The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) Concept Environmental and Social Review Summary Concept Stage (ESRS Concept Stage) Public Disclosure Date Prepared/Updated: 06/22/2020 | Report No: ESRSC01430 Jun 22, 2020 Page 1 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Vietnam EAST ASIA AND PACIFIC P173716 Project Name Vietnam: Binh Duong Water Environment Improvement Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Water Investment Project 11/15/2020 3/25/2021 Financing Borrower(s) Implementing Agency(ies) Socialist Republic of Binh Duong Provincial Vietnam Wastewater and Drainage Management Board (WDMB) Public Disclosure Proposed Development Objective(s) The project development objectives are to improve municipal wastewater services and manage rainwater inundation risks in selected areas of the South Binh Duong region. Financing (in USD Million) Amount Total Project Cost 293.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] Located in Vietnam’s Southern Key Economic Region (SKER) , Binh Duong province is highly industrialized and urbanized. 77.2% of its population lives in urban areas against a national average of 31.3%. Its provincial per capita income is 69,241.00 (in 2018 price, and thousand VND), 1.62 times the national average. However, the province lags behind in terms of wastewater and drainage services and is suffering from increasing pressures imposed by wastewater generation. Meanwhile, Binh Duong was named one of the urban areas with the most typical smart city development plan in the world for the second time in 2019 . Innovations and success in managing its emergent urban Jun 22, 2020 Page 2 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) wastewater and drainage problems in Binh Duong will offer invaluable experiences for other Vietnamese provinces as well as other urban areas around the world. The proposed Project is aligned with the World Bank’s Country Partnership Framework (FY2018-2022 Report No. 111771-VN). The proposed project contributes to the World Bank Group’s twin goals of reducing poverty and boosting shared prosperity. The project is consistent with the Country Partnership Framework (CPF) 2018-22. The operation underpins a core strategic thrust of CPF for strengthening resilience to climate change impacts, environmental protection, and improved management of natural assets. Specifically, it supports the following objectives: to improve planning, management, and delivery of infrastructure and land in cities; to increase climate resilience and strengthen disaster risk management; and to strengthen natural resource management and improve water security. The proposed projects consider emerging lessons and strategic shifts proposed in the Performance and Learning Review (PLR) of the CPF (134020-VN) as it aims to deepen engagement at sub-national level with borrowing capacity. The proposed project will focus on three towns in the South Binh Duong region including Thuan An, Di An and Tan Uyen. The proposed infrastructure interventions include: (i) Expanding wastewater treatment capacity and access, including expanding and constructing the domestic wastewater collection and treatment system for Tan Uyen, Thuan An, and Di An towns, and Performance Based Conditions (PBCs) on Household Connections and water reuse; and (ii) Improving urban flood resilience under climate change, comprising constructing stormwater drainage systems in the proposed project areas, and using nature-based solutions to mitigate urban inundation risks. The proposed non- infrastructure work of the project is developing integrated urban water management institution and capacity. Public Disclosure D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] Binh duong province is located in the Southeast region of Viet Nam. It is bordered by Ho Chi Minh City in the South, Dong Nai province in the East, Tay Ninh province in the West and Binh Phuoc province in the North. The project area is located in the Southern part of Binh Duong province, including Tan Uyen town, Thuan An and Di An cities where are highly urbanized and have many large industrial zones. The total project area is approximately 336.3 square km and the population (2019) of all project towns is about 1.3 million people, occupying 52.4% of total population of the province. The provincial topography is hierarchical in the lower direction from North to South. Binh Duong region has different forms of geomorphology including eroded area, accumulated area, some areas have just been both eroded, accumulated and deposited. Currently, the forest area of Binh Duong has been seriously reduced with the coverage of only 28%. Due to the shrink of forest and the heavily damage of vegetation, erosion effects along streams and erosion channels on the terrain surface tend to rise especially in regions with human economic activities. The climate in Binh Duong is hot and rainy, the humidity is quite high. It has a stable monsoon tropical climate which divided into two distinct seasons: the dry and the rainy seasons. The rainy season usually starts from May to the end of October. The main transport route in the project area is road system with National Road No 13 connecting HCMC with Cambodia through Binh Duong and Binh Phuoc provinces. Two main rivers are the Saigon and Dong Nai rivers going through Binh Duong and connecting with Dong Nai province and Ho Chi Minh City in the North – South Corridor. The Dong Nai river originates from Lang Biang Plateau in central highland region and flows through the provinces of Lam Dong, Dak Nong, Binh Phuoc, Dong Nai, Binh Duong and Ho Chi Minh City with a length of 586 km and a basin of 38,600 km². It is one of main river systems in the southern key economic region, and is sources for water supply for majority part of Binh Duong, Ho Chi Minh City and Dong Nai province. The Sai Gon river originates from Cambodia and Jun 22, 2020 Page 3 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) flows through Thu Dau Mot city of Binh Duong province to HCM city. The two rivers confluence at the downstream of Binh Duong province to form Nha Be river which then discharges to the East Sea. The fast economic growth, coupled with rapid urbanization and high rates of immigration into the Southern Binh Duong Region result in degradation of water quality in the Dong Nai and Sai Gon River. Stormwater runoff and domestic wastewater generated from the cities and towns are discharged into the Dong Nai River and Sai Gon River with limited treatment, exacerbating pollution to the Dong Nai river system. Binh Duong province is highly industrialized and urbanized with 77.2% of its population living in urban areas, compared to a national average of 31.3%. Binh Duong in general, and the project towns in particular, have attracted many international and national investors with many industrial zones were established providing a manufacturing employment hub for the region. This results in low unemployment rate in the project area which was less than 2.0% in 2018. Its provincial per capita income is VND69,241.000 (in 2018 price), which is 1.62 times the national average. Average income per person per month in the province is VND 5.8 million, while the average income for the project towns is VND8.0 million. Poverty incidence of Binh Duong province in 2018 is quite low, about 1.62% (compared to a national rate of 7%). Initial screening also shows that the project area is not home to sensitive social and cultural sites such as low-income communities, cultural heritage or archeological sites/temple/churches/ pagodas of national or regional importance. D. 2. Borrower’s Institutional Capacity At the provincial level, Binh Duong Provincial People Committee (PPC) will be executing agency of the project, overseeing project implementation, directly related departments and implementing agencies, ensuring compliance with government regulations and World Bank policy requirements. Related Departments at provincial level such as Public Disclosure Department of Natural Resources and Environment (DONRE), Department of Plan and Investment (DPI), Department of Finance (DOF), Department of Construction (DOC) and the Department of Agriculture and Rural Development (DARD) will be playing roles of coordination and will engage in various technical reviews and approval procedures during project preparation and implementation. Binh Duong Province’s Wastewater and drainage Management Unit (PMU) will be the owner of the project and will be responsible for overall project management, including procurement, financial management, environmental and social management, contract management, day-to-day supervision of project activities, training, monitoring and evaluation, and communication with the Bank. All these entities have been involved in the preparation and implementation of previous projects funded by the WB in the province understand WB policies and requirements, and have experience in preparation and implementation of the WB financed projects. At city and town level, the city People’s Committees and related agencies will be responsible for the overall environmental and social safeguards implementation of the project. Their responsibilities will include land acquisition, implementation of the resettlement and compensation for those households affected by proposed works within their administrative jurisdictions. The key authorities in managing land acquisition and resettlement include the district resettlement committee, the district land fund development center, and the Department of Natural Resources and Environment . Among 3 project towns, Di An and Tan Uyen towns have been implementing World Bank-financed projects, including Viet Nam water supply and wastewater treatment project in Di An town and Transmission efficiency project in Tan Uyen town. Therefore, they have experience with the World Bank’s safeguards requirements. Although the implementing agencies have successfully applied environmental and social safeguards policies of previous World Bank-financed projects, they are not familiar with the new Environmental and Social Framework (ESF) which requires additional social and environmental risk management, including the concepts of proportionality and adaptive management, as well as the standards related to labor management, community health and safety, occupation, health and safety (OHS), modified natural habitats and the requirements for systematic stakeholder engagement. An ESF capacity of the implementing agency and related stakeholders will be assessed Jun 22, 2020 Page 4 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) systematically during project preparation to analyze the Borrower’s and other implementing agencies’ capacities and to identify opportunities for strengthening and enhancing coordination, and a capacity building program will be developed for implementation. In addition, the World Bank team will provide training in the ESF implementation for the PMU and related agencies and will continue providing the necessary support during project preparation and implementation to ensure that new environmental and social standards are properly applied to the project. The client capacity to address environmental and social risks will be further enhanced through the recruitment of qualified supervision consultants, PMU E&S specialists, and an independent monitoring consultant. II. SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Substantial Environmental Risk Rating Substantial The project environmental risks and impacts are related to the implementation of investments under components 1 and 2. The type of investments under component 1 includes construction of stormwater sewerage, sewage collection, sewage pumping stations, and stormwater drainage network in the participating town/cities; construction of a 20,000 m3/d Wastewater Treatment Plant (WWTP) in Tan Uyen town; upgrading of the capacity of the existing WWTPs for Thuan An and Di An cities with additional treatment capacity of 17,000 m³/day and 20,000 m³/day, respectively; embankment of about 1 km of canal bank in Thuan An city; and dredging of about 1.5 km of Suoi Tre drainage canal in Tan Uyen, the outlet of Tan Uyen WWTP to the Dong Nai river. The proposed project will bring about positive environmental impacts on the city and Dong Nai river basin by Public Disclosure improving water quality, reducing urban floods, enhancing climate resilience, and improving community health and livelihood. The project investments are of moderate to large scale and located in the urban area and on agricultural land with an environment heavily modified by human activities. There is no natural habitat or critical habitat in the immediate proximity to the project area except for the Dong Nai river, a natural habitat located about 1.7 km downstream of the proposed new WWTP, and also a major source of water supply to the downstream communities. The preliminary screening also found no cultural heritage in a proximity to the project area. The main environmental risks and impacts during construction would be degradation of the local air, soil, and water environment due to exhaust gas emission and waste generation and disposal; water quality degradation and impacts to aquatic species and irrigation activities due to moderate scale dredging and generation of considerable amount of dredging materials; traffic safety and business disturbance; worker and community health and safety; damages to existing weak structures and local houses due to dredging or piling; and safety risk due to unexploded ordnances (UXO) left from the war. The main environmental risks during operation would be water pollution, especially to Dong Nai river, due to failure or malfunction of the WWTPs; environmental pollution due to emissions, odors, and generation of substantial amount of sludge from the WWTPs and maintenance of the sewerage collection system; and worker health and safety risks due to exposure to hazardous chemicals and pathogens. However, the risks and impacts during construction and operation are not expected to be significant, mostly reversible, and could be mitigated by good design and management practices. Component 2 will focus on the development of integrated urban water management strategies of the South Binh Duong region, integrated urban water management planning, trainings on integrated urban water management. Inadequate consideration of the environmental aspects in the strategies and plans may pose some risks during implementation. Jun 22, 2020 Page 5 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) The implementing agencies (IAs) demonstrated technical and institutional capacity by successful design and implementation of the previous World Bank-financed projects in the area water and wastewater management. Although the IAs have good World Bank safeguards experience, they are not familiar with the additional requirements of the new ESF and related environmental and social standards (ESSs), posing a risk of unsatisfactory management of risks and impacts consistent with the ESSs. However, this will be supplemented by implementation of a program for ESF capacity building which will be developed during project preparation. Given the type, location, sensitivity, and scale of the project, the nature and magnitude of the potential environmental risks and impacts, and the capacity the IAs to manage the environmental risks and impacts in a manner consistent with the ESSs, the environmental risk is assessed as Substantial. Social Risk Rating Substantial Project activities will take place in a limited geographical area where there is an ethnically homogenous population (covering three districts, where the vast majority of the population are ethnic Kinh – the dominant population in Viet Nam). The project will acquire about 12ha of agricultural land from 46 households for the construction of Tan Uyen WWTP and dredging of about 1.5 km of Suoi Tre drainage canal in Tan Uyen, the outlet of Tan Uyen WWTP to the Dong Nai river, while wastewater drainage system and rainwater routes will be constructed in the existing roads’ bed, and will not require land acquisition. No households will be significantly affected or relocated due to land acquisition. This is because the 12ha of land to be acquired is distributed across the 46 HHs constituting a minor portion of household’s productive land holding in each case, due to linear nature of the project works. Also, although there are additional social risk management requirements specified by the new Environmental and Social Standards of the World Bank, (including social risks and impacts to occupation and community health and safety related to labor influx Public Disclosure such as sexual exploitation abuse, sexual harrassment, and communicable diseases) these are predictable, mitigatable and manageable. This is so, as the number of workers to be mobilized is estimated to be about less than 300 workers, with the vast majority being recruited locally and distributed across three project towns. Local communities of the project towns are well placed for dealing with such social risks related to labor influx in similar oprations and in industrial zones. Binh Duong province has estalished a system of services providers in Binh Duong city and the project towns (e.g. temporary accomodation, electricity, water supply, health care centers, hospitals, schools, ect.) to meet demands of local people and migrant workers. However, since the project is being prepared under the COVID19 crisis circumstances there is an increased potential for workers to spread communicable diseases. This risk will be addressed by instituting careful community health and safety measures and labor management procedures informed by relevant health protocols. The other adverse social impacts will relate to the temporary disruption or limitation of traffic and utilities during the construction phase, and the client in question has demonstrated their capacity to mitigate such impacts in previous projects. Furthermore, the responsibility for land acquisition and resettlement lies principally with district government units, who have experience in successfully applying the World Bank's involuntary resettlement policy in previous bank financed projects, where complaints that arose were dealt with in a timely and effective manner, without being escalated, and land was delivered for the project in a timely fashion. The Bank team will provide training to the land fund development centerson the requirements of the new ESF during project preparation and implementation to strengthen their capacity to deliver the land required for the project in a timely fashion and in compliance with the new ESF. Although the limited land acquisition requirements, the modest number of contracted workers to be mobilized, and limited temporary disruption to social and economic life likely to be caused by the project, there is uncertainty about potential impacts due to expansion of two WWTPs and the WDMB is currently understaffed, it is their first experience under the ESF, a substantial social risk rating is proposed for the project. Jun 22, 2020 Page 6 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: As part of E&S screening, the team has reviewed a number of relevant documents, including project concept note, available draft project proposal including the proposed investments, Land law, Environmental Protection Law, Labor Code, etc. The potential environmental impacts/risks of the proposed project during construction and operation are expected mostly reversible, moderate to substantial, and could be managed via an appropriate environmental and social assessment (ESA) and mitigation plans to be developed during the project preparation and implementation. The ESA will be conducted in a manner consistent with the requirements of the ESF and relevant ESSs to inform decision making in planning and technical design. The ESA will assess the adequacy of current infrastructure design standards applicable to the proposed investments, considering the impacts of climate change. The ESA will examine project infrastructure planning and design of the wastewater collection and treatment system; analyze the alternative wastewater treatment technologies in line with the provincial urban water planning documents; and integrate climate change impacts into urban planning and infrastructure design. Public consultation and disclosure of information during the ESA process will be in line with the relevant ESSs. During preparation, the Borrower will prepare an Environmental and Social Impact Assessment (ESIAs) in accordance Public Disclosure with ESS1, other relevant ESSs, and national environmental and social assessment regulation. The ESIA will describe institutional framework, the project and baseline conditions, identify and assess the potential environmental and social impacts and risks, and propose mitigation measures and plans to implement the measures. The ESIA will follow requirements of the relevant ESSs in identifying and managing the environmental and social risks and impacts including direct, indirect, and cumulative impacts. The ESIA will facilitate a more holistic approach towards the design of urban flood management investments (man-made and natural based solutions), urban drainage system, sewerage collection system, and wastewater treatment. The ESIA will also assess the adequacy of current infrastructure design standards applicable to the proposed investments, considering the impacts of climate change and foreseeable changes of urban landscape. Regarding construction and upgrading of the WWTPs, in addition to assessing the construction related impacts, the ESIA will focus on the site selection, plant design, and treatment technology to minimize generation of air emissions and odors, waste, sludge, and pathogens, and efficient use of water and energy. During WWTP operation, the ESIA will cover the environmental impacts related to wastewater and sludge treatment, discharge, and use including: i) liquid effluents; ii) solid waste; iii) air emissions and odors; iv) hazardous chemicals; and v) ecological impacts. Occupational health and safety impacts during the construction of the WWTPs are common to other large industrial projects and are addressed in the General EHS Guidelines. Occupational health and safety impacts associated with the operational phase of the WWTPs primarily include the following: i) accidents and injuries; ii) chemical exposure; iii) hazardous atmosphere; iv) exposure to pathogens and vectors; and v) noise. These impacts will also be covered under the ESIA. The ESIA will examine the potential environmental impacts associated with wastewater collection system including: i) uncontrolled discharge of domestic wastewater into aquatic systems and onto street; and ii) leaks and overflows Jun 22, 2020 Page 7 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) from the sewerage system as a result of the inability of the collection system to manage the volume of wastewater due to high flows during rain events or power loss, and blockages. Considering the Borrower’ limited ESF implementation capacity, the ESIA will assess ESF capacity needs systematically to analyze the Borrower’s and other implementing agencies’ capacities and to identify opportunities for strengthening and enhancing coordination. The assessment could include the activities related to E&S management such as identification of key tasks for environmental and social (E&S) risk management; identification of relevant institution and actors involved in implementation; analysis of institutional arrangements and links; assessment of individual institutional capacity; recommendation of actions to strengthen and monitoring institutional capacity during implementation. For Component 2, during development of the integrated urban water management strategies of the South Binh Duong region, and integrated urban water management planning, environmental and social issues will be identified, assessed, and incorporated into the strategies and plans. An Environmental and Social Management Plan (ESMP) will be prepared as an integral part of ESIA. The ESMP will consist of a set of mitigation, monitoring, and institutional measures to be carried out during project implementation and operation to avoid adverse environmental and social risks and impacts, offset them or reduce them to acceptable levels. The ESMP also includes the measures and actions needed to implement the measures. It will require the contractor of each construction package prepare contractor’s ESMPs (C-ESMPs) to cover ECOPs for addressing common construction impacts and relevant specific mitigation measures. The ESMP also include technical design and management measures to address the environmental risks and impacts (sludge, odor, risks of WWTP mal function, etc.) during operation of WWTPs. The World Bank Group Environmental, Health and Safety Guidelines will also be applied during the development of ESIA. The Borrower will prepare a resettlement action plan (RAP) and a Public Disclosure stakeholder engagement plan (SEP) proportionate to the nature and scale of the project activities and its potential risks and impacts. During implementation, mitigation measures will be incorporated into technical design, construction, and operational contracts. The Borrower will prepare an Environmental Social Commitment Plan (ESCP). The ESCP will set out the activities to be carried out during project implementation and could be adjusted during the project cycle in line with the evolution of environmental and social risk and impacts. Areas where “Use of Borrower Framework” is being considered: Although Vietnam has an advanced E&S Framework, there are gaps between the environmental and social assessment regulation and practice, especially in description of the environment, level of impact analysis and mitigation measures, and public consultation and disclosure of information. In addition, there is no experience of the implementing agencies in implementing and applying ESF and its associated environmental and social standards. Therefore, there are no plans to use the Borrower’s E&S Framework within this project. ESS10 Stakeholder Engagement and Information Disclosure Along with the project proponents (Binh Duong PPC and PMU), direct beneficiaries and project affected people, there are a number of interested parties identified as stakeholders during initial screening. At provincial level, these include the Provincial People’s Committees, related departments such as DONRE, DARD, DOF, DOC, DPI. At the town level, these comprise Town People’s Committees, Compensation Committees and Land Fund Development Branches of the town, and Political-Social Organizations at town and commune level (Fatherland Front, Women’s Union, Jun 22, 2020 Page 8 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) Farmers’ Union, Veteran Union, the Youth Union, the Elderly Union) as well as representatives of urban resident groups. Since the project is prepared under COVID19 crisis circumstances, any project-related impacts on vulnerable and marginal groups and individuals may exacerbate existing hardships. Disadvantaged and vulnerable groups under these circumstances may be the elderly, disabled or those who are rendered unable to preserve their livelihoods and therefore exceptionably susceptible to impacts from the project (temporary restrictions on business activities or land taking that affects livelihoods). These groups should be identified in the engagement plan and measures identified to prevent or minimize associated impacts.. During the preparation of the project, stakeholders will be involved in environment and social impact assessment and consultations on mitigation measures for social risks and impacts, including measures for compensation and resettlement. Depending on the situation with COVID19, a mix of conventional media (radio, television) for information provision and internet and mobile telephone text based communications for soliciting feedback of different stakeholders could be used during project preparation, depending on the social distancing requirements in place . The Implementing agency will prepare a stakeholder engagement plan (SEP) proportionate to the nature and scale of the project activities and its potential risks and impacts and which will include a Grievance Redress Mechanism (proportionate to potential risks and impacts) that will be publicized, accessible, allows anonymity, maintains records, and provides feedback to complainants. A Grievance Redress Mechanism (GRM) will be established in coordination with localized grievance redress processes in order to ensure that all concerns and complaints are captured and addressed by implementing agencies and competent bodies. One innovative feature, of the administrative system in Viet Nam, is the one stop shop established at all administration levels from ward/commune level to provincial level, for citizen to lodge their Public Disclosure concerns or grievances. If grievances cannot be resolved through this mechanism, then the issue can be escalated to a Provincial inspectorate or the provincial court. However, a GRM should be established at project level to facilitate efficiency and effectiveness of resolving complaints of affected people. The project GRM will be an integrated part of the SEP. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions The project will require direct workers (for the implementing agencies), contracted workers (to work on construction sites for recruited contractors) and primary supply workers (to provide aggregate material and equipment). The project is not expected to require community workers. Vietnam already has in place a relatively comprehensive (and evolving) framework for labor and working conditions such as the Labor Law (2019), the Law on Occupational Health and Sanitation (2015), the Social Security Law (2014), and the Official and Card Law (2019). Vietnam also recently ratified Right to Organize and Collective Bargaining Convention, which will come into effect in July 2020. The policies and regulations stated in this legislation reflect the principles of ESS2 on issues such as fair treatment, non- discrimination and equal opportunities to workers, supports the rights and benefits of the workers, recognizing workers’ rights to establish or join associations of workers, prohibition on sexual harassments/forced labors/child labor (under 15), etc. As the PMU is a government entity where laws and regulations have to be followed, trade unions and official grievance redress mechanisms exist. Therefore, minimal risks related to ESS2 for direct project Jun 22, 2020 Page 9 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) workers are foreseen. The labor management procedures for the PMU will be assessed during preparation. The exceptional circumstances of Covid19 crisis are likely to pose occupational health and safety concerns for project workers. Provision of PPE, protocols for hygiene and distancing at the workplace, including transport of workers, as well as emergency response protocol in event of an outbreak (where would be infected workers be isolated, sent for treatment) need to be addressed in the labor management procedures. One challenge on the application of this framework is the lack of systematic labor inspection, especially when it comes to construction contractors and primary suppliers, where there is a heavy reliance on self-reporting. For contracted workers, a template for labor management procedures (LMP) will be developed for inclusion in the bidding documents. For primary suppliers of materials and equipment, there is neither the practice, or experience, of conducting due-diligence on labor and working conditions among potential sources of aggregate material and equipment. Therefore, a monitoring procedure will need to be in place prior the commencement of works, to ensure compliance with national laws and ESS2. In addition to labor management procedures, and primary supplier monitoring systems, the implementing agency will develop OHS procedures (to be included in the ESMP), a grievance redress mechanism specific to labor and working conditions, and a system for monitoring third party contractors compliance with agreed OHS and LMP. ESS3 Resource Efficiency and Pollution Prevention and Management At this stage of project identification, the potential impacts related to resource efficiency and pollution prevention and management are identified in the activities under components 1 of the project. Given the type and scale of the project, a considerable amount of resources (e.g. energy used during operation of WWTPs) and construction Public Disclosure materials will be required, and the adverse impacts on human health and environment are expected to be moderate to substantial. Nevertheless, risks and impacts related to the release of pollutants and odor, waste generation, the management and disposal of dredged materials during construction and sludge from operation of WWTPs, impact on the community, and resource use efficiency will be assessed, and mitigation measures will be proposed during project preparation. Dredged material management plan (DMMP) will be prepared and included in the ESMP. The adverse impacts and risks relating to storage, transportation, and disposal of dredged materials and generated sludge will be included and determined in the ESA process. Risks and impacts due to generation of hazardous and non- hazardous waste will be assessed and addressed via ESA process, taking into account the standards set out in the World Bank Group Environmental, Health, and Safety Guidelines (WBG EHSG). In addition, the risks during operation of WWTPs (e.g. fire risk, chemical leakage, pollution due to malfunction of WWTPs) will be addressed during the ESIA process. Emergency response plans and/or solutions to manage the risks during WWTPs operation will be prepared and included in the ESMP. During the ESA process , if it is determined that the project will produce significant emissions due to exhaust gases during construction and operation, an estimate of gross Green House Gas (GHG) emissions resulting the project will be required, provided that such estimation is technically and financially feasible. The project will adopt measures, specified in the WBG EHSG and other Good International Industry Practice (GIIP), for efficient use of raw materials and for optimization of energy use, to the extent technically and financially feasible. ESS4 Community Health and Safety The initial screening on social risk and impact related to human traffiking and sexual exploitation and abuse (SEA)/ sexual harassment (SH) associated with worker influx indicated that the risk was low, with an less than 300 workers Jun 22, 2020 Page 10 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) required at the project sites during construction phase, and most of the labor being sourced locally, and some works taking place in peri-urban areas, and other works taking place in urban roads or within the existing WWTPs. However, during preparation, the project should (i) undertake a mapping of service providers and assess the capacity and quality of these services for the survivors, (ii) assess the ability of the implementing agencies to respond to SEA/SH risks, (iii) assess the risk of SEA/SH for the project, (iv) establish procedures to review and update risk assessments during project implementation, (v) identify and include appropriate mitigation measures for including in the project design and bidding documents (including worker codes of conduct). In addition, efforts will be made to manage the potential labor influx by developing a labor influx management strategy to be included in the ESA. Other aspects of community health and safety that need to be considered during project preparation include risks to human health, associated with road traffic safety, noise, dust as well as the disposal of sludge and dredged materials, as well as risks of the transmission of communicable diseases (such as COVID19) due to project activities. For the management of risks related to communicable diseases, Community Health Guidelines, that will reflect national and international guidelines, will be prepared as an annex to the ESIA. In addition, a road traffic management assessment in the project areas will be necessary, as well as the pre-identification of sites for the safe disposal of sludge from dredging of the canal and operation of WWTPs. Standard measures in the WBG EHSG to ensure the community health and safety of communities during the construction and operation of infrastructure project will be considered. These include the measures in general facility design and operation, communication and training, and the measures to address physical hazards, chemical hazards, personal protective equipment, special hazard environments, and monitoring. The potential increase of traffic risks and negative effects on road safety will be assessed during the ESA process, and a traffic management plan will be developed and incorporated as part of ESMP. The transport management plan for the dredged sludge will be developed for part of the DMMP. The quality of dredged sludge will Public Disclosure be analyzed and identification of sites for safe disposal of sludge will be conducted as part of ESMP, with suitable deposits confirmed and ready before dredging works may start. The transport management plan for the dredged sludge will be developed for part of the DMMP. Mitigation measures will be incorporated in the design of the WWTP and ESMP to ensure that generated odor and sludge during the operation of WWTPs will properly managed. The need for additional measures of this ESS will be further assessed during project preparation as part of ESA process. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement The initial screening shows that the project will require an estimated amount of 12ha agricultural land for constructing Tan Uyen WWTP and dredging Suoi Tre canal in Tan Uyen town leading to economic displacement from about 46 households. However, no household will be significantly affected or relocated due to land acquisition. The expansion of 2 existing WWTPs in Thuan An and Di An towns does not require land acquisition because the works will be implemented in the existing WWPTs. The current project design proposals for sewage and rainwater drainage routes will be constructed under the roads’ bed to avoid land acquisiton, as well as the disruption of comercial activities and resettlement in densely populated urban areas. Land required for disposal of sludge will be public land in the peri-urban area. An assessment will be conducted by the PMU to collect data and information for preparation of a resettlement action plan (RAP) for the project. All proposed works and their boundaries are identified at the preparation stage, so a resettlement policy framework is not required. A resettlement action plan will be prepared to meet the requirements of the new ESF of the World Bank. At the implementation stage when detailed project designs is available, (and following the completion of a detailed measure survey and replacement cost study) the RAP will be updated and disclosed locally to affected people. Jun 22, 2020 Page 11 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources The project investments are located in the urban area and on agricultural land with an environment heavily modified by human activities. The preliminary screening found that is no natural habitat or critical habitat in the immediate proximity to the project area except for the Dong Nai river, a natural habitat located about 1.7 km downstream of the new WWTP to be constructed by the project. The existing green space in the project areas mainly include shrubs, coconut tree, bamboo and banana with low biological values. These drainage canals, which are the outlets of the WWTPs can be considered aquatic ecosystems and home for aquatic species, are relatively narrow and shallow during the dry season. The project will assess potential impacts on the land-based and aquatic habitats in and around project area of influence although the potential impacts on aquatic habitats is likely to be limited. The Borrower will conduct the ESA in accordance with requirements of ESS6 during project preparation and implementation. The risks and impacts on biodiversity and aquatic ecosystem will be assessed as part of ESA process. The ESA will include measures to avoid, mitigate, minimize or compensate for the disturbance or negative biological impacts through the siting of the works, engineering design or construction practices. In addition, the project also has opportunity to support improving the area and quality of the modified and natural habitats, e.g. by planting of protected native trees along the new/affected roads where the construction activities of wastewater collection system happen, promoting the maintenance/creation of vegetation cover along the upgrading canals and in the premises of the WWTPs, etc. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities The project will be implemented in the urban area where there is no ethnic minority people living or their collective Public Disclosure attachment to the project area. Therefore, this ESS is not relevant. ESS8 Cultural Heritage The screening during project identification identified no tangible cultural heritage such as pagodas, churches, family shrines, cemeteries or temples and intangible cultural heritage located in the immediate proximity of the project proposed investments. The scope of applicability of this ESS will be further assessed during project preparation as part of ESA process. During preparation the ESIA will screen to identify the tangible and intangible cultural resources available within the area of influence of the Project, assess the potential impacts, and propose appropriate mitigation measures. In any case, the ESA will at a minimum produce a chance find procedure for physical cultural heritage that may be affected during project implementation, as well as a screening process to minimize possible impacts on cultural heritage such as pagodas, churches, family shrines and temples. ESS9 Financial Intermediaries The project will not channel funds through financial intermediaries, the PMU will manage the fund. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways Yes Jun 22, 2020 Page 12 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) The wastewater from WWTP will be discharged into canals linked to Dong Nai River Basin of which Saigon is a major tributary. The Saigon river originates in Cambodia and meets the Dong Nai river downstream of Binh Duong province. OP 7.50 is triggered as the project interventions include the construction of WWTPs which will discharge treated effluent into the Dong Nai River system. The determination on the notification requirement will be made during Project preparation. OP 7.60 Projects in Disputed Areas No The project will not be implemented in disputed areas. III. WORLD BANK ENVIRONMENTAL AND SOCIAL DUE DILIGENCE A. Is a common approach being considered? No Financing Partners No financing partners, so no common approach is considered B. Proposed Measures, Actions and Timing (Borrower’s commitments) Actions to be completed prior to Bank Board Approval: Public Disclosure Actions to be completed prior to Bank Board Approval: - Final draft Environmental and Social Impact Assessment (ESIA) - Final draft Resettlement Action Plan (RAP) - Final daft Stakeholder Engagement Plan (SEP) - Final draft Labor Management Procedures (LMP) - Final draft Environmental and Social Commitment Plan (ESCP) (ii) Prior to project appraisal, disclose the draft SEP, RAP, ESIA, and ESCP, LMP in a timely manner, in an accessible place, and in a form and language understandable to project-affected parties and other interested parties as set out in ESS10, so they can provide meaningful inputs into project design and mitigation measures. Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): Possible issues to be addressed in the Borrower ESCP: - Commitment to prepare the relevant instruments per Environmental and Social Standards (ESSs’) requirements (ie., SEP, RAP, ESIA, and ESCP, LMP). - Adequate allocation of resources (human, finance) for application/implementation of ESF, ESSs and relevant instruments. - Commitment to prepare and implement a capacity build plan with strong focus on application/implementation of ESF, ESSs and relevant instruments. - Update Resettlement Action Plan, based on detailed designs and the latest Detailed Measure Survey and Replacement Cost Study, and establish associated grievance redress mechanism. - Establish a Project Level Grievance Redress Mechanism. - Update Stakeholder Engagement Plan based on the public health situation regarding communicable diseases. Jun 22, 2020 Page 13 of 14 The World Bank Vietnam: Binh Duong Water Environment Improvement Project (P173716) C. Timing Tentative target date for preparing the Appraisal Stage ESRS 01-Jul-2020 IV. CONTACT POINTS World Bank Contact: Abedalrazq Khalil Title: Sr Water Resources Mgmt. Spec. Telephone No: 5720+13657 / 65-650-13657 Email: akhalil@worldbank.org Contact: Vinh Nguyen Title: Senior Water Supply and Sanitation Specialist Telephone No: 5777+8366 / 84-243-9378366 Email: vnguyen2@worldbank.org Borrower/Client/Recipient Borrower: Socialist Republic of Vietnam Implementing Agency(ies) Public Disclosure Implementing Agency: Binh Duong Provincial Wastewater and Drainage Management Board (WDMB) V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Abedalrazq Khalil, Vinh Nguyen Practice Manager (ENR/Social) Susan Shen Recommended on 10-Jun-2020 at 06:35:57 EDT Safeguards Advisor ESSA Peter Leonard (SAESSA) Cleared on 22-Jun-2020 at 11:56:40 EDT Jun 22, 2020 Page 14 of 14