines are typically aligned along the edge of existing roads and within the specified road reserve. Prime Ministerial Edict, 27 September 1999, entitled Measures to Eliminate Anarchical Land Grabbing, declares public land on the verge of roads and railways that must not be occupied as follows:

National road 2, 3, 6 and 7: 25 m from center line.

National road 1, 4, 5: 30 m from center line.

National road 11, 22, 64, 78: 25 m from center line.

Provincial roads: 20 m from center line.

Commune roads: 15 m from center line.

Not applicable in towns.


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Railways 20 m from center line in urban areas, 30 m in rural areas, 100 m where there is threat of avalanche or in old growth forest.

24. This legislation has implications in that the alignment of sub-transmission lines proposed under this Project will be located within what is essentially the legally designated road reserve. From an environmental perspective the road reserve can be regarded as a brown field site.

3. National and Regional Environmental Policies and Plans

25. The Kingdom of Cambodia has a number of national environmental policies and plans, including the National Environmental Action Plan 1998-2002. This plan addresses six key environmental areas, including energy development, although energy transmission is not discussed.

26. Cambodia is a member of the Greater Mekong Sub-Region (GMS) program, which promotes closer economic ties and cooperation among the six countries that share the Mekong River. A strategic thrust of the program is to ―protect the environment and promote sustainable use of shared natural resource‖.

27. The second socioeconomic development plan 2001-2005 (SEDP II) prepared by the RGC is the key plan for reducing poverty in Cambodia. It includes the aims of equitable distribution of income at the national level and sustainable utilization of natural resource and environmental protection.

4. Electric Power Technical Standards

28. Relevant Cambodian electric power standards include:

General Requirements of Electric Power Technical Standards of the Kingdom of Cambodia, Issued by the Ministry of Industry, Mine and Energy in Accordance with the Electricity Law of the Kingdom of Cambodia (2004, amended 2007). The standards were prepared with support from JICA.

Specific Requirements of Electric Power Technical Standards of the Kingdom of Cambodia, Issued by the Ministry of Industry, Mine and Energy in Accordance with the Electricity Law of the Kingdom of Cambodia (2007).

29. Relevant EDC electric power standards include:

Design Standards, Distribution Networks, Electricite du Cambodge, 2007.

5. Heritage Legislation

a. APSARA Authority

30. APSARA, the Authority for the Protection and Management of Angkor and the Region of Siem Reap (hereafter referred to as the APSARA Authority), was established in 1995. It is in charge of research, protection and conservation of cultural heritage of the Angkor Protected Landscape (APL), as well as urban and tourist development. In December of 1995 the World Heritage Committee confirmed Angkor's permanent inscription on the List of World Heritage Sites in Danger.


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31. There are several royal decrees related to the establishment and authority of the APSARA Authority and the protection of the cultural heritage of Angkor:

Royal Decree NS/RKT/0295/12 establishing a National Authority for the Protection and Management of Angkor and the Region of Siem Reap, named APSARA (1995, amended in 1998 by Decree NS/RKT/0199/18).1

Royal Decree 001/NS establishing Protected Cultural Zones in the Siem Reap/Angkor Region and Guidelines for their Management.2 - The decree establishes management zones within Siem Reap (Zone 1:

Monumental Sites; Zone 2: Protected Archaeological Reserves; Zone 3: Protected Cultural Landscapes; Zone 4: Sites of Archaeological, Anthropological or Historic Interest; and Zone 5: The socio-economic and cultural development zone of the Siem Reap/Angkor Region). These zones are further described in Chapter IV.

- Article 20 states that ―for all protected cultural resorts of the Angkor Protected Landscape (Zone 1, 2, 3, 4, 5), installation of power grids with high voltage is prohibited but installation of electric power grids with medium voltage supplied by the local distributors is permitted on the condition that they are not highly visible.‖

32. There are also decree establishing the Koh Ke site and transferring it to the APSARA Authority, and sub-decrees with regards to policing, hotel zoning and regulations, and entrance fees.

b. The Heritage Law

33. The primary legislation of Cambodia pertaining to cultural heritage is the 1996 Law on the Protection of Cultural Heritage (NS/RKM/0196/26).3 Both the looting and the export of antiquities without a permit are criminalized. Section 7 of the law also includes procedures for chance discoveries of cultural property during construction.

6. International Conventions and Agreements

34. Cambodia is signatory to a number of international conventions and agreements.

a. Convention on Biological Diversity (CBD, 1995)

35. The United Nations convention on Biological Diversity was ratified by Kingdom of Cambodia in 1995. The three objectives of this convention are to conserve biodiversity; to sustainably use biological resources; and to fairly and equitably share the benefits resulting from the use of genetic resources. In accordance with its responsibilities under this convention the Government has prepared the National Biodiversity Strategy and Action Plan (2002) that sets out an Implementation Strategy.

1 See http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree1.html and

http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree2_text.html for English translations. 2 See http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree3_text.html for an English

translation. 3 See http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree4_text.html for an English

translation.

http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree1.html

http://www.autoriteapsara.org/en/apsara/about_apsara/legal_texts/decree2_text.html




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b. Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar, 1975)

36. Cambodia become a party to the Convention on Wetlands of International Importance in 1999, formally listing three Ramsar sites in the north, center and south-west of the country, with plans to consider further sites.

c. ASEAN agreement on the Conservation of Nature and Natural Resources (1985),

37. Cambodia signed the ASEAN Agreement on the Conservation of Nature and Natural Resources in 1985, committing itself to maintaining essential ecological processes, preserving genetic diversity and ensuring sustainable natural resource use.

38. Other international environmental agreements for which Cambodia is a signatory include:

United Nations Framework Convention on Climate Change;

Kyoto Protocol;

Vienna Convention on the Protection of the Ozone Layer;

International Trade in Endangered Species of Wild Flora and Fauna (CITES);

Desertification;

Marine Life Conservation;

Hazardous Wastes;

Ship Pollution;

Tropical Timber 94; and,

Whaling.

d. International Conventions Protecting Cultural Heritage

39. International cultural heritage protection conventions for which Cambodia is a signatory include:

The Convention for the Protection of Cultural Property in the Event of Armed Conflict, The Hague, 1954 and its Protocol, ratified by Cambodia in 1962;

The Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property, Paris, 1970, ratified by Cambodia in 1972;

The Convention concerning the Protection of the World Cultural and Natural Heritage (World Heritage Convention, Paris 1972), ratified by Cambodia in 1991; and

The UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects, ratified by Cambodia in 2002.


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B. EDC Capacity Assessment

40. EDC’s Social, Environment and Public Relations Unit (SEPRU) currently comprises seven staff including:

Chief – Electrical Engineer.

Two deputy chiefs – one electrical engineer and one civil engineer.

Four staff – two environment specialists and two resettlement specialists.

41. SEPRU was established in 2003 and at the time comprised of two persons, a director and a deputy director. One new staff member per year was recruited in 2008 to 2010 and two new staff recruited in 2011.

42. Over the years SEPRU has received training in environment and social/resettlement issues through various workshops ( 2-5 days) provided by MOE for line ministries and funded through donor projects. Key agencies providing the training have included ADB, World Bank JICA and Sida, the Swedish aid agency. Topics have included environmental and social safeguards policies and requirements of the main donors, EIA methodologies, climate change issues, CDM, PCB’s and general environmental pollution management. As a result of being involved in a number of donor funded energy projects SEPRU is well acquainted with environmental safeguards planning, implementation and monitoring.

43. The main function of SEPRU is to monitor the implementation of safeguard requirements for donor projects according to their respective EMPs, and to ensure compliance with MOE’s policies and requirements. This involves:

organizing and undertaking stakeholder consultations and information disclosure with assistance from project consultants;

ensuring compensation payments are made; and,

resolving any public grievances.

44. SEPRU works closely with implementation consultants to ensure contractual compliance with environmental and social mitigation requirements. Staff resources at SEPRU are sufficient for the current workload and are being continually reviewed and adjusted according to need. SEPRO plans to recruit two more staff over the next year.

45. In light of the above it is considered that EDC has sufficient in-house capacity to implement relevant national environmental laws and meet the safeguard requirements of the ADB. Nonetheless, the Project Implementation Consultant environmental specialists (international and national) will support and backstop the EDC, as described in Chapter VIII.

IV. ENVIRONMENTAL ASSESSMENT PROCESS

A. Screening and Categorization – Defined Subprojects

46. Subprojects in Kampong Thom, Kampong Cham and Siem Reap province have been classified as ADB Environment Category B, requiring the preparation of an Initial Environmental Examination (IEE) report in accordance with the ADB’s Safeguard Policy Statement (SPS). An IEE has been prepared.


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B. Screening and Categorization –Subprojects Developed During Implementation

47. The following process will apply to Subproject 4 and 5 and any other subprojects that may be proposed during implementation.

48. Environmental screening and categorization will be conducted by the PIC environmental consultants in conjunction with the EDC SEPRO, utilizing the REA Checklist presented in Appendix 1. The PIC will make an environmental categorization recommendation, but the official categorization will be undertaken by ADB. The subproject will be assigned to one of the following categories:

i) Category A. Proposed project is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented; impacts may affect an area larger than the sites or facilities subject to physical works. A full-scale environmental impact assessment (EIA) including an environmental management plan (EMP), is required.

ii) Category B. Proposed project’s potential environmental impacts are less adverse and fewer in number than those of category A projects; impacts are site-specific, few if any of them are irreversible, and impacts can be readily addressed through mitigation measures. An initial environmental examination (IEE), including an EMP, is required.

iii) Category C. Proposed project is likely to have minimal or no adverse environmental impacts. No EIA or IEE is required although environmental implications need to be reviewed.

iv) Category FI. Proposed project involves the investment of ADB funds to, or through, a financial intermediary.

49. The subproject’s category will be determined by its most environmentally sensitive component. If the subproject is found to contain activities in the prohibited investment list (Table 5.1) the subproject will be disallowed.

Table 5.1: ADB Prohibited Investment Activities List

The following do not qualify for Asian Development Bank financing:

(i) production or activities involving harmful or exploitative forms of forced labor4 or child

labor;5

(ii) production of or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements or subject to international phase outs or bans, such as (a) pharmaceuticals,

6 pesticides, and herbicides,

7 (b) ozone-

4 Forced labor means all work or services not voluntarily performed, that is, extracted from individuals under threat of

force or penalty. 5 Child labor means the employment of children whose age is below the host country’s statutory minimum age of

employment or employment of children in contravention of International Labor Organization Convention No. 138 ―Minimum Age Convention‖ (www.ilo.org).

6 A list of pharmaceutical products subject to phaseouts or bans is available at http://www.who.int.

7 A list of pesticides and herbicides subject to phaseouts or bans is available at http://www.pic.int.


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depleting substances,8 (c) polychlorinated biphenyls

9 and other hazardous chemicals,

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(d) wildlife or wildlife products regulated under the Convention on International Trade in Endangered Species of Wild Fauna and Flora,

11 and (e) transboundary trade in waste or

waste products;12

(iii) production of or trade in weapons and munitions, including paramilitary materials;

(iv) production of or trade in alcoholic beverages, excluding beer and wine;13

(v) production of or trade in tobacco;

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(vi) gambling, casinos, and equivalent enterprises;10

(vii) production of or trade in radioactive materials,

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components thereof; (viii) production of, trade in, or use of unbonded asbestos fibers;

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(ix) commercial logging operations or the purchase of logging equipment for use in primary tropical moist forests or old-growth forests; and

(x) marine and coastal fishing practices, such as large-scale pelagic drift net fishing and fine mesh net fishing, harmful to vulnerable and protected species in large numbers and damaging to marine biodiversity and habitats.

C. Anticipated Environmental Impacts

50. Based on the IEE undertaken for Subproject Subproject 1 (Kampong Thom province ), Subproject 2 (Kampong Cham province), and Subproject 3 (Siem Reap province), it is anticipated that subprojects will generate insignificant negative environmental impacts due to the following:

MV (22 kV) sub-transmission lines will be sited along existing road corridors and within existing road reserves - no access roads or transmission line right of way is required;

the scope of construction activities is limited involving small teams of workers, minimal use of powered mechanical equipment and extremely limited excavation;

there will be no significant land acquisition and resettlement impacts; no physical relocation will be required, and there will only be limited acquisition of livelihood trees and, possibly, very limited acquisition of private land;

no workers camps will be required;

8 A list of the chemical compounds that react with and deplete stratospheric ozone resulting in the widely publicized

ozone holes is listed in the Montreal Protocol, together with target reduction and phaseout dates. Information is available at http://www.unep.org/ozone/montreal.shtml.

9 A group of highly toxic chemicals, polychlorinated biphenyls are likely to be found in oil-filled electrical

transformers, capacitors, and switchgear dating from 1950 to 1985. 10

A list of hazardous chemicals is available at http://www.pic.int. 11

A list is available at http://www.cites.org. 12

As defined by the Basel Convention; see http://www.basel.int. 13

This does not apply to project sponsors who are not substantially involved in these activities. Not substantially involved means that the activity concerned is ancillary to a project sponsor's primary operations.

14 This does not apply to the purchase of medical equipment, quality control (measurement) equipment, and any equipment for which ADB considers the radioactive source to be trivial and adequately shielded.

15 This does not apply to the purchase and use of bonded asbestos cement sheeting where the asbestos content is less than 20%.


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mapping has been undertaken to assess the extent of mine and UXO contamination in the Project area, removal costs have been estimated, and clearance procedures developed;

recycling of used lead acid batteries (ULABs) will be encouraged;

no significant natural habitats will be affected due to the location of MV sub transmission lines along existing road reserves outside of nationally protected areas with biodiversity significance (national parks and wildlife sanctuaries);

impacts within the Angkor Protected Landscape (APL) will be insignificant due to minimal incursions along existing roads at the periphery of the APL, the small scale of construction activities, and implementation of APSARA Authority specified mitigation measures; and,

maintenance during operation will be limited to trimming of vegetation to maintain safety clearances and occasional technical maintenance to ensure safety of lines and pole-mounted transformers.

51. For subprojects that have not yet been defined this should be considered a preliminary assessment only, however, to be further refined during the subproject environmental assessment.

D. Preparation of Subproject Environmental Assessments

52. As noted above, an IEE covering subprojects 1, 2, and 3 was prepared in compliance with Appendix 1 (Safeguard Requirements 1: Environment) of ADB's SPS (2009). The following process will apply to all subprojects developed during Project implementation.

53. The PIC environmental specialists, in cooperation with SEPRU, will liaise with ADB to determine the specific requirements for the environmental assessment of the proposed subproject. The conduct of the environmental assessment shall be consistent with Appendix 1 (Safeguard Requirements 1: Environment) of ADB's SPS (2009).

54. Appendix 1 of SPS outlines the requirements that borrowers/clients should meet when delivering environmental safeguards for projects supported by ADB. It discusses the objectives and scope of application, and underscores the requirements for undertaking the environmental assessment process. The document also includes particular environmental safeguard requirements pertaining to pollution prevention and abatement, occupational and community health and safety, and conservation of physical cultural resources. It also outlines specific environmental criteria to be used for subproject roads selection, for example, exclusion from negative lists for procurement or environmentally sensitive areas unless specific requirements in the SPS 2009 are met.

55. The environmental assessment report will include an EMP detailing the following: (i) mitigation measures for all identified adverse impacts during pre-construction, construction stages of the or subproject roads, (ii) monitoring measures to assess environmental performance and impacts to ambient environment, and (iii) implementation arrangements including responsibilities and schedule.

56. The environmental assessment will follow the outline provided in Appendix 2 of this EARF, which is specified in ADB's SPS 2009. In addition, the IEE prepared for Subprojects 1, 2, and 3 will be a model for the preparation of the Subproject 4 and 5 assessments.


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57. The environmental assessment will be prepared by the PIC environmental specialists, in close cooperation with EDC’s SEPRU. The draft environmental assessment will be submitted to ADB, and will be revised based on feedback received. The environmental assessment will be officially submitted by the EDC to ADB, and will form a document of the borrower.

E. Ministry of Environment Approval

58. The PIC environmental specialists will consult the Ministry of Environment (MoE) to determine whether the subproject requires an environmental assessment under the Law on Environmental Protection and Natural Resources Management (No: NS/RKM/1296/36) and the Sub-Decree on Environmental Impact Assessment Process (Sub- Decree 72, 11 August 1999). If an assessment is required, it is understood that EDC will submit the ADB assessment report, with a summary translated into Khmer, to MoE for review and forward a copy to the project approval Ministry (Ministry of Industry Mines and Energy), though this will need to be confirmed in consultation with EDC and the MoE. The current Cambodian environmental regulation does not require an environmental assessment report for 22 kV sub-transmission lines.

F. Mine and UXO Clearance

59. In Cambodia there is still risk of encountering land mines and UXO during construction in some areas, the result of a protracted sequence of internal and regional conflicts that affected the country from the mid 1960s until the end of 1998. The nature of landmine and UXO contamination is highly complex; the north-western regions bordering Thailand are heavily affected, while other parts of the country (mainly the East) are considered moderate to low impact, affected mainly by UXO. Mines and UXO have caused a high number of both military and civilian casualties, and have hindered national development.

60. To mitigate the risks posed by mines and UXO, mapping was undertaken to assess the extent of mine and UXO contamination in the Project area, removal costs were estimated, and clearance procedures were developed. The process is presented in Appendix 3 and is summarized below.

61. The Cambodian Mine Action and Victim Assistance Authority (CMAA) has the responsibility to regulate, coordinate and monitor mine action activities throughout Cambodia. The CMAA was requested to identify known mine and unexploded ordinance (UXO) within two Project area zones:

- 100 m either side of the 22 kV distribution lines (e.g. 200 m wide zone in total), this being the maximum area that construction activities might reasonably take place;

- 1000 m either side of the 22 kV distribution lines (e.g. 2000 m wide zone in total), this being a safety zone to take into account any errors that might occur from using different data mapping sources.

62. The contamination maps were produced based on the current contamination polygons contained within the CMAA database, and are presented in Figures 1 to 5, Appendix 3. An area of 353.8 ha has been identified as being mine or UXO contaminated for Subprojects 1, 2, and 3 (Table 1, Appendix 3). Based on costs associated with contamination removal for similar projects, CMAA estimates that clearance cost at $850,000 for Subproject 4 and 5. This estimate is based on known mine/UXO contamination only, and further ground truthing will be required prior to mine/UXO clearance to better determine the extent of contamination and cost of clearance.


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63. Mine/UXO removal will be the responsibility of the installation contractor, though they will not undertake the clearance themselves – they will contract an accredited mine/UXO removal agency in each province, with the process being guided by the Mine Action Planning Unit (MAPU) at the Provincial Hall.16 All clearance works should be completed and appropriate documentation submitted to the installation contractor and EDC before any MV sub-transmission line installation works start.

64. Please see Appendix 3 for additional information on UXO/mine mapping and clearance.

G. Revision of Subproject Environmental Assessment during Construction

65. During the construction works, if unexpected impacts arise subproject environmental assessments will be reviewed by the PIC environmental specialists and the EMP will be updated in response to any new assumptions on construction and operational issues or any unpredicted impacts.

16 There is no MAPU in Kandal Province. The CMAA will directly coordinate the development of the clearance plan,

provincial approval and identification of an accredited demining operator.


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V. INFORMATION DISCLOSURE CONSULTATION AND PARTICIPATION

A. Consultation Activities Undertaken

66. As part of the project preparation process a household survey was conducted. The survey covered 500 households in 20 villages (25 households per village) in Kampong Thom and Siem Reap provinces. The household survey was complemented by 12 focus group discussions (FGDs) conducted in a sub-sample of six villages.

B. Additional Planned Disclosure and Consultation Activities

67. The above noted surveys were important for ensuring that the Project will have the maximum socio-economic benefit; however, limited Project and environment related information was made available during the survey process, and EDC will conduct additional consultation and disclosure activities during the Project construction and operation phases.

1. Environmental Assessment Disclosure

68. Subproject environmental assessment reports will be disclosed on the ADB website (www.adb.org ). A Khmer summary will also be posted on the EDC website (www.edc.com.kh), along with either the full report or a link to the full report on the ADB website. A Khmer summary of the report will be made available in hard form at the EDC Provincial Offices.

2. Consultation and Outreach

69. EDC will carry out a consultation and outreach programme during Project construction and operation (all three subprojects):

Newspaper advertisements in local Khmer newspapers in all Project provinces will provide Project related information, including contact points, how to access the IEE report, and information on the Grievance Redress Mechanism (GRM). Advertisements will be in Khmer.

Road side signs in all construction areas will provide the same information as above. As this is a linear Project, signs will be moved as needed as construction progresses. Signs will be in Khmer.

Similar information will also be conveyed by EDC to affected commune councils in Khmer pamphlets.

During the operation phase EDC will also provide information on lead acid battery (LAB) recycling, including the environmental and economic benefits of recycling, and contact information for the most environmentally progressive recycling companies in each province (this information will be collected by the PIC environmental specialists and made available through the REEs who will in turn make it available at the household level).

EDC will also deliver electricity safety awareness in Project communities during the operation phase where there has hitherto been little experience of living with grid based electricity.

http://www.adb.org/

http://www.edc.com.kh/


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VI. GRIEVANCE REDRESS MECHANISM

A. Introduction

70. A project grievance can be defined as an actual or perceived Project related problem that gives ground for complaint by an affected person (AP). As a general policy, EDC will work proactively toward preventing grievances through the implementation of impact mitigation measures and community liaison activities that anticipate and address potential issues before they become grievances. This will be the responsibility of EDC’s Social, Environment and Public Relations Unit (SEPRU). Nonetheless, during construction and operation it is possible that unanticipated impacts may occur if the mitigation measures are not properly implemented, or unforeseen issues occur. In order to address complaints if or when they arise, a Project grievance redress mechanism (GRM) has been developed in accordance with ADB requirements and Government practices. A GRM is a systematic process for receiving, evaluating and addressing AP’s Project-related grievances

B. Type of Grievances

71. Any AP will be able to submit a grievance with EDC if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. Grievances could include:

Negative impacts on a person or a community (e.g. financial loss such as from loss of roadside trees, health and safety issues, nuisances, etc.).

Dangers to health and safety or the environment.

Social impacts due to construction team activities or impacts on social infrastructure.

Failure to comply with standards or legal obligations.

Harassment of any nature.

Criminal activity.

Improper conduct or unethical behavior.

Financial malpractice or impropriety or fraud.

Attempts to conceal any of the above.

72. The GRM will be made public throughout the public consultation process, and will be maintained during operation and maintenance.

C. Grievance Resolution Process

73. The GRM consists of 5 steps, and is presented in Figure 6.1. Each step is explained below.


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Step 1: EDC Social, Environment and Public Relations Office (SEPRU)

Grievances will initially be addressed by the EDC SEPRU. Grievances can be submitted through various means, including through the contractors, the Project Implementation Consultant (PIC), provincial EDC Offices, or via the local Commune Committee. In all cases the grievance will be recorded in writing and then forwarded to SEPRU.

Upon receipt by the SEPRU, the grievance will be recorded, reviewed and assessed for eligibility. If determined that a grievance is not connected to a Project activity or that the Project is being carried out in full compliance with applicable national and international standards, SEPRU will so explain in writing to the complainant. In all other cases SEPRU will investigate, assess the validity of the grievance, and in consultation with the contractor and PIC, seek measures to redress valid grievances and prevent such incidents occurring again.

SEPRU will have 15 days to resolve the grievance and respond to the complainant in writing, including disclosing the results of the investigation and the proposed course of action, if any. Depending on the nature of the complaint the course of action will be implemented by the contractor or EDC. If the complainant considers the issue to be satisfactorily resolved, they will be asked to sign a Statement of Satisfaction. If the grievance remains unresolved SEPRU will advance the grievance to the relevant Commune Council.

Step 2: Commune Council

The Commune Council will record the grievance, further investigate the grievance, and in consultation with SEPRU attempt to reach a resolution agreeable to both the complainant and SEPRU. The Commune Council will have 15 days to resolve the grievance and respond to the complainant and SEPRU in writing, including disclosing the results of the investigation and the proposed course of action, if any. Depending on the nature of the complaint the course of action will be implemented by the contractor or EDC. If the complainant considers the issue to be satisfactorily resolved, they will be asked to sign a Statement of Satisfaction. If the grievance remains unresolved the Commune Council will advance the grievance to the relevant District Committee.

Step 3: District Office

The District Office will record the grievance, further investigate the grievance, and in consultation SEPRU attempt to reach a resolution agreeable to both the AP and SEPRO. The District Office will have 15 days to resolve the grievance and respond to the complainant and SEPRU in writing, including disclosing the results of the investigation and the proposed course of action, if any. Depending on the nature of the complaint the course of action will be implemented by the contractor or EDC. If the complainant considers the issue to be satisfactorily resolved, they will be asked to sign a Statement of Satisfaction. If the grievance remains unresolved the District Office will advance the grievance to the relevant Provincial Hall.

Step 4: Provincial Hall

The Provincial Hall will record the grievance, further investigate the grievance, and in consultation with SEPRU attempt to reach a resolution agreeable to both the AP and SEPRU. The Provincial Hall will have 30 days to resolve the grievance and respond to


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the complainant and SEPRU in writing, including disclosing the results of the investigation and the proposed course of action, if any. Depending on the nature of the complaint the course of action will be implemented by the contractor or EDC. If the complainant considers the issue to be satisfactorily resolved, they will be asked to sign a Statement of Satisfaction. If the grievance remains unresolved the AP will have the option of advancing the grievance to the judicial process.

Step 5: Judicial Process or ADB Accountability Mechanism

The AP may advance the grievance to the Provincial Court. If the AP is not satisfied with the Provincial Court judgment, there may be an opportunity for appealing to a higher level of court. The AP may also choose to approach ADB under the Accountability Mechanism.

D. Grievance Follow-up

74. EDC may contact the complainant at a later stage to ensure that the activities continue to pose no further problems. If there is a remaining problem, the issue will be treated as a new grievance and re-enter the process.

E. Confidentiality and Anonymity

75. An AP submitting a grievance may wish to raise a concern in confidence. If the complainant asks SEPRU to protect his or her identity, it will not be disclosed without consent. Details of submissions and allegations will remain secure within the team responsible for investigating the concerns.


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Figure 6.1: Grievance Redress Mechanism (GRM)

Affected Person

Grievance

1. EDC SEPRU

Not Redressed

3. District Office

4. Provincial Hall

5a. Appeal to Provincial Court

5b. Appeal under ADB’s Accountability Mechanism

1

Redressed

2. Commune Council

Not Redressed

Redressed

Not Redressed

Redressed

Not Redressed

Redressed

1 The ADB Accountability Mechanism provides a forum where people adversely affected by ADB-

assisted projects can voice and seek solutions to their problems and report alleged noncompliance of ADB's operational policies and procedures. It consists of two separate but complementary functions: consultation phase and compliance review phase. For more information see: http://beta.adb.org/site/accountability-mechanism/main

http://beta.adb.org/site/accountability-mechanism/main


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VII. INSTITUTIONAL ARRANGEMENTS AND RESPONSIBILITIES

A. Project Implementation Arrangements

76. The Electricite du Cambodge (EDC) will be the project executing agency (EA) and will have overall responsibility for implementation. The implementing agency (IA) will be EDC, Project Management Office 1. EDC will be supported by a Project Implementation Consultants (PIC).

B. Environmental Assessment Preparation

77. Environmental assessments were undertaken for subprojects 1, 2, and 3. Environmental assessments for Subproject 4 and 5 and any other subprojects defined during implementation will be prepared by the PIC environmental specialists, in close cooperation with EDC’s SEPRU. The draft environmental assessments will be submitted to ADB, and will be revised based on feedback received. The environmental assessment will be officially submitted by the EDC to ADB, and will form a document of the borrower.

C. Support to EDC

78. The PIC will complement existing EDC staff, and will include international and national environmental specialists. With respect to environmental safeguards, as noted in Chapter III, it is generally considered that EDC has sufficient in-house capacity to implement relevant national environmental laws and meet the safeguard requirements of the ADB. Nonetheless, the PIC environmental specialists (international and national) will support and backstop the EDC, including but not limited to:

reviewing bidding documents to ensure EMP requirements have been included;

undertake a design audit to check that all APSARA Authority stipulations have been addressed for Project components within the APL;

establishing environmental monitoring and reporting procedures that are in accordance with ADB requirements;

undertaking environmental compliance monitoring;

providing a brief refresher training to SEPRU on EMP implementation including ADB monitoring and reporting requirements; and

assisting in the preparation of periodic monitoring reports.


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VIII. MONITORING AND REPORTING

A. Environmental Monitoring

79. The subproject environmental assessments will include an Environmental Monitoring Plan (EMoP) including:

monitoring tasks to ensure mitigation measures have been implemented effectively during each Project stage;

schedule and responsibility for monitoring; and,

monitoring costs.17

80. Environmental monitoring will consist of routine systematic checking that the above mitigation measures have been implemented effectively during each stage of the Project. The PIC Environmental Specialists, with support from EDC’s Social, Environment and Public Relations Office (SEPRO) will monitor the implementation status of the EMP, including identifying any non-compliance, proposing actions and a timeline for rectifying deficiencies and following up on the status of previous non-compliances.

B. Reporting

81. Throughout the construction period the PIC Environmental Specialists in consultation with SEPRU will prepare quarterly environmental monitoring report for compilation and inclusion in progress reports submitted to ADB and MoE. The reports will include a summary of the results of site inspections and will focus on key issues of concern that need to be resolved.

17 These are already included in the Subproject 1 and 2 IEEs.


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APPENDICES



APPENDIX 3: MINE/UXO MAPS AND CLEARING COST ESTIMATE


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Instructions:

(i) The project team completes this checklist to support the environmental classification of a project. It is to be attached to the environmental categorization form and submitted to the Environment and Safeguards Division (RSES) for endorsement by the Director, RSES and for approval by the Chief Compliance Officer.

(ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions are adequately considered, refer also to ADB's (a) checklists on involuntary resettlement and Indigenous Peoples; (b) poverty reduction handbook; (c) staff guide to consultation and participation; and (d) gender checklists.

(iii) Answer the questions assuming the ―without mitigation‖ case. The purpose is to identify potential impacts. Use the ―remarks‖ section to discuss any anticipated mitigation measures.

Country/Project Title:

Sector Division:

SCREENING QUESTIONS Yes No REMARKS

A. Project Siting

- Is the Project area adjacent to or within any of the following environmentally sensitive areas?

- Note: If project area is adjacent to any of the sensitive areas below, please indicate the minimum distance (km) from the project area boundary


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- Cultural heritage site

- Protected Area

- Wetland -

- Mangrove -

- Estuarine -

- Buffer zone of protected area -

- Special area for protecting biodiversity -

B. Potential Environmental Impacts

- Will the Project cause…

- Encroachment on historical, cultural areas or archeologically significant areas?

- encroachment into precious ecosystem (e.g. sensitive habitats like protected forest areas or terrestrial wildlife habitats?

- deterioration of surface water quality due to silt runoff, and sanitary wastes from construction workers ?

- short-term soil erosion and silt runoff due to construction?

- increased local air pollution due to construction activities?

- chemical pollution resulting from use of herbicides for clearing of vegetation during construction and maintenance?

- possible use of PCBs (transformers or capacitors)

- noise and vibration from construction activities?


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- Tree removal or pruning?

- dislocation or involuntary resettlement of people

- changes in land use, loss of productive land?

- public exposure to electromagnetic fields?

- aesthetic degradation and property value loss?


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A typical environmental assessment report contains the following major elements. The substantive aspects of this outline will guide the preparation of the report, although not necessarily in the order shown.

A. Executive Summary This section describes concisely the critical facts, significant findings, and recommended actions.

B. Policy, Legal, and Administrative Framework This section discusses the national and local legal and institutional framework within which the environmental assessment is carried out. It also identifies project-relevant international environmental agreements to which the country is a party.

C. Description of the Project This section describes the proposed project; its major components; and its geographic, ecological, social, and temporal context, including any associated facility required by and for the project (for example, access roads, power plants, water supply, quarries and borrow pits, and spoil disposal). It normally includes drawings and maps showing the project’s layout and components, the project site, and the project's area of influence.

D. Description of the Environment (Baseline Data) This section describes relevant physical, biological, and socioeconomic conditions within the study area. It also looks at current and proposed development activities within the project's area of influence, including those not directly connected to the project. It indicates the accuracy, reliability, and sources of the data.

E. Anticipated Environmental Impacts and Mitigation Measures This section predicts and assesses the project's likely positive and negative direct and indirect impacts to physical, biological, socioeconomic (including occupational health and safety, community health and safety, vulnerable groups and gender issues, and impacts on livelihoods through environmental media [Appendix 2, para. 6]), and physical cultural resources in the project's area of influence, in quantitative terms to the extent possible; identifies mitigation measures and any residual negative impacts that cannot be mitigated; explores opportunities for enhancement; identifies and estimates the extent and quality of available data, key data gaps, and uncertainties associated with predictions and specifies topics that do not require further attention; and examines global, transboundary, and cumulative impacts as appropriate.

F. Analysis of Alternatives This section examines alternatives to the proposed project site, technology, design, and operation—including the no project alternative—in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and monitoring requirements. It also states the basis for selecting the particular project design proposed and, justifies recommended emission levels and approaches to pollution prevention and abatement.


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G. Information Disclosure, Consultation, and Participation This section:

(i) describes the process undertaken during project design and preparation for engaging stakeholders, including information disclosure and consultation with affected people and other stakeholders;

(ii) summarizes comments and concerns received from affected people and other stakeholders and how these comments have been addressed in project design and mitigation measures, with special attention paid to the needs and concerns of vulnerable groups, including women, the poor, and Indigenous Peoples; and

(iii) describes the planned information disclosure measures (including the type of information to be disseminated and the method of dissemination) and the process for carrying out consultation with affected people and facilitating their participation during project implementation.

H. Grievance Redress Mechanism This section describes the grievance redress framework (both informal and formal channels), setting out the time frame and mechanisms for resolving complaints about environmental performance.

I. Environmental Management Plan This section deals with the set of mitigation and management measures to be taken during project implementation to avoid, reduce, mitigate, or compensate for adverse environmental impacts (in that order of priority). It may include multiple management plans and actions. It includes the following key components (with the level of detail commensurate with the project’s impacts and risks):

(i) Mitigation:

(a) identifies and summarizes anticipated significant adverse environmental impacts and risks;

(b) describes each mitigation measure with technical details, including the type of impact to which it relates and the conditions under which it is required (for instance, continuously or in the event of contingencies), together with designs, equipment descriptions, and operating procedures, as appropriate; and

(c) provides links to any other mitigation plans (for example, for involuntary resettlement, Indigenous Peoples, or emergency response) required for the project.

(ii) Monitoring:

(a) describes monitoring measures with technical details, including parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits and definition of thresholds that will signal the need for corrective actions; and


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(b) describes monitoring and reporting procedures to ensure early detection of conditions that necessitate particular mitigation measures and document the progress and results of mitigation.

(iii) Implementation arrangements:

(a) specifies the implementation schedule showing phasing and coordination with overall project implementation;

(b) describes institutional or organizational arrangements, namely, who is responsible for carrying out the mitigation and monitoring measures, which may include one or more of the following additional topics to strengthen environmental management capability: technical assistance programs, training programs, procurement of equipment and supplies related to environmental management and monitoring, and organizational changes; and

(c) estimates capital and recurrent costs and describes sources of funds for implementing the environmental management plan.

(iv) Performance indicators: describes the desired outcomes as measurable events to the extent possible, such as performance indicators, targets, or acceptance criteria that can be tracked over defined time periods.

J. Conclusion and Recommendations This section provides the conclusions drawn from the assessment and provides recommendations.


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APPENDIX 3: SUBPROJECT MINE/UXO MAPS AND CLEARANCE PROCESS

Introduction Cambodia’s landmine problem is the result of a protracted sequence of internal and regional conflicts that affected the country from the mid 1960s until the end of 1998. The nature of landmine and unexploded ordinance (UXO) contamination in Cambodia is highly complex. The north-western regions bordering Thailand are heavily affected, while other parts of the country (mainly the East) are considered moderate to low impact, affected mainly by UXO. Mines and UXO have caused a high number of both military and civilian casualties, and have hindered national development. Mine clearance started along the Cambodia-Vietnam border by the Cambodian People’s Revolutionary Army in 1979 with thousands of hectares (ha) of land cleared and thousands of mines/UXO destroyed to provide safe resettlement and agricultural land, despite the lack of substantial financial, technical and modern equipment support. The inception of official humanitarian mine clearance in Cambodia dates back to 1992. Mine risk education (MRE) started in 1993 focusing on providing mine and UXO awareness messages to returnees and internally displaced persons settling in affected areas when the armed conflicts had ended. Cambodia has achieved major progresses from 1992 to 2009. Some 52,918 ha of mined affected land have been cleared nation-wide for housing, farming and other infrastructures and 860,159 anti-personnel mines, 19,952 anti-tank mines and 1,907,621 explosive remnants of war have been destroyed. The number of casualties has been reduced from 4,320 in 1996 to 244 in 2009. The Cambodian Mine Action and Victim Assistance Authority (CMAA) has the responsibility for regulating, coordinating and monitoring mine action activities throughout Cambodia. It was established in September 2000 by the RGC, and is chaired by Prime Minister Hun Sen.18 Project UXO Mapping Project UXO mapping was undertaken to assess the extent of mine and UXO contamination in the Project area. The CMAA was requested to identify known mine and unexploded ordinance (UXO) within two Project area zones: - 100 m either side of the 22 kV distribution lines (e.g. 200 m wide zone in total), this being

the maximum area that construction activities might reasonably take place; - 1000 m either side of the 22 kV distribution lines (e.g. 2000 m wide zone in total), this being

a safety zone to take into account any errors that might occur from using different data mapping sources.

The contamination maps were produced based on the current contamination polygons contained within the CMAA database, and for Subproject 3 are presented in Figures 1 to 3. It should be emphasised that the maps are based on known mine and UXO contamination only,

18 Source: National Mine Action Strategy 2010-2019, Royal Government of Cambodia, 2010.


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and are indicative in nature. Further ground truthing will be required prior to mine and UXO clearance to better determine the extent of contamination.


37

Figure 1: Known Mine and UXO Areas in Relation to Proposed MV Sub-transmission Lines, Oddar Meanchey Province, Subproject 6. Source: CMAA, 2012


38

Figure 2: Known Mine and UXO Areas in Relation to Proposed MV Sub-transmission Lines, Banteay Meanchey Province, Subproject 5. Source: CMAA, 2012


39

Figure 3: Known Mine and UXO Areas in Relation to Proposed MV Sub-transmission Lines, Kandal Province, Subproject 4. Source: CMAA, 2012


40

Project Mine/UXO Clearance Based on the CMAA mapping results, an area of 353.8 ha has been identified as being mine or UXO contaminated within a 200 m wide zone centred on the MV alignments for Subprojects 1 and 2 (Table 1). Based on costs associated with contamination removal for similar projects, CMAA estimates that clearance will cost a total of 1.06 million USD for the two subprojects. This estimate is based on known mine and UXO contamination only, and further ground truthing will be required prior to mine and UXO clearance to better determine the extent of contamination and cost of clearance in each province.

Table 1: Known Mine/UXO Contamination and Estimated Costs for Removal, by Province and Subproject

No. Province / Subproject

Affected Area (m2) within

a 200 m wide zone centred on the MV

Alignment

Estimated Removal Cost (USD)

1 Siem Reap / Subproject 3 1,564,813

469,443.90

2

Kampong Cham and Kampong Thom / Subproject 1 and 2

1,973,738

592,121.40

Subtotal Subproject 1, 2, and 3 3,538,551 1,061,565.30

3 Oddar Meanchey / Subproject 6 131,148

39,344.40

4 Banteay Meanchey / Subproject 5 26,493

7,947.90

5 Kandal / Subproject 4 692,803

207,840.90

Subtotal Subproject 4, 5, 6 850,444 255,133.20

Project Total

4,388,995

1,316,699.50

Source: CMAA, 2012.

Mine/UXO removal will be the responsibility of the installation contractor, though they will not undertake the clearance themselves – they will contract an accredited mine/UXO removal agency in each province. CMAA has summarised the process, which varies by Province, as follows:

For Kampong Thom (Subproject 1), Siem Reap (Subproject 3) and Banteay Meanchey (Subproject 5), Oddar Meanchey (Subproject 6) provinces:

- The installation contractor will contact the Mine Action Planning Unit (MAPU) at the Provincial Hall in each province and provide detailed alignment maps and the CMAA mine/UXO contamination maps. The respective MAPUs will assist in the development of a clearance work plan in each province.

- The plan for mine/UXO clearance must be approved by the provincial authority. The respective MAPUs will coordinate this.


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- The respective MAPUs will advise as to the next steps, including contacting accredited demining operators for field investigations, refining clearance costs, and preparing clearance contracts. Where more than accredited operator exists, contracts for clearance of affected areas may be put out to tender.

- All clearance works should be completed and appropriate documentation submitted to the installation contractor and EDC before any MV sub-transmission line installation works start.

For Kampong Cham Province (Subproject 2): - Further to the points above, there is only one accredited demining

organization operational in Kampong Cham Province, the Cambodia Mine Action Center (CMAC).19

For Kandal Province (Subproject 4): - Installation contractor to contact CMAA as there is no MAPU in Kandal

Province. - The CMAA will directly coordinate the development of the clearance plan,

provincial approval and identification of an accredited demining operator.

19 See http://www.cmac.gov.kh/.

http://www.cmac.gov.kh/

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