Sewer system projects environmental management plan


INSTITUTIONAL STRUCTURE 5.1. GENERAL



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5. INSTITUTIONAL STRUCTURE




5.1. GENERAL

This section provides information concerning proposed institutional arrangements, authorities and responsibilities to minimize impacts depicted in the EMP during implementation of Water Supply System Rehabilitation and Sewer System Projects. Within this scope, existing administrative structure of Denizli Municipality was examined and the demand for re-arrangements in order to conduct the committed services was investigated.



5.2. EXISTING ADMINISTRATIVE (INSTITUTIONAL) STRUCTURE

In accordance with the Municipality Law (Article 14), Denizli Municipality is responsible for supply, storage and distribution of water to be used for domestic and industrial purposes as well as collection and treatment of wastewaters. Denizli Municipality is structured as departments called “directorates”. In this regard, Directorate of Water and Sewerage Works is the main department responsible from the proposed project works. This directorate is responsible from construction, operation and maintenance of water supply and distribution (water supply and treatment systems) as well as wastewater collection and treatment (sewer network and wastewater treatment plants) systems. The Directorate of Water and Sewerage Works is structured in the form of a number of sub-divisions including water system maintenance, sewer system maintenance, wastewater treatment plant operation, water subscription, project approval & licensing, bidding & controlling and WB project management. The most important problem in these units is the lack of staff. Thus, every staff of the directorate typically works for more than one division.


Directorate of Water and Sewerage Works has no separate budget and accountancy. Revenues are collected by the Directorate of Accounting and transferred to the general Municipal Budget. Water supply and sewer system services are then financed from this budget. Equipment service and material procurement for maintenance works are managed by the Directorate of Purchasing.
Denizli Municipality water and sewer services are executed by 85 personnel. 36 of which are permanent workers (14 in sewer works, 20 in water works and 2 in treatment plant); 37 of which are temporary workers (16 in water works, 2 in treatment plant and 3 in office work); 11 of which are officers and 1 of which is a contracted staff. A total of 6 engineers are employed within the Directorate of Water and Sewerage Works, of which 4 are civil engineers, 2 are environmental engineers and 1 is a mechanical engineer. The rest of staff is primary school graduates.
The works conducted by the Directorate of Water and Sewerage Works are recorded via daily and monthly reports. Divisions also prepare daily work reports about the tasks to be completed on a daily basis and submit to the Directorate of Water and Sewerage Works. After completion, an additional report is prepared concerning the final status of the completed works. Furthermore, Directorate of Water and Sewerage Works presents reports to the Major and to the Directorate of Public & Media Relations on monthly basis.

5.3. PROPOSED INSTITUTIONAL ARRANGEMENTS IN THE SCOPE OF THE ENVIRONMENTAL MANAGEMENT PLAN (EMP)

The details on how responsibilities would be shared and who would perform the defined tasks (mitigation measures, monitoring plans, etc) during the execution of the EMP for successful implementation of the project were discussed separately for construction and operational phases in previous sections of the report.


Denizli Municipality is the owner of the “Water Supply System Rehabilitation and Sewer Systems Projects” and has direct and indirect responsibilities for the implementation of the EMP during operational and construction phases, respectively (see Table 4.1 and Table 4.2). In this context, the municipality should ensure that the EMP is added to the tender documents prepared for determining the contractor. Consequently, the interested contractors would be assured to propose a bid, which would include the costs associated with his responsibilities related to environmental management avoiding future problems that might occur in later phases of the project. In other words, the contractor could not claim that he was uninformed about works related to environmental protection as was seen in many other projects where the related EMP was not included in tender documents.
During the construction phase, It is proposed that a Health Safety and Environment-HSE officer is assigned by the Contractor to properly implement the EMP and to monitor the environmental impacts as suggested in this report. While HSE will, on one hand, implement EMP will, on the other hand, play a crucial role in providing the communication with the related institutions including the Municipality, the Ministry of Environment and Forestry and the Non-governmental organizations (NGOs) etc.
The second most important point for successful implementation of the EMP is the training of the personnel (engineers, technical staff and workers) that will work in the construction activities in order to raise their awareness in environmental issues. The contractor should inform and train its personnel about the environmental issues in general and about the requirements of the EMP in particular. To achieve this objective, the contractor could use its own resources or consult private companies or related departments of universities. The environmental training program should include the following points:


  • Environmental impacts of the project and mitigation measures

  • Reporting principals and understanding its rules

  • Briefings on official laws and institutions related to the environmental dimensions of the projects

  • Training of the personnel about public and media relations

  • Training of the personnel about environmental accidents and interferences

The contractor is in charge of keeping all records related to the environmental training of its staff. Internal audits should be conducted to test the effectiveness and the adequacy of the training. The contractor is required to ensure that the personnel of its subcontractors would also take the environmental training and should consider this issue in its protocols with its subcontractors.


In addition to the technical issues mentioned above, the contractor should be involved in public awareness activities. In this context, the establishment of a Public Relations Unit (PRU) is strongly suggested. PRU would act as the responsible unit in hearing, documenting and acting accordingly with regards to the complaints related to the negative environmental impacts of the project. Thus, the contractor should prepare a complaint procedure such that all complains and proposals could be directed to the PRU. All records of complaints will be recorded by the PRU and will be directed to the relevant technical personnel in charge such that the required action and mitigating measures could be taken. Moreover, routine public hearings will be conducted by the PRU about the developments in the project. The municipality will also inform the public via its web site about the services provided within the scope of the project. The web site will also be designed interactively such that the complaints of the public could be sent online. The Municipality and the contractor will work in coordination in these aspects.
During construction phase, contractor will prepare monthly reports summarizing the EMP activities and monitoring plan results and submit to Denizli Municipality. In this context, the contractor will work, particularly for environmental monitoring works, with companies (Independent Monitoring Company – IMC) granted Laboratory Certificate of Proficiency or Laboratory Certificate of Preliminary Proficiency by Republic of Turkey Ministry of the Environment and Forestry.
Similarly, the municipality shall evaluate the monitoring reports presented by the contractor in accordance with the relevant environmental and municipality legislations and shall inform the Bank of Provinces. If requested, these reports will also be given to the Denizli Provincial Directorate of Environment and Forestry. In case of a warning from any institution regarding faulty implementation of the EMP, contractor will take necessary measures and will report the results back to Denizli Municipality.
Consequently, planned tasks of the construction phase will be shared by the contractor and the municipality in order to comply with the EMP and to achieve high environmental performance. Contractor is primarily responsible for training of key personnel & staff, preparation of Emergency Action Plan - EAP, corrective actions, internal auditing, reporting, handling of complaints and commissioning of IMC (if required). As owner of the project, municipality has responsibility to conduct relations with media in accordance with the general implementation rules of public investments. Besides, municipality should assist the contractor in preparing EAP and in internal auditing. IMC (if required) is responsible for environmental quality monitoring and training of key personnel.
During the operational phase of “Water Supply System Rehabilitation and Sewer Systems Projects”, a management team is to be formed by the municipality within its institutional structure both to follow the environmental performance of the projects regularly and to operate the facilities efficiently. Personnel among the operation team should be assigned by the municipality to follow the environmental issues.
The municipality will establish a PRU to evaluate the complaints and suggestions from the public during the operational phase. This unit will run the public relations. Furthermore, the inhabitants of Denizli will be informed about the water and wastewater services and water quality etc.. Additionally, Denizli Municipality will provide training of personnel (engineers, technical staff, workers etc.) about environmental impacts and monitoring.
If operation activity is contracted to a private company, these arrangements will be requested from the company in accordance with an agreement to be signed between the company and the municipality.


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