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Photo 5. Exhibits given to The Historical and Country Studies museums of Shamkir by IoAE for
demonstration.
Photo 6. Exhibits keeping in the close and open places such as old church survivals given by IoAE
to The Historical and Country Studies museums of Shamkir
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Appendix 6
Summary table
NGO WORKING GROUP TITLE: Cultural Heritage AWG
NGO WORKING GROUP MEMBERS: Elman Yusifov, Farida Huseynova, Jeyhun Musayev, Aga Aliyev, Saltanat Zulfugarova
(student)
AUDIT OBJECTIVES: 1. Audit performance of SCP requirements of Cultural Heritage Management Plan
2. Audit performance of SCP in meeting commitments
3. Audit of contractor (CCIC) and National Partners (the ANAS IAE and the Ministry of
Culture) performance in meeting SCP requirements and commitments
4. Audit of procedure of finding, cataloguing, presentation and report to public
communication of archaeology findings.
BP/BTC/SCP responses may be characterized as below:
Accept (A): We accept the reported non-conformance, finding, observation, recommendation. We will take appropriate steps, or provide
evidence on how BP/BTC/SCP has already addressed this issue.
Accept with Qualification (AwQ): We understand and appreciate the audit result in question, but we disagree with some aspect of non-
conformance, finding, observation or related recommendation, as presented. We therefore “qualify” our agreement by providing details
of our policies and/or actions that address the issue(s) raised.
Reject (R): We disagree with the Audit result; in the BP/BTC Summary provide our views.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit performance of SCP requirements of Cultural Heritage Management Plan
Findings
F1
The
Contractor
didn’t fully cover
information
on
archaeology
in
the
training
course.
R1:
We
recommend
Contractor to take this fact
into consideration in the
future activity.
(negative finding)
R: The training course to which Audit Group refers is a general Health, Safety,
Environment and Security Induction for all staff, and as such, includes such topics as
Environmental, Cultural and Archaeological Awareness, Spill Response, Noise
Abatement, ESMS Awareness, Contractor Implementation Plans. In addition to this
training, which provides overview knowledge for office-based staff, toolbox talks
were developed to present field staff with more specific training and information, on
a variety of topics. Specific tool box talks covering Cultural Heritage were given to
all teams who encounter Cultural Heritage issues as part of their work scope.
BP/BTC/SCP and CCIC believe that trainings provided by CCIC have been robust
and fit to purpose.
F2
Contractor
Control
Plan
reflected
in
Ecological
and
Social
Management
System (ESMS)
manual
was
missed.
R2: It is important to pay
more attention to this issue
in the future.
(negative finding)
R: BP/BTC/SCP and CCIC recognize the importance of establishing and following
environmental and social management systems.
In fact, early versions of ESMS do note a Contractor Control Plan for Cultural
Heritage. This document does exist. However, the current ESMS (provided to Audit
Group) reflects a decision later in the project execution that BTC/SCP staff and
resources were better positioned to assume management and operational authority
over Cultural Heritage than CCIC. For this reason, BTC/SCP staff made available to
Audit Group a Cultural Heritage Management Plan, which sets forth the actions
intended to provide assurance of cultural heritage protection. Thus the (current)
ESMS makes no mention of a Contractor Control Plan. This is because BTC/SCP
has assumed direct control of responsibilities once planned for contractor. Thus a
CCP is no longer required.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit performance of SCP requirements of Cultural Heritage Management Plan
Findings
F3
The Strategic Plan on Cultural
Heritage
Protection
along
with
Gobustan State Historical Artistic
Reservation
has
not
been
developed yet.
R3: It is recommended
to
accelerate
preparation
of
the
Strategic
Plan
for
Protection of Cultural
Heritage
along
with
The Gobustan State
Historical
Artistic
Reservation.
(negative finding)
AwQ: BP/BTC/SCP and CCIC have worked extensively with the
Gobustan Preserve management and relevant authorities. While the
BTC/SCP commitment is to “discuss the possibility …to develop a
management plan,” this obligation has been surpassed. A Working
Group was set up at the outset of the project to manage the
production of an integrated Cultural Heritage and Environmental
Management Plan for the Gobustan Reserve. However it became
apparent that UNESCO was in fact helping the Ministry of Culture in
producing a very similar plan, in line with the Gobustan Reserve’s
application for World Heritage Status. BTC/SCP therefore decided
that, rather than duplicate resources, they would provide assistance
to the Gobustan Reserve in other ways to enable the MoC to better
manage the reserve. To date this has included:
• Provision of GIS training, computers, GPS equipment and software
to the MoC to electronically record and manage rock art within the
reserve.
• Translation of books and articles into English.
• Assistance with international conferences on Gobustan Rock Art.
Non-conformances
NC1
Commitment:
According to ESIA manual, the audit
program consists of 3 activities:
▪Contractor’s self provision;
▪The audit of Contractor by the BTC;
▪External audits. (ЕSIA. Section
6.4.4.1.)
Non-conformance:
Contractor’s self-provision was not
realized.
R4: Cultural Heritage
Protection
is
very
sensitive
field.
Therefore,
self-
provision
is
very
necessary. Contractor
has to discuss this
issue and take into
consideration
in
its
activities.
R: BP/BTC/SCP and CCIC agree that Cultural Heritage protection is
sensitive, and indeed crucial to the successful construction of a world-
class export pipeline. By “self-provision”, the ESMS Manual refers to
internal audits undertaken by the contractor, of contractor activities.
CCIC has undertaken internal audits of its activities. However, as
noted above, in the case of Cultural Heritage, the activities in
question have passed to BTC/SCP. BTC/SCP have undertaken
regular internal audits and daily and weekly ongoing monitoring of
Cultural Heritage issues. A CCIC internal audit of activities which it is
no longer responsible for would have been meaningless, and was
thus not pursued.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit performance of SCP in meeting commitments
Findings
F4
The archaeologists of the company
held trainings for the contractor
staff. Important measures were
taken in educating archaeologists,
as well as slideshows prepared on
the base of archaeological findings
were
presented
to
the
staff
members.
(positive finding)
A: BP/BTC/SCP and CCIC believe, like the Audit Group, that the
archaeological and cultural heritage of Azerbaijan has significant
national and international value. For this reason, we are pleased by
Audit Group’s commendation of our extensive efforts to protect these
findings.
F5
The SCP is providing a fruitful work
together with Ministry of Culture of
the Azerbaijan Republic department
of “Exploration and Protection of
Monuments”;
Special
committee
was created in order to perform the
commitments. The SCP provided
the reservation representatives with
training.
The
reservation
got
technical equipments. Currently the
digital base of the reservation is
developing.
(positive finding)
A: As above, we are pleased by Audit Group’s commendation of our
extensive efforts to protect the cultural heritage of Azerbaijan.
F6
Researches were conducted as the
result
of
the
advice
of
representatives of the IoA in the
area of Tovuzchay (KP 377-378) in
the 60 meters from 44m corridor.
(positive finding)
A: As above, we are pleased by Audit Group’s commendation of our
efforts to protect the cultural heritage of Azerbaijan.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit performance of SCP in meeting commitments
Findings
F7
As a result of wrong planning
the part of the reservation area
was separated into two parts
and one of the separated parts
was left uncontrolled after the
pipeline was built.
R5: Immediate measures
must be taken to have a
control over reservation
area,
which
was
left
uncontrolled
as
a
separation
of
the
reservation area into 2
parts.
(negative finding)
R: BP/BTC/SCP consulted extensively with relevant national
authorities in the process of pipeline routing. Rather than “wrong
planning”, the pipeline route was chosen with enormous care, and
passes a very short distance through the extreme north eastern edge
of the reserve. The Audit Group, in noting reservations regarding the
pipeline’s relationship to the Gobustan Reserve, should be aware that
the route passes through a (previously) disturbed area away from all
locations of archaeological significance.
The above withstanding, since the pipeline itself is below ground, we
do not consider normal pipeline operations an impediment to the
Gobustan Reserve’s control of the “separated part,” which is indeed
their right and responsibility.
Non-conformances
NC2
Commitment :
According to SCP Commitments
208 (158) and 210 (162) on
Cultural
Heritage
Protection
operative archeological control
will be ensured during pipeline
construction.
Non-conformance:
SCP commitments # 208 (158)
and 210 (160) on Cultural
heritage protection plan were
not implemented adequately.
R6:
The
better
archeological control over
in future activities must be
ensured.
R: By “control” BP/BTC/SCP and CCIC understand that our
commitments have been to ensure that: “There will be specialist
archaeological surveillance present during the clearance of the ROW
and facility sites,” and that “an archaeologist with a watching brief will
accompany the construction activities on the pipeline.” We strongly
disagree with the statement that this has not been undertaken.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit of contractor (CCIC) and National Partners (the ANAS IAE and the Ministry of Culture) performance
Non-conformances
NC3
Commitment:
According to the ESIA, ”Decisions
concerning the significance of the
archaeological monuments and
relevant actions will be accepted
jointly with The Ministry of Culture
of the AR and The Institute of
Ethnography “;
According to “Historical and
Cultural Monuments Protection”
law of the Azerbaijan Republic
adopted in 10.04.1998, №470-IQ;
«The permission from appropriate
executive organs and opinion of
the NSAA for soil or construction
works in the area of historical and
cultural monuments and
instructions given by them should
be followed». CHMP 1.6
paragaph18.
Non-conformance:
The commitment of “The
importance and decisions on
archaeological findings will be
made by Ministry of Culture of
Azerbaijan Republic together with
IoAE.” was not met. The Ministry
of Culture was not involved in this
activity.
R7: The ties with
Ministry of Culture
must be restored
immediately. Legal
documentation of them
must be ensured. BP,
BTC, SCP together
with Ministry of Culture
of Azerbaijan Republic
and IoAE must
establish work group to
protect archaeological
monuments.
R: BTC/SCP has worked closely with both the MoC and IoAE on the
routing and construction stages of the project.
It is not, however, the remit of BTC/SCP to interfere in the internal
communication mechanisms between two national regulatory bodies.
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No. Issue
Related
Recommendation
BP/BTC/SCP response* (A, AwQ, R) and explanation
Audit of procedure of finding, cataloguing, presentation and report to public communication of archeology findings
Findings
F8
Computerized
catalog
of
archaeological findings was not
prepared.
R8: It is recommended
to
accelerate
preparation
of
computerized
catalogue
of
archaeological findings.
(negative finding)
AwQ: The BP/BTC/SCP commitment in question is, if there is a case of a
“Significant area where unavoidable impact (will) occur”, it “will be fully
recorded, published in academic journals and in a popular form. In this
way, the information can be made available for the people of Azerbaijan
and other nations”.
As has been discussed with the Audit Group, Phase 5 of the Cultural
Heritage Management Plan, to be undertaken after pipeline construction,
is exclusively focussed on activities that will bring the scope and
magnitude of archaeological findings to the attention of the interested
public. In fact, Phase 5 is currently underway and includes cataloguing
and analysis of artefacts, production and publication of results from each
site excavated, web site preparation and launch and also the production
of a glossy coffee table book.
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