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Montenegro  
Ministry of Health, Labour and Social Welfare 
 
Health System Improvement Additional Financing Project  
(MHSIAFP) 
 
Reconstruction of Bijelo Polje Health Care Center 
Environmental Impact Assessment and Environment Management Plan 
 
February 24, 2009
E2205 
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EXECUTIVE SUMMARY
 ………………………………………………………………………….. 3
 
1
INTRODUCTION
 …………………………………………………………………………...…..… 5 
2
ENVIRONMENTAL ASSESSMENT RULES AND PROCEDURES
 
…..…………...……….. 5 
2.1 WB EA policies ……...…………………………………………………………………………...   5 
2.2 National EA rules and procedures…………………………………………………………….…… 6 
3
ENVIRONMENTAL IMPACT ASSESSMENT
 ………………………………………………… 7 
3.1 Scope of the EA …………………………………………………………………………………… 7 
3.2 Baseline conditions ……………………………………………………………………………….. 7 
3.3 Potential Environmental Impacts ………………………………………………………………… 12 
4
ENVIRONMENTAL MANAGEMENT PLAN
 ………………………………………………... 13 
4.1 Environmental guidelines ……………………………………………………………………...… 13 
4.1.1 Design phase …………………………………………………………………………………… 13 
4.1.2 Reconstruction phase …………………………………………………………………………... 14 
4.1.3 Operation ………………………………………………………………………………………. 15 
5
MONITORING AND SUPERVISION PLAN
 ………………………………………………….. 19 
6
RESPONSIBILITY FOR EMP IMPLEMENTATION AND FINANCING   
 …………….…. 22 
7
PUBLIC DISCLOSURE AND CONSULTATION
 …………………………………………….. 23 
8
APPENDICES 
8.1 Legislation ……………………………………………………………………………………….. 24 
8.2 List of consulted people ………………………………………………………………………….. 25 
8.3 Minutes of the public consultation of the EMP ………………………………………………….. 26 
8.4 Decision of the Ministry of Tourism and Environmental Protection.............................................. 27 
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EXECUTIVE 
SUMMARY 
 
1. 
Project Objective.
 
The objectives of the Project are to put in place the first steps towards a 
reformed health system in Montenegro, giving priority to increasing capacity for policy, planning 
and regulation; stabilizing health financing; and 
improving primary health care service 
delivery
.
2. 
Project description.
 Under the project Additional Financing, the Ministry of Health proposes to 
finance the reconstruction and expansion of the Health Center in Bijelo Polje. 
3. 
 
Project location
.
The health center to be reconstructed is placed in the centre of town. The 
location was selected according to existing planning documents for its reconstruction and 
expansion with all its necessary amenities. The planned facility is surrounded by a number of 
residential units intended for collective and individual residence, and that is one of the 
characteristics of any city centre. 
4. 
Project category.
 In accordan
ce with the Bank’s safeguard policies and procedures, including 
OP/BP/GP 4.01 
Environmental Assessment
,
the proposed Project is classified as the 
Category B 
Project
 for environmental assessment purposes as it is not expected to generate significant 
environmental impacts. This requires preparation of the following: (i) an Environmental 
Assessment, which includes environmental evaluation of the proposed project site; (ii) an 
Environment Management Plan, which would include steps for mitigating any potential impacts 
identified, together with respective monitoring plan, budgets, responsibility and schedules of 
execution.  
5. 
Purpose of the Environmental Assessment
.
The purpose of the Environmental Assessment (EA) 
is to identify significant environmental impacts of the project (both positive and negative), and to 
specify appropriate preventive actions and mitigation measures (including appropriate monitoring) 
to prevent, eliminate or minimize any anticipated adverse impacts. An Environmental Assessment 
(EA) was carried out by an independent local consultant, based on what was prepared a simple 
Environmental Management Plan (EMP). The EA report was prepared based on the following: (i) 
analysis of the existing national legal documents, regulations and guidelines; (ii) WB safeguard 
policies, as well as guiding materials; (iii) national EA and Construction legal framework; (iv) 
existing EIAs for similar projects; (v) environmental evaluation of the proposed project site; and, 
(vi) results of consultations with the representatives from all interested parties and stakeholders. 
6. 
National Regulatory framework for EA
.
Montenegro has developed its own EA rules and 
procedures brought in line with the EU directives, and also in line with the WB EA requirements. 
The main regulatory acts in this area are: the Law on Environmental Protection (“Official Journal 
of Montenegro”, no. 51/08), the Law on Environmental Impact Assessment (“Official Journal of 
the Republic of Montenegro”, no. 80/05), the Law on Construction of Facilities (Official Journal 
of the Republic of Montenegro, no. 55/00), the Rulebook on the contents of the Environmental 
Impact Assessment (“Official Journal of Montenegro”, no. 51/08), Bylaw on projects that require 
Environmental Impact Assessment Study (“Official Journal of the Republic of Montenegro”, no. 
20/07). According to applicable legislation on the EA, the projects that involve reconstruction of 
healthcare institutions do not require a special review, but should include environmental 
requirements into the design documents to be applied during the construction activities. 
7. 
EA Institutional framework and capacities.
 The EA institutional capacity of the Ministry of 
Health, Labour and Social Welfare of Montenegro, along with the municipality’s controlling 
departments was assessed during the EA study and was concluded these institutions have relevant 
capacities to perform their duties concerning enforcing EMP provisions. 
 
8. 
Potential environmental impacts. 
It is expected the project will not generate any large scale and 
significant environmental and social impacts. Possible adverse environmental impacts are related 
to reconstruction and operation phases and are the following: (a) Dust and noise due to the 
demolition and construction; (b) Dumping of demolition and construction wastes,
 
accidental 
spillage of machine oil, lubricants, etc; and, (c) Risk associated with handling wastes during 
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operation (municipal, hazardous, medical, etc.). All these potential environmental impacts are 
minor and could be easily managed during the project implementation. The reconstruction, 
expanding and superstructure of Bijelo Polje Health Centre will be done on the available land 
which is owned by the Centre and currently is not legally or illegally used, and thus will not imply 
any of involuntary resettlement issues. 
The Project will also provide positive social impacts. The rehabilitation and expanding of the 
Centre will improve social conditions for the population and would contribute to improving local 
population livelihoods.   
9. 
Environment Management Plan.
 The EMP covers: (a) short description of applicable laws, 
policies on environment procedures for environmental screening, EIA preparation and 
implementation, as well as EIA institutions and responsibilities; (b) description and evaluation of 
the proposed project site; (c) Environmental Guidelines (EG), specifying: (i) potential  
environmental and social impacts of the reconstruction activities;  (ii) proposed mitigation and 
monitoring measures to be applied during the project implementation; and (iii) description of EMP 
implementing arrangements, institutional capacities as well as procedures for supervision, 
monitoring, and reporting.  It is proposed that the contractor will ensure the workers safety, will 
undertake relevant measures for preventing dust and noise pollution, proper handling, 
transportation and disposal of construction and medical waste materials.  
10. 
Monitoring Plan.
 The EMP includes a Monitoring Plan with measures that will be employed to 
track the effectiveness of the mitigation measures and described the environmental indicators to be 
monitored, along with the monitoring methods, frequency, as well as the monitoring and reporting 
procedures, including institutional arrangements. 
 
11. 
Coordination of the EA with the National Environmental Protection Authorities.
 The Ministry 
of Tourism and Environmental Protection has published the request for deciding upon the 
necessity for Environmental Impact Assessment, submitted by the Ministry of Health, Labour, and 
Social Welfare, in printed media relevant in the region of Bijelo Polje. The documents submitted 
for getting the decision on the necessity for conducting the EAI included: (a) Description of the 
location; (b) Project description; (c) Description of potential considerable environmental impact of 
the Project; and (d) Filled questionnaire on the environmental impact assessment of the Project. 
Interested authorities and organizations, and interested public have been given the opportunity to 
provide their opinion to the competent authority on the submitted request within ten days from the 
date of submission. Within 14 days upon the expiry of the period for public review on the need to 
prepare the Environmental Impact Assessment for rehabilitation and expanding of Health Center 
in Bijelo Polje, the Ministry of Tourism and Environmental Protection issued a Decision stating 
that the envisaged reconstruction of the Health Center in Bijelo Polje does not require a special 
Environmental Impact Assessment study (protocol 01-3995/5, dated January 26, 2009). 
 
12. 
EA reporting and consultations
.
The Ministry of Health, Labor and Social Welfare disclosed the 
draft summary of the EMP for wide public on the web-page of the Ministry 
(www.mzdravlja.vlada.cg.yu
)
on February 13, 2009, inviting all the interested parties to provide 
comments on and to attend the document public consultation. The invitation was also e-mailed 
directly to municipality of Bijelo Polje and its secretariats for urban planning, environmental 
protection, residential-communal affairs, communal police, and local environmental NGOs. One 
week later, on February 20, 2009, the PMN conducted a consultation meeting on the document 
where have participated representatives from different municipality departments (see annex 8.3). 
The meeting concluded that the draft document covered practically all potential impacts and 
possible mitigation measures. On March 11, 2009 MoHLSW organized also a public consultation 
of the EMP document with the representatives from the local population. After the consultations 
the draft EMP was revised, taking into account inputs from the consultation. The final version of 
the EMP was provided to the World Bank, and will be used by the government agencies during 
the project implementation.
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INTRODUCTION
 
The development objective of the Health System Improvement Additional Financing Project is to put 
in place the first phase of steps towards reform of the health system in Montenegro, giving priority to 
increasing capacity for policy, planning and regulation; stabilizing health financing and improving 
primary health care service delivery. Specifically, under the project Additional Financing, the Ministry 
of Health proposes to finance the reconstruction and expansion of the Health Center in Bijelo Polje. 
The Project will supports capital investments, to include full reconstruction and rehabilitation, 
including expanding the existing facility by constructing an extension - a new wing to the existing 
building, and building of an additional floor on top of the existing facility. As decided by the the state 
Ministry of Tourism and Environmental Protection, these activities would not have major 
environmental impacts and therefore, it is not necessary to conduct a full environmental assessment to 
identify the potential environmental impacts and land acquisition issues. Still, a series of measures will 
be proposed in the form of a site specific environmental management plan (EMP) for purposes of 
avoiding and/or minimizing potential adverse impacts and of successful negotiating the additional 
financing.
 
The report covers the following issues: 
(i) 
An overview of project activities and identification physical investments/actions envisaged 
under the project which might have impacts to environment; 
(ii) 
Description of baseline conditions and environmental evaluation of the proposed project site; 
(iii) 
The policy, legal and administrative framework, including the role and responsibilities of the 
Ministry of Health, Labor and Social Welfare of Montenegro (MOHLSW) and other agencies 
in this project related to environmental issues; the environmental and construction permitting 
process of Montenegro applicable to the proposed works; and, 
(iv) 
In line with identified potential impacts and effects, suggested mitigation and monitoring 
measures.   
2
ENVIRONMENTAL ASSESSMENT RULES AND PROCEDURES 
2.1 WB EA POLICIES
 
The World Bank requires environmental assessment (EA) of projects proposed for Bank financing to 
help ensure that they are environmentally sound and sustainable, and thus improve decision making 
(OP 4.01, January 1999).  EA is a process whose breadth, depth, and type of analysis depend on the 
nature, scale, and potential environmental impact of the proposed project. EA evaluates a project's 
potential environmental risks and impacts in its area of influence; examines project alternatives; 
identifies ways of improving project selection, silting, planning, design, and implementation by 
preventing, minimizing, mitigating, or compensating for adverse environmental impacts and 
enhancing positive impacts; and includes the process of mitigating and managing adverse 
environmental impacts throughout project implementation. The Bank favors preventive measures over 
mitigation or compensatory measures, whenever feasible. EA takes into account the natural 
environment (air, water, and land); human health and safety; social aspects (involuntary resettlement, 
indigenous peoples, and cultural property); and trans-boundary and global environmental aspects. It 
also takes into account the variations in project and country conditions; the findings of country 
environmental studies; national environmental action plans; the country's overall policy framework, 
national legislation, and institutional capabilities related to the environment and social aspects; and 
obligations of the country, pertaining to project activities, under relevant international environmental 
treaties and agreements. The Bank does not finance project activities that would contravene such 
country obligations, as identified during the EA. The project triggers the following WB policies: 
OP/BP/GP 4.01 Environmental Assessment and OP 17.50 Disclosure Policy.
 
The Bank undertakes environmental screening of each proposed project to determine the appropriate 
extent and type of EA. The Bank classifies the proposed project into one of four categories, depending 
on the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential 
environmental impacts. In this way risks associated with project actions can be effectively anticipated 
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in advance before project implementation, and addressed by direct mitigation activities in the design, 
planning and construction supervision process as well as during the operation of the facilities. 
 
The Project has been rated "B" as activities under the project are not expected to generate significant 
adverse environmental effects as they are focusing on reconstruction of the existing health care 
building. Based on this the project requires an EA and a simple Environment Management Plan. The 
project will not involve any resettlement or land acquisition and thus the Involuntary Resettlement OP 
is not triggered. The reconstruction and a small extension of the health care center will be done on the 
available municipal land. Other safeguards policies are not triggered.  
 
2.2 National EA rules and procedures 
Procedures preceding construction in Montenegro are the following: land acquisition, location permit 
procurement, environmental impact assessment, and construction permit procurement. For the type of 
projects/activities envisaged under MHSIP Project the full EIA is not required, which is confirmed by 
the decision of the Ministry of Tourism and Environmental Protection (see attached) protocol 01-
3995/5, dated January 26, 2009). After issuance of all relevant permits, completion of construction 
works, and before utilization of the object, it is necessary to obtain an Operation Permit. 
Location permit  
Location permit is an administrative document defined by the Law on Urban Planning and Spatial 
Management (Official Journal of RM No. 28/05). It is issued based on Physical Planning document 
and on special related laws, bylaws and regulations. 
Location permit defines important characteristics of planned intervention and specifically: form and 
size of construction, purpose, size (height, number of floors) and area of the constructed object, 
auxiliary objects on construction site (garages, storages, septic tanks, etc.), architectural form of the 
object (roof, materials and other factors depending on surroundings), site organization, methods and 
conditions of connection of the object to public traffic surface (including parking lots) and communal, 
electrical energy, telecommunication and water supply and sewerage infrastructure.  
Construction permit 
Construction permit is an administrative document defined by the Law on Construction of Facilities 
(Gazette RM No. 55/00). After verification and issuance of the permit, the construction may start. The 
document confirms that the main project activities are in compliance with Location permit and all 
special conditions issued by authorized bodies and obtained. In addition, the construction permit 
provides and assessment of the project conformity with other construction regulations, defined in the 
construction laws and by-laws. For instance the assessment takes into consideration the following 
issues: mechanical resistance, stability of building, fire protection, sanitary health and environmental 
conditions, operational safety, energy efficiency, thermal insulation, access and mobility in the object. 
The ownership and the construction rights on the parcel are as well defined. 
Operational permit 
Operation permit is issued after the technical assessment of the constructed object is done and if is 
proven that the object has been constructed in compliance with Construction permit requirements and 
the design document.  
EMP and administrative procedures preceding construction 
The Environmental Management Plan (EMP) comprises procedures to recognize and control the 
quality of environment and to identify and implement measures in the process of implementation of 
the investment, aiming at mitigation of negative environmental impacts and environmental protection. 
Montenegro EIA laws and bylaws require a specific EMP as an obligatory document only in the case 
of investment projects with significant environmental impacts. In the case of construction and/or 
reconstruction projects like it is proposed in this project there is no need for a specific EIA&EMP 
study. In such cases the basic EMP elements are specified in relevant permits and documents 
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preceding construction, whose supervision is under the jurisdiction of different Ministries and 
agencies. 
3
ENVIRONMENTAL IMPACT ASSESSMENT 
3.1 Scope of the EA  
The purpose of the environmental assessment (EA) is to identify the significant environmental impacts 
of the project (both positive and negative) and to specify appropriate preventive actions and mitigation 
measures (including appropriate monitoring) to prevent, eliminate or minimize any anticipated adverse 
impacts. An Environmental Assessment (EA) was carried out by an independent local consultant, 
based on what was prepared a simple Environmental Management Plan (EMP).  The EA report was 
prepared based on the following: (i) analysis of the existing national legal documents, regulations and 
guidelines; (ii) WB safeguard policies, as well as guiding materials, including EMP Checklist for 
small scale construction projects; (iii) national EA and Construction legal framework; (iv) existing 
EIA for similar projects; (v) site visits and evaluation; and, (vi) results of consultations with the 
representatives from all interested parties and stakeholders. 
 
3.2 Baseline conditions 
Civil works to be conducted comprise full reconstruction and rehabilitation of the existing Health Care 
Centre, including expansion of the facility by constructing a new wing to the existing building, and 
building of an additional floor on top of the facility. The Center was constructed about 60 years ago 
and currently 
can’t accommodate the needs for medical services for about 50 thousand inhabitants of 
the municipality. 
 
The existing facility is two floors building with well fenced adjacent area. The Centre and the land 
where it is placed are fully owned by the municipality. The proposed site is placed within the 
developed section of the city.  Its area is small – about 0.4 ha and is bounded by single-family 
dwellings from the Eastern side and by an apartment bloc from Western side. From the northern side, 
the site is bounded by an unused land plot, while from the Southern side, - by the city road. The 
distance from the private houses and the apartment bloc is about 15-20 meters.  
 
The center is connected to the city water supply system, but not to the sewage network and uses for 
that purpose a septic tank. The existing heating system is in poor condition and based on electricity. 
On the Northern side, at the distance of about 50 meters it is bounded by a river.  
The basic construction elements of the existing facility (foundation, the ceiling and the walls) are in 
good conditions and there is no need to modify and/or strengthen them. The proposed extension of the 
building is rather small – will be constructed one facility wing with an area of about 200m2, connected 
to the main building. The proposed activities outside of the extension and construction of an additional 
floor will also include:  full rehabilitation of the first floor, replacement of the electrical, heating, water 
supply and sanitation systems, connection to the city sewage system, fencing of the center’s area from 
the western side, as well as creating a special parking lot. The existing facility has no hazardous 
materials, in particular no asbestos was used for roofing as well as an insulation material.  
 
All reconstruction activities will be conducted on the land which is fully in municipality’s ownership 
and not legally and or illegally occupied, and thus there is no need for any acquisition of additional 
land. The area which belongs to the health center is fenced from three sides and might be easily 
identified also from the forth side. The designer of the center provided clear explanations there will 
not be any activities outside the land belonging to the center. 
 
Satellite image of the project location is presented in the illustration below: 
 
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Geological characteristics 
 
The project site is placed on an alluvial plateau of the left bank of the Lim River. The shelf of the 
alluvial sediments is composed of sandstone and slate, weakly indented surface. The prominence in the 
Paleozic relief is filled with coarse-grained alluvial sediment. The Lim riverbed is shallow, relatively 
flat in all of its width, cut into (3.5-4.0m) alluvial and sediments of the Paleozic relief. This shows neo-
tectonic activity of the area, that is, subsidence of the erosion base of the Lim River, which resulted in 
the Lim River cutting into already formed alluvial plateau. 
 
Loose “cover” is composed of alluvial sediment. These are formed in the immediate surroundings of the 
water course, and in the riverbed to a lesser extent. The thickness of alluvial sediment is 3-5m, and in 
lithology terms, gravel boulders and sand, whose main rock is mainly composed of quartzite and quartz 
sandstone, are dominant. They are characterized by a relatively weak to moderate compactness in the 
lower zone and low compactness in the upper zone of sediments. 
 
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In the area of the Lim riverbed, there is a considerable presence of round and semi-round blocks of 
various dimensions. 
 
Vegetation  
 
The existing Health Center is located in urban environment, which is characterized by a small number of 
flora representatives, which are not that important. On the project site there are a series of trees, mostly 
coniferous as well as bushes. The adjacent to the Center areas are covered by grass. On the Southern 
side there are other trees: bitter oak, oak, plantations of black pine, beech and birch. None of these trees 
are protected by law. 
Climate characteristics, precipitation and air 
The climatic conditions of the project site heavily depend on the existing relief which influences the 
distribution and the volume of precipitation, air humidity, etc. The review of climate in Bijelo Polje 
requires the knowledge of climate factors such as: trends of air temperatures, humidity, cloudiness, 
insulation, precipitation and wind. The data presented below are related to the measurement period of 
1947-2004. 
Air temperatures for Bijelo Polje are presented in Table 3.2.1. 
Table 3.2.1: 
mean monthly and annual air temperatures (°C)
 
LOCATION
M
O
N
T
H
S
year
 
1
II
III
IV
V
VI 
VII
VIII
IX
X
XI
XII
Bijelo
 
Polje
 
-1.7
0.7
4.6
9.0
13.2
16.2
18.0
17.6
14.3
9.4
4.7
0.1
8.8 
From the presented data it is possible to specify the mean monthly temperatures in the project site 
range between -1.7°C in January and 23,3°C in July. The summer is relatively short, and the warmest 
months are July and August. Average annual air temperature is 8.8°C. 
The precipitations and their distribution, in addition to relief, is determined by the distance of the 
location from the sea. The precipitation volumes, as mean monthly values, and their annual level are 
presented in the Table below. 
Table 3.2.2:
 Average monthly and annual precipitation 
LOCATION
 
M
O
N
T
H
S
year
Bijelo Polje
 
I
II
III
IV
V
VI
VII
VIII
IX
X
XI
XII
74
67
60
70
77
73
64 
60
65
79
107
86
883
The average minimum precipitation of 601mm/m
2
in Bijelo Polje occurs in March and August. The 
maximum, monthly average precipitation occurs in November 107 and December 861mm/m
2
.
Average 
annual precipitation amounts of 8831mm/m
2
.
From the data presented in Table 3.2.2 it possible also to 
conclude that the precipitation in the area of Bijelo Polje is balanced during the year and by months. 
Rain and mizzle in the region from Berane to Bijelo Polje, may, average, last 1-10 days a year, and 
range from 36 to 168 days a year. The number of snowy days is, at average, 38 days, ranging from 
minimum 8 to 125 days a year. Snow stays at average 55 days a year, and lasts from 1 to 96 days. Hail 
and storms may last, at average, 25 days a year, and occur and last from 1 to 55 days. The number of 
foggy days, at average, is 55, with minimum 9 days and maximum 105 days a year. 
 
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The data are presented in Table 2.5, and it shows that the highest mean speed belong to SW (south-west) 
winds, which blow with average speed of 3.3 m/s, while eastern (E) winds have the lowest average 
speed of only around 1,1 m/s. North and south winds are dominant. 
 
Table 3.2.4.: 
Data on average wind speed by direction in mls and frequency of some directions 
Direction 
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
TIHO
Frequency 
in % 
17.6
3.9 
0.1
0.0 
0.1
0.1
0.4
2.5
11.7
4.0 
2.4
3.3 
1.1
0.5 
1.1
5.8 
45.3 
Av.speed 
in u 
m/s
3.0
3.1 
2.8
3.2 
1.1
1.2
1.7
2.4
2.8
3.3 
3.5
3.4 
2.8
2.3 
2.2
2.4 
Max. 
speed 
15.5
15.5
6.7
6.7 
2.4
4.4
9.3
12.3
22.6
18.9
15.5
15.5 
9.3
9.3 
9.3
12.3 
In the region of Bijelo Polje, Lim valley extends in the north-south direction, and it can be assumed that 
this direction will be dominant in relation to frequency and mean and maximum wind speed. However, a 
valid assessment of this climate parameter is not possible without quality measurements or numeric 
modelling of winds in the region of Bijelo Polje (it is noticeable that the most frequent winds and the 
strongest winds in Bijelo Polje come from the north, which is a result of topography around the Lim 
valley). 
 
Based on available survey data (HMZCG and JUCETI-Podgorica), the parameters of air quality for the 
region of Bijelo Polje are presented in Table 3.2.5. 
 
Table 3.2.5.: 
Mean values of air quality for the region of Bijelo Polje 
 
2002g.
2003.g.
Smoke and soot      ΅g/m
3
14.71
24,3
SOx                        ΅g/m
3
31,96
20,9
NOx                        ΅g/m
3
2,16
2,8
Floa
ting particles    ΅g/m
3
72,86
74,2
Sed. mat.      mg/m
2
/day
/
144,3
Ammonia                ΅g/m
3
1,74
1,04
Formaldehide         ΅g/m
3
/
1,66
Hydrog
-
sulphide    ΅g/m
3
5,92
1,57
Phenol                    ΅g/m
3
1,42
/
Fluoride        
΅g/m
3
0,07
/
From the presented data that the air quality in the surveyed region is satisfactory. 
 
The presented data show that the analyzed parameters are within standard limits applicable to 
precipitation above the territory of Montenegro. 
 
3.3 Potential Environmental Impacts 
 
As described in the Project scope, activities supported by this Project relate to rehabilitation and 
expanding of an existing Health Center. The Project activities are not expected to generate significant 
adverse environmental effects as they are focusing largely on refurbishment and reconstruction of the 
existing facility, Potential environmental impacts can be classified into three categories 
–related to 
design, construction, and to operation. The main potential impacts that derive from the reconstruction 
activities are the following: 
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a. 
Dust and noise: 
These impacts occur during both demolition and construction activities and are 
sites specific. To avoid
 
these impacts it is needed to follow up the existing best construction 
activities which are well known and applied in the country and set up in the EMP; 
b. 
Asbestos:
 
asbestos has not been used in the construction of this Health Center, and will not be 
used either in the planned rehabilitation, expanding and superstructure; 
c. 
Soil contamination:
 
construction activities may cause some contamination of soil by hydro-
carbon, or while it is moved during construction works, which also results in the contamination of 
surface and underground water. Contractors should take measures to avoid this; 
d. 
Waste handling and spill response:
 
Routine construction activities will generate solid and liquid 
wastes including drywall, machine oil, paints, and solvents.  Minor spills of fuel and other 
materials are likely to occur during the course of construction.  Improper handing of on-site wastes 
and response to spills could result in adverse effects on the local environment including 
groundwater, surface waters, terrestrial ecosystems, and local residents. 
Environmental impacts during operational phase are related mostly to the following: 
-
Medical Waste Handling
:
medical waste include sharp objects (discarded needles/syringes, 
scalpel blades, empty glass vials, or other sharp objects); laboratory wastes (including specimen, 
urine and blood, cultures and material that they have contact with, hazardous chemical waste, and 
biological reagents). To minimize their impacts it is necessary to follow-up the rules and 
procedures of their handling specified in the Strategy of Medical Wastes management; 
-
General Waste Handling and Spills
:
Health Center facilities may generate a stream of non-
infectious solid and liquid waste, and experience occasional spills of machine oils, paints and 
other similar substances.  If improperly handled these materials can negatively affect terrestrial 
and aquatic ecosystems and expose local residents to health hazards and nuisance.  
All these impacts can be effectively dealt with, if they are recognized through this EMP in the design 
phase. In this project, implementation of mitigation measures can be advised on three levels: design, 
construction/reconstruction and operation. These measures should be feasible and cost effective 
aiming at eliminating, offsetting and reducing adverse environmental impacts. The measure should not 
only deal with recognized risks, but should as well be used as guidance to make facility more 
environmentally friendly and sustainable.
 
4
ENVIRONMENTAL MANAGEMENT PLAN 
The Environmental Management Plan (EMP) has been prepared in order to integrate environmental 
concerns into the design and implementation of the proposed Project. The EMP is based on the WB 
EMP Checklists for small scale construction activities and would support: 
(a)  inclusion of the EMP follow-up procedures in the Project Implementation  Manual; 
(b) inclusion of  Environmental guidelines in construction contracts; 
(c) highlighting of EMP follow-up responsibility within the PMN; 
(d) specifying mitigation and avoidance measures during the implementation of the proposed 
activities; 
(e) monitoring and evaluation of mitigation/avoidance measures identified in the site-specific review 
and in the EMP. 
 
4.1 Environmental Guidelines  
The Environmental Guidelines section of the EMP details the specifics to be addressed during the 
design and reconstruction of the health center. The guidelines cover the handling of construction 
debris generated, selection of construction materials and construction methods with limited impact on 
the environment, as well as the handling of wastes, and storage of hazardous materials under project 
supported activities.  
Page  12
  
Page
 12/32 
  
4.1.1 Design phase  
During the design phase many important issues could be approached, investigated and best choices 
incorporated into detailed project documents. Designer should apply the best construction practices 
with regard to proposed activities, design of object in a manner that are accessible, energy efficient, 
taking into consideration adaptation of building to the existing surrounding landscape and surrounding 
architecture and also, taking into account special requirements related to the need for appropriate 
system/facilities to handle medical waste. 
4.1.2 Reconstruction phase 
During the reconstruction phase the emphasis is on possible environmental impacts that follow the 
demolition and construction works. Issues that could be addressed are: construction and other waste 
management, minimization of dust and noise, site restoration, temporary storage of the material, 
storage of hazardous materials, traffic management plan, working hours, encroachment into the 
neighbor territory.  
Noise reduction
.
Before any beginning of the work it is recommended to inform neighbors either 
directly or through local billboards or newspapers on the reconstruction activities. The noise should be 
limited by using good management practice and limiting works on regular daily shift. The equipment 
and machinery used should be calibrated according to the Regulations on the allowed limit values of 
sound and noise (
Law on Protection from Noise (“Official Journal of Montenegro”, no. 45/06)). 
Dust minimization
.
Temporary technical solutions and measures for dust minimization during 
reconstruction should be used. For the transportation of earthlike or any other dusty material to the 
construction site or of the construction site watering or covering of the cargo should be implemented. 
Reduction of dust on construction/reconstruction site during dry season of the year can be 
accomplished by watering the ground surface. At the same time, water should not be wasted. Reducing 
speed of the vehicles can be another applicable measure. Workers that perform demolition should be 
introduced with safety equipment, while dust from the object should be prevented by enclosing of 
construction site or use of screens. 
Construction wastes and spills. 
It is recommended that contractor prior to start of the works ask the 
facility to remove all equipment and material that will no longer be used and to dispose of it or recycle 
it in a proper manner. Wastes where ever possible should be minimized, separated and handled 
accordingly.  
When wastes are separated as advised in the Law on Waste Management (“Official Journal of 
Montenegro”, no. 80/05) they are more manageable. Some materials like doors or ceramics sinks 
might be usable on the site again. Non-usable materials should be taken to appropriate place for 
recycling. For non recyclable wastes, in agreement with municipality the wastes will de deposited on 
city landfill. Open burning and illegal dumping of any waste is strictly prohibited.  
In addition to solid wastes, some amounts of hazardous wastes will be produced on the site: like the 
remaining from paints, enamels, oiled packaging, oils, material contaminated with oil, insulation 
material, medical wastes etc. –based on the provisions of the Law on Waste Management (“Official 
Journal of Montenegro”, no. 80/05), - all wastes have to be collected and handed over to the local self-
government body authorized for collection and transportation of hazardous waste, i.e. public 
communal enterprise “Lim”, Bijelo Polje. 
Medical wastes have to be separated and stored in special receptacle and must be handed to authorized 
company within 8 days since its generation. Infectious wastes have to be stored in hermetically sealed 
receptacles. 
As a general requirement is that the existing building elements to be demolished (walls, ground 
cement slabs etc.) should be carefully demolished and the debris should be sorted and removed as 
directed by the EMP (to be determined during the preparation phase of the project). All valuable 
materials (doors, windows, sanitary fixtures, etc) should be carefully dismantled and transported to the 
storage area assigned for the purpose. Valuable materials should be recycled within the project or sold. 
 
Page  13
  
Page
 13/32 
  
Site organization and restoration.
 Construction site should be fenced off in order to prevent entry of 
public, and general safety measures would be imposed. The projection is that there would not be any 
major temporary inconveniences regarding traffic or other due to reconstruction works, and the ones 
that arise will be minimized through planning and coordination with contractors, neighbors and 
authorities
.
The traffic in the part of Voja Lješnjaka Street will be somewhat burdened by trucks 
supplying construction material and removing waste, but not to the extent of having to stop the traffic, 
or having it rerouted. Therefore, during reconstruction, the traffic would remain uninterrupted, and it is 
the Contractor’s responsibility to make sure this is the case throughout the reconstruction phase. After 
completion of works the site should be restored as planned in the design. All wastes and machinery 
should be removed from the location. Given the geology attributes of the location, the works are to be 
executed in the morphological level of a terrace; therefore, planned works cannot cause erosion 
Temporary storage of material (including hazardous materials). 
Stockpiling of construction material 
should be avoided if possible. If not, construction material should be stored on the construction site, 
and protected from weathering. Hazardous materials like paints, oils, enamels and others should be 
kept on impermeable surface, and adsorbents like sand or sawdust should be kept for handling small 
spillage. Handling with the material should be consistent with the instructions on Material Safety Data 
Sheets. 
Encroachment into neighboring territory. 
There is no need for
 
encroachment into neighboring 
territory and it is not permitted.  
Archeological and cultural monument. 
If encountering archaeological finds during preparation of the 
site for the construction, the contractor should stop the works, respond immediately and notify the 
municipal authorities, the Republic Bureau for Cultural Heritage Protection of Montenegro and the 
project team in the MHLSWMN.  
Working hours. 
To avoid noise and disturbance of neighbors the works should be conducted in a daily 
shift, meaning from 7 am to 6 pm. For other working hours special permits are required. 
4.1.3 Operation 
During the operation the main emphasis should be on proper waste management. 
Medical waste management.
 Per existing legislation, each institution issues internal order for waste 
management. In this order different waste types would be identified and for each of them the manner 
of their handling would be described. By screening proposed investment it is obvious that in addition 
to municipal waste medical waste will occur. 
Medical wastes could be classified into following categories: a) hazardous wastes: infective wastes, 
chemical wastes containing toxic substances, sharp objects, citostatics and citotoxic, amalgam waste 
and other hazardous waste; b) non hazardous medical wastes. Medical wastes have to be separated and 
stored in special receptacle and must be handed to authorized company within 8 days since its 
generation. Infectious wastes have to be stored in hermetically sealed receptacle. The institution 
should develop a plan for medical wastes management. Supervision on the implementation of the plan 
will be carried out by County’s sanitary inspection. The legal entity disposing or treating such wastes 
should be in a possession of license for handling hazardous waste – medical wastes. 
 
All impact minimization and/or avoidance measures for both construction and operation phases are 
summarized in the table 4.1.4, presented below.  It is proposed the MoHLSW and the WB will 
monitor that such provisions are in place in the bidding documents and follow-up contracts. 
Furthermore, the consultants to be engaged in the design of the reconstruction of the facility 
supplemented by advice from the Bank team will advice on management of environmental risks, 
including from arising from reconstruction works, including appropriate disposal of construction 
waste, and mitigating effects of noise and dust. Contracts and bill of quantities will include clauses for 
appropriate disposal of unacceptable construction material and disposal of construction waste. 
Procurement documents will specify that no environmentally unacceptable materials will be used.  
Page  14
 
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Page  15
 
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1
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19
 
5
MONITORING AND SUPERVISION PLAN 
The EIA study specifies also the monitoring activities. Parameters to be monitored, frequency, 
modality and schedule of monitoring activities are presented in the Table 5.1. 
The project implementation will be supervised by the WB (during its supervision missions) 
and by the local ecological and environmental construction inspectors. 
The project implementation progress reports will contain a special section concerning EMP 
implementation and compliance with the WB and National environmental requirements. 
The construction company will present semi-annually short reports on EMP implementation 
to the Coordinating body for the EMP implementation. 
 
Page  20
 
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6
RESPONSIBILITY FOR EMP IMPLEMENTATION AND FINANCING 
During the reconstruction phase, monitoring of the EMP implementation is going to be funded as part 
of provisions of the reconstruction supervision contract, and is the responsibility of the reconstruction 
supervision firm to be selected to perform the supervision of works. 
 
Implementation of specific EMP-stipulated mitigation measures during the reconstruction will be 
funded as part of provisions of the reconstruction works contract, and is the responsibility of the firm 
selected to execute the reconstruction works. 
 
For purposes of implementing the EMP-stipulated mitigation measures during the operation phase of 
the facility, the management of Health Center Bijelo Polje is going to assign two of the relevant 
existing staff members to act within a Coordinating Body for EMP implementation, with the 
possibility of hiring a technologist, on a part-time basis. No considerable costs would arise, given that 
the relevant existing staff members would be financially stimulated through certain salary increase 
percentage, depending on the extent of their monthly engagement, the same pertaining for potential 
honorary-based engagement of a technologist.  
 
Members of the Coordinating Body for EMP implementation would be responsible for making sure 
that the Health Center staff get familiar with the EMP-stipulated environmental impact mitigation 
measures and act accordingly in terms of all aspects of waste management. 
The members of the Coordinating body will be selected/appointed taking into account his/her 
knowledge of the EA/environmental protection requirements. Familiarity with the relevant legislation 
in this field (appendix 8.1), as well as MHSIAFP EIA&EMP, would be a requirement, for which no 
considerable costs would arise.  
The existing EA capacities within the local environmental inspectorate are adequate. 
Coordinating body will be also responsible for supervising independently or jointly with the State 
Ecological Inspectorate the mitigation and environmental protection measures stipulated in 
Environmental Management Plan  
 
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7
PUBLIC DISCLOSURE
 
and Consultation  
The Ministry of Health, Labor and Social Welfare has disclosed the draft EA summary for wide public 
on the web-page of the Ministry (www.mzdravlja.vlada.cg.yu
)
on February 13, 2009, inviting all the 
interested parties to attend the public discussion on the posted document. The invitation was also e-
mailed directly to municipality of Bijelo Polje and its secretariats for urban planning, environmental 
protection, residential-communal affairs, communal police, and local environmental NGOs. One week 
later, on February 20, 2009, the PMN conducted a public briefing and consultation meeting on the 
document. (see Annex 8.3 with the minutes of the consultation). The meeting concluded that the draft 
EMP document covered practically all potential impacts and possible mitigation measures.  The draft 
EMP was revised after the meeting taking into account inputs from the consultation.  The final version 
of the EMP was provided to the World Bank, and will be used by the government agencies in the 
project implementation.  
 
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24
 
8
APPENDIces  
8.1 Legislation 
·
The Law on Environmental Protection (“Official Journal of Montenegro”, no. 51/08),  
·
the Law on Environmental Impact Assessment (“Official Journal of the Republic of 
Montenegro”, no. 80/05),  
·
the Law on Construction of Facilities (Official Journal of the Republic of Montenegro, no. 
55/00),  
·
the Rulebook on the contents of the Environmental Impact Assessment (“Official Journal of 
Montenegro”, no. 51/08),  
·
Bylaw on projects that require Environmental Impact Assessment Study (“Official Journal of 
the Republic of Montenegro”, no. 20/07), 
·
The Law on Waste Management (“Official Journal of Montenegro”, no. 80/05), 
·
The Law on Protection from Noise (“Official Journal of Montenegro”, no. 45/06). 
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25
 
8.2 List of consulted people 
 
-
Dr. Svetozar Cerovi, Director of Dom zdravlja Bijelo Polje, 
 
-
Mr. Radovan Obradovic, Chief Administrator, Municipality of Bijelo Polje,  
-
Ms. Danijela Lazarevic, Environmental Inspector, Bijelo Polje Municipality, 
-
Mr. Vladimir Lukovic, Designer, Civil Engineer, 
-
Mr. Meho Tokovic, Designer, Mechanical Engineer, 
-
Ms. Sava Vuletic, Advisor, Agency for Environmental Protection, 
-
Mr. Darko Novakovic, Hydrogeologist, Hydro Meteorological Institute of Montenegro, 
-
prof. dr. Goran Sekulic, Civil Engineering Faculty of Podgorica. 
 
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8.3 Minutes of the public consultation of the EMP 
 
M
I
N
U
T
E
S
Of the public discussion regarding the summary of the Environmental Impact Assessment and 
the Environment Management Plan for the reconstruction of PHC Center in Bijelo Polje 
 
The Ministry of Health, Labour and Social Welfare of Montenegro organized two public discussions 
on the summary of the Environmental Impact Assessment and the Environment Management Plan for 
the reconstruction of PHC Center in Bijelo Polje, situated in the centre of the city at Voja Lješnjaka 
Street, Pruška settlement. The first one was conducted on March 11
t
h
and the second one – on March 
20
th
,
2009. 
 
The first consultation brought together representatives from the local population. The inhabitants of 
the households in the close vicinity of PHC Center in Bijelo Polje were distributed hard copies of the 
Executive Summary of the EIA&EMP on March 4, 2009, and asked to come to the  PHC Center in 
Bijelo Polje on March 11, 2009 for a meeting with the BP PHC  Center management in order to 
express any of their concerns regarding the  
planned reconstruction. Representatives of the local population that attended the meeting were: 
Raosavljevic Veljo, Bulatovic Vojo, Medojevic Vukoman and Puletic Zvonko. 
PHC Center management representatives at the meeting were: Svetozar Cerovic, Director of PHC 
Center in Bijelo Polje, Andelina Drljevic, Secretary, PHC Center, Jelena Pekovic, Chief Nurse of the 
PHC Center, Velizar Lukovic, and Designer of the reconstruction of PHC Center, Ibrahim Lukac, and 
Accounting Manager of PHC Center. Representatives of the local population were acquainted with the 
details of the planned PHC Center reconstruction and, in that regard, relevant facts of the 
Environmental Impact Assessment and Environmental Management Plan. None of the local population 
representatives had any comments, objections or suggestions regarding the presented information, nor 
they expressed any concerns regarding the environmental impact mitigation measures prescribed by 
the EIA&EMP document. There was a unanimous conclusion that the EIA&EMP document included 
undertaking mitigation measures to cover all potential environmental impacts. 
 
The second consultation was organized with the municipality representatives and other interested 
partiers.. The EMP document was made available to all interested parties on February 13, 2009, on the 
web-site of the Ministry of Health, Labour and Social Welfare at: 
www.mzdravlja.vlada.cg.yu
.
The public discussion was held on Friday, February 20
th
 2009, at 12:00, in the premises of PHC Center 
Bijelo Polje.At the beginning of the public discussion, the participants were welcomed by the local 
environmental consultant, Mr. Aleksandar Duborija, who was involved in preparation of the above 
documents and who chaired the public discussion. 
The public discussion was attended by: 
-
Svetozar Cerovi, Director of PHC Center in Bijelo Polje,
 
-
An
elina Drljevi, Secretary, PHC Center,
 
-
Jelena Pekovi, Chief Nurse of the PHC Center,
 
-
Danijela Lazarevi, Environmental Advisor in the Municipality of Bijelo Polje,
 
-
Velizar Lukovi, Desig
ner of the reconstruction of PHC Center, 
-
Ibrahim Luka, Accounting Manager of PHC Center.
 
Mr. Duborija made an introduction and informed the participants about the procedure of the impact 
assessment in relation to this document, which preceded the public discussion. 
Neither individuals nor institutions have submitted any objections, suggestions or statements in 
relation to these documents within the period defined for this purpose. 
Mr Duborija presented all the relevant facts from the Environmental Impact Assessment and the 
Environment Management Plan related to the reconstruction of PHC Center in Bijelo Polje.  
This was followed by Mr. Svetozar Cerovi presenting all the requirements which imposed an urgent 
reconstruction of PHC Center. The facility needed internal remodelling in order to support the PHC 
organizational change, to rationalize inefficient use of space, as well as to facilitate the functioning of 
group practices. 
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27
 
Velizar Lukovi, the Designer of the reconstruction of 
PHC Center highlighted the most important 
details of the reconstruction project. 
Mr. Duborija then presented the mitigation measures to be undertaken during the operational phase of 
the PHC Center, related to the Environment Management Plan.  
The participants agreed with the presented and concluded that the draft EMP document covered 
practically all potential impacts and possible mitigation measures. 
 
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8.4 
Decision of the Ministry of Tourism and Environmental Protection 
 
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