Ahmedabad Municipal Corporation and Gujarat Urban Development Mission Government of Gujarat Gujarat Resilient Cities Partnership: Ahmedabad City Resilience Project (G-ACRP) P175728 Negotiated ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) September 27, 2022 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. India, through the Government of Gujarat (GoG) will implement the Gujarat Resilient Cities Partnership: Ahmedabad City Resilience Project (the Project), with the involvement of the Ahmedabad Municipal Corporation (AMC), and Gujarat Urban Development Mission (GUDM), as set out in the Loan Agreement. The International Bank for Reconstruction and Development, has agreed to provide the financing (P175728) for the Project, as set out in the referred agreement. 2. The GoG shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the World Bank. The ESCP is a part of the Loan Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement(s). 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the GoG shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the World Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the World Bank. 4. As agreed by the World Bank and the GoG, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the GoG through AMC and GUDM and the World Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the World Bank and the GoG, the Commissioner of AMC and the CEO of GUDM. The GoG shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Quarterly reports to the World Bank AMC and GUDM Prepare and submit to the World Bank regular monitoring reports on the environmental, throughout Project implementation, social, health and safety (ESHS) performance of the Project, including but not limited to commencing after the Effectiveness the implementation of the ESCP, status of preparation and implementation of E&S Date. Submit each report to the World instruments required under the ESCP, stakeholder engagement activities, and Bank no later than 30 days after the end functioning of the grievance mechanism(s) ESMP implementation, Monitoring of of each reporting period. Environmental parameters as in ESIA Monitoring Plan Submit Annual Third Party Audit to the World Bank Audit to be conducted at the end of each implementation year, and report to be submitted within a month of completion of audit B INCIDENTS AND ACCIDENTS Notify the World Bank no later than 48 hours after learning of the incident or AMC and GUDM Promptly notify the World Bank of any incident or accident related to the Project which accident. has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, cases of sexual exploitation and Provide subsequent report to the World abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or Bank within one month after learning of multiple injury [specify other examples of incidents and accidents, as appropriate for the the incident or accident. type of operation]. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate. Subsequently, at the World Bank’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence; Insurance, Corrective Actions and Status of its implementation C CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the Require contractors and supervising firms to provide monthly monitoring reports on World Bank as annexes to the reports to AMC ESHS performance to AMC in accordance with the metrics specified in the respective be submitted under action A above. bidding documents and contracts, and submit such reports to the World Bank. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain a PIU in AMC with qualified staff and resources to support Establish and maintain a PIU at AMC as AMC management of ESHS risks and impacts of the Project including one Environmental set out in the Loan Agreement. Recruit Specialist, one Environmental Engineer specialized in Sewerage and Drainage works with all required staff by Project appraisal expertise and experience on Occupational and Community Health and Safety, one Social completion, and thereafter maintain development and Resettlement Specialist, and one Stakeholder Engagement and Gender these positions throughout Project Specialist. implementation. Nominate/recruit one environmental specialist and one social specialist in GUDM Nominate/recruit required staff by GUDM Project appraisal completion, and thereafter maintain these positions throughout Project implementation. Engage a qualified Project Management Consultant (PMC) to support AMC PIU with Within one month of signing legal AMC sufficient E&S staffing (as in ESMF) and engage a qualified RAP implementation consultant. agreements AMC to include in bid documents that each contractor (including DBOT contractors) will The specialists will need to be included AMC be required to have qualified and experienced (as per ToR in ESMF) Environmental as essential manpower in the Bid Specialist, Environmental Engineer with qualification and experience in Occupational and Documents and in the bid submitted by Community Health and Safety, Heritage Specialist, Biodiversity Management Specialist, the contractors including DBOT and Social Development Specialist on its payroll and ensure that these specialists remain contractors and they will start working engaged throughout the project period no later than 30 days after contract signing between AMC and the contractors or issue of Letter of Intent by AMC to start the works to the contractor; whichever is earlier. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS Prepare and disclose the Environmental and Social Management Framework (ESMF) Adopt the ESMF prior to Project AMC and GUDM consistent with the relevant ESSs. appraisal, and thereafter implement the ESMF throughout Project implementation. AMC Prepare and disclose updated ESIAs for subprojects on STP rehabilitation and / or new construction (Vasna 240 MLD STP and Vasna 350 MLD STP) based on Feasibility Reports 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY to initiate DBOT Contract procurement which will be implemented initially following Preparation of ESIAs to be coterminous ESMF procedures. These shall be updated as per the Detailed Designs when prepared by with Feasibility Studies. Finalization, DBOT contractor during implementation stage. Approval and Disclosure updated ESIAs and ESMP based on detailed designs shall be completed before issue of bid AMC documents to the contractors. To be updated by the DBOT contractor prior to start of works Prepare, get approved, disclose, update ESIAs for all subprojects and technical Assistance Preparation of ESIA to be coterminous activities following ESMF procedures. with detailed design of investments by DBOT contractors, Consultants. These Cause DBOT contractors to adopt, update and implement the subproject-specific should be prepared and approved as Environmental and Social Impact Assessment (ESIA) and Environmental and Social per ESMF prior to initiating any work on Management Plan (ESMP) based on final detailed design, as set out in the ESMF and site. Once adopted, implement the AMC ESIAs. respective ESMP throughout sub- project implementation. 1.3 MANAGEMENT OF CONTRACTORS Incorporate the relevant aspects of the ESCP, ESMS, ESIAs, ESMPs, including the relevant Prior to issuance of Expression of AMC E&S documents and/or plans, and the Labor Management Procedures, into the ESHS Interest (EOI) notice for contractors specifications of the procurement documents with contractors. Thereafter ensure that the contractors comply with the ESHS specifications of their respective contracts Bidding documents and contracts to include relevant measures of the ESMP 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY During Bid document preparation Preparation of Contractors-ESMP that will include Cultural Heritage Management Plan and Biodiversity Management Plan where applicable, Waste Management Plan, OHS Plan, SEA/SH Action Plan, Community Health and Safety Plan, Labor Management Plan, Traffic One month prior to site mobilization Management Plan, Waste Management Plan, Workers’ Camp Management Plan, etc. that will be acceptable to AMC, and the World Bank 1.4 TECHNICAL ASSISTANCE Ensure that the consultancies, studies, capacity building, training, and any other Throughout Project implementation. AMC and GUDM technical assistance activities under the Project including, inter alia TA sub-components under components 1 and 3 are carried out in accordance with terms of reference acceptable to the World Bank, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. GUDM will apply the provisions of ESMF, RPF and other instruments for TA activities as Throughout Project implementation. relevant. 1.6 ASSOCIATED FACILITIES Identify “Associated Facilities� as per ESF by screening of all sub-projects, as part of Throughout Project implementation subproject ESIAs and management/mitigation measures shall be proposed in ESMP. Ensure that all Associated Facilities meet the requirements of the ESSs, to the extent that AMC has control or influence over such Associated Facilities. In cases where the requirements of the ESSs cannot be followed, the Bank will require AMC to demonstrate the extent to which it cannot exercise control or influence over the Associated Facilities by providing details of the relevant considerations, which may include legal, regulatory and institutional factors. The Bank team will review each case and make a final decision based on available facts and information. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Prepare, adopt and disclose the LMP AMC prior to appraisal, and thereafter implement the LMP throughout Project implementation. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Prepare, adopt and implement the Labor Management Procedures (LMP) for the Project, including, inter alia, provisions on working conditions, management of workers relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish grievance mechanism prior engaging Project workers and AMC Establish, maintain, and operate a grievance mechanism for Project workers, as thereafter maintain and operate it described in the LMP and consistent with ESS2 and with prevailing national and throughout Project implementation. state labor laws and specific legislations on construction workers. The GRM will be responsive to SEA/SH complaints. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Prepare, adopt, and implement occupational, health and safety (OHS) measures specified OHS plan will be prepared by contractor in the LMP. prior to site mobilization and AMC and GUDM implemented during civil works Contractors EHS person shall have qualification in Life & Fire Safety, and prepare L&FS For all contracts, throughout plan and implement the same implementation Monitor and Supervise OHS at all sites Monitoring and Supervision during civil works (pre-construction, construction and operation stages) as an integral part of construction supervision and quality assurance Conduct OHS Audit and implement suggested actions to improve work safety OHS Audit should be minimum one, annually ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Hazardous and non-hazardous waste management plan: Throughout project implementation: Contractor ESMP to include hazardous and non-hazardous waste management pre-planning / preconstruction, guidelines to handle material at site. construction, and operation stages Construction waste, debris, sludge, screened materials, and other waste disposal: disposal site management and restoration plan: Contractor ESMP to include construction 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY waste and other waste disposal site management and restoration plan including allocated budget to implement the plan. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Throughout project implementation: AMC and GUDM Monitor all emissions / discharges / disposal of wastes from project facilities during pre-planning / preconstruction, construction and operation stages and ensure that the discharges from project facilities construction, and operation stages into the environment are as per latest limits suggested by MoEFCC, GPCB, and National Green Tribunal (which is stringent than WB-EHS (W&S) suggested Standards – the General Discharge Standards for Disposal of Treated Effluents to Surface Water and/or Irrigation under Environmental Protection Act 1986) whichever is stringent. The technology shall be upgraded to meet the directions of GPCB in the consent orders. AMC, before letting out treated sewage In case of disposal of treated effluent for Irrigation through Fatehwadi Canal, AMC shall through Fatehwadi Canal or any other renew the Consent from GPCB to permit the same. Discharge shall be initiated only in line canal, for irrigation / other purposes with the requirements laid out in GPCBs latest Guidelines on Discharge of Treated Effluents for Irrigation (2019): including Conducting a Study on impact (impact on soil, crops, communities) of use of such discharge for irrigation through an Agricultural University, arriving at additional standards, preparing Irrigation Management Plan for the command area, through stakeholder consultations. Ensure that pollution from project facilities do not negatively impact the environmental Throughout project implementation: components and communities downstream. Undertake annual Pollution audit along with pre-planning / preconstruction, E&S Audit and confirm this. construction, and operation stages Preparation of plan prior to contractors’ Efficient use water and other resources: mobilization and monitored throughout Contractor ESMP to include project’s ‘specific water use and water conservation plan the project implementation period and other resource source and use and conservation plan. Contractor will ensure that resource required for civil works is not sourced from unauthorized sources. Construction material sourcing plan: Prepare, adopt, and implement construction material sourcing plan as a part of the ESMP Environmental monitoring: Contractor to monitor and ensure continuously and as required by consent conditions or any regulation or guidance; quality of treated sewage and drainage discharged from each facility or recycled and reused ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the adoption AMC Prepare, adopt and implement a Traffic Management Plan and implementation of the ESMP. 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption Assess and manage specific risks and impacts to the community arising from Project and implementation of the ESMP. AMC activities, including, inter alia, air, noise and dust pollution, disposal of untreated sludges from the STPs, risks of labor influx, response to emergency situations, and include mitigation measures in the ESMPs to be prepared in accordance with the ESMF. 4.3 SEA AND SH RISKS Same timeframe as for the adoption AMC and GUDM and implementation of the ESMP. Adopt and implement a SEA/SH action and/or related measures as part of the ESMP, to manage the risks of SEA and SH. 4.4 DAM SAFETY Before finalizing the design of STP AMC Undertake hydrological and flood assessment, including a dam break analysis, return construction / rehabilitation / upgrading flood assessments (for various return flood periods) and prepare Emergency Action Plan works prior to the design of the investments (STPs) and associated structures  Outcome/output of this assessment shall be incorporated in the design of all STPs Implement dam safety assessment which might be impacted and subsequently assessed in C-ESIA & mitigation recommendations and Emergency measures if required included in C-ESMP. Emergency Preparedness and Action Plan throughout project Response Plan and Disaster Management Plan shall be part of all ESIAs implementation. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK Prepare and adopt the RPF prior to AMC appraisal, and thereafter implement the Prepare, adopt and implement a Resettlement Policy Framework (RPF) for the Project, RPF throughout Project consistent with ESS5. implementation. 5.2 RESETTLEMENT PLANS Adopt and implement the respective AMC RAP, including ensuring that before Prepare, disclose and implement Resettlement Action Plan (RAP) including a Livelihood taking possession of the land and Restoration Plan (LRP) if required based on site specific ESIAs. related assets, full compensation has been provided Prior to commencement of civil work at the STP sites and each identified section of the sewerage network 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 5.3 GRIEVANCE MECHANISM Establish the grievance mechanism AMC All land and resettlement related complaints will be addressed by the Project GRM asprior to commencement of project described in section 10.2 activities, and thereafter maintain and operate the mechanism throughout Project implementation ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS To be prepared as part of ESIA and AMC Prepare, adopt and implement a Biodiversity Management Plan for subprojects which implemented and monitored during might have impacts or risks on biodiversity project period ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS Adopt and disclose the CHMP prior to AMC appraisal, and thereafter implement the Prepare, adopt and implement a Cultural Heritage Management Plan (CHMP) consistent CHMP throughout Project with ESS8. implementation. 8.2 CHANCE FINDS Describe the chance find procedures in Describe and implement the chance finds procedures, as part of the ESMF and CHMP of the ESMF and CHMP. Implement the the Project. procedures throughout Project implementation. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION AMC and GUDM Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent Adopt the SEP prior to appraisal, and with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, thereafter implement the SEP relevant, understandable and accessible information, and consult with them in a throughout Project implementation.] culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism AMC and GUDM Establish, publicize, maintain, and operate an accessible grievance mechanism, to prior to commencement of project receive and facilitate resolution of concerns and grievances in relation to the Project, activities, and thereafter maintain and promptly and effectively, in a transparent manner that is culturally appropriate and operate the mechanism throughout readily accessible to all Project-affected parties, at no cost and without retribution, Project implementation including concerns and grievances filed anonymously, in a manner consistent with ESS10. 10 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 Based on E&S Capacity Assessment (as described in the ESMF), following types of training During Project implementation AMC and GUDM will be provided to the relevant target groups, such as PIU staff, PMC, stakeholder community, project workers, consultants, contractors, sub-contractors  Orientation training to staff of PIUs (AMC and GUDM) on the World Bank ESF, G-ACRP ESMF, and its implementation modality (screening, scoping etc.)  Training to AMC PIU, GUDM PIU, PMC staff on:  Issues of Land acquisition and involuntary resettlement,  Issues of vulnerable and disadvantaged people,  ESIA and RAP,  Occupational health and safety, community health and safety,  Labor practices,  Cultural heritage management,  Biodiversity Management  Disaster Management specially Flooding & Earthquakes,  Traffic and road safety,  Consultant Procurement and Contract Management including Guidelines on environmental and social conditions in the BOQ/contract documents, and  Implementation of ESMP  Management of Construction Impacts  Construction Supervision and audit  SEA/SH prevention and response CS2 Provide training for Project workers on occupational health and safety including on Throughout the project implementation AMC disaster prevention and emergency preparedness and response period 11 | P a g e