A road safety audit for the project has not been undertaken and it was reported that EBRD will commission this study soon. It is recommended that if this study is undertaken, its recommendations should be implemented and this is included in the ESAP. However it was reported that the safety design aspects of the road follow the Kazakhstan standards which are increasingly aligned to international standards of best practice.
According to SNiP RK 3.03.09-2006, the road “Kapshagai – Kutry” km 0-67 is an international road. The norms and standards used for the design are set out in SNiP RK 3.01-01-2008 (08.09.2015) and SNiP RK 3.03.09-2006. The technical standards according to the SNiPs are presented in Table 7 and Table 8 below.
Table 7 – Main Technical Norms (within Kapshagai)
| No | Name of Parameters | Requirements of SNiP 3.01-01-2008 (dated 08.09.2015) | Road Parameters |
| Road category | Highway: the main zonal continuous and controlled movement | ||
| Calculated speed, km/h | |||
| Number of lanes | |||
| Width of a lane, m | 3.75 | 3.75 | |
| Width of the roadway, m | 15.0 | 15.0 | |
| Width of dividing strip without road barriers, m | According to approved plan | 3.0 | |
| The smallest radius of the curves in the plan, m | |||
| The greatest longitudinal slope, ‰ | |||
| The greatest width of the land base, m | |||
| The width of the pedestrian part of the sidewalk, m | 3.0 | 3.0 |
Table 8 – Main technical Norms (Main Road)
| N0 | Name of Parameters | Requirements of SNiP 3.03-09.2006 | Road Parameters |
| Road category | 1b | 1b | |
| Calculated speed, km/h | |||
| Number of lanes | |||
| Width of a lane, m | 3.75 | 3.75 | |
| Width of the roadway, m | 15.0 | 15.0 | |
| Width of dividing strip without road barriers, m | No less than 5 m | - | |
| Width of the dividing strip with railings along the road axis, m | No less than 2 m + the width of a barrier | 3.00 | |
| Curb width, m | 3.75 | 3.75 | |
| Width of the reinforcement strip by type of main road: -on the side of the dividing strip, m -by the side of the curb,m | 1.00 Up to 2.50 | 1.00 2.50 | |
| Width of the land base, m | 25.5 | 25.5 | |
| Transverse slope of the roadway and the reinforcement strip, ‰ | |||
| The transverse slope of the curb, ‰ | |||
| The greatest longitudinal slope, ‰ | |||
| The shortest visibility distance for oncoming traffic, m | |||
| The smallest radius of the curves in the plan, m | |||
| in the plan, m | |||
| in the longitudinal profile: | |||
| convex, m | 15 000 | 15 000 | |
| concave, m | 5 000 | 5 000 | |
| Slope steepness at embankment slope height | |||
| Up to 3.0 m | 1:4.0 | 1:4.0 |
Technical safety features of the project are aligned with item 10.10 of the SNiP 3.03-09.2006 and ST RK 1412-2010 and include:
¡ Dividing strips, which are intended for the separation of counter flows and preventing cars from going to the oncoming lane; and
¡ Transitional speed bands near junctions and on the approach to bus stops and rest areas (the length of the acceleration and deceleration bands was adopted in accordance with the SNiP for the Ib road category).
Other standards used for the design of safety features include:
¡ ST RK 1412-2010 "Technical means of organizing traffic". Rules for the use of road signs, markings, traffic lights, road barriers and guiding devices.
¡ ST RK 1125-2002 “Road signs”.
¡ ST RK 1124-2003 “Road marking”. Technical requirements. (ВS EN 1436:200).
¡ ST RK 2368-2013 “Metal safety barriers”.
All road safety features are approved by the committee of administrative police of the Ministry of Internal Affairs of Kazakhstan Republic No 5-5-8-168/5-204 dated 13.02.2017.
The project design includes 4 rest areas. The approach to these rest areas will use transition-speed lanes to reduce the speed of vehicles. The rest areas will include pavilions for resting, waste containers, toilets and pedestrian access paths.
The project includes provision of two bus stops. Location of the bus stops was approved by Local authorities of both Kapchagai town and Iliyski district. On approach to the bus stops the road is equipped with transition – speed lanes.
In order to ensure safe crossing of the road, there will be two zebra crossings located near the bus stops. Zebra crossings will be equipped with “noise” strips, which will be located across the road 1 metre apart and made out of thermoplastic. The “noise” strips design is compliant with the requirements of ST RK STB 1538-2007 “Artificial uneven surfaces on roads and streets”.
There will be two pedestrian crossings equipped with traffic lights on the section of the road within the border of Kapchagai Town.
Metal mesh will be installed along the whole length of the road to prevent animals going onto the road.
There have been no accidents recorded for the 67 km section of road in 2016 and 2017. Although there were no reported accidents and no fatalities in 2016-2017 on the 67 km section of the road, there have been a significant number of accidents over the last few years on the full road alignments between Astana and Almaty.
Under PR4, there is a requirement to take into consideration relevant EU road and traffic safety management standards and, where appropriate, to undertake a road safety audit for each phase of the project and routinely monitor incident and accident reports to identify and resolve problems or negative safety trends. Where there are vehicles or fleets of vehicles (owned or leased), there should be appropriate training provided to workers on driver and vehicle safety. There should be regular maintenance of all project vehicles.
6 gap analysis and supplementary information
6.1 APPROACH
A gap analysis has been conducted against applicable local legislation, the EIA Directive, EBRD PRs, and best practice requirements. The key findings are presented in this chapter of the report.
6.1.1 ALTERNATIVES AND CUMULATIVE ASSESSMENT
The EIA Directive requires both an assessment of alternatives and an assessment of cumulative effects which are not referenced or included within the EIA. At consultation meetings it is understood that alternatives of the detailed design of the road were presented. The assessment of alternatives will, as a minimum, need to:
¡ Outline the reasonable alternatives considered for the Project (design, location and scale);
¡ Appraise each alternative, including high-level environmental impacts; and
¡ Clearly outline the main reasons for the chosen option over the alternatives presented.
The cumulative assessment will, as a minimum, need to:
¡ Outline other existing and / or approved projects; and
¡ Consider the potential for cumulative effects of the Project in relation to other projects (e.g. on material availability etc.).
Both the assessment of alternatives and the cumulative assessment would typically be individual chapters within an EIA. It has therefore recommended that the EIA is updated or an addendum to the existing EIA is developed and this is included in the ESAP.
6.1.2 AIR QUALITY, NOISE AND VIBRATION
The EIA Directive and EBRD PR3 require consideration to be given to potential impacts on air quality and impacts associated with noise and vibration.
6.1.2.1 AIR QUALITY
Identification of air quality receptors along the route alignment has not been undertaken. Such sensitive receptors are likely to include properties and settlements, and sensitive ecological habitats, either adjacent to, or, in the immediate vicinity of the route alignment. The EIA does reference a number of settlements in the area, including the Kurty and Akshi settlements, however the proximity of these settlements from the Project is not stated. As discussed in previous chapters, there are a number of farms close to the road and associated planned construction areas that need to considered and further details are provided below.
It is understood that no baseline air quality assessment has undertaken, and mitigation measures have not been identified for either the construction or operational phases. It is therefore recommended that the following steps are undertaken with regards to preventing adverse impacts on air quality (potential to influence human health and the environment):
¡ Identify and map potentially sensitive receptors along the route alignment (e.g. properties and settlements). The map should also consider any ecological habitats that may be sensitive to air quality;
¡ Undertake baseline air quality monitoring for NO2 and PM10 at sensitive locations along the alignment for a minimum of three months (preferably six months) prior to the start of construction. The monitoring should be undertaken in accordance with EU Standard Methods for monitoring, as published in 2005;
¡ Undertake an assessment of the Project (during construction and operation) to identify any potential worsening (or improvements) in air quality at the identified sensitive receptors;
¡ Continue to undertake air quality monitoring during the construction;
¡ Undertake visual dust monitoring daily during construction, and dust dampening measures taken if required; and
¡ Establish a complaints hotline for the duration of the works and the number should be displayed at appropriate locations near the road.
The baseline monitoring shall be considered supplementary EIA information and included in the ESMS and/ or in the CEMP and this recommendation is provided in the ESAP.
The air quality monitoring will require a continuous analyser and diffusion tubes at the sensitive receptors. The purpose of this monitoring is to determine the change and absolute values of atmospheric pollutants as per the standards at sensitive receptors as a result of the Project. As shown in Table 9 below, the Air Quality Standards in Kazakhstan are either equal to or more stringent than EU standards.
Table 9 – Air Quality Standards
| Pollutant | Kazakhstan Standards (MCP a/ mg/m3) | EU Standard | ||||
| Pollutant | 20 Min | 24 Hours | 1 Hour Average | 24 Hour Average | Annual Average | Maximum Daily 8 Hour Mean |
| Nitrogen Dioxide (NO2) | 0.085 | 0.04 | 0.2 mg/m3 (may be exceeded 18 times per year) | 0.04 mg/m3 | ||
| Particulate matter (PM10) | 0.15 | 0.05 | 0.05 mg/m3 (may be exceeded 35 times per year) | 0.04 mg/m3 | ||
| Carbon Monoxide (CO) | 5.0 | 3.0 | 10 mg/m3 | |||
| Lead (Pb) | 0.001 | 0.0003 | 0.0005 mg/m3 |
As mentioned previously there are a number of properties that are in close proximity to the road. The closest being Farm 4 which originally fell inside the Kurty junction but following later revisions the junction was set 50m west of the farm house at the same elevation as the house. There are also other farms or residents in close proximity to the road include a residential area in Kapshagai where a realigned section will mean that the road is closer, Farm 3, Farm 5, Farm Brigada 9 and Farm 11. Therefore at Farm 4 and potentially other properties as listed and to be determined by an air quality specialist, modelling is recommended.
To evaluate these impacts modelling is suggested with the local software Ekolog. For the input data, traffic intensity and composition on the road and the junction will need to be determined or assumed for the worst case in the uncertainty range. From this data, a stationary source located at the road opposite these farms houses is to be assumed. Then pollutants dispersion needs to be modelled from this stationary source. The Ekolog takes into account the distance, relevant elevation of the source and receptor and climatic data including the least favourable for dispersion conditions.
The software algorithm overestimates pollution and it is rare that the actual pollutants concentration achieves the modelled values. Thus if the modelling shows concentration below the maximum permitted for residential areas, no further actions are recommended for these farms. If modelling shows high levels, then air quality monitoring should be undertaken. A pair of diffusion tubes should be set at the façades of houses. The tubes should be replaced at the end of each month. A year observations of NOx and SO2 concentration should be acquired in this way. Concentrations of PMs are to be assumed proportional to these pollutant concentrations unless significant exceedances and fluctuation of results are recorded. Then PM2.5 and PM10 should be measured at the worst case climatic conditions (if possible).
The farmer’s opinion on the air quality should be recorded at each tube exchange.
6.1.2.2 NOISE AND VIBRATION
Identification of noise and vibration receptors along the route alignment has not been undertaken. Sensitive noise and vibration receptors are likely to include properties and settlements either adjacent to, or, in the immediate vicinity of the route alignment. The EIA does reference a number of settlements in the area, including the Kurty and Akshi settlements, however the proximity of these settlements from the Project is not stated. As discussed in previous chapters, there are a number of farms close to the road and associated planned construction areas that need to considered and further details are provided below.
It is understood that a baseline noise and vibration assessment has not been undertaken and nor have mitigation measures been identified for either the construction or operational phases. It is therefore recommended that the following steps are undertaken with regards to preventing adverse impacts associated with noise and vibration (potential to influence human health and the environment):
¡ Identify and map potentially sensitive receptors along the route alignment (e.g. properties and settlements). The map should also consider any ecological habitats that may be sensitive to noise and vibration;
¡ Undertake baseline day-time, evening and night-time noise monitoring at sensitive locations prior to the start of construction. The monitoring should be undertaken in accordance with Directive 2002/49/EC ‘Relating to the Assessment and Management of Environmental Noise’ (the Environmental Noise Directive) and / or the anticipated EU Noise Policy;
¡ Undertake an assessment to identify any locations with existing elevated noise levels, and to consider the implications of any increases on these locations;
¡ Undertake an assessment of anticipated noise and vibration levels during construction and operation at identified sensitive receptors;
¡ Undertake noise and vibration monitoring during construction;
¡ Implement noise control measures as appropriate (e.g. locate activities that generate large noise volumes, such as crushers and pilling away from noise receptors); and
¡ Establish a complaints hotline for the duration of the works and the number should be displayed at appropriate locations near the road.
The baseline monitoring shall be considered supplementary EIA information and included in the ESMS and/ or in the CEMP and this recommendation is provided in the ESAP.
The noise standard in Kazakhstan Regulations is 70-80 A-weighted decibels (Dba). The Environmental Noise Directive does not set binding noise limits, it leaves this to the discretion of the member states, however the standards stated in the IFC’s ‘General EHS Guidelines: Environmental: Noise Management’ (2007) are widely applied to projects and provide an alternative international standard. The IFC Standards are set out in Table 6 5. The IFC noise standards for commercial areas are comparable to the Kazakhstan noise limits, but the IFC noise standards for residential areas are lower. The IFC noise standards are presented in Table 10 below.
Table 10 – IFC Noise Standards
| Receptor | IFC Noise Standard (Dba) | |
| Land Use Type | Daytime (07.00-22.00) | Night Time (22.00-07.00) |
| Residential Areas | ||
| Commercial/ Industrial Areas |
As with Air Quality, a noise modelling assessment by a noise specialist should also be conducted in accordance with the standard methodology taking into account the recording of traffic noise with the records of the traffic numbers and composition, in relation to the closest properties as indicated above. It may be that such as assessment would identify the need for mitigation in the form of noise screening. A noise screen may also slighlty reduce air pollutant concentrations.
6.1.3 RESOURCE EFFICIENCY
The EIA Directive and EBRD PR3 require consideration of resource efficiency. The consideration of resource efficiency shall as a minimum include an options appraisal of measures to improve and promote resource efficiency regarding:
¡ Energy use;
¡ Water use;
¡ Use of other resources;
¡ Materials use (and the material supply chain); and
¡ Recovery and reuse of waste.
EBRD PR3 also notes that benchmarking data from other projects should be obtained and included, where practicable / available. It is acknowledged that the options appraisal regarding water use and the recovery and reuse of waste should be inherent outcomes from the other recommendations. See Sections below on water use, waste water and waste.
It is proposed that a Resource Efficiency Technical Note (or equivalent) is produced to summarise the options appraisal. The Technical Note will be considered supplementary EIA information and this is included in ESAP.
6.1.4 GHG AND CLIMATE CHANGE
The EIA does not acknowledge or assess projected GHG emissions associated with the construction and operational phases of the Project. The EIA does not acknowledge or assess the vulnerability of the Project to climate change. Both the EIA Directive and EBRD PR3 state the need for a GHG and climate change assessment to ensure that the Project does result in adverse, or easily avoidable GHG emissions and that the design of the Project is resilient to projected climate change.
An assessment of GHG and climate change shall, as a minimum:
¡ Estimate GHG emissions during construction and operation;
¡ Include options appraisal of measures to avoid or minimise GHG emissions during construction and operation; and
¡ Include an assessment of the vulnerability of the Project to climate change.
It is proposed that a GHG and Climate Change assessment is produced as supplementary EIA information and this is included in ESAP.
EBRD PR3 states that, should a Project be estimated to produce more than 25,000 tonnes of CO2 (equivalent annually), it will be necessary to report GHG emissions in the Annual EHS Report to the Bank. The project CO2 equivalent emissions should be benchmarked against this figure.
6.1.5 WATER USE AND WASTEWATER
Both the EIA Directive and EBRD PR4 acknowledge the need for an assessment relating to water and wastewater management in order to:
¡ Prevent over-burdening of non-potable and potable water supplies;
¡ Reduce, where practicable, water use and wastewater generation; and
¡ Pollution and discharge prevention (notably to the the Kapchagay Water Reserve, groundwater, and the small watercourses, albeit mostly dry throughout the year which the road crosses).
As identified in the EIA, non-potable construction water will be sourced from the Kapchagay Water Reserve and potable construction water will be sourced from the supply to Kapchagay City, Kurty Village, and Akshi Village. However, neither the demand for non-potable and potable construction water nor the capacity of the sources to meet the demand is stated in the EIA. The only information provided is that the water consumption for the construction period is 464,857.1981m3. A Water use permit from the inspection is already in place and it is assumed that the authorities would have undertaken an assessment to provide limits that are sufficient for the Project while not depleting water resources. All wastewater will be transported to appropriately licenced waste water disposal companies. The method for delivery and disposal of the water and wastewater to/ from the site will be by tanker. It is therefore recommended that further assessment is undertaken, the assessment shall detail, as a minimum:
¡ The quantification of construction potable and non-potable water demands;
¡ The quantification of construction wastewater demands;
¡ An outline water and wastewater balance. The balance shall be verified and/ or developed in collaboration with the Basin Inspection Department(s) responsible for the construction water (non-potable, sourced from the Kapchagay Water Reserve) and drinking water (potable, sourced from the supply to Kapchagay City, Kurty Village, and Akshi Village) (as identified in the EIA) and the appropriately licenced wastewater disposal companies;
¡ Consideration of practicable measures to reduce water use and wastewater generation during the construction of the Project;
¡ How construction wastewater will be managed, so as to avoid pollution or excessive discharges into the Kapchagay Water Reserve, groundwater, and the small and medium watercourses which the road crosses; and
¡ How the design incorporates measures for surface water capture and treatment.
EBRD PR4 also states that: “For Projects with a high water demand (greater than 5,000 m3/day), the following must also be provided:
¡ A detailed water balance must be developed, maintained and reported annually to the EBRD;
¡ Opportunities for continuous improvement in terms of water use efficiency should be identified;
¡ Specific water use (measured by volume of water used per unit production) must be assessed; and
¡ Operations must be benchmarked to available industry standards of water use efficiency.”
It is proposed that the Water and Wastewater Management is provided as supplementary EIA information and this is included in ESAP.
6.1.6 WASTE
Both the EIA Directive and EBRD PR3 require an assessment regarding the production of waste and the identification of any likely significant effects. Although the EIA includes estimated waste arisings during construction, it does not assess likely significant effects and as such an additional baseline study is recommended to identify suitable options and appropriately licenced facilities for the recovery, reuse and disposal of inert, non-hazardous and hazardous waste. Options shall be identified in accordance with waste hierarchy and the proximity principal. The baseline study shall be shall be streamlined with the Resource Efficiency Technical Note (or equivalent). The baseline study shall utilise the waste quantities presented in the EIA. The waste will be stored at camp sites and construction pads. The baseline study will be considered supplementary EIA information.
In addition, the EIA does not identify any mitigation measures and as such following the baseline study presented above, mitigation measures will need to be identified to avoid adverse environmental impacts associated with waste. Measures shall be inclusive of, but not limited to:
¡ Ensuring all personnel design out waste where practicable;
¡ Ensuring contactors are aware of how to avoid and manage waste arisings (e.g. through Tool Box Talks);
¡ Ensuring the appropriate waste segregation onsite (e.g. receptacles for recyclables, non-recyclables and hazardous waste); and
¡ Ensuring the contractor obtains a chain of custody for all waste removed from the site.
The mitigation measures shall be included in the ESMS and/ or in a CEMP and/ or in a specific Waste Management Plan and this is included in the ESAP.
6.1.7 CONTAMINATION
The EIA Directive requires certain project characteristics to be considered and documented. This is inclusive of characteristics which pose risks to human health and/ or the surrounding environment. Contaminated soils are a key project characteristic which can pose risks to human health and/ or the surrounding environment. The EIA does not acknowledge that potentially contaminated soils along the route alignment have been identified and, if applicable, tested to determine risks to human health and/ or the surrounding environment.
As a result an additional baseline study is recommended to identify contaminated soils along the alignment and any associated control and mitigation measures to avoid environmental impacts. The baseline study shall as a minimum consist of:
¡ A review of current and historical potentially contaminative uses of the Site, and of land uses in the vicinity of the site; and
¡ A summary of site walkover, undertaken by an appropriate expert, to identify potential sources of contamination.
From the visit to the road which is in a relatively remote area it is considered that contaminated soils are not likely to be present. Alhough there was observed to be a wastewater channel that flowed under a bridge that could be a source of some contamination from the wastewater. Nonetheless, the baseline study should be undertaken to confirm this and this will be considered supplementary EIA information and this is included in the ESAP. Some data has been compiled for the road design from geotechnical assessments with some analysis of soils for design and construction purposes and also water analysis from Ile Channel. These were carried out for:
¡ The road
¡ The bridge over Ile canal
¡ Cattle underpass at 5+21.56
¡ Junction
The assessments include information on geology and hydrology, soil properties, chemical analyses of water and construction materials.
6.1.8 NATURAL ENVIRONMENTAL HAZARDS
Both the EIA Directive and EBRD PR4 require assessment and consideration of all applicable environmental hazards. The EIA clearly outlines the baseline sensitivity of the region, and thus inherently the Project, to earthquakes. The region is located in an area of high seismic activity, with the closest seismic station of Almaty registering approximately 200 earthquakes per annum. Although it is acknowledged that the majority of these are minor (in a zone with no faults where an earthquake on the 7 Richter Scale with probability 1 in 1000 years is possible) the potential for an earthquake with adverse impacts remains. With regard to flooding, there is a catchment area of some 685km2 and 22 drainage pipes and even not considering 10 underpasses which are not located at the lowest parts, it is considered that flooding is unlikely. Annual precipitation is only 267mm/year with the maximum 36mm in April and May. With regard to the wastewater discharge channel beneath the only bridge at 9.212 km, data reportedly shows that the risk of flooding is low. Although the road will be at an elevated height it is understood that it will not be prone to snow drifts and will also not be at risk of landslides. It was reported that some of these risks had been taken into account during the design and checked by the Emergency Situation Committee Regional Department on the design approval.
Nonetheless the EIA does not consider any natural environmental hazards apart from earthquakes albeit in limited detail, and further assessment should be carried out to confirm the information provided above.
As a result an additional baseline study is recommended to expand upon the earthquake assessment in the EIA and include assessments relating to the impacts, risks and design measures for:
¡ Earthquakes;
¡ Landslides; and
¡ Floods.
The baseline study will be considered supplementary EIA information and this is included in the ESAP.
6.1.9 TEMPORARY LAND ACQUISITION
EBRD PR5 requires land acquired for temporary structures or activities during construction to be returned to its original state/ use. The EIA does not identify mitigation measures for the return of land acquired to its original state/ use at the end of the construction phase. It is recommended that such mitigation measures are identified. Mitigation measures will be inclusive of but not limited to:
¡ Removal of structures, equipment, materials and waste;
¡ Any necessary landscaping/ re-grading; and
¡ Replanting and re-seeing.
Where practicable, in accordance with best practice, the mitigation measures should also promote improvements to the original state/ use. The mitigation measures shall be included in the ESMS, and/ or in a CEMP and this is included in the ESAP. Although resettlement is not envisaged land is being acquired and there could also be affected informal land use and therefore it is recommended that a Livelihood Restoration Framework (LRF) should be developed and this is included in the ESAP.
6.1.10 BIODIVERSITY AND LIVING NATURAL RESOURCES
Both the EIA Directive and EBRD PR1 and PR6 require an assessment is undertaken to identify, conserve and protect habitats, biodiversity and living natural resources. Although the EIA provides a brief summary of the flora and fauna along and in the immediate vicinity of the route alignment, the EIA does not include a descriptive methodology as to how these conclusions were drawn (e.g. following desk based studies, ecological site walkovers, habitats surveys etc.). With regards to flora the EIA states that “rare and endangered plant species were not found in the area”. With regards to fauna, the EIA states that the area “is not related to breeding grounds, feeding, animal shelter and migration routes”. However, the EIA does not include a descriptive methodology as to how this baseline information was obtained, or how these conclusions were drawn (e.g. following desk based studies, ecological site walkovers, habitats surveys etc.) and does not define the study area considered.
As result, a comprehensive baseline study and subsequent assessment is recommended to identify flora and fauna habitats, biodiversity and living natural resources present in the area. The baseline study shall utilise the information presented in the EIA. In addition to the ICUN Red Book species already noted, the baseline study should place focus on species and habitats protected under Council Directive 92/43/EEC and Directive 2009/147/EC of the European Parliament and of the Council. Following the completion of the baseline study, an assessment should be undertaken of the risk and likely significance of the Project to current baseline conditions. The assessment shall include consideration for, but not be limited to, habitat loss, habitat degradation/ fragmentation, presence of invasive species and impacts to migratory corridors. The assessment will identify the need for further studies/ investigations. The baseline study and subsequent assessment should be provided as supplementary information to the EIA.
In addition, the EIA does not identify any mitigation measures and as such following the baseline study and assessment presented above, mitigation measures will need to be recommended to avoid adverse environmental impacts (where identified) to protect habitats, biodiversity and living natural resources in the area. Measures shall be inclusive of, but not limited to:
¡ Taking a precautionary approach;
¡ Adoption of the mitigation hierarchy;
¡ The promotion of good international practice (GIP) with regards to sustainability and the use of natural resources (including through the supply chain of the Project); and
¡ Avoiding vegetation clearance during the bird breeding season.
The mitigation measures shall be included in the ESMS, and/ or in a CEMP, and/ or in a specific Biodiversity Management or Action Plan and this is included in the ESAP.
6.1.11 CULTURAL AND ARCHAEOLOGICAL HERITAGE
The EIA states that there no areas of cultural and historic importance in the region of the construction. It also states that there are no natural monuments located in the area of operation.
In November 2015 “Kazarchelogiya” carried out an investigation with the purpose of identifying objects of historical and cultural heritage within the borders of reconstruction works area for the road “Kapchagai – Kurty”. The investigation was undertaken according to item 39 of the Republic of kazakhstan law “On protection and use of historical and cultural heritage” dated 02.07.1992. Kazakhstan legislation forbids destruction of any archeological monuments. The research included a desk based study of available information, including historical literature and maps, as well as a physical investigation along the full length of the road. As a result of these studies, it was stated that no cultural or historical heritage is present within the researched area. The report was approved by the Ministry of Culture and Sports on 08.11.2015 (letter N 09-03-22/11043).
On this basis no further work is required to supplement the EIA in terms of the baseline. However, it is recommended that there should be proposed procedures/ plans in place for chance finds other than to stop work and until the ‘relevant competent authorities’ have made an assessment and issued a permit for the continuation of the work. This is included in the ESAP.
During the visit to the road, two memorial sites were seen. Even though they may be far enough from the planned road and they would not be affected by the project directly, it is necessary to make sure that the access to them will not be blocked. Although there are no burials under the memorial stones, some sites may be sensitive when it comes to relocation or limitation of access due to the spiritual culture of rural Kazakh people. There are no processes under the Kazakh law to address this issue. Mitigation measures have been recommended to preserve memorial sites along the road and, if necessary, to identify the appropriate relocation processes with the informed consent of the owner of the memorial sites. This is included in the ESAP.
6.1.12 VISUAL IMPACTS
The EIA Directive requires Projects to avoid and minimise adverse visual impacts, where practicable. The EIA does not identify visual receptors along the route alignment or identify mitigation measures with regards to visual impacts.
Mitigation measures will need to be recommended to avoid and minimise adverse visual impacts, where these are identified. Measures shall be inclusive of, but not limited to:
¡ Undertaking a study to identify visual receptors in advance of construction activities commencing;
¡ Sensitive construction screening; and
¡ Sensitive landscaping.
The road will introduce a raised structure in a relatively flat landscape; therefore the visual impact of this should be considered, although it is considered unlikely to be any adverse visual impacts. The mitigation measures shall be included in the ESMS, and/ or in a CEMP, and/ or in a specific Landscape Management Plan.
6.1.13 EMERGENCIES
In accordance with best practice and the EIA Directive, EBRD PR3 and PR4, potential emergency situations and potential accidents that may have an impact on the environment during construction and once operational must be identified and prepared for. Such identification and preparedness measures are typically documented in an Emergency Preparedness and Response Plan (or equivalent) for each emergency situation and potential accident. It is recommended that this Plan is included in the ESMS and, if applicable, in the CEMP and this is included in the ESAP.
6.1.14 SUMMARY OF IMPACTS AND MITIGATION AND OVERALL CONCLUTIONS
The EIA has been developed in accordance with the rules, regulations and standards of the Republic of Kazakhstan for the design and construction of roads, although there are gaps as detailed previously in relation to an ESIA that would be developed to international best practice standards. Within the EIA there is no summary table of all impacts and mitigation proposed. A summary of these have been collated in Table 11 below incuding additional recommendations that are proposed with regard to mitigation measures.
Table 11 – Environmental and Social Impacts and Mitigation Identified in EIA
| Environmental Resource | Phase | Impacts Identified In The EIA | Mitigation Measures Identified In The EIA | Recommendations |
| Air Quality, Noise and Vibration | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | ¡ Establish the baseline conditions, potential impacts of the Project and suitable mitigation measures with regards to air quality, noise and vibration; and ¡ Undertake modelling at nearby properties |
| Resource Efficiency | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | ¡ Produce a Resource Efficiency Technical Note (or equivalent) that includes an options appraisal of measures to improve and promote resource efficiency covering: · Energy use; · Water use; · Use of other resources; · Materials use (and the material supply chain); and · Recovery and reuse of waste. |
| GHG and Climate Change | Construction/ Operation | No clear identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | Produce a GHG and Climate change assessment to include: ¡ An estimation of GHG emissions during construction and operation; ¡ An options appraisal of measures to avoid or minimise GHG emissions during construction and operation; and ¡ An assessment of the vulnerability of the Project to climate change. |
| Water Use and Wastewater | Construction Operation | Potential impacts to: ¡ Kapchagay Water Reserve due to non-potable construction water demand; and ¡ Kapchagay City, Kurty Village, and Akshi Village due to potable water demand. No identification of receptors or impacts included in the EIA. | The mitigation measures included in the EIA are: ¡ The water intake areas should be equipped with hard soil and special containers, to prevent pollution; ¡ The water intake equipment should have small nets in order to prevent the capture of fish fry; and ¡ The tankers (used to deliver water) will be cleaned and chlorinated every 10 days. As above | ¡ Prepare and document water and wastewater management and design information, which includes as a minimum: · The quantification of construction potable and non-potable water demands; · The quantification of construction wastewater demands; · An outline water and wastewater balance; · Consideration of practicable measures to reduce water use and wastewater generation during the construction of the Project; and · How construction wastewater will be managed, so as to avoid pollution or excessive discharges into the Kapchagay Water Reserve, groundwater, and the small and medium watercourses which the road crosses. ¡ Obtain, review, and if applicable update a permit(s) for water use. Prepare and document water and wastewater management and design information, which in addition to the above, includes how the design incorporates measures for surface water capture and treatment. |
| Waste | Construction Operation | Although an estimate of construction waste arisings in included in the EIA there is no of receptors or impacts. No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. No identification of mitigation measures included in the EIA. | ¡ Undertake a baseline study to identify suitable options and appropriately licenced facilities for the recovery, reuse and disposal of inert, non-hazardous and hazardous waste. Options shall be identified in accordance with waste hierarchy and the proximity principal. The baseline study shall utilise the waste quantities presented in the EIA; and ¡ Introduce mitigation measures to avoid adverse environmental impacts associated with waste. Measures shall be inclusive of, but not limited to: · Ensuring all personnel design out waste where practicable; · Ensuring contactors are aware of how to avoid and manage waste arisings (e.g. through Tool Box Talks); · Ensuring the appropriate waste segregation onsite (e.g. receptacles for recyclables, non-recyclables and hazardous waste); and · Ensuring the contractor obtains a chain of custody for all waste removed from the site Recommendations have not been included as operational wastes will be limited to ad hoc waste arisings and/or waste risings scheduled maintenance. |
| Contamination | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | Undertake a baseline study to identify contaminated soils along the alignment and any associated control and mitigation measures to avoid environmental impacts. The baseline study, shall, as a minimum consist of: ¡ A review of current and historical potentially contaminative uses of the Site, and of land uses in the vicinity of the Site; and ¡ A summary of site walkover, undertaken by an appropriate expert, to identify potential sources of contamination and requirements for further investigations and/or mitigation/control measures. |
| Natural Environmental Hazards | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | Undertake a detailed baseline study with regards to natural environmental hazards. The baseline study should expand upon the earthquake assessment in the EIA and include assessments relating to the impacts, risks and design measures for: ¡ Earthquakes; ¡ Landslides; and ¡ Floods. |
| Temporary Land Acquisition | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | ¡ Introduce mitigation measures to ensure that land acquired for temporary structures or activities during construction is returned to its original state / use. Where practicable the state/ use shall be improved. Mitigation measures to include: · Removal of structures, equipment, materials and waste; · Any necessary landscaping / re-grading; and · Replanting and re-seeing. ¡ Obtain, review, and if applicable update a permit(s) for temporary and permanent land use. |
| Biodiversity and Living Natural Resources | Construction/ Operation | A description of the flora and fauna along and in the immediate vicinity of the route alignment is included in the EIA. The EIA implies that there are no receptors or impacts. | No identification of mitigation measures included in the EIA. | ¡ Undertake a baseline study to identify habitats, biodiversity and living natural resources present in the area. In particular on species and habitats protected under Council Directive 92/43/EEC and Directive 2009/147/EC of the European Parliament and of the Council. Subsequently, undertake an assessment of the risk and likely significance of the Project. The assessment shall include, but not be limited to, habitat loss, habitat degradation / fragmentation, invasive species and migratory corridors. The assessment will identify the need for further studies / investigations. The baseline study shall utilise information currently presented in the EIA; and ¡ Introduce mitigation measures to protect, conserve, and avoid adverse impacts to habitats, biodiversity and living natural resources in the area to include: · Taking a precautionary approach; · Adoption of the mitigation hierarchy; · The promotion of good international practice (GIP) with regards to sustainability and the use of natural resources (including through the supply chain of the Project); and ¡ Avoiding vegetation clearance during the bird breeding season (if applicable). |
| Cultural and Archaeological Heritage | Construction Operation | The EIA states that there no receptors or impacts. The EIA states that there no receptors or impacts. | No identification of mitigation measures included in the EIA. No identification of mitigation measures included in the EIA. | ¡ Summairse study conclsusions that there are no cultural and archaeological heritage sites of significance ¡ Set up a procedure in place for chance finds; and ¡ Introduce mitigation measures to preserve and avoid adverse impacts to memorial sites in the area and if necessary identify the appropriate relocation processes with the informed consent, and if requested supervision from the owner of the memorial site (relatives). Recommendations have not been included as once operational the risk of discovering Cultural and Archaeological Heritage should be negligible. |
| Visual Impacts | Construction/ Operation | No identification of receptors or impacts included in the EIA. | No identification of mitigation measures included in the EIA. | ¡ Undertake a baseline study to identify and assess the potential landscape and visual impacts associated with the Project; and ¡ Introduce mitigation measures to avoid and minimise adverse visual impacts. Measures shall be inclusive of, but not limited to: · Undertaking a study to identify visual receptors in advance of construction activities commencing; · Sensitive construction screening; and · Sensitive landscaping. |
6.2 Assessment against specific EIA Requirements
6.2.1 KEY EIA REQUIREMENTS
A summary of the compliance status against the EU EIA Directive Annex III is presented in Table 12 below.
Table 12 – Compliance with the EU EIA Directive
| Requirement of EU EIA Directive Annex III | Compliance Assessment |
| The characteristics of the Project must be considered, with particular regard to the size and design of the whole project. | An outline description of the project is provided in the existing EIA. The description and the associated mapping are not considered to be sufficiently detailed. |
| The characteristics of the Project must be considered, in cumulation with other existing and / or approved projects. | The EIA does not include either a list of other existing and / or approved projects or the potential for cumulative effects of the Project in relation to other projects (e.g. on material availability etc.). |
| The characteristics of the Project must be considered, with regards to the use of natural resources, in particular: ¡ Land; ¡ Soil; ¡ Water; and ¡ Biodiversity. | ¡ Land - the EIA does not include an appraisal of temporary land acquisition for temporary structures or activities during construction. ¡ Soil - the EIA does not state whether potentially contaminated soils along the route alignment have been identified and, if applicable, tested. ¡ Water - the EIA identifies the sources for the supply of non-potable construction water and potable construction water and an overall figure is provided. However, the demand and capacity of the sources are not stated in the EIA. ¡ Biodiversity - the EIA includes a description of the flora and fauna along and in the immediate vicinity of the route alignment. The EIA implies that there are no receptors or impacts. However, the EIA does not include a descriptive methodology as to how this baseline information was obtained, of how these conclusions were drawn (e.g. following desk based studies, ecological site walkovers, habitats surveys etc.) and does not define the study area considered. |
| The characteristics of the Project must be considered, with regard to the production of waste. | The EIA includes estimated waste arisings during construction. However, the EIA does not identify measures for waste storage and segregation on site or suitable options and appropriately licenced facilities for the recovery, reuse and disposal of inert, non-hazardous and hazardous waste. |
| The characteristics of the Project must be considered, with regard to pollution and nuisances. | The EIA does not include the identification of air quality, noise and vibration receptors (key receptors to pollution and nuisance) along the route alignment. |
| The characteristics of the Project must be considered, with regards to the risk of major accidents and/or disasters which are relevant to the project concerned, including those caused by climate change, in accordance with scientific knowledge | The EIA outlines the baseline sensitivity of the region, and thus inherently the Project, to earthquakes only. The EIA does not assess how the design of the Project will be refined to reduce the risks associated with earthquakes and other natural disasters / major accidents are not identified. |
| The characteristics of the Project must be considered, with regard to the risks to human health. | Although the EIA acknowledges the need for measures on safety and health at work, it does not clearly identify particular risks to human health as a result of either the construction or operational phases of the Project. |
| The environmental sensitivity of geographical areas likely to be affected by the Project must be considered with particular regard to, the existing and approved land use. | Although is descriptive text relating to the surrounding environment, the only consideration of environmental sensitivity in the EIA relates to the topics of biodiversity and living natural resources and cultural and archaeological heritage. The EIA states that there are no sensitives relating to either topic. However it does not include a descriptive methodology as to how this baseline information was obtained, how these conclusions were drawn, and it does not define the study area considered. |
| The environmental sensitivity of geographical areas likely to be affected by the Project must be considered with particular regard to, the relative abundance, availability, quality and regenerative capacity of natural resources. | The EIA does not readily consider the environmental sensitivity of geographical areas with regards to the relative abundance, availability, quality and regenerative capacity of natural resources for any topic. |
| The environmental sensitivity of geographical areas likely to be affected by the Project must be considered, with particular regard to the absorption capacity of the natural environment. | The EIA does not readily consider the environmental sensitivity of geographical areas with regards to the absorption capacity of the natural environment for any topic. |
| The likely significant effects of the Project on the environment must take into account the magnitude and spatial extent of the impact. | The EIA does clearly not describe either the magnitude or the spatial extent of any impacts. |
| The likely significant effects of the Project on the environment must take into account the nature of the impact. | The EIA does not clearly describe the nature of any impacts (e.g. temporary, permanent etc.). |
| The likely significant effects of the Project on the environment must take into account the transboundary nature of the impact. | There is no consideration of the transboundary nature of any impacts in the EIA. |
| The likely significant effects of the Project on the environment must take into account the intensity and complexity of the impact. | The EIA does clearly not describe either the intensity or complexity of any impacts. |
| The likely significant effects of the Project on the environment must take into account the probability of the impact. | The EIA only acknowledges the probability of emergency situations, not any other impacts. |
| The likely significant effects of the Project on the environment must take into account the expected onset, duration, frequency and reversibility of the impact. | The EIA does clearly not describe eitherthe expected onset, duration, frequency or reversibility of any impacts. |
| The likely significant effects of the Project on the environment must take into account the cumulation of the impact with the impact of other existing and / or approved projects | This is not included in the EIA as it does not include either a list of other existing and / or approved projects. |
| The likely significant effects of the Project on the environment must take into account the possibility of effectively reducing the impact | The EIA does clearly not describe either the possibility of effectively reducing any impacts |
6.2.2 SOCIAL REQUIREMENTS
With particular regard to social issues, the EIA Directive emphasises the need for effective public participation in decision-making, as well as the participation of associations, organisations especially non-governmental organisations. The directive highlights the public participation ensures accountability and transparency of the decision-making process and raises public awareness of environmental issues. Disclosure of impact assessment documents for public comments is also a requirement under the directive emphasising that the direct and indirect effects on the population, human beings and human health should also be included in the documents.
The information to the public could be communicated by public notices or by other appropriate means such as electronic media, posters, brochures or phone calls early in the assessment process. Reasonable time-frames should be provided for the public to prepare and participate in the consultation activities ensuring that information is made available in an appropriate manner. The results of consultations should be recorded and taken into account during the project.
The public has the right to seek other formal channels to request a review procedure such as cases before a court of law or another independent and impartial body established by law to challenge the legality of decisions, acts and plans.
The 2014 amendment included more emphasis on the protection and promotion of cultural heritage and strengthen public access to information. The amendments allows for information to be gathered and incorporated in the design even when it is not coming through a formal stakeholder engagement channel.
The national EIA requirements also provide for early engagement of relevant and interested stakeholders to participate in the decision making and share their opinions and feedback on the Project.
The EIA contains a chapter on social and economic environment which provides a generic methodology which should normally be used for assessment of social and economic impact. The chapter does not clearly identify any sensitive receptors in the project area but rather refers to local people. The chapter concludes that a positive impact is expected due investments and development of the area associated with the project, however, it is not clear if any kind of assessment described within the chapter has been conducted.
The EIA contains a recommendation with regards to mitigation of Health and Safety risks by providing all relevant training to workers, providing PPE and continious monitoring of compliance with Health and Safety regulations and requirements.
7 conclusions and recommendations
7.1 PROJECT BENEFITS
The road project is considered to provide benefits that include a vastly improved road network, with the EBRD potentially funded section part of “Centre - South” corridor linking the cities of Almaty, the largest city and economic and cultural centre, with Astana, the capital. Currently, the 67 km “Kapshagai-Kurty” road is a Kazakh Category 2 road with two lanes. The road will be reconstructed to comply with the Kazakh Category 1b highway requirements.
The road’s asphalt pavement is now past its effective working life and its condition is rapidly deteriorating due to a combination of traffic loading and the age of the road surface. Reconstruction of the road is now urgently required to improve the ride quality of the road, minimise road user costs and provide a road surface that can be maintained in a cost effective manner. In addition, widening of the road will improve road safety as currently the narrow width of the road forces drivers to cross into the oncoming traffic lane to overtake vehicles or avoid potholes. Other upgrades or new features will also include a junction, off ramps, cattle and agricultural machinery underpasses, rest areas, bus stops and zebra crossings, a bridge and traffic lighting.
It is expected that the new road will significantly reduce travelling distance as the drivers who currently use M36 via Karaoi (125 km) will use the new shorter route instead (67 km).
7.2 Summary against EBRD Performance Requirements
7.2.1 INTRODUCTION TO EBRD COMPLIENCE MATRIX
In respect of specific EBRD Performance Requirements (PRs), the environmental and social appraisal has been conducted against these requirements as presented in the previous chapters. A high level summary of the project against the performance requirements is provided in Table 14 below in a compliance summary table in accordance with EBRD guidance.
The compliance summary provides a systematic review of project compliance with the EBRD Environmental and Social Policy, as defined through the applicable Performance Requirements (PRs). The scope of compliance is for all PRs applicable to non-FI projects, such as this project. Following, a review of the PRs all are applicable with the exception of PR7 Indigenous people and PR9 Financial Intermediaries.
The details in the compliance table will provide a baseline against which to judge future performance of the project through the annual environmental and social reporting process that is undertaken by EBRD. The compliance table as provided in the ToRs provides between 2 and 10 indicators for each of the applicable PRs: 1 - 10.
7.2.2 EBRD COMPLIENCE SUMMARY GUIDENCE
For all PRs (Indicators with whole number references) a summary of overall compliance with the PR has been provided. Where there are derogations from a PR, a justification has been provided and supporting documents referenced as required.
For each indicator within a PR, three steps have been completed as below in accordance EBRD guidance:
1. Decide whether the indicator is applicable. For Category A and B projects the starting point is that all indicators are applicable unless the project has no significant aspects relevant to the indicator (i.e. no risks), in which case the indicator should be scored "NA" and a brief summary of the reason given. For Category C projects the starting point is all indicators are NA unless the project has a significant aspect relevant to the indicator (i.e. there is a material risk).
2. Decide whether an opinion is possible. If not (for example if the indicator will apply, but it is too early in the project) score as "NOP" and provide a brief summary of why. Where lack of opinion represents a material omission to the review refer to where this is addressed in the report and summarise any recommendations.