E3033
Bosnia and Herzegovina
Real Estate Registration Project
Framework Environmental Management Plan
March 2012
GENERAL INFORMATION
The Real Estate Registration Project activities would focus on cadastre and land registry
data updating and harmonization and integration of this data in urban areas. This is due to
the fact that the activity rate of property markets, as well as the discrepancy rate between
cadastre and land register data, is much more significant in urban and peri-urban areas than
in rural areas. There is great potential for a boost in the economy if non-registered urban
properties were included in the formal registration systems. Up-to-date spatial data is in high
demand in urban areas also in support of the urban planning and plan upgrading that
addresses the question of buildings without the permit of use, and for property taxation.
The project would have three components:
A) Real estate registration data development
B) Real estate registration infrastructure development
C) Policy and institutional development, and project management
Component B of the project will include funding for renovation of offices. Drawing on the
experience of successful EMP development and implementation for the ongoing Land
Registration project which financed the same types of works, a similar approach will be
taken for this Project as well.
DESCRIPTION OF WORKS AND ASSOCIATED ENVIRONMENTAL IMPACTS
The works will mostly entail indoor rehabilitation and refurbishment of existing, or newly
acquired office space for the Real Estate Registration Offices. Minor construction, carpentry
and masonry works are envisaged, including physical arrangements which would facilitate
operations and user-friendliness of the offices.
Main environmental impacts envisaged at this stage would deal with following sound
construction practices - as related to disturbances to the immediate neighbors, dust and
noise generation, waste management, chance findings and possible encounters of
hazardous wastes or materials such as asbestos.
The works will not include land acquisition or works beyond the existing footprints of the
buildings. The works will not include demolition of buildings and will be done in respect to all
of the legal requirements in country and/or entity, as well as the World Bank’s Operational
Policy 4.01 on Environmental Assessment.
Since the exact locations of future works are not known at this stage, a template EMP within
this document will be used for all future locations, revised and adapted as per the local
conditions on site. It is also the Client’s obligation to be aware of, and to meet all of the local
permitting requirements.
ANALYSIS OF LOCAL ENVIRONMENTAL AND PERMITTING REQUIREMENTS
The following laws have provisions on construction and reconstruction activities in the two
entities of Bosnia and Herzegovina:
FBiH:
• Law on Physical Planning and Land Use(official Gazette of FBiH, No 02/06) and
• Law on Construction Land (official Gazette of FBiH, No 25/03)
RS:
• Law on Spatial Planning (official Gazette of RS, No 84/02),
• Law on Construction Land (Official Gazette of RS, No 41/03, 86/03)
Environmental Impact Assessment
The Environmental Impact Assessment and the issue of Environmental Permitting for the
investment construction projects and industrial facilities are regulated by the Laws on
Environmental Protection in both entities and District Brcko, including appropriate bylaws on
plants and processes that can only be placed into operation if they possess an
environmental permit. According to this legislation, an environmental permit is not necessary
for reconstruction works within a building, whereas new construction can be mandated to
have an environmental permit based on the characteristics of the building. In RS,
environmental permits for significant potential polluters are issued at the Entity level, while
the lesser polluters are dealt with at the Municipal level. In Federation BiH, the permitting
procedure is conducted in a similar manner, where the municipal level is replaced by the
Cantonal level. The environmental permits also contain provisions of the Laws on Waste
Management of both entities.
Permits Required for Construction Works
• Location /urbanistic Permit
• Environmental Permit (if deemed project may have a negative environmental impact)
• Construction Permit
• Operational Permit
Note: In cases where the façade or the entire building is placed under a form of protection of
state or entity, the adequate procedures must also be respected, and opinions of relevant
institutes obtained prior to start of works.
ENVIRONMENTAL MITIGATION PLAN
Design Phase
Issue
Mitigation Measure
Costs
Institutional
Responsibility
Reviewing rehabilitation
plans/ detailed design
Harmonization with measures proposed in EMP
(accessibility, energy efficiency, use of
environmentally friendly construction materials,
etc.)
Part as a project
activities, included in
operating cost
Contractor’s design
team and Project
Management Team
(PMT),
Works on buildings that are
under a form of protection
by the state (monuments)
Ensure that rehabilitation works are within the
interior of the building
To be determined
Project Management
Team
Seek clearance from the relevant authorities (Entity
Institutes for Monument Protection or State
Commission on Protection of Monuments)
Comments
Construction Phase
Issue
Mitigation Measure
Costs
Institutional
Responsibility
Comments
End-of-life equipment,
office furniture or other
miscellaneous waste
Reuse and recycling whenever possible; adequate
disposal at approved and appointed disposal site in
other cases
Contractor and/or
end user – Cadastral
office
Construction waste
Separation of wastes, reuse and recycling
whenever possible
Contractor (or other
entity, depending
on the Contract)
Will be specified in
bidding documents
(compliance with EMP)
Contractor
The contractor needs to
organize a training for all
staff on how to recognize
asbestos, and to establish
procedures for removal
of asbestos using
adequate protective
equipment, limiting
breaking of asbestos, and
storing it safely in airtight containers before
handling over to
authorized removal
agencies (as per the
Entity ministry list of
Hazardous waste
management companies).
Disposal of non-recyclable waste organized with
municipal service providers; no burning or illegal
dumping
Hazardous wastes (possible small quantities, e.g.
paints, oils) handled separately, according to
relevant regulations; handling of hazardous wastes
has to be documented
Removal of asbestos
containing materials
Removal of asbestos pipes will comply with all
applicable state and federal regulations, including
those for construction standards, health and
safety, emission standards for hazardous air
pollutants and transport and disposal of hazardous
waste. (In lieu of national legislation use Directive
2003/18/EC of the European Parliament and of the
Council of 27 March 2003 amending Council
Directive 83/477/EEC on the protection of workers
from the risks related to exposure to asbestos at
work: highest permissible concentration of
respirable dust to 0.1 fiber/cm3; Good Practice
Note: Asbestos: Occupational and Community
Health Issues, the World Bank)
To be agreed during
construction, if relevant
Construction Phase
Issue
Mitigation Measure
Costs
Chance finds
If encountering archaeological findings during
rehabilitation works, contractor should stop
operations and notify competent authorities
Noise
Working hours limited to daily shifts
N/A
Ensure minimal disruption to other users of the
building
Contractor’s cost
Institutional
Responsibility
Comments
Contractor
Contractor
Use of attested machinery
No idling of machinery or transport vehicles on site
Dust
Watering or coverage of dusty materials; adjusting
the speed of vehicles in transport
Contractor’s cost
Contractor
Dust from demolition works can be minimized by
enclosing the object; workers should wear
appropriate equipment
Use chutes for disposal of waste material from
higher floors
Construction materials
Requirements for energy efficient and
environmentally friendly materials integrated in
procurement notices, and adequate choices made
at procurement
N/A
Contractor
Site organization and
restoration
Plans to minimize disturbances to the
neighborhood made (including plans to avoid
traffic jams based on heavy duty equipment and/or
transport of materials)
N/A
Contractor
Fencing off the construction site and/or safety
signs and warnings clearly posted as applicable
The site will be cleaned from all debris and waste
materials and restored to the state planned in the
designed upon completion of works; all machinery
will be removed
Design documents to
include specifications
Design documents to
include specifications
Contractor’s cost
Contractor’s cost
Operational Phase
Issue
Generation of solid waste
on premises
Mitigation Measure
Adequate measures for recycling and reuse of all
such materials (including paper and old
equipment/furniture)
Costs
Institutional
Responsibility
End user
Buildings should have contractual agreements with
local public utilities on waste collection and
management
Connection to a wastewater
collection system
The building should either have a connection to the
wastewater collection system, or an adequately
sized and designed leak-proof septic tank with
regular maintenance schedules through an
accredited company
End user
Comments
ENVIRONMENTAL MONITORING PLAN AND SUPERVISION
Construction Phase
WHAT
Parameter to be monitored
WHERE
Is the parameter to be
monitored
On site
HOW
Is the parameter to be
monitored
Part of regular inspection
WHEN
To monitor the parameter
(frequency)
During construction at
intervals in accordance with
national legislation
Construction Inspectorate
Construction waste
management (including
hazardous)
On site
Visual inspection of waste piles
and intervals of removal
Weekly
Site Supervisor to monitor
Presence of asbestos and
other hazardous materials
On site
Rehabilitation works are
conducted in line with relevant
regulations (construction
permit, if it will be necessary)
RESPONSIBILITY
Contractor to implement
Review documentation for
waste collection and/or hand
over, especially for hazardous
wastes
Visually
Weekly, have workers notify at
first notice
Site Supervisor to monitor
Contractor to implement
Noise and dust emissions
On site
Sensory
Upon complaint
Safety signs and notifications
On site
Visual inspection
At start of the works and every
30 to 60 days thereafter
Site Supervisor to monitor
Prior to start of works
Site Supervisor to monitor
Contractor to implement
Contractor to implement
EMP IMPLEMENTATION RESPONSIBILITIES
The Environmental Management Plan provided in this document will be reviewed for each of the
proposed Project locations and adjusted based on the varying local conditions.
Such an updated EMP will be disclosed in a public place prior to, and for the duration of start of
works. The EMP will also be a part of the bidding and contractual documents, binding therefore the
hired Contractor to implement all of the listed mitigation measures and for the hired Supervisor to
ensure all of the measures have been implemented.
The Site Supervisor will provide a section on compliance with the EMP in their regular progress
reporting.
Overall responsibility for the implementation of this EMP stays with the Project Implementation Unit –
that is Administrations for Geodetic and Real-Property Affairs of both Entities. The project is to be
implemented by the in close cooperation with the respective MOJs in accordance with the
requirements of the project.
CAPACITY DEVELOPMENT AND PROPOSED PROJECT ORGANIZATION
Even though the overall responsibility remains with the PIU, and knowledge of the World Bank
environmental safeguard requirements will be shared with the PIU, the bidding and contractual
documents will be used to transfer this obligation onto the Contractor.
It is desirable for the chosen Site Supervisor to be knowledgeable of the environmentally-friendly
construction processes, and to organize a brief training on EMP compliance with the Contractor and
staff prior to start of works.
PUBLIC DISCLOSURE
The Framework EMP, along with an invitation to the public consultation meeting was disclosed
publically on the web-pages of the Federal Ministry of Justice (www.fmp.gov.ba) and the Federal
Administration for Geodetic and Real-Property Affairs (www.fgu.com.ba) in early March 2012. The
public consultation was announced in the daily papers (Dnevni avaz and Nezavisne novine) with
targetted invitations sent to already identified potential stakeholders from a number of institutions and
entities at various levels, that deal with environmental protection. As the Framework EMP was small
in size, it was easy to send it with the invitations, most of which were done by e-mail or fax.
The public consultation meeting was held on March 20, 2012 in the Federal Ministry of Justice,
Valtera Perica street 15, in Sarajevo, starting at 11:00. This public consultation meeting was done for
both entities and was organized in cooperation by the PIUs from FBiH and RS.
Based on the discussion during the public consultation meeting, there are no significant (or any)
changes to be made to the Framework EMP. Most of the discussion was related to the local
procedures and raising environmental awareness in the manner that the World Bank is requiring this
Project to do. List of attendees and Minutes of Meeting are given in Annex 1 of this document.
ANNEX 1 : MINUTES OF MEETING FROM PUBLIC CONSULTATIONS AND LIST OF ATTENDEES
Real Estate Registration Project – BiH
Minutes of Meeting from Public Consultations for the Framework EMP
Public consultations held in Sarajevo, March 20, 2012.
The public consultation meeting was opened by Mr. Edib Mehmedovic, manager of the PIU in
Federation BiH, presenting both the current Land Registration Project and the future Real Estate
Registration Project. The opening statement was also strengthened by Mr. Hidajet Halilovic, Assistant
Minister of Justice of FBiH, with an introduction of the state of cadastre and land registration books.
Mr. Darko Miskovic, Assistant Director of the Republic Administration for Geodetic and Real-Property
Affairs of Republika Srpska spoke of the current situation and conditions in RS.
Vedran Kordic, on behalf of the two PIUs presented the Framework EMP document.
Mr. Mladen Rudez, Assistant Minister of Environment and Tourism of FBiH has spoken highly of the
requirements of the World Bank on integrating environmental protection as a pre-requisite of their
projects, and to have such public consultations, as the overall situation in BiH does not provide for
much support to the environmental protection. Mr. Rudez has elaborated on the legal framework for
environmental protection in BiH as well as the mechanism of environmental permitting, and the
advances made in this field. He has explained that in 2002/2003 a set of 6 new environmental alws
has been drafted and that the EU Directives mentioned in the Framework EMP are integrated into
the Entity laws.
Ms. Belma Kljuco Vlasic on behalf of the Novo Sarajevo municipality has stated that in FBiH there is a
separation of responsibilities between the Municipality, Canton and the Federation, and that there is
a lack of clarity who is responsible over what parts of environmental protection, but that for the Real
Estate Registration Project the Framework EMP will serve as a guideline. She also asked from the
Federal Ministry of Environment and Tourism to organize a seminar or workshop on environmental
permitting.
Mr. Igor Dizdar on behalf of the Federal Ministry of Physical Planning has explained the varied levels
of responsibility between the Municipality, Canton and Federation related to construction permits,
and noted that for reconstruction of the land or real-estate registry offices no permits would be
needed, and that such works would be considered as “regular maintenance” except in cases when
the building is under a specific form of protection (monument of culture, heritage site, etc.)
Ms. Azra Agic on behalf of the Novi Grad Sarajevo Municipality has expressed her satisfaction with
the rules and procedures that are required by the World Bank.
Ms. Antonija Sikimic on behalf of the Federal Administration for Geodetic and Real-Property Affairs
has joined in the discussion related to the environmental permits and responsibilities specifically
touching upon the issue of preventing illegal construction in industrial areas and legalization of such
buildings.