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ENVIRONMENTAL AND SOCIAL

MANAGEMENT PLAN

COC SAN HYDROPOWER PROJECT

FINAL REPORT

COLBEN ENERGY VIETNAM JSC. AND VIET HYDRO PTE. LTD.

14 August 2013

www.erm.com

ENVIRONMENTAL RESOURCES MANAGEMENT 0184835 COC SAN HPP

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 14 AUGUST 2013

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1 INTRODUCTION

1.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT REQUIREMENTS

This report sets out the proposed Environmental and Social Management System

(ESMS) for the Coc San Hydropower Project (the “Project”). The ESMP describes how

the various environmental and social management activities that the Project will be

undertaking fit into the Project’s wider systems and organisational structure.

This report aims to:

• Present the Project’s structure including roles and responsibilities to govern the

implementation of the ESMP;

• Include the Environmental, Health and Safety (EHS) policy for the Project to

comply with;

• Describe monitoring, evaluation and reporting plan for the environmental and

social performance; and

• Draw together the measures proposed to mitigate and manage environmental

and social impacts from the Supplementary ESIA into an outline ESMP.

With the limitations as described in the following section, this report is developed in

a high level of an ESMP. It is noted that this report should be read in conjunction with

the Supplementary ESIA of the Coc San Hydropower Project.

1.2 LIMITATIONS

At the time of developing this report, the Project is in early stage of construction and

temporarily suspended to look for funding. This report is developed based on the

information that is available at this time and provided to ERM for review. It is noted

that several information (i.e. EHS policy, roles and responsibilities of environmental

and social department and Environmental and Social Management System (ESMS)) is

not available to provide to ERM. Therefore, where the information is not available,

recommendations/relevant elements are proposed by ERM for the Project to take

into consideration.

1.3 STRUCTURE OF THE PLAN

The structure of this Environmental and Social Management Plan is as follows:

Section 1: Introduction (this section)

Section 2: The Project’s organisational structure and EHS principles

Section 3: Environmental and Social Management System

Section 4: Project Environmental and Social Management Plan



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2 THE PROJECT’S ORGANISATIONAL STRUCTURE AND EHS PRINCIPLES

2.1 THE PROJECT’S STRUCTURE

The Coc San Hydropower Project is owned and invested by the Colben Energy

(Vietnam) Joint Stock Company (“CEVJSC”, referred as the “Project Company”).

CEVJSC is a 51% subsidiary of the Colben Energy Holding (Vietnam) Ltd. (“CEHV”) and

30% and 19% of Vietnam Infrastructure Development and Finance Investment JSC

(“VIDIFI”) and HVD Construction and Investment Consultants JSC (“HVD”),

respectively.

On 25th

October 2012, Colben Energy Holding (Vietnam) Ltd. has entered into a

subscription agreement with Viet Hydro Pte. Ltd. (“VietHydro”) to issue shares of up

to 33,992,840 ordinary shares in CEVJSC representing up to 73.6% of the enlarged

paid up capital of CEVJSC.

CEHV is a wholly owned subsidiary of Asiatic Group (Holdings) Ltd. Asiatic Group

Holdings Ltd (“AGHL”) is a Singapore-based investment holding company. AGHL

mainly operates in Singapore, Cambodia, Vietnam and Malaysia. AGHL operates in

two business segments: Fire fighting and protection and Power related.

VietHydro is a wholly owned subsidiary of InfraCo Asia, which was established in

2010 and is headquartered in Singapore. InfraCo Asia is an infrastructure

development company owned by the Private Infrastructure Development Group (the

“PIDG”). PIDG principals comprise government agencies from countries such as

United Kingdom, Switzerland, the Netherlands, Sweden, Austria, Ireland, Germany,

Australia and the World Bank Group.

Upon the completion of the conditions precedent set out in the transaction

documents, InfraCo Asia expects to acquire majority stake in the Project Company by

subscribing, at par to new shares in the Project Company. The amended Investment

Certificate (to the satisfaction of Viet Hydro) was issued by the Lao Cai People's

Committee on 11 June 2013. The completion of the Conditions Precedent has

happened on 04 July 2013. Viet Hydro has subscribed to shares in the Project

Company (as per the schedule approved in the amended Investment Certificate),

making Viet Hydro a majority shareholder. At financial close, InfraCo Asia (through

its subsidiary) is expected to have equity shareholding of 73.6% with the remaining

15% with CEHV, 8.1% with VIDIFI and 3.3% with HVD.

Colben Energy Holding Private Ltd has appointed Zhejiang Hydropower Construction

& Installation Co. Ltd (“ZHCIC”) as the Engineering, Procurement and Construction

(EPC) Contractor for the Coc San Hydropower Project. The EPC contract has now (on

26 June 2013) been novated and restated to be between the Project Company and

the EPC Contractor, ZHCIC. The Contract covers both the Civil Works and Mechanical

& Electrical Works.



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2.1.1 Construction Phase

All employees of the Project Company and the EPC contractor who are working

onsite during the construction phase must comply with the EHS Policies of the

Project. The Environmental, Social, Health and Safety (ESHS) aspects of the Project

are managed and monitored under EHS team of the Project. It is noted that the

following structure is proposed by ERM to include key relevant roles of the

Management Board including shareholders (i.e. VietHydro, CEHV, VIDIFI and HVD),

Project Manager, Construction Manager, EHS team of the Project Company and the

EPC and how they fit into the Project’s organisation as depicted in Figure 2.1.

Figure 2.1 Proposed Organisation Structure of the Project in Construction

Roles and responsibilities for ESHS performance implementation during construction

in compliance with the ESMP should be clearly appointed for the EHS team as

follows.

EHS Manager

• Keeps abreast of applicable Vietnamese legal requirements per the Project’s

regulatory tracking process;

• Defines EHS responsibilities for employees within the Project and ensures that

those responsibilities are fulfilled;

• Works to establish a world class safety culture at the Project during construction;

• Obtains all regulatory EHS permits and approvals for the Project;

• Maintains the Project’s EHS permits, records and monthly reporting to the

Government, the Lenders, the Project Manager and the Management Board;

• Ensures that all documentation and records that are required comply with the

ESMP that are current, available, auditable and properly executed in accordance

with the Project quality assurance requirements;



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• Reviews and recommends approval status for subcontractors’ EHS documents

that are intended to be incorporated in the Project;

• Reviews monitoring reports before submitting to the relevant authorities;

• Establishes and implements an EHS auditing process, field inspections and safety

walk programs ensuring appropriate corrective actions are tracked and

completed in a timely manner;

• Coordinates development of EHS training programs;

• Leads EHS incident investigations and distribute results of investigation reports

and lessons learned;

• Interfaces with all appropriate authorities associated with EHS accident/incident

investigations;

• Lead the weekly EHS meetings and report the ESHS performance status to the

Project Manager and the Management Board.

Community Liaison Officer

• Communicates EHS policies to interested parties;

• Implements the Stakeholder Engagement Plan as proposed in the Supplementary

ESIA;

• Works with the EHS Manager to ensure appropriate actions/management

programs are built into the annual action plan to achieve the requirements under

social performance of the ESMP;

• Ensures that the social monitoring activities are conducted in compliance with

the monitoring plan of the ESMP;

• Reviews third party audit reports from a community perspective;

• Reviews community-related documents and records annually to determine

whether they can be destroyed or whether they should be retained.

Environmental Officer

• Ensures that all Project site’s activities are being carried out in compliance with

the applicable environmental regulations;

• Personally conducts workplace inspections;

• Check that the necessary corrective and preventative actions have been

undertaken;

• Liaise with the EPC Contractor EHS officers regarding performance and problems

and attend the weekly EHS meetings;

• Coordinates to monitor, audit and report the results to the EHS Manager;

• Reviews the monitoring reports and submits to the EHS Manager for their review

before sending to the relevant authority.

Health and Safety Officer

• Ensures that the Project, at all times, fully complies with the applicable

regulations and also with the Project’s health and safety policy;

• Conducts daily site walk throughs and inspections to ensure safety performance

at the construction site;



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• Collects health and safety data and reports health and safety performance to the

EHS Manager;

• Retains incident investigation reporting records and investigation reports;

• Coordinates the monitoring, audits and inspection schedule and action tracking

system;

• Reports monitoring and auditing results to the EHS Manager;

• Attends the weekly EHS meetings;

• Periodically prepares and submits health and safety report to the relevant

authority.

2.1.2 Operation Phase

At the time of writing this report, the Project is in early stage of construction,

therefore the organisation structure of the Project in operation phase (see Figure

2.2) is tentative and no specific responsibility of each role are identified yet. As

indicated in Figure 2.2, the ESHS performance will be responsibility of the Safety and

CSR Officer. Due to the work load for implementation of the ESMP during operation,

the Project is recommended to allocate one more staff to involve under safety and

CSR position. Responsibilities for ESHS performance are suggested by ERM as below.

It should be noted that these responsibilities are subject to update depending on the

situation of the project at operation phase.

Figure 2.2 Organisational Structure of the Project in Operation

Source: Colben Energy (Vietnam) Joint Stock Company, 2013.

Note: CSR: Corporate Social Responsibility; IT: Information Technology.

Since the Safety and Corporate Social Responsibility (CSR) Officer will be the person-

in-charge of this ESMP during operation, role and responsibility of this position are

discussed in details as follows.



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Safety and CSR Officers

EHS responsibilities

• Ensures that all operation activities are being carried out in compliance with the

applicable EHS regulations;

• Personally conducts workplace inspections;

• Collects EHS data and reports ESHS performance to the Plant Director;

• Retains incident investigation reporting records and investigation reports;

• Coordinates the monitoring and audits as required by the ESMP;

• Reviews the environmental monitoring report prepared by the contractor and

submits to the relevant authority;

• Prepares and submits health and safety report to the relevant authority.

Corporate Social Responsibility

• Helps to implement an open, transparent communication policy that serves to

formulate the Project's EHS policies.

• Implements the Stakeholder Engagement Plan as proposed in Supplementary

ESIA;

• Ensures that the social monitoring activities are conducted in compliance with

the monitoring plan of the ESMP;

• Reviews third party audit reports from a community perspective;

• Reviews community-related documents and records annually to determine

whether they can be destroyed or whether they should be retained.

2.2 EHS POLICIES

No specific environmental, health and safety (EHS) policy of the Project is currently

available. Therefore, the following EHS policy is proposed by ERM and it is subject to

review, consideration and updating by the Project Company. The EHS policies are

proposed to demonstrate the Project’s commitment to the environmental, health

and safety protection for its employees, contractors and the community during the

Project’s life.

2.2.1 Environmental policy

• Carefully carry out and implement relevant Vietnamese national regulations on

environmental protection.

• Make efforts to conduct environmental protection at the project site during

construction and operation.

• Meet or exceed all the environmental legislation that relates to the Project.

• Impacts on the environment shall be measured and monitored, and set targets

for ongoing improvement.

• Carry out training programs for employees to raise awareness of environmental

issues and enlist their support in improving the Project’s ESHS performance.



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2.2.2 Health and safety policy

• All work activities need to be conducted in a safe manner that promotes personal

health, safety and well-being;

• Eliminate all risks to ensure health and safety of all employees;

• Strictly abide by the Vietnamese national health and safety regulations;

• People including contractor/sub-contractor are expected to adhere to all

occupational health and safety related programs and requirements adopted by

the Project;

• Each individual is responsible for their own safety as well as the safety of their

teammates and the people in the communities in which they work; and

• Any person or contractor has a right to stop work if they identify an unsafe

working condition.



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3 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM

3.1 INTRODUCTION

As mentioned in Section 1, there is currently no Environmental and Social

Management System (ESMS) that has been established for and applied by the

Project. It is necessary that an ESMS should be established to reflect the Project’s

commitments to the environment, social, health and safety of its employees,

contractors. An ESMS should cover construction and operational aspects that have

the potential to affect, positively or negatively, the environment, health, safety or the

community in which the Project and/ or its contractors /sub-contractors operate.

With reference to the ISO 14001 framework, an ESMS should include elements of the

“plan, do, check, review cycle” as illustrated in Figure 3.1. An ESMS should be

designed to ensure that effective processes are in place to identify and manage ESHS

risks and opportunities and improve associated performance and accountability.

Figure 3.1 Plan, Do, Check, Review Cycle



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3.2 SUPPORTING MANAGEMENT PLANS

3.2.1 Contractor Management Plan

Review scope of work. The contracting of services, the purchase, hire or lease of

equipment and materials, and activities with partners, are carried out with attention

so as to minimize any adverse ESHS impacts. The contractors will be required to

submit a scope of work as part of their contracts with the Project Company. The

scope of work will include details of tasks, numbers of contractors, duration of

contract, schedule of work, and location of work, prior to it being issued to potential

bidding contractors. Additionally, registers of significant aspects (risks) of the

contractors are required to submit to the Project Company to determine the hazards

and level of risks that the contractors will be required to manage as part of their

work. The Project Company shall maintain the registers together with the scope of

work.

Develop contractor EHS selection criteria. Contractor EHS selection criteria will be

developed to assist selection based on the details included in the scope of work.

Contractors must be able to demonstrate that they have the competence to manage

ESHS issues and meet the selection criteria by providing references, details of

experience, qualifications and skills, and information on their ability to manage such

issues. The contractor should also be able to provide personnel who have received

training in EHS management.

Successful contractor to complete a risk assessment. The successful contractor shall

complete a risk assessment of their work to identify hazards associated with contract

tasks /activities and methods of controlling or preventing them and submit it to the

Construction Department for approval prior to commencement of work.

Management of contractor non-conformance. Any non-conformance report will be

prepared following consultation with the contractor. Where the contractor does not

rectify the issue within the agreed time frame a second non-conformance report may

be issued. In this situation suspension or termination of the contract will need to be

considered. Where the non-conformance is performed by a subcontractor of a direct

contractor, the direct contractor will be responsible for ensuring that the

subcontractor rectifies the issue. However, if not rectified, the overall contract with

the direct contractor is at risk.

Maintain a register of approved and inducted contractors. A register of approved

and inducted contractors (including direct contractors and subcontractors) shall be

maintained. On completion of any training, completion records should be prepared.

They shall be kept in a format that is readily accessible and updatable to allow for the

insertion of additional contractors’ information as they are identified.

3.2.2 Change Management Plan

Risk Assessment Screening. When any need of change occurs, a Risk Assessment

Screening of that change should be conducted.



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Request Change. If the Risk Assessment Screening deems that there may be an

impact on the ESHS performance, the change must be assessed to determine

whether the change is appropriate and does not cause a significant negative impact.

Change Review and Approval. The result of the Risk Assessment Screening should be

reviewed to decide whether the change is approved.

In event that the change is approved, a Change Approval Form should be completed

and returned to the person making the change request, with a status of "accepted".

If the change is not approved, a discussion on whether an alternative change, with

fewer impacts, can be formulated which would ultimately have the same result

should be conducted between Management and the person making the change

request. If an agreement can still not be reached, the change shall be rejected. The

reasons for the rejection shall be recorded and returned to the person making the

change request, with a status of "rejected".

Record Change Requests. The copies of the Change Approval Form and associated

documents shall be kept.

3.2.3 Dam Safety and Reservoir Management Plan

The ESMP for a hydroelectric project would normally be expected to include a Dam

Safety and Reservoir Management Plan. According to the Operational Policy of Safety

of Dams of the World Bank, the dam of this Project is large dam1; it is therefore

required to comply with the following safety requirements of the World Bank2:

• reviews by an independent panel of experts throughout the period of

construction of the dam and the start of operations;

• implementation of detailed plans developed for construction supervision and

quality assurance, instrumentation, operation and maintenance, and emergency

preparedness;

• periodic safety inspections of the dam after completion.

Regarding reservoir management, a Reservoir Operation Procedure has been

developed as part of the Feasibility Study report and approved by the Vietnam

Government in 2007. Therefore, the Project is required to comply with this

Procedure to ensure the reservoir safety performance. Additionally, in terms of

reservoir management, the Project needs to take into account the management of

access to the reservoir; measures to control access by people and domestic animals

to the reservoir margin; aquatic weed control; and development of the possibilities

for other beneficial uses of the reservoir.

3.2.4 Training Plan

In order to ensure that only competent/trained individuals/contractors performing

tasks having the potential to cause a significant ESHS impact, a training plan should

1 Large dams: dams that are 15 meters or more in height, or are between 10 and 15 meters and present special design

complexities (e.g., an unusually large flood-handling requirement, location in a zone of high seismicity, or foundations that

are complex and difficult to prepare).

2 Only requirements relevant to the construction and operation are stated here.



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be prepared and implemented. The following are the proposed steps in

development and implementation of a training plan for the Project to consider.

Conduct a training needs assessment. ESHS training needs assessments are required

to be conducted to address both applicable regulatory requirements and other needs

related to the management of the significant ESHS aspects in order to ensure those

with ESHS-related responsibilities are competent to carry them out. In particular, for

each position or role, the training necessary to prevent or control hazards,

incidents/accidents and/or conflict/impacts on construction workers /employees

/communities; and further to fill the gap between current knowledge and skills and

the established competencies for the position or role. Training needs are also

identified through results of risk assessment for each activity.

Develop and implement training plans. The training plan then shall be developed

and implemented based on the outcome of the training needs assessment. A

training plan documents what training programs are needed to be run, when they

will be conducted, and who will attend. It is reviewed whenever new risks or work

activities are introduced and following any incident investigation or accident and

emergency that identifies training needs.

Competency training is conducted as soon as possible to ensure the employees or

on-site contractors receive training before beginning the assigned function.

Develop and implement training programs. Training programs shall be developed

and implemented in accordance with the training plan. All training programs

developed will meet legislative requirements at a minimum. Specific programs

concerning management of high risk activities will meet internal, Vietnamese

standards and IFC Guidelines for competency at a minimum.

Maintain and keep training records. Records of content of training plans, programs

and courses should be kept in place. For each training program, the trainer shall

make a record of course attendance. All trainings undertaken and record evidence of

each individual’s competency shall be recorded. The training needs assessment will

be readily updatable to allow for the insertion of training identified as needed or

completed.

Review and evaluate training programs. The Safety Engineer shall review an outline

of the program objectives and content from the person conducting the training,

internal or external to the Project Company, prior to conducting the training program

from the perspective of achieving an appropriate level of competency and delivering

the program at the appropriate literacy and numeracy level.

3.2.5 Framework for Livelihood Restoration Plan (LRP) and Community Development Plan

(CDP)

The following proposed framework for the Project has been provided on the basis of

a review of the information available to date and the stakeholder meetings as

mentioned in Section 7.5.5 of the Supplementary ESIA. It can be summarized as

below.



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Eight heads of eight affected villages and 25 affected households were invited for the

interview before site visit. At the site visit, the interview was conducted via face to

face interviews with 25 affected households and eight heads of villages in total. The

survey was conducted by questionnaires developed for household and village head in

two different forms. The survey aimed to collect socio-economic baseline data of the

affected communities and their awareness of the Project’s impacts including negative

and positives and their concerns.

As discussed in Section 7.5.5 of the Supplementary ESIA, the major concerns and

suggestions of the local authorities and local people in terms of livelihood restoration

and community development include:

• Irrigation system for farming. As discussed in Section 7.6.1, number of affected

households is recognised starting farming on their new reclaimed land after their

land was acquired by the Project. However, irrigation water access for such land

is reportedly a big issue and through the interview, the affected households

expected to get support to develop/improve the irrigation systems for affected

villages (i.e. of Trung Chai Commune);

• Road improvement for daily transportation. During the socio-economic survey,

apart from Luong Do and Luong Giang villages of Coc San Commune, roads

connecting between other affected villages and the main road are mainly dirt

roads or gravel tracks. During dry conditions, the dirt or gravel tracks can be

accessible by motorbike, however, during a wet conditions, they are only

accessible by foot;

• Electricity access. Of all the villages, only Luong Do and Chu Cang Ho villages are

connected to the National Electricity Grid. However, not all households in these

villages are connected to electricity grid. One reason for this is that some

households cannot afford the cost to transfer electricity from the pole to their

remote houses;

• Jobs for villagers, especially who have lost more than 70% of their land. Farming

and plantation is the two predominant livelihoods of the affected households.

Losing land is consequently leading to lose livelihoods and income. Given the low

education and working skills of the project population, finding new livelihood or

income sources will be challenging. Therefore, education and skill training are the

two primary options for livelihood restoration that the Project needs to take into

account;

• Support for vulnerable group. It is estimated that 16 % of the total affected

households is vulnerable group because of the project activities. Vulnerable

group includes:

� Women led/ abandoned households;

� Households with main earning members above the age of 70;

� Households with members who are differentially abled either mentally or

physically or injured war veterans;

� Orphans; and

� Poor households with small land holdings.

Based on the above concerns and discussion, frameworks for livelihood restoration

and community development are proposed as in Table 3.1 and Table 3.2,

respectively. It is noted that these are merely frameworks and as such they are



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subject to further update and development based on ongoing discussions between

the Project and local authorities as well as results from public

consultation/stakeholder engagement which will be conducted in the future. The

LRP and CDP will need to be reviewed periodically to ensure they address the actual

expectations of the stakeholders.

The key principles proposed for the LRP Framework are:

• Avoid significant change from the existing livelihoods;

• Ensure opportunities for all existing livelihoods affected by the project;

• Take into account health and age of affected people; and

• Pay more attention on vulnerable group.

Table 3.1 Livelihood Restoration Plan Framework

Livelihood Restoration Programs Target Groups

Vulnerable group

Land-based

livelihood

• Train and guide women to plant medicinal herbs

and sell them in the Sa Pa market at a higher price.

Dao women (i.e. Tong Sanh

Commune)

• Provide some funding for basic materials, provide

training on how to improve productivity of

vegetables and sell to the market.

Vulnerable group of the

three affected communes

Skill-based

livelihood

• Training on animal breeding (i.e. pigs and poultry

breeding).

• Provide some funding for basic materials of

breeding.

Vulnerable group of the

three affected communes

• Training on handicraft (i.e. making souvenir to sell

in Sa Pa market) etc

Mong women (i.e. Trung

Chai Commune)

Educational

opportunities

• Opportunities to continue studying to complete

high-school (e.g. continuing education program).

Young generation (i.e. 15-

20 years old) of affected

households, set priority for

households that are

considered vulnerable

Other groups

Land-based

livelihood

• Technical and financial assistance to provide access

to water for irrigation;

• Training on new agricultural practice;

• Provide seeds and seedling.

Households who lost less

than 70% of their

agriculture and plantation

land

Skill-based

livelihood

• Training on specific aspects such as animal

breeding, handicraft etc.

• Focusing on trade-based training, such as welding,

fitting, carpentry etc. to increase employability of

impacted households.

Households who lost from

and more than 70% of

their agriculture and

plantation land

In order to conduct community development activities the Project should work

closely with the local authorities. In particular, it includes but not limited to:

• take into account the local Community Development Plan developed by the local

authorities,



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• discuss with the local authorities which activities/programs are appropriate for

the Project to assist to;

• select activities/programs and in collaboration with the local authorities to

develop an action plan;

• allocate human and financial resources for selected activities/programs; and the

budget for developing these should include in the annual financial plan of the

Project.

The following is number of community development programs proposed for the

Project to take into consider. However, as discussed above these programs should be

considered in conjunction with the existing local CDPs and should be developed in

collaboration with the local authorities.

Table 3.2 Community Development Plan Framework

Community Development Programs Target groups

Infrastructure

improvement

Technical and financial support to

develop and improve:

• Irrigation system;

• Electricity transmission lines;

• Road accessing to villages

Affected villages (except Luong Do and

Luong Giang of which the infrastructure is

available) that is prioritised includes:

• Vu Lung Sung and Po Si Ngai,

• Xin Chai and Chu Lin 2,

• Ky Cong Ho and Chu Can Ho

Education support • Financial/in-kind support to

schools in the affected

communes.

• Offering of scholarship for good

students whose families are poor

and located in affected

communes.

• Trung Chai

• Tong Sanh

• Coc San

Community health

support

• Infrastructure/ facilities for health

services.

• Access to health care in remote

areas where ethnic minorities

have limited access to the public

health service.

• Trung Chai

• Tong Sanh

• Coc San

Sanitation support • Building village toilets for the

affected villages.

For all affected villages, set priority for the

affected villages of Trung Chai and Tong

Sanh.

Note: The priority order of the target groups is set based on the significance of the project impacts on

the villages and infrastructure condition status of the villages.

3.2.6 Stakeholder Engagement Plan

Stakeholder engagement including stakeholder identification, stakeholder

engagement approach during the implementation of the local EIA and the

Supplementary ESIA and a future stakeholder engagement plan was discussed in

details in Section 7.5 of the Supplementary ESIA. In this report, only actions required

for future engagement including disclosure, consultation and grievance mechanism

are included. These actions are summarized in Table 3.3.



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Table 3.3 Stakeholder Engagement Plan

Activity Purpose and Expected Outcome Time frame

Information

disclosure

and

Stakeholder

consultation

Final ESIA For stakeholders to understand the

project development, potential impacts

and commitments to mitigation

measures. The Final ESIA will present

details how concerns raised during the

stakeholder engagement process are

addressed.

Prior to resuming

construction

activities

Environmental and Social

Management Plan

(ESMP)

For stakeholders to be aware of the plan

of environmental and social

management of the project.

Opinions of stakeholders on the plan

should be considered by the project

owner in updating the plan.

Prior to continue

construction

activities

Livelihood Restoration

Plan (LRP)

For stakeholders to be aware of the

livelihood restoration activities offered

by the Project. Opinions of stakeholders

on the plan should be considered by the

project owner in updating the plan.

Consultation: When

the Draft LRP is

ready.

Disclosure: When

the Final LRP is

ready.

The Final LRP should

be completed prior

to operation phase.

Community

Development Plan (CDP)

For stakeholders to be aware of the

community development activities

offered by the Project. Opinions of

stakeholders on the plan should be

considered by the project owner in

updating the plan.

Consultation: When

the Draft CDP is

ready.

Disclosure: When

the Final CDP is

ready.

Environmental and Social

Monitoring Report

For stakeholders to follow the

environmental and social management

status of the project.

Semi-annually

during construction

and operation

Grievance mechanism For affected/interested people to be

aware of the availability of a grievance

mechanism.

Immediately after a

formal grievance

mechanism has

been approved

Grievance

mechanism

Develop a grievance

mechanism and allocate

a person/team to be in

charge to receive and

response grievances/

concerns of affected/

interested people and

provide guidance to such

people on grievance

mechanism.

For affected/interested people to lodge

their grievances/concerns to the project

owner and/or local authority

Prior to resuming

construction

activities



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Activity Purpose and Expected Outcome Time frame

On-going

consultations

The Project should keep the

stakeholders updated with any change in

the project development throughout

project life.

The stakeholders should be consulted if

the project’s change may affect them.

Grievance mechanism should be always

available for the stakeholders and

interested people to lodge their

concerns/complaints.

Throughout the

project life



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4 PROJECT ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

4.1 OBJECTIVES OF THE ESMP

The objectives of the ESMP include:

• Ensuring compliance with regulatory authority stipulations and guidelines which

include local, national and international;

• Ensuring that there is sufficient allocation of resources on the project budget so

that the scale of ESMP-related activities is consistent with the significance of

project impacts;

• Verifying environmental and social performance through information on impacts

as they occur;

• Responding to unforeseen events; and

• Providing feedback for continual improvement in environmental and social

performance.

4.2 IMPACT ASSESSMENT SUMMARY

Impacts and mitigation measures as identified in the Supplementary ESIA are

summarised in Table 4.1.

Table 4.1 Impact Assessment Summary

Project Activities/Impacts Significance of Impacts

Aspects Impacts

Impact

Direction

Before

Mitigation With Mitigation

Construction

Hydrology and

water quality

Land clearance, excavation,

backfilling, dumping, and

construction works Negative Minor Minor

Industrial and domestic

wastewater Negative Minor Minor

Impacts on downstream

sedimentation and erosion Negative

Minor to

Moderate Minor

Biodiversity and

ecosystem

services

Potential habitat loss,

fragmentation and

vegetation removal Negative Minor Minor

Disturbances to wildlife

(particularly species of

conservation interest) Negative

Negligible to

Minor

Negligible to

Minor

Potential impacts in the

intermediate stage

between construction and

operation Negative Minor Minor

Social

Land loss and change of

land use purposes Negative Major Moderate

Loss of livelihoods and

income Negative Major Moderate

Increase in prevalence Negative Moderate Minor



18

Project Activities/Impacts Significance of Impacts

Aspects Impacts

Impact

Direction

Before

Mitigation With Mitigation

diseases including water-

born, vector-born and

sexually transmitted

diseases (STDs)

General disturbances and

tension with local

community Negative Moderate Minor

Public safety issue adjacent

to the Project site and

along the Highway 4D Negative Moderate Minor

Impacts on social and

cultural heritages Negative Negligible Negligible

Increase pressure on basic

infrastructure, services and

local government capacity Negative Moderate Minor

Increase of local

employment and revenue Positive - -

Increase in expenditure due

to increased wages and

employment opportunities Positive - -

Operation

Hydrology and

water quality

Water impairment within

the reservoir Negative Minor Minor

Impacts on bypass reach Negative

Minor to

Moderate Minor

Impacts on flow

downstream of

powerhouse Negative Negligible Negligible

Impacts on downstream

sedimentation and erosion Negative

Minor to

Moderate Minor

Biodiversity and

ecosystem

services

Potential impacts on

aquatic and riparian

habitats and flora Negative Moderate Moderate

Impacts on aquatic fauna Negative Moderate Moderate

Impacts on terrestrial fauna Negative Negligible Negligible

Social

Impacts on livelihoods Negative Negligible Negligible

General disturbances and

tension with local

community Negative Minor Minor

Increase in local

employment opportunities,

taxation revenue, and

demand for materials and

services Positive - -

Increase in the supply of

electricity Positive - -

4.3 THE OUTLINE ESMP

The identified impacts and proposed mitigation and management measures including

verification, reporting schedules and responsibilities for implementation of this ESMP

are outlined in Table 4.2. The mitigation and management measures included in this

outline ESMP reflect all mitigation and management measures required by the

Supplementary ESIA and the local EIA (i.e. Registration of Environmental Standard



19

Satisfaction). It is noted that the following mitigation and management measures are

only proposed for the negative impacts assessed Minor to Moderate and Major as

summarized in Table 4.1.



20

Table 4.2 Outline ESMP

No. Source of Impact Potential Impact/

Issue

Reference Specific Actions (including parameters, location

and standards/thresholds)

Means of Verification Timing and

Frequency

Responsibility Reporting

Requirements

A. Construction

1 Hydrology and Water Quality

1.1 Impact on

downstream

water quality -

Land clearance,

excavation,

backfilling,

dumping, and

construction

works

Elevated bed and

suspended sediments

in water column

Section

5.3.1 –

SESIA and

Section

5.1.2.1 –

Local EIA

• Carry out the construction strictly according

to the blueprint and the specification.

• Prohibit counter-gradient slope in excavation

and over-excavation.

• Before construction, build the construction

site with water intercepting and draining

ditches and sand sediment ponds, to reduce

flow of sands and slag entering the rivers and

minimize the effects on water quality due to

construction site runoff that contains soil,

stone, coarse debris and slags etc.

• Consider effective measures for cutting up

water and drainage in design.

• Fence the foundation pits with water binders

to prevent such foundations from being

soaked and generating sediment-laden runoff

to water environment; timely drain the water

buildups, and backfill the completed pits to

eliminate possible sources of sediment-laden

runoff.

• Protect the excavation workface from direct

exposing to surface and ground water so as

to avoid soil collapsing and eroding from

entering the water environment. Carry out

the earth excavation on layer by layer from

up to down and load the earth material from

excavation into the truck directly and then

deliver to the dumping sites designated for

the project.

• Conduct monitoring

on physical-chemical

parameters of surface

water and effluent

from construction

site.

• Semi-annually

during

construction

• Environmental

Officer and

Construction

Department

• Submit the

monitoring

report to

DoNRE

1.2 Impact on

downstream

water quality -

Industrial and

domestic

wastewater

Water pollution due to

fuels (i.e. petroleum,

gasoline, lubricant etc.)

and waste oil from

maintenance sites and

vehicles

Section

5.3.1 -

SESIA and

Section

5.1.2.1 –

Local EIA



21


Issue




Frequency


Requirements

• Minimize the land clearance areas where

possible, add surface protection and re-

vegetation after finishing the construction to

control soil erosion caused by rainstorm.

• Collect hard wastes (i.e. soil, stone, coarse

debris) not to let water flow sweep them

down to the stream, to limit the pollution of

the water resources.

• After finishing the dumping of waste the

dumping sites, cover waste tailings dumping

by growing grass or plants on top and surface

to avoid overflowing and runoff washing out

to the surface water source.

• Prepare a construction plan including

construction elements, sequence and

number of construction workers to minimize

the potential impacts; and avoid the rainy

(flooding) season for construction.

Water pollution due to

domestic wastewater

Section

5.1.2.1 –

Local EIA

• Construct septic tanks to collect and treat

domestic wastewater during construction.

• Conduct the

monitoring on

effluent from the

construction site

• Semi-annually

during

construction

• Environmental

Officer

• Include in the

environmental

monitoring

report

1.3 Impacts on

downstream

sedimentation

and erosion due

to construction

of Mong Sen

Reservoir

Change the Dum

River’s hydraulic and

sediment transport

characteristics

Section

5.3.4 –

SESIA and

Section

4.1.2.2 –

Local EIA

It is difficult to predict the locations and rates of

erosion and sedimentation downstream of the

Mong Sen Reservoir with certainty, the following

countermeasures should be considered should

erosion become a concern at certain locations.

• Seasonal inputs of fine sediment to the

tailwater from the reservoir;

• Conduct the

monitoring on

erosion including

stream bed, stream

bank and cross

sections

• Quarterly during

construction

Environmental

Officer and

Construction

Department

Internally report

on eroded and

failing river bank

locations to the

Project Manager



22


Issue




Frequency


Requirements

• Energy dissipaters where flows are outlet

into the main flow in combination with the

bank strengthening and erosion control

measures to limit erosion at these

vulnerable locations; and

• Bank strengthening and stabilisation

measures could be hardened concrete

structures, gabion, rip rap, river training

with logs, and strategic placement of

vegetation.

• Avoid dumping waste rock near the Dum

River.

downstream the

powerhouse

• Conduct the

monitoring on

sediment loads to

the reservoir to

identify the changes

in sediment loads

from the upstream

drainage area.

• Conduct visual

inspection of all

river banks to

evaluate and report

eroded and failing

river bank locations.

• NA


construction

• Monthly during

construction

• NA

2 Biodiversity and Ecosystem Services

2.1 Land clearance

and construction

activities

Loss and fragmentation

of habitat and existing

vegetation

Section

6.4.1 -

SESIA

Site reinstatement by the following activities:

• Roadside tree planting along the access

roads;

• Restore the areas under the transmission

corridor (except the tower footprint) and

temporary facilities (e.g. offices, camp,

storehouse and material processing plants)

scattered throughout the Project site to their

original status at the end.

Minimise the impacts caused by construction

activities of the Project:

• Avoid any damage and disturbance,

particularly illegal dumping on the areas

other than those designated, to the

NA NA Environmental

Officer and

Construction

Manager

Internally report

to the Project

Manager



23


Issue




Frequency


Requirements

surrounding vegetated area in particular

where close to the river during

construction;

• Restrict all construction activities within the

works boundary, regularly check the work

site boundaries to ensure that they are not

breached and that damage does not occur

to surrounding areas in particular the river;

and

• Prohibit and prevent open fires within the

Project site and provide temporary

firefighting equipment on site.

Disturbances on

wildlife including:

• A reduced density

of disturbance-

sensitive species

around the source

of impact;

• Habitat

fragmentation

resulting from the

new access roads

and transmission

line; Wildlife traders

and loggers.

Section

6.4.2 -

SESIA

• Conduct training on the importance of

ecological resources and how to protect

them (including awareness-raising regarding

illegal hunting) for all workers.

• Restrict all construction activities within the

works boundary.

• Restrict hunting, fishing and open fire on

site and in nearby areas.

• Control the minimum speed of equipment

and vehicles to not disturb fauna, especially

those which may be nocturnal or have

specific migratory routes.

• Minimise dust, light, noise and vibration to

reduce disturbance to animals during

construction.

• Shorten duration of river closure/ diversion

for the construction of water retaining dam

as much as practicable.

NA NA Environmental

Officer and

Construction

Manager

Internally report

to the Project

Manager

3 Accidents and incidents

3.1 Fire and

explosion

Bush fire Section

5.1.6 –

• Develop and implement waste management NA NA Health and Safety

Officer

Internally report

to the Project



24


Issue




Frequency


Requirements

accidents Local EIA plan to avoid from inappropriate waste

disposal and waste burning;

• Raise awareness of onsite workers about

forest protection and fire and explosion

fighting and prevention.

Manager

Occupational health

and safety

Section

5.1.6 –

Local EIA

• Ensure the design of the explosive storage

area meet safety requirements of Vietnam

relevant regulation.

• Record all explosive materials used for

construction activities (i.e. blasting).

• Make announcement to surrounding

communities prior to blasting.

• Install warning signs at the blasting areas.

• Provide emergency response and

occupational health and safety training for

all workers working on site.

• Provide PPE for all workers working on site.

• Check all equipment before operating.

NA NA Health and Safety

Officer

Internally report

to the Project

Manager

3.2 Traffic accidents Traffic accidents Section

5.1.6 –

Local EIA

• Develop and implement a Traffic Control

Plan to avoid increasing local traffic.

• Ensure all vehicles of the Project meet

safety and technical requirements of

Vietnamese relevant regulations.

• Install speed control signs surrounding the

project area and ensure all drivers comply

with the required speed at the area near

the site.

NA NA Health and Safety

Officer and

Construction

Manager

Internally report

to the Project

Manager



25


Issue




Frequency


Requirements

4 Social

4.1 Land acquisition Land loss and change

of land use purposes

Section

7.6.1 -

SESIA

• Pay the unpaid amount to eight affected

households who have not received full

compensation payment.

• Issue advanced warning to the land owners

who are still cultivating on land in the area of

the future reservoir after acquisition.

• Incorporate concerns and suggestions of

affected households collected from the audit

to the Livelihood Restoration Plan (LRP);

• Develop and implement a LRP aiming to

guide and support the PAP on restore their

livelihoods and income, targeting at

vulnerable groups in particular.

• Develop a SEP including assigning Community

Liaison Officer to ensure effective project

information disclosure and communication

with the PAP, including develop and disclose

a Grievance Procedure.

• Assist local Community Development Plan

focusing on nine affected villages.

• Conduct completion

audit for the

compensation

payment to evaluate

livelihood and income

restoration after

compensation.

• Conduct the

monitoring on the

implementation of

livelihood restoration

and community

development

programmes.

• Conduct a completion

audit for the


programmes.

• Conduct the

monitoring on

stakeholder

engagement.

• One-off when

compensation

payment has been

completed.


the

implementation of

the LRP and CDP.

• One-off when the

LRP has been

completed.


the project’s life.

Community Liaison

Officer and

Construction

Department

Internally report

to the Project

Manager

Loss of livelihoods and

income

Section

7.6.1 -

SESIA

• Develop and fully implement a LRP and a SEP.

• Keep updating the LRP until livelihood of

affected people are proved to be completely

restored or improved.

• Conduct the

monitoring on

stakeholder

engagement and


programmes.

• Conduct a completion

audit for the


programmes when

these have been


the

implementation of

the LRP and during

project’s life for

the SEP.

• One when the LRP

has been

completed.

Community Liaison

Officer and

Construction

Department

Internally report

to the Project

Manager



26


Issue




Frequency


Requirements

completed.

3.2 Influx of workers

to the project

area

Increase in prevalence

diseases including

water-born, vector-

born and sexually

transmitted diseases

(STDs)

Section

7.6.1 -

SESIA

Implement good practices and close cooperation

between the Project managers, contractors and

local authorities as follows:

• Develop and implement the Code of Conduct

(CoC) for the project to regulate the

performance of all workers to be onsite.

• Conduct training on public health, including

STDs, for all construction workers prior to the

commencement of construction.

• Require contractor to provide recreational

activities to workers.

• Patrol the presence of sex workers in the

construction area.

• Propagandise public health and sanitary

protection in corporation with local

authorities and clinics.

• Conduct the health

and safety

performance

monitoring at the

project site.

• Conduct health and

safety audit.


construction.

• Annually during

construction.

Community Liaison

Officer and Quality

and Safety

Department

Internally report

to the Project

Manager

General disturbances

and tension with local

community

Section

7.6.1 –

SESIA and

Section

5.1.5 –

Local EIA

• Develop and implement the SEP including

information disclosure, public consultation

and grievance mechanism to guide the

communication with local community and

other stakeholders.

• The construction contractor will designate

ethnically representative Community Liaison

Officers for each construction team with the

responsibility for interacting with the local

community.

• Deliver joint Contractor induction training on

CoC to provide guidance on requirements for

culturally appropriate behaviours, and an

overview of the risks to foreign staff whilst in

Vietnam. The training will include key

sensitivities to ensure workers do not

• Conduct the

monitoring on

stakeholder

engagement.

• Record and keep

records of all

induction training.



• At the time of

induction training

provision.

Internally report

to the Project

Manager



27


Issue




Frequency


Requirements

unintentionally cause offense to important

local cultural and spiritual practices.

• Provide training on CoC and Human Right to

the security team of the project.

• In collaboration with the local authorities,

collect data on influx of workers and propose

appropriate management plan to control the

influx and prevent the influx related issues.

3.3 Increase local

traffic due to

construction

activities

Public safety issue

adjacent to the Project

site and along the

Highway 4D

Section

7.6.1 -

SESIA

• Set a speed limit on the access roads.

• Clearly demarcate and flag the construction

site.

• Timely communicate to and announce other

road users (including buffalo herders that

herds their stocks near the roads or use the

roads to access to grazing land) regarding

passing of oversized or substantial amounts

of heavy machinery and equipment.

• Establish a security team to ensure no

entrance of local people to the construction

site.


and safety

performance

monitoring at the

project site.


safety audit.


construction.

• Annually during

construction.

Community Liaison

Officer and Quality

and Safety

Department

Internally report

to the Project

Manager

Increase of pressure on

basic infrastructure,

services and local

government capacity

Section

7.6.1 -

SESIA

• Communicate to hired workers that family

members should not move to the area, due

to the limited availability of local facilities and

services.

• Offer the construction workers suitable leave,

as well as an appropriate salary to enable

them to regularly visit their family during

their time of employment.

• Set up clinic to provide basic healthcare for

workers during the construction phase. This

clinic should be open to local residents.

• All foreign workers will be registered with the


and safety

performance

monitoring at the

project site.

• Conduct the

monitoring on

stakeholder

engagement.


safety audit.


construction.


project’s life.

• Annually during

construction.

Community Liaison

Officer and Quality

and Safety

Department

Internally report

to the Project

Manager



28


Issue




Frequency


Requirements

administrative government as required by

Vietnamese law.

• Develop and implement the SEP and delegate

Community Liaison Officers and induction

training for workers to reduce the potential

issues that need governance.

B. Operation

1 Hydrology and Water Quality

1.1 Impact on

downstream

water quality -

Water

impairment

within the

reservoir

Water temperature

increase, oxygen levels

decrease and changes

in chemistry and

organism and nutrient

runoff loads

Section

5.3.1 –

SESIA and

Section

5.2.1.1 –

Local EIA

Due to the nature of the project, small changes

in downstream water quality are expected as a

result of the reservoir water impoundment. No

specific mitigation measures are considered to

be required in this regard. However, some

sediment control good practices should be

considered to be implemented to reduce

sediment and agricultural runoff from entering

the reservoir. These include:

• riparian buffers,

• control of deforestation within the

watershed,

• planting trees for recovering vegetation cover

along reservoir bank,

• develop and implement a bottom withdrawal

for removing bed sediment of the reservoir,

• consider to select the appropriate fertilizer

for the vegetation cover along reservoir bank.

• NA • NA • Safety and CSR

Officer

• Internally

report to the

Plant Director

1.2 Impact on the

bypass reach-

Interruption of

the water flow

along a 7 km

stretch of the

Dum River

Changes in river

morphology between

the dam and the

powerhouse, including

shallower water depth,

narrowing wetted

channel width, slower

Section

5.3.2 –

SESIA and

Section

5.2.1.1 –

Local EIA

• Keep the ecological flow rate of 0.55m3/s

from the Mong Sen Reservoir to sustain the

downstream ecological environment. It is

noted that this value is subject to change and

approval of relevant authorities if there is any

change relating to the surface water

exploration permit of the Project.


on the effectiveness

and adequacy of the

maintained ecological

flow rate.

• Annually in two

years

• Safety and CSR

Officer

• Internally

report to the

Plant Director



29


Issue




Frequency


Requirements

between the dam

and the

powerhouse

flow velocity, and

decreases in frequency

and magnitude of

channel-forming floods

compared to the

existing flow and

morphologic conditions

• Review of the effectiveness and adequacy of

the maintained ecological flow rate. The

ecological flow rate may require to be

adjusted according to the results of the

review.

• Comply with the Reservoir Operation

Procedure in inundation and discharge.

1.3 Impacts on

downstream

sedimentation

and erosion -

Reservoir storage

will act as a

physical barrier

to the sediment

transport

downstream

Change in

sedimentation and

erosion patterns and

stream morphology

Section

5.3.2 –

SESIA

It is difficult to predict the locations and rates of

erosion and sedimentation downstream of the

Mong Sen Reservoir with certainty, the following

countermeasures should be considered should

erosion become a concern at certain locations.

• Seasonal inputs of fine sediment to the

tailwater from the reservoir;

• Energy dissipaters where flows are outlet

into the main flow in combination with the

bank strengthening and erosion control

measures to limit erosion at these

vulnerable locations; and

• Bank strengthening and stabilisation

measures could be hardened concrete

structures, gabion, rip rap, river training

with logs, and strategic placement of

vegetation.

• Conduct the

monitoring on

erosion including

stream bed, stream

bank and cross

sections downstream

the powerhouse.

• Conduct the

monitoring on

sediment loads to the

reservoir to identify

the changes in

sediment loads from

the upstream

drainage area.

• Conduct visual

inspection of all river

banks to evaluate and

report eroded and

failing river bank

locations.

• Semi-annually

during operation.

• Annually during

operation.

• Monthly

inspection during

operation.

Safety and CSR

Officer

Internally report

to the Plant

Director



30


Issue




Frequency


Requirements

2 Biodiversity and Ecosystem Services

2.1 Diversion of

impounded

water from the

Mong Sen

Reservoir via

diversion tunnel

Potential impacts on

aquatic and riparian

habitats and flora

Section

6.4.4 –

SESIA and

Section

5.2.2.1 –

Local EIA

• Control the flow rate of 0.55 m3/s at all the

time. It is noted that this value is subject to

change and approval of relevant authorities

if there is any change relating to the surface

water exploration permit of the Project.

• Separate water behind the dam of the

Mong Sen reservoir as to fulfil the

downstream water demand.

• Free overflow flood water from the Mong

Sen Retaining dam during the wet season.

• Planting trees for recovering vegetation

cover along reservoir bank and the project

area.

NA NA Safety and CSR

Officer

Internally report

to the Plant

Director

2.2 Changes in

aquatic habitats

and the loss of

habitat

connectivity

between the

areas upstream

and downstream

of the dam due

to the change in

flow

Impacts on aquatic

fauna

Section

6.4.5 -

SESIA and

Section

5.2.2.2 –

Local EIA

• Guarantee ecological flow rate no less than

0.55 m3/s in the diversion reach. It is noted

that this value is subject to change and

approval of relevant authorities if there is

any change relating to the surface water

exploration permit of the Project.

• Review of the effectiveness and adequacy

of the maintained ecological flow rate. The

ecological flow rate may require to be

adjusted according to the results of the

review.

• Reforest the area temporarily occupied

during the project’s construction.

• Raising awareness of workers and

community in forest protection.


on the effectiveness

and adequacy of the

maintained ecological

flow rate.

• Annually in two

years

• Safety and CSR

Officer

• Internally

report to the

Plant Director



31


Issue




Frequency


Requirements

3 Social

3.1 Non-local

workers/

migrants

Tension with local

community

Section

7.6.2 -

SESIA and

Section

5.2.3 –

Local EIA

• Keep implementation of the SEP during the

project’s life to guide the communication

with local community and other

stakeholders.

• Provide training on Code of Conduct, Human

Right and traffic safety to all employees,

especially the security team of the project.

• Ensure all non-local workers are registered

with the local authority.

• Monitor the

implementation of

stakeholder

engagement.

• Record and keep

records of all training.

• Record all non-local

workers.



• At the time of

training provision.

• When new hiring

of non-local

workers happens

Safety and CSR

Officer and Admin

Department

Internally report

to the Plant

Director



32

4.4 MONITORING PLAN

Monitoring serves to supply information to create a better understanding of the

Project’s impact on the environment so that adequate management actions can be

taken to reduce liability during the Project’s life.

Monitoring must be kept to a manageable task and therefore must target the most

important instructions in the ESMP, where the risk of environmental damage is the

greatest.

Monitoring should cover the following:

• monitor the higher risk activities/areas more frequently;

• regular collection of samples for scientific analysis;

• routine observations of behaviors and practices;

• noting of unusual events, incidents and accidents (natural and human triggered);

• changing trends in results over time;

• brief statement on whether or not conditions of the ESMP are being met; and

where it is reportable to authorities;

• data analysis by competent personnel;

• possible reasons why conditions are not being met;

• corrective action plans; and

• monitoring results from corrective action plans.

Table 4.3 provides details of the monitoring plan as part of this ESMP. It is noted that

this monitoring plan is an integrated plan of the monitoring programs required by the

Supplementary ESIA and local EIA. This monitoring plan must be periodically reviewed

and updated as per any change in the Project development.



33

Table 4.3 Monitoring Plan

Topic Aspect Objective/Parameters Frequency Recording and Reporting Responsibility Reference

A. Construction

Hydrology and

water quality

Water quality • Physical - chemical parameters of surface

water and effluent from construction site.

• Sediment loads to the reservoir to identify

the changes in sediment loads from the

upstream drainage area.

• Semi-annually during

construction


construction

• Submit the monitoring report

to DoNRE

• Environmental

Officer

• SESIA

Erosion • Erosion including stream bed, stream bank

and cross sections downstream the

powerhouse

• Visual inspection of all river banks to evaluate

and report eroded and failing river bank

locations


construction

• Monthly during

construction

• Internally report on eroded

and failing river bank locations

to the Project Manager

• Environmental

Officer and

Health and Safety

Officer

• SESIA

Biodiversity and

ecosystem

Biodiversity and ecosystem • Minimize the loss and fragmentation of

habitat and existing vegetation


construction

• Include in the environmental

monitoring report to submit

to the DoNRE

• Environmental

Officer

• Local

EIA

Air quality Air quality • TSP, CO, NOx, SO2, THC, and Pb • Semi-annually during

construction



to the DoNRE

• Environmental

Officer

• Local

EIA

Noise, vibration Noise, vibration • Ensure limiting construction activities

creating high noise level at nigh time

• NA • Include in the environmental


to the DoNRE

• Environmental

Officer

• Local

EIA

Social Land loss and change of land use

purposes

• Compensation payment to evaluate

livelihood and income restoration after

compensation.

• The implementation of livelihood restoration

• One-off when

compensation payment

has been completed.

• Quarterly during the

implementation of the

• Internally report to the Project

Manager


Manager

Community Liaison

Officer (for all of

these monitoring)

• SESIA



34


and community development programmes.

• Completion of the livelihood restoration

programmes.

• Stakeholder engagement.

LRP and CDP.

• One-off when the LRP

has been completed.


project’s life.

• Completion audit report to

the Lenders


Manager

Influx of workers to the project

area; and

Increase local traffic due to

construction activities

• Health and safety performance at the project

site.

• Health and safety audit.


construction.

• Annually during

construction.


Manager

• Community

Liaison Officer

and Health and

Safety Officer

• SESIA

B. Operation

Hydrology and

Water Quality

Water Quality • Sediment loads to the reservoir to identify

the changes in sediment loads from the

upstream drainage area.

• H2S and CH4 generated near the dam

• Water quality at discharge point and points

along Ngoi Dum stream. Monitoring

parameters include pH, electrical

conductivity, oxygen demand (DO),

turbulence, Total Disposal Solid (TDS),

Chemical oxygen demand (COD), Biochemical

oxygen demand (BOD), Phosphate, Nitrate,

Metal, Coliform, etc.

• Flooding, erosion, and sediment in rainy

season

• Annually

• Semi-annually

• Semi-annually

• NA

• Internally report to the Plant

Director



to the DoNRE



to the DoNRE



to the DoNRE

Safety and CSR

Officers (for all of

these monitoring)

• SESIA

• Local

EIA

• Local

EIA

• Local

EIA

Hydrology and erosion • The effectiveness and adequacy of the

maintained ecological flow rate.

• Erosion including stream bed, stream bank

and cross sections downstream the

powerhouse

• Annually in two years


operation.

• Monthly inspection


Director


Director

Safety and CSR

Officers (for all of

these monitoring)

• SESIA

• SESIA



35


• Visual inspection of all river banks to evaluate

and report eroded and failing river bank

locations.

• Flow rate, water level at the downstream

• Water loads to the reservoir

• Downstream water use

during operation.

• Semi-annually

• Annually

• Semi-annually


Director



to the DoNRE



to the DoNRE



to the DoNRE

• SESIA

• Local

EIA

• Local

EIA

• Local

EIA

Biodiversity and

Ecosystem

Services

Biodiversity and Ecosystem

Services

• The effectiveness and adequacy of the

maintained ecological flow rate

• Fauna, flora and fish in the reservoir

• Biodiversity decrease

• Annually in two years

• Semi-annually

• Semi-annually


Director



to the DoNRE



to the DoNRE

Safety and CSR

Officer (for all of

these monitoring)

• SESIA

• Local

EIA

• Local

EIA

Noise and

vibration

Noise and vibration • Noise and vibration • Semi-annually • Include in the environmental


to the DoNRE

• Safety and CSR

Officers

• Local

EIA

Social Stakeholder engagement • Stakeholder engagement implementation


project’s life.


Director

• Safety and CSR

Officer

• SESIA



36

4.5 ESMP AUDIT, REPORTING AND CORRECTIVE ACTION

4.5.1 Monitoring, Auditing and Reporting

The performance and effectiveness of the various elements of the ESMP can be

evaluated via monitoring and audit, and if necessary corrective actions can be

implemented.

Monitoring and monitoring reporting requirements for elements of environmental and

social performance are included in the Outline ESMP as Table 4.2. Report of

environmental and social performance monitoring including all monitoring results of all

elements of the ESMP should be prepared on an semi-annual basic and submitted to the

Project Manager (construction phase)/ Plant Director (operation phase) for their review.

Third party audit should be conducted annually to entirely evaluate the environmental

and social performance of the Project against the ESMP requirements. Audit report shall

be submitted to and reviewed by the Project Manager in construction phase and Plant

Director in operation phase.

4.5.2 Corrective Actions

Corrective actions and disciplinary procedures should be set out, and where possible,

included in contractual agreements (i.e. with the contractor). Without fixed disciplinary

action there is a risk that environmental and social management measures will not be

implemented.

Where the persons in charge for implementation of the ESMP find that the

contractor/sub-contractor has violated the environmental and social management

measures set out in their contractual agreement(s), corrective actions and disciplinary

actions will be taken. “Management of contractor non-conformance” of the Contractor

Management Plan (Section 3.2.1) should be applied.

During the Project life, in event of any changes occur, the persons in charge need to

follow the Change Management Plan as proposed in Section 3.2.2 to deal with these.

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