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Environmental and Social Action Plan

Big Almaty Ring Road Project

August 2019

www.erm.com

http://www.erm.com/erm/main.nsf/pages/homepage?opendocument

Environmental and Social Action Plan

Big Almaty Ring Road Project

Prepared for

BAKAD Consortium

August 2019

Draft

CONTENTS

1 ABOUT THIS DOCUMENT 1

2 ENVIRONMENTAL AND SOCIAL ACTION PLAN 2

LIST OF ACRONYMS

Acronym Full Form

ADB Asian Development Bank

AO Joint-Stock Company

AoI Area of Influence

BAKAD Big Almaty Ring Road

CHAP Culture Heritage Action Plan

EBRD European Bank for Reconstruction and Development

ESAP Environmental and Social Action Plan

ESIA Environmental and Social Impact Assessment

ESMS Environmental and Social Management System

HSES Health, Safety, Environment and Social

HSMP Health and Safety Management Plan

GIIP Good International Industry Practice

IFC International Finance Corporation

IsDB Islamic Development Bank

ISO International Organization for Standardization

PK Survey mark (100 m station)

PR Performance Requirement

PS Performance Standard

RMF Road Maintenance Facility

RO Rural Okrug

RoW Right of Way

SCMP Supply Chain Management Plan

SEP Stakeholder Engagement Plan

SPS Safeguard Policy Statement

SPV Special Project Vehicle

TMP Traffic Management Plan

WMP Waste Management Plan

ERM EURASIA LTD. ESAP

BAKAD PROJECT AUGUST 2019

1

1 ABOUT THIS DOCUMENT

This document is the Environmental and Social Action Plan (ESAP) for the Big Almaty Ring Road Project (BAKAD Project or the Project). This Plan was prepared by ERM Eurasia Limited (ERM or Consultant) for the consortium of companies that implement the Project and hereinafter referred to as BAKAD Consortium or SPV.

BAKAD Consortium includes the following members: Alsim Alarko Sanayi Tesisleri ve Ticaret A. Ş., Makyol Inşaat Sanayi Turizm ve Ticaret A. Ş., Korea Expressway Corporation and SK Engineering & Construction Co. Ltd.

Project will potentially be funded by a group of international financial institutions, hereinafter collectively referred to as Potential Lenders. The Potential Landers may include: the European Bank for Reconstruction and Development (EBRD), the Asian Development Bank (ADB), the International Finance Corporation (IFC) and the Islamic Development Bank (IsDB).

At all Project stages, SPV will seek to minimize negative impacts of the Project

activities on human health, environment and affected communities, while

maximizing benefits for residents within the Project area of influence (AoI) as

well as for other parties affected by the Project.

ESAP has been developed to provide Project with a tool to collect, arrange and track commitments under the Project Standards1, including mitigation measures resulting from the Environmental and Social Impact Assessment (ESIA) and provided by the Project design (embedded controls).

The ESAP is a ‘living’ document that should reflect any changes in the Project implementation and organization as well as any new incoming Project-related social and environmental data. Therefore, additional mitigation measures as part of this ESAP may be further revised in line with the outcomes of the detailed Project design and upon the completion of the ongoing and potential future studies.

1 Project Standards are Kazakhstan laws, regulations, Lender’s requirements, standards, guidelines and other documents ;

Project Standards are listed in the ESIA report and in environmental and social management plans



2

2 ENVIRONMENTAL AND SOCIAL ACTION PLAN

Environmental and Social Action Plan is set out below in a table format (Table 1).

Actions were grouped according to the relevant topics.

The following parameters are specified in the table for each of the proposed actions:

Project commitments according to Project Standards or benefits (e.g., impact mitigation and management), determining the need for the action;

Corresponding requirements;

Resources, who is expected to implement the action;

Action timeframe;

Performance criteria for the action (for example, the presence of reporting documents, published information, etc.);

Performance status of the action by the time of writing:

o not initiated, due later (an action is scheduled, but the start date or condition has not yet occurred);

o in progress, pending (an action is being implemented);

o performed (closed);

o not performed, overdue (an action is not performed when due);

o excluded (an action has been excluded from the ESAP).



3

Table 1 Environmental and Social Action Plan for the BAKAD Project

# Action Applicable

requirements

Resources.

Responsibilities

Timeframe Performance criteria Performance status

1. Assessment and Management of Environmental and Social Impacts and Issues

1.1 Develop and implement policies on

health & safety (H&S Policy),

environment (Environmental Protection

Policy) and social aspects (Social Policy)

that will also be cascaded to the EPC

contractor and, subsequently, to the O&M

company and their subcontractors. The

Policies, consistent with the principles of

the Potential Lenders’ requirements, will

provide the overarching objectives and

principles that will guide the project to

achieve sound environmental and social

performance and will specify

commitment for compliance with the

applicable laws and regulations.

PR1 EBRD

PS1 IFC

ADB SPS

SPV 30 days prior start of the

construction

Environmental Policy Statement

Social Policy Statement

Environmental,

Social and Health

and Safety Policies

were submitted on

21st June and

reviewed by LTA.

Final version

pending.

1.2 Develop, implement and maintain an

Environmental and Social Management

System (ESMS) for the project. The ESMS

will define roles and responsibilities of

the Consortium and its contractors and

incorporate the necessary policies,

procedures and plans including those

developed during the ESIA process. The

ESMS will include: (a) the E&S policies

aligned with Potential Lenders’

requirements; (b) procedures for

screening, scoping, assessment and

management of environment, health,

PR1 EBRD

PS1 IFC

ADB SPS


construction

Submission of ESMS and relevant

documentation

The principles

regarding ESMS and

OHS are defined,

however some

documents are still

to be finalized



4

# Action Applicable

requirements

Resources.

Responsibilities


safety and social risks and impacts; (c)

stakeholder mapping and engagement

procedures including a community

grievance mechanism; (d) E&S

management organization structure, roles

and responsibilities; (e) requirements and

procedures for environmental and OHS

training of employees and contracted

workers; (f) internal and external

communication procedures; (g)

emergency preparedness and response;

(h) monitoring of E&S and OHS

performance; (i) internal and external

audit requirements; (j) procedures for

management review and for change

management; and (k) contractor

management.

Develop SPV HSES Manual.

1.3 Adopt the organizational structure under

ESMP and assign relevant persons

PR1 EBRD

PS1 IFC

ADB SPS`

SPV

EPC Contractor

30 days prior start of the

construction

The following documentation

reviewed by LTA and approved

by Lenders, as well as approved

by the Project Manager:

Organizational structure;

Assigned personal are

acknowledged with job

descriptions with a clear

specification of the duties and

powers to implement the ESMS

In Progress

Organizational

structure provided

during the site visit

12-13th June.

1.4 Ensure that the EPC contractor develops

and implements a detailed Construction


PR1 EBRD

PS1 IFC

SPV

EPC Contractor

Prior construction

works are commenced

at any Project site

Submission of CESMP including

all the listed documents

In progress



5

# Action Applicable

requirements

Resources.

Responsibilities


Plan (CESMP) that as a minimum will

include: (a) Sediment and Erosion

Control Plan with site specific sediment

and erosion control plans developed; (b)

Surface Water and Groundwater

Management Plan including storm water

management; (c) Waste Management

Plan for Construction; (d) Pollution

Prevention and Control Plan with site

specific pollution prevention and control

plan (water, wastewater, air pollution,

noise and vibration); (e) Road Safety

Management Plan; (f) Traffic and

Transport Management Plan; (g)

Emergency Management and Response

Plan; (h) Quarry EHS Management Plan

(covering air pollution, noise and

vibrations, water, solid waste, and

progressive rehabilitation; (i) Spill

Response Plan; (j) Subcontractor

Management Plan; (k) Community

Health and Safety Management Plan; (l)

Complaints Logging and Response

System; (m) Local Hiring Plan; and (n)

Environmental Monitoring Plan and (o)

Biodiversity management plan to address

all construction phase related impacts

addressed in the ESIA (section 6.6). All

management plans will include the

relevant E&S performance targets,

monitoring and reporting requirements.

(BAKAD RoW,

quarries, access roads)

Twelve out of

expected 27

documents

submitted so far.

Preparation and

review ongoing.



6

# Action Applicable

requirements

Resources.

Responsibilities


1.5 Ensure that the O&M company develops

and implements an Operations ESMP

(OESMP) that at a minimum will include

the all relevant management plans listed

under 1.4.

PR1 EBRD

PS1 IFC

SPV

EPC Contractor

6 months prior to start

operation

Submission of OESMP

Submission of monitoring

program

Not started

1.6 Adopt and update (where appropriate)

environmental and social management

plans (as well as develop additional

plans, procedures, details etc., as

envisaged by MPs). The list of ESMPs

include the following:

Framework Health, Safety,


Plan,

Community Health, Safety and

Security Management Plan,

Construction Camp Environmental

Management Plan,

Construction Environmental

Management Plan,

Cultural Heritage Framework

Management Plan,

Local Employment Plan,

OHS and Labour Management Plan,

Environmental Monitoring Plan,

Supply Chain Management Plan,

Traffic Management Plan,

Waste Management Plan,

PR1 EBRD

PS1 IFC

ADB SPS

GIIP

SPV

Prior to the first

disbursement, however

not later signing

contract with any of the

Subcontractor aimed to

commence construction

works at any Project

sites (BAKAD RoW,


Set of ESMPs, as well as relevant

additional specific plans,

procedures, details adopted by the

Consortium and cascaded to EPC

and all subcontractors

In progress

SPV prepared and

submitted relevant

management plans.

Relevant EPC

management plans

are still under

preparation.



7

# Action Applicable

requirements

Resources.

Responsibilities


Spill Response Plan

1.7 Obtain all necessary permits and

approvals from authorities

PR1 EBRD

PS1 IFC

ADB SPS

National legislation

EPC Throughout the Project Design approval

Permit for construction

Permit for quarry development

Permits for water use

Permits for water discharge

Permits for waste management on

site

Working permits

Permits for emissions for plants

In progress

Design approved for

sections 4 and 8b

1.8 Develop and adopt Emergency

Preparedness and Response Plan

PR4 EBRD

PS1 IFC

PS4 IFC

ADB SPS


SPV

EPC Contractor in

collaboration with

local Emergency

Services

Subcontractors

Prior to the first


not later than

commencement of

construction works at

any Project sites

(BAKAD RoW,


Emergency Preparedness and

Response Plan

In progress

1.9 Appoint an independent competent road safety auditor to undertake a Road Safety Audit in line with EU Directive 2008/906/EC on completion of final design and at key stages as indicated in the Directive.

Following RSA include the economically viable safety improvements into the design by mutual agreement with the Lenders.

A road safety inspection shall be carried out on road prior to opening once

PR1 EBRD

PS1 IFC

ADB SPS

GIIP

SPV As detected by the

schedule of the Road

Safety Audits

RSA reports Not initiated



8

# Action Applicable

requirements

Resources.

Responsibilities


operational, to verify recommendations accepted in previous RSA have been adequately implemented and if appropriate action plan developed for low cost remedial road safety measures.

1.10 Perform geo-hazards survey to identify

current and potential exogenous

geological processes and conduct

engineering-geological zoning of the

Project area on the risk of occurrence and

features of the development of exogenous

geological processes and phenomena

(including erosion).

Following the results of the survey

implement Change Management

Procedure and identify if reassessment of

environmental and social impacts is

required. Update related documents

accordingly

PR1 EBRD

PS1 IFC

SPV with the

assistance of

experienced

geological experts

(company)

Project Design Team

IA Consultant

Prior to the first


not later than obtaining

the approval of the

design by the State

Report on engineering-geological

survey

Report on implementation of the

Change Management Procedure

with conclusions on necessity of

reassessment of environmental

and social impacts.

If necessary:

Updated Project design

documentation

Supplementary Environmental

and Social Impact Assessment

report reflecting design changes

followed by the report on

engineering geological survey

Updated relevant MPs,

procedures etc.

Not initiated

1.11 Perform a detailed hydrogeological

survey of parts of the valleys of the rivers

Bolshaya Almatinka, Malaya Almatinka

and Karabulak, where the straightening

(permanent or temporary) of river beds

is planned, in order to assess the

significance of channel migration impacts

PR1 EBRD

PS1 IFC

SPV with the

assistance of

experienced

hydrology and

hydrogeology

experts (company)

Project Design Team

IA Consultant

Prior to obtaining the

approval of the design

by the State for relevant

road section

Report on results of

hydrogeology survey

Prepare a Supplementary

Environmental and Social

Impact Assessment report

reflecting design changes


hydrogeological survey

Ongoing

Certain information

from the

hydrological survey

conducted in 2018

were added into the

Surface waters

Appendix, based on



9

# Action Applicable

requirements

Resources.

Responsibilities


on the mode of groundwater discharge

and risk of flooding.

Incorporate the results to the section’s IA

study (local EIA and Supplementary

Lender’s Information Package)

Update relevant MPs,

procedures etc.

which potential

flood zones were

identified within the

BAKAD area.

No detailed

hydrogeological

survey undertaken

so far.

Final decision on

realignment of

riverbeds is yet to be

made.

1.12 Assess baseline conditions of structural

elements the houses located in residential

areas alongside the highway route,

construction sites and the transportation

routes where intensive flows of heavy

traffic is expected (potential vibration

impact), carry out the need for the

structural integrity survey (where

appropriate) on properties at risk

PR1 EBRD

PS1 IFC

ADB SPS

EPC After the finalization of

Scheme of

Transportation Routes

and before the start of

construction

Report on baseline conditions of

houses located near transportation

routes

Not initiated

1.13 Conduct additional air quality baseline

measurements, assess new baseline

conditions, and update modelling and

mitigation measures in line with new

assessment.

Update management plans and costs in

line with new assessment, if necessary.

Conduct Health Impact Assessment

(HIA) based on the updated AQ impact

assessment to identify any highly

PR1 EBRD

PS1 IFC

ADB SPS

SPV Q1 2020 Report on baseline conditions.

Updated ESIA package and

relevant management plans and

costs.

Not initiated.



10

# Action Applicable

requirements

Resources.

Responsibilities


impacted responsive receptors and

provide specific mitigation measures to

address any major residual impacts

focused on measures for specific

receptors. The implementation of these

mitigation measures will be the

responsibility of the Grantor.

1.14 As indicated under PS1, the Consortium

will employ a competent social

specialist(s) who will be responsible for

managing the actions to be taken by the

Consortium within the scope of ESAP,

and any other corrective action plans in

line with lenders requirements. The

specialist(s) will also act as a Community

Liaison Officer to liaise with GoK and

local government offices, manage

community grievances and undertake the

necessary public consultation activities

during the LAR planning and

implementation, and construction works.

PR5 EBRD

PS5 IFC

ADB SPS

SPV Prior to commencement

of construction works

within the BAKAD

RoW (or at each specific

start-up complex)

Job description for the social

specialist

Social specialist(s) hired and

acting throughout the

construction works

Not initiated

Social Specialist

appointed

2. Labour and Working Conditions

2.1 Develop and adopt Human Resources

Policy (HR Policy) and procedures. The

Policy and procedures will cover and

ensure compliance with the relevant

requirements for the following:

(i) Non-discrimination, equal rights

and equal pay;

PR2 EBRD

PS2 IFC

ADB SPS

SPV

EPC

Prior to commence


any Project sites

(BAKAD RoW,


HR Policy statement

HR procedures

Requirements on following the

Project HR Policy Statement and

implementation relevant HR

procedures are included in the

contracts with Subcontractors

Ongoing



11

# Action Applicable

requirements

Resources.

Responsibilities


(ii) Prevention of child labour and

forced labour;

(iii) Workers’ rights and obligations;

(iv) Freedom of association and right

to collective bargaining;

(v) Informing workers about their

rights, obligations, liabilities, and

entitlements;

(vi) Terms of employment including

recruitment, hours of work, overtime

arrangements and overtime

compensation, rights to refuse overtime

requests;

(vii) Contractor management;

(viii) Workers accommodation:

processes and standards – guidance notes

by IFC and EBRD 2009;

(ix) Occupational health and safety;

(x) Commitment to apply zero

tolerance for any proven case of gender

based violence, workplace harassment

and sexual exploitation and abuse; and

Formal grievance mechanism.

2.2 Undertake external labour audits to be

conducted by competent professionals

once a year during the construction

period to ensure compliance with

Lenders’ requirements and safe working

conditions by the Consortium and its

PR2 EBRD

PS2 IFC

ADB SPS

SPV Prior to commence

construction works

Once a year during the

construction

Submission of labour audit

implementation schedule

Submission of contract of third

party auditor hired

Not initiated



12

# Action Applicable

requirements

Resources.

Responsibilities


contractors, including adequacy of

workers’ accommodation conditions.

2.3 Develop, adopt and implement a Gender

Action Plan to promote good

international HR policies and practices

with respect to gender and equal

opportunities in the Company’s

workforce and implement them through

improvements to HR policies and

practices. The Gender Action Plan will

also capture high standards of gender-

based violence and harassment

prevention and mitigation, in accordance

with the Code of Conduct and other HR

policies.

Monitor that the subcontractors hired by

the Company follow guidance based on

the Gender Action Plan, including in

promoting the number of women in

construction.

The Contractor to ensure that sub-

contractors/suppliers apply the same

standards

EBRD PR2 EBRD Technical

Cooperation budget

SPV

EPC Contractors

Subcontractors

Prior to the first


not later than signing

contract with any of the

Subcontractor aimed to



sites (BAKAD RoW,


Technical cooperation

within two (2) years

after signing loan

agreement

Requirements on implementation

relevant actions from Gender

Action Plan are included in


Introduction of improved HR

policies and standards (based on

the recommendations of the

Technical Cooperation), such as

introduction of performance-

based pay, demonstrable

improvement in the diversity of

workforce, introduction of strong

GBVH requirements and policies,

etc.

Not initiated

2.4 Ensure that any accommodation

provided to project workers is designed,

constructed and maintained in line with

EBRD and IFC guidelines for workers’

accommodation 2009.

PR2 EBRD

PS2 IFC

ADB SPS

SPV Throughout the Project

implementation

Submission of a document

identifying main features of

workers accommodation camps

supported with visual materials

Not initiated

To be updated, as

construction camps

have already been

constructed.



13

# Action Applicable

requirements

Resources.

Responsibilities


2.5 Develop and adopt Code of Conduct for

all workers employed on site, including

the workforce of sub-contractors and key

suppliers that will include requirements

to behaviour of workers during site

works and during staying in camps

The Code of Conduct will address risks

associated with interaction and presence

of local communities within the project

area, such as sexual exploitation and

harassment; the code of conduct will be

incorporated in the induction training for

all staff and construction workers of the

EPC contractor and its sub-contractors.

Monitor its implementation to ensure that

there are effective external and internal

grievance mechanisms and its employees,

contractor’s workers and the

communities are informed on how to use

these mechanisms.

PR2 EBRD

PS2 IFC

ADB SPS

SPV

Prior to commence


any Project sites

(BAKAD RoW,


Code of Conduct

Code of Conduct is distributed

in the Construction Camps and

on all Project sites (e.g. wall

charts in canteen and other

regular visited places)

Workers’ Code of

Conduct has been

submitted to the

LTA for a review on

3rd July.

LTA had no

comments.

2.6 Provide all workers as minimum with

induction training on labour-related

documents (HR Policy, Code of Conduct,

OHS & Labour MP, other labour-focused

procedures) and contract

PR2 EBRD

PS2 IFC

ADB SPS

SPV

EPC contractor

Sub-contractors

Prior to commencement

of construction works at

any Project site

(BAKAD RoW,

quarries, access roads) –

until end of June 2019

Logs of introductions +

inductions provided

In progress

2.7 Conduct the Security Risk Assessments in

order to document security risks, security

response and potential impacts. Develop

Terms of Reference/Requirements for the

security services based on the results of

PR2 EBRD

PR 4 EBRD

PS2 IFC

PS 4 IFC

ADB SPS

SPV

EPC Contractor

Prior to Project

approval by Lenders,

but before signing

contract with Security

Company

Security Risk Assessments

Report

Not initiated



14

# Action Applicable

requirements

Resources.

Responsibilities


Security Risk Assessments, including

procedures and training program on use

of weapon (if applicable)

Terms of

Reference/Requirements for the

Security Contractor

2.8 Develop and adopt the Code of Conduct

for Security Personnel

PR2 EBRD

PR 4 EBRD

PS2 IFC

PS 4 IFC

ADB SPS

SPV Prior to Project

approval by Lenders,

but not later than

signing contract with

Security Company

Code of Conduct for Security

Personnel:

Requirements to follow the


Personnel are included in

contract with the Security

Company

Code of Conduct for

Security Personnel

has been submitted

to the LTA for a

review on 3rd July.

LTA had no

comments.

Security Contractor Prior to mobilization of

the Security personnel

on the Project sites

Requirements to follow the


Personnel are included in

personal contracts with security

personnel

In progress

2.9 Develop and deliver the induction to

armed security personnel on UN

Voluntary Principles on Human Rights

before the security staff is permitted on

site

PR2 EBRD

PR 4 EBRD

PS2 IFC

PS 4 IFC

ADB SPS

SPV

Security Contractor

Prior to mobilization of



Induction program

Logs of trainings provided

Not initiated

2.10 Cascade key requirements on labour and

working conditions, such as forced

labour, child labour, accommodation)

across SPV’s contracting chains,

including sub-contractors and core

suppliers.

PR2 EBRD

PR 4 EBRD

PS2 IFC

PS 4 IFC

ADB SPS

SPV Prior to the start of the

construction works

Signed contracts with

contractors, sub-contractors,

suppliers

Annexes of 5

subcontracting

agreements were

not submitted for

review.

2.11 Develop background screening

procedures to ensure that security

personnel provided by Security

Contractor are adequately trained,

PR2 EBRD

PR 4 EBRD

PS2 IFC

SPV

Security Contractor

Prior to mobilization of



Background screening

procedures on compliance with

Not initiated



15

# Action Applicable

requirements

Resources.

Responsibilities


licensed and familiar with Consortium

requirements

PS 4 IFC

ADB SPS

Project’s requirements for the

Security Contractor

Compliance Report of the

Security Company (self-

assessment)

2.12 Develop and adopt a grievance redress

mechanism for all workforce on site,

including sub-contractors’ workers

PR2 EBRD

PS2 IFC

ADB SPS


SPV

EPC Contractor

Sub-contractors

Key Suppliers

Prior to the ESIA

package disclosure

Grievance Mechanism:

accessible to internal

stakeholders, as described in

ESIA Vol. III Technical

Appendix 4.0 SIA, Section

4.7.4.7 and Occupational

Health & Safety and Labour

Management Plan, Annex B7

available in Kazakh, Russian,

Turkish and/or other

appropriate languages (if

applicable)

Internal and external

stakeholders are informed in the

GM availability

In Progress

Grievance Form

available on Project

website in English,

Russian and

Kazakh.

Complaints Logging

and Response

System (Grievance

Mechanism) MP has

been provided on

22nd June. LTA

provided their

comments on 2nd

July. New revision

pending.

Prior to the first

disbursement, but not

later than signing

contracts with

Subcontractors aimed to



sites (BAKAD RoW,


Requirement on GM adoption and

implementation is included in


In Progress



16

# Action Applicable

requirements

Resources.

Responsibilities


3. Resource Efficiency and Pollution Prevention and Control

3.1 Include embedded controls and

mitigation measures defined in the ESIA

for construction and operation stages to

appropriate Project design

documentation, site layout plans, work

schedules, procedures, manuals and

management plans (listed in row 1.6)

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

Project Design Team

EPC Contractor

Prior to the first


not later to obtaining

the approval of the

design by the State

Project design documentation

Site layout plans

Work schedules

Procedures and manuals as

defined by the ESAP and ESMPs

(listed in row 1.6) (e.g.

Construction dust management

procedure)

In progress

3.2 In the project design and construction

phases implement noise mitigation

measures as identified by the additional

noise study to ensure residual noise

levels at the sensitive receptors are

compliant with the Kazakhstan legal

noise level requirements which are in line

with WHO noise guidelines, including:

Asphalt surface

Construction of noise barriers;

Construction of berm structures

In case, monitoring results indicates

exceedance of project standards,

Speed limitation for car and trucks

will be set by the Grantor for those

sections.

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

Project Design Team

EPC Contractor

Prior to approval

Project design by the

state expertise

Submit design of the noise

mitigation measures as part of the

road main design to Lenders’ for

approval

In progress

3.3 Develop/update a noise monitoring plan

for the construction phase, for the closest

sensitive receptors off-site prior to works

starting on each new section of the route.

This will ensure that if levels at receptors

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

Project Design Team

EPC Contractor

Prior to works starting

on each new section of

the route.

Noise monitoring plan

Noise monitoring report and

evidences of implementation of

any mitigation measure required

Not initiated



17

# Action Applicable

requirements

Resources.

Responsibilities


exceed the standards or the 3 dB

threshold, measures are taken to reduce

noise levels to ensure compliance with

Kazakhstan and WHO guidelines.

3.4 In the project operational phase, develop

a noise monitoring plan to assess the

effectiveness of implemented measures

and perform detailed noise monitoring,

according to the plan.

Based on the monitoring results, the

Consortium jointly with Grantor, will

design and implement additional noise

mitigation measures as required to ensure

potential residual noise levels at the

sensitive receptors are compliant with

Kazakhstan legal requirements, WHO

guidelines, and the 3dB threshold.

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

Project Design Team

EPC Contractor

Noise monitoring plan:

March 30, 2023 or 2

months before

commencement of

operation

Noise monitoring report

and evidences of

implementation of any

mitigation measure

required: April 30, 2025

or 18 months post

commencement of

operation

Noise monitoring plan

Noise monitoring report and

evidences of implementation of

any mitigation measure required

In progress

3.5 Develop and implement an Awareness Raising Programme for the affected community, especially social infrastructure facilities, that could be helpful in reduction of adverse health impacts from traffic-related air emissions and noise. Such programme shall aim to inform the affected community about the measures they can take to minimise their exposure to air pollution and noise such as keeping windows and doors closed during peak traffic times (e.g., morning and evening rush hours).

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

EPC Contractor

Prior to the start of

motorway operation

Awareness Raising Program

developed and approved by

Potential Lenders

Leaflets and other information

materials prepared

Awareness raising meetings held

in all sensitive locations with all

key affected communities as part

of SEP activities

Not initiated

4. Community Health and Safety



18

# Action Applicable

requirements

Resources.

Responsibilities


4.1 The Consortium, in collaboration with the

Grantor, will develop a Community

Severance Mitigation (mobility) Plan

which will identify relevant mitigation

measures acceptable to Lenders and will

define implementation responsibilities.

The Consortium will report to Lenders on

Grantor’s approvals of the relevant

design changes.

PR4 EBRD

PS4 IFC

ADB SPS

GIIP

EPC Contractor

Prior to the first


not later the

commencement of

construction work at

any Project site

Community Severance Mitigation

Plan

Not initiated

4.2 The Consortium will ensure that EPC and

O&M contractors prepare and implement

Occupational Health and Safety

Management Plans (OHSMP) for both

construction and operational phases. The

OHSMP will include detailed procedures

for: hazard identification and risk

assessment; job and task specific hazard

analyses, provision and use of personal

protective equipment (PPE); training; safe

working procedures; prevention,

reporting, recording, investigation,

analysis of accidents and incidents, and

follow up corrective actions; emergency

response; provision of medical care, first

aid and provision of medical treatment;

workplace and health monitoring;

measures for prevention of disease

spread; fire prevention and fighting

system; transportation of workers,

inspections and audits; performance

reporting; and management review.

PR4 EBRD

PS4 IFC

ADB SPS

GIIP

SPV

EPC Contractor

Prior to the first


not later the

commencement of


any Project site

Prior to commencement

of operation

Occupational Health and Safety

Management Plans (OHSMP) for

construction and operational

phases

In progress for EPC

Contractor



19

# Action Applicable

requirements

Resources.

Responsibilities


4.3 Develop Driver training program that

provides training on safe driving and fuel

economy (e.g. moderate acceleration and

driving at safe speeds)

PR4 EBRD PS4 IFC

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

EPC Contractor

Sub-contractors

Prior to the first


not later the

commencement of


any Project site

Driver training program Induction

driver trainings logs

Not initiated

4.4 The Consortium will require the EPC

contractor to develop and implement the

relevant OHS procedures for demolition

and utility replacement works and

procedures for asbestos screening,

handling and disposal in line with good

international industry practices

PR4 EBRD PS4 IFC

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

EPC Contractor

Prior to start site

clearance within the

BAKAD RoW

OHS procedures for demolition

and utility replacement works

Procedures for asbestos screening,

handling and disposal

In progress

Demolition OHS

Procedure

submitted. LTA

provided comments.

Final version

pending.

4.5 In case of residual adverse impacts will

be shown by updated Air Quality Impact

Assessment conduct Health Impact

Assessment to identify specific recipients

of the impact and develop a management

plan with focus on mitigation at receptor

(e.g. improvement of ventilation system

etc.)

PR4 EBRD PS4 IFC

PR3 EBRD

PS3 IFC

ADB SPS

GIIP

SPV

EPC Contractor

HIA to be conducted by

July 2020

Management plan to be

prepared by January

2021

Report on HIA results

Management plan submitted and

reviewed by LTA

Not initiated

5. Land Acquisition, Involuntary Resettlement and Economic Displacement

5.1 Carry out a land acquisition audit of the

entire Project as part of site handover

process in order to confirm if additional

permanent land acquisition is required or

not.

If the site handover, design or/and

construction will be carried out section by

section, then SPV should conduct a

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)

Land acquisition audit report

cleared by Lenders

Not initiated

LAA for sections 4

and 8b has been

performed



20

# Action Applicable

requirements

Resources.

Responsibilities


sectional land acquisition audit to certify

absence/presence of additional

permanent land acquisition needs.

5.2 Develop the Resettlement Plan in case

land acquisition audit confirms the need

for additional land acquisition, and

submit it for implementation to the GoK

(Committee of Roads). Delivery of

Resettlement Plan is monitored and

verified by External Monitor.

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)

Resettlement Plan developed by

the Consortium and approved by

Lenders

Resettlement Plan adopted and

implemented by GoK (CoR)

Completion Report issued by

External Monitor and approved

by Lenders

Not initiated

5.3 Develop and implement livelihood

support measures for APs, including but

not limited to those defined below.

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)

Regular monitoring reports

Not initiated

5.3.1 In cases when compensation or

replacement land plot/property is not yet

provided to affected persons (AP) and/or

APs are still living in acquired property,

Consortium to ensure access to property

until the issue is fully resolved by

Grantor and AP is relocated.

In case of affected business, Consortium

will consider possibility to use the

products/services of affected

business/people for construction works

or in construction camps. Consortium

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)

Mitigation measures implemented

by Consortium


Not initiated



21

# Action Applicable

requirements

Resources.

Responsibilities


will also provide special assistance to

vulnerable groups (see 5.3.4).

5.3.2 In cases of APs with informal property

located within RoW, Consortium will

discuss with Grantor and seek design-

based solution to avoid relocation of the

house. Consortium will maintain access

to the property of AP until the

compensation is paid and APs relocate.

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)


by Consortium


Not initiated

5.3.3 In case of APs with unviable residual

land plot (reviewed through GRM and

confirmed by Grantor), Consortium is to

provide support the APs, if technically

feasible, by connecting the land to

irrigation channels, providing

agricultural inputs, including machinery

and equipment. Consortium will make

sure that APs with unviable residual land

plots are aware of this option.

Consortium to provide other measures

that include provision of special

assistance to vulnerable affected people

(see 5.3.4) and support to APs involved in

agriculture (see 5.3.5).

PR5 EBRD

PS5 IFC

ADB SPS

SPV Throughout project

implementation

GRM and regular monitoring

reports

Not initiated

5.3.4 Consortium will provide assistance to

vulnerable affected persons during

relocation (e.g. truck, machinery,

equipment, etc.). Consortium will make

sure that APs are aware of this option.

PR5 EBRD

PS5 IFC

ADB SPS


implementation


Not initiated



22

# Action Applicable

requirements

Resources.

Responsibilities


5.3.5 In case the acquired land plots or land

plots in process of acquisition are used

for agriculture, Consortium (in

consultation with Grantor) will schedule

implementation of civil works in a

manner providing the APs with an

opportunity to collect the harvest (or

payment of compensation by Grantor for

lost harvest).

In case of affected businesses involved in

ongoing agricultural activities,

Consortium will consider possibility of

using the produce grown/cultivated on

lands of affected owners/users (e.g. as a

supply for construction camps kitchen).

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)


by Consortium


Not initiated

5.3.6 Consortium will coordinate with Grantor

and implement measures to avoid or

minimize access issues for owners/users

(including operating businesses) of the

properties adjacent to BAKAD RoW. In

case the alternative access road is

provided to APs by the relevant

authorities, the Consortium will provide

support to APs during relocation of gate

structure and other necessary works.

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex) and

throughout

implementation of

works


Not initiated

5.4 Hire an external consultant to monitor

and report on the implementation of

Resettlement Plan, and other future land

acquisition and resettlement processes

which will be undertaken by the GoK for

the project and on compliance with the

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex)

Completion Report needs to be

approved by Lenders prior to the

start of the civil works.

In progress.



23

# Action Applicable

requirements

Resources.

Responsibilities


relevant provisions of Lenders. At

completion of the land acquisition and

resettlement related plans and programs,

the consultant will carry out a completion

audit to verify the expected outcomes

achieved as per the requirements of

Lenders.

5.5 Ensure that the EPC and O&M

contractors will include, in their Local

Employment Plans, mechanisms for

maximizing the employment of affected

people where feasible based on workforce

needs and skills required.

PR5 EBRD

PS5 IFC

ADB SPS

SPV

EPC Contractor

Prior to the first

disbursement, but not

later than signing

contracts with

Subcontractors aimed to



sites (BAKAD RoW,


Provisions on implementation of

the Local Employment Plan is

included in contracts with EPC

Contractor and subcontractors

5 subcontracting

agreements have

already been signed,

however none have

been submitted for

review.

EPC Contractor

Subcontractors

Evidences of implementation of

the Local Employment Plan (e.g.

HR Policy provisions, orders,

protocols on engagement with

APs and local akimats (providing

information on requirements in

workforce, available opportunities

for supply etc.))

Not initiated

5.5.1 Develop and implement Local

Employment Plan for the affected

communities, with the priority to be

given to the people affected by the past

land acquisition.

Depending on their aptitude, skills and

experience, Consortium may provide the

members of affected households with

employment opportunities that may

PR5 EBRD

PS5 IFC

ADB SPS

SPV

EPC Contractor

Throughout project

implementation

Local Employment Plan


Not initiated



24

# Action Applicable

requirements

Resources.

Responsibilities


include skills upgrade and temporary

jobs under Local Employment Plan

during implementation of civil works for

BAKAD. Consortium will make sure that

APs are aware of this option.

5.6 Consortium in collaboration with Grantor

will ensure establishment and operation

of a GRM. Resolution of grievances shall

be pursued in accordance with

established GRM and Grievance Redress

Committee shall seek resolution of the

issue on case-by-case basis.

PR5 EBRD

PS5 IFC

ADB SPS


implementation

GRM established, focal points and

GRC members nominated

Monitoring reports

GRM established

Nomination in

progress

5.7 Consortium will also ensure preparation

and implementation of an effective

internal monitoring mechanism of LAR

activities.

PR5 EBRD

PS5 IFC

ADB SPS


implementation

Regular monitoring reports,

Completion reports

Not initiated

5.8 Consortium will collaborate with Grantor

to ensure capacity building and

institutional strengthening of project state

counterparts involved in land acquisition

and resettlement (including Experience

Exchange Sessions to akimats and other

project state counterparts). Consortium’s

social/resettlement specialist will be

available to provide guidance to all

stakeholders regarding Lenders’ social

safeguard requirements.

PR5 EBRD

PS5 IFC

ADB SPS



within the BAKAD


start-up complex) and

throughout project

implementation

Provision of training and capacity

building (training materials,

curricula, list of participants);

Monitoring reports

Not initiated

6. Biodiversity Conservation and Sustainable Management of Living Natural Resources



25

# Action Applicable

requirements

Resources.

Responsibilities


6.1 Conduct additional studies during the

growing season of ephemeroids in order

to establish their presence within the

Project AoI. Develop mitigation measures

if required and consider them in the

Detail Design of the Project

PR6 EBRD

PS6 IFC

ADB SPS

SPV with the

assistance of relevant

experts

Project Design Team

IA Consultant

Prior to the first



the approval of the

design by the State

Report on results of spring

vegetation survey with

recommended mitigation

measures

If necessary:

Update Project design

documentation

Supplementary Environmental

and Social Impact Assessment

report reflecting design changes


hydrogeological survey

Update relevant MPs,

procedures etc.

Closed

6.2 Include embedded controls and

mitigation measures defined in ESIA for

construction and operation stages to

appropriate Project design

documentation, site layout plans, work

schedules, procedures, manuals and

management plans (listed in row 1.6),

including the following requirements:

Do not perform the construction works

in riverbeds during spawning and

breeding seasons of Balkhash Perch

(Perca schrenki) (from early spring to

late may);

Appoint biodiversity expert to

accompany construction works within

the floodplain and meadow-steppe

PR6 EBRD

PS6 IFC

ADB SPS

GIIP

SPV

Project Design Team

EPC Contractor

Prior to the first



the approval of the

design by the State

Project design documentation

Site layout plans

Evidences on engagement with

agricultural users regarding the

schedule of construction works

(minutes of meetings, engagement

letters etc.)

Updated work schedules

Procedures and manuals as

defined by the ESAP and ESMPs

(listed in row 1.6)

In progress

Project HSES

Organization Chart

does not include

Biodiversity Expert

as a separate role.

Chart should be

amended to include

required role.

Detailed

information about

the Biodiversity

Expert role and

responsibilities

should be provided

in the CESMP.



26

# Action Applicable

requirements

Resources.

Responsibilities


communities and areas with trees and

shrubs (see habitat map - figure 2.7–18

in Section 2.7 of ESIA Volume III) from

early March to late June.

Approve the construction schedule

with the affected farmers to avoid

additional damage to their agricultural

crops (this particularly refers to

vulnerable fruit plantations, such as the

Yury Badenko Farm)

6.3 Develop Landscape Plan (in order to plan

the planting of trees envisaged by

TEO/Feasibility Study), including:

Identification of locations of plantings

Identification of species to be planted

Identification of suppliers of significant

amount of trees and shrubs

(confirmation from local suppliers for

their capacity to deliver the required

amount is the best option)

Development of the procedure to exclude

alien species introduction to the Project

area

PR6 EBRD

PS6 IFC

ADB SPS

GIIP


SPV

EPC Contractor

Subcontractors (if

applicable)

Prior to one year of the

first plantations

Trees Planting Program

developed and approved by state

authorities

Not initiated

6.4 Complete the assessment of the technical

feasibility of the river bed realignment

alternatives, including feasibility of river

bed restoration, and will integrate the

results in the environmental management

plan and EPC contractor requirements

PR6 EBRD

PS6 IFC

ADB SPS

GIIP


SPV

EPC Contractor

30 days before

construction phase for

particular road section

will commence

Project design documentation Ongoing



27

# Action Applicable

requirements

Resources.

Responsibilities


6.5 Ensure that the Project design

documentation contains the biodiversity

mitigation and management measures

identified by the ESIA among others (i)

culverts that can be used by small

animals for passage, (ii) cattle lanes, (iii)

culverts to maintain natural riverbed

width and level.

PR6

PS6

ADB SPS GIIP


SPV, EPC 30 days before

construction phase for

particular road section

will commence

Project design documentation Ongoing

7. Indigenous People

Not applicable to the Project

8. Cultural Heritage

8.1 Commission a competent company

(having experience with Lenders’

requirements) to develop a Cultural

Heritage Action Plan (CHAP) for all of

the objects and sites identified within and

in the vicinity of the BAKAD including

activities to be undertaken for

consultation with affected people as per

the requirements of Lenders. CHAP

should be aligned with key requirements

of Cultural Heritage Framework and

Lenders’ requirements.

PR8 EBRD

PS8 IFC

ADB SPS

GIIP

SPV or EPC

Contractor (as per

contract between

SPV and EPC

Contractor)

Prior to approval the

Project by Lenders

Contract between SPV and

cultural heritage expert

For the execution of

the Archaeological

works throughout

all stages of the

Project, the

Consortium has

contracted

“Kazarchaeology”

LLP

Latest version of

CHAP under

review.

Still work in

progress.

8.2 The same consultant company will carry

out an archaeological screening at Issyk

quarry as part of the CHAP.

PR8 EBRD

PS8 IFC

ADB SPS

GIIP

SPV or EPC

Contractor (as per

contract between

Before opening the

quarry

Report on results of the screening

on quarry sites

For the execution of

the Archaeological

works throughout

all stages of the



28

# Action Applicable

requirements

Resources.

Responsibilities


SPV and EPC

Contractor)

Project, the

Consortium has

contracted

“Kazarchaeology”

LLP

Screening not yet

initiated.

8.3 Develop a chance finds procedure and

ensure archaeological monitoring, as part

of CHAP, through competent

professionals who will be contracted by

the EPC contractor prior to any

construction works on archaeological

sites

PR8 EBRD

PS8 IFC

ADB SPS

GIIP

SPV or EPC

Contractor (as per

contract between

SPV and EPC

Contractor)

30 days prior to

construction works

commence approval

obtained by Lenders

Chance find Procedure Chance finds

procedure included

in CHAP.

New revision

pending.

8.4 Reburial management plan and reburial

procedure to be prepared in line with

ESIA package requirements and CHAP

before commencement of construction

works in areas of modern cemeteries

identified by ESIA, in case that final

design solution shows that the cemeteries

will be affected by the project.

PR 4, 8 EBRD

PS 4, 8 IFC

ADB SPS

GIIP

SPV or EPC

Contractor

Before commencement

of construction works in

areas of modern

cemeteries identified by

ESIA

Updated Cultural Heritage Action

Plan

(Reburial Management Plan,

Reburial Procedure, if required)

In progress

Cultural Heritage

Action Plan

prepared and

version 2 under

review.

9. Financial Intermediaries

Not applicable to the Project

10. Information Disclosure and Stakeholder Engagement

10.1 Put in force Grievance Mechanism

external stakeholders as described in SEP

PR1 EBRD

PR10 EBRD

ADB SPS

SPV

EPC Contractors

Prior to the ESIA

package disclosure Grievance Mechanism accessible on the Project web-site on Kazakh, Russian and English languages

In progress

Grievance Form

available on Project

website in English,



29

# Action Applicable

requirements

Resources.

Responsibilities


ADB PCP

PS1 IFC

Internal and external stakeholders

are informed on the GM

availability

Russian and

English.

Complaints Logging

and Response

System (Grievance

Mechanism) MP has

been provided on

22nd June. LTA

provided their

comments on 2nd

July. New revision

pending.

10.2 Review and update the SEP as per the

recommendations identified in the Risk

Assessment Process and the Land

Acquisition Audit

PR1 EBRD

PR10 EBRD

ADB SPS

ADB PCP

PS1 IFC

SPV Upon the completion of

the Risk Assesment

Process and LAA

Updated SEP Not initiated

10.3 Complete public disclosure meetings for

the ESIA in accordance with agreed

schedule between Grantor, Potential

Lenders and Consortium to demonstrate

meaningful consultation with all project

affected stakeholders and vulnerable

people as per Potential Lenders

requirements. Reflect the outcomes

derived from these meetings into relevant

E&S management plans.

PR1 EBRD

PR10 EBRD

ADB SPS

ADB PCP

PS1 IFC

SPV

Consulting

contractor(s)

As per schedule agreed

between Grantor,

Lenders and

Consortium

Prior to ADB board

approval

ESIA disclosure meetings

MoMs of meetings

In progress

Preparation of

presentations for

Disclosure Meetings

in progress

10.4 Complete Broad Community Support

procedure

PS1 IFC SPV

Consulting

contractor(s)

As per schedule agreed

between Grantor, IFC

and Consortium

MoMs of meetings

Report on procedure

implementation

Not initiated



30

# Action Applicable

requirements

Resources.

Responsibilities


10.5 Incorporate in the Change Management

Plan periodical review and update

requirement for the Stakeholder

Engagement Plan in order to address

future needs of the project resulting from

(i) site specific engagement needs of each

section; (ii) any change in project design;

and (iii) any future land acquisition.

PR1 EBRD

PR10 EBRD

ADB SPS

ADB PCP

PS1 IFC


construction

Submission of Change

Management Plan

Not initiated

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