Environmental Monitoring Report

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Environmental Monitoring Report
Environmental Monitoring Report

Project Number: 51423-002
Loan number: L3895, L3896
Grant number: G9205
Period covered: July - December 2020
February 2021

MONGOLIA: Vegetable Production and Irrigated
Agriculture Project

Prepared by Project Management Unit for the Ministry of Food, Agriculture and Light Industry

This environmental monitoring report is a document of the borrower. The views expressed herein
do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may
be preliminary in nature. In preparing any country program or strategy, financing any project, or
by making any designation of or reference to a particular territory or geographic area in this
document, the Asian Development Bank does not intend to make any judgments as to the legal
or other status of any territory or area.
Mongolia: Vegetable Production and Irrigated
Agriculture Project
Semi-Annual Environment Progress Report (No. 1)
July – December 2020

Project Number: 51423-002

                       Prepared by the Project Implementation Unit

                                     February 2021
TABLE OF CONTENTS

1   INTRODUCTION                                                                          3
    1.1    Project Background                                                            3
    1.2    Purpose of the Report                                                         3
    1.3    The Overall Project Progress                                                  4
2   IMPLEMENTATION OF THE EMP                                                             5
    2.1    Roles and Responsibilities for EMP and Monitoring Implementation              5
    2.2    Environmental Monitoring Data and Safeguard Related Activities                5
    2.3    Environmental Capacity Building and Training                                  6
3   CONCLUSION, RECOMMENDATIONS AND NEXT STEPS                                            7

    3.1    Overall Environment                                                           7
    3.2    Okhindiin tal subproject                                                      7
4   APPENDICES                                                                            9
    4.1  APPENDIX I. EMP and Monitoring Implementation Progress                           9
    APPENDIX II. Roles and Responsibilities for EMP and Monitoring Implementation        28
    APPENDIX III. List of Subprojects and Activities                                     30
    APPENDIX IV. Project Implementation Progress                                         37
    APPENDIX V. Stakeholders Attended in the Capacity Building and Training Activities   37
1     INTRODUCTION

1.1     Project Background
1.      The Mongolian agriculture sector has high potential for growth and livelihood
opportunities. However, only about 51% of the country’s annual vegetable demand is met by
domestic production (2008‒2016).1 Irrigation services are supported by the Ministry of Food,
Agriculture, and Light Industry (MOFALI), which owns most of the irrigation infrastructure
and provides support for maintenance. There are currently more than 380 irrigation schemes
in Mongolia. Almost all irrigation systems are recognized as being inefficient in use of water
resources, have outdated and unsustainable infrastructure, and with insufficient investment
in maintenance. Currently, about 54,000 ha are under irrigation against a potential area of
around 400,000 ha, with the government aiming to increase irrigated land to 120,000 ha by
2030. However, this remains a challenge with many of the irrigation systems being old and
requiring substantial maintenance and rehabilitation.

2.      The Vegetable Production and Irrigated Agriculture is an ADB loan project (the
project) with the grant financed by the Japan Fund for Poverty Reduction. The total budget
of the project is $46.25 million of which regular loan $14.7 million and concessional loan
$25.3 million from ADB’s ordinary capital resources and $2.0 million grant from JFPR, the
central and local government contribute $4.25 million. The project commenced in May 2020
for the project period of seven years. The project impact is income generation and enterprise
support for smallholder vegetable farmers increased. The expected outcome is increased
efficiency of climate-resilient agricultural production and marketing.

3.      The outputs of the project will be (i) efficient and climate-resilient irrigation
infrastructure and management systems installed; (ii) environmentally sustainable
agriculture production systems improved; and (iii) technical Institutional, and management
capacity and coordination strengthened. The project design follows the principles of (i)
upgrading irrigation systems; (ii) improving the efficiency of resource use in agricultural
production through improved seeds and investment in farming equipment; (iii) improving the
quality and safety of end-products for consumers; and (iv) ensuring that there is an
opportunity to participate in equitable benefit sharing from the project. The list of subprojects
and detailed activities to be executed under each subproject is provided in Appendix No.3.
1.2     Purpose of the Report
4.     The purposes of this report is to describe current progress related with project’s EMP
implementation and other environment related activities of the project and present the
outcome, provide recommendations, conclusions for the second half of 2020 and propose
relevant next steps. The report is aimed to provide the project environmental progress to
government, ADB and other project stakeholders but also it serves as a systematic and
instrumental guiding document for the environmental monitoring of the PIU.

1 Main vegetables that are produced in Mongolia are beet, cabbage, carrot, cucumber, garlic, onion, tomato, and
turnip. National Statistics Office of Mongolia. 2019. Mongolian Statistical Yearbook 2018. Ulaanbaatar.

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5.    This report was developed by the Environmental Safeguards Specialist of the PIU in
cooperation with other PIU members given the frequent consultations with consulting firms
and based on the review of corresponding project administration and environmental
documentations. The report covers period of monitoring from July to December.

1.3    The Overall Project Progress
6.     PIU conducted the baseline survey in project’s target soums such as Batsumber
soum of Tuv aimag, Sant and Zuunburen soums of Selenge aimag, Kherlen soum of Khentii
aimag, Telmen, Uliastai, Jargalan of Govi-Altai aimag, Sagsai and Bayannuur of Bayan-Ulgii
aimag from 8 October to 1 December. However, due to the travel restriction caused by the
COVID-19 internal cases in the country, the survey process has been stopped and the team
could not visit the Khaliun soum of Govi-Altai aimag, Erdeneburen and Altai soums of Khovd
aimag. Due to the quarantine set from the Government of Mongolia, the team has been
locked down in Bayan-Ulgii aimag from 11 November to 1 December. Based on the obtained
information, the PIU has prepared the baseline survey report and presented the findings to
the PSC on 28 December.

7.     A chart for monitoring a progress status of the project implementation plan was
developed as given Appendix No.4 of this report. The weighted total cumulative progress
of the projects is 8.8 percent for this reporting period. The project commencement was
slowed down and recruitment was delayed of the PIU staff as well as relevant consultants
bidding took longer time than expected.

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2    IMPLEMENTATION OF THE EMP
2.1       Roles and Responsibilities for EMP and Monitoring Implementation
8.     Key institutions responsible for the overall supervision of the EMP implementation
are Project Steering Committee (PSC), Ministry of Food, Agriculture and Light Industry
(MOFALI), Ministry of Finance (MOF) and General Agency for Specialized Inspection. The
PIU, specifically Environment Specialist, state environmental inspectors at soum level are
responsible for enforcement of the EMP also actual EMP implementation and reporting lie
on the construction companies for irrigation systems etc. Detailed institutional
responsibilities for EMP implementation2 are included in the Appendix No. 2.

2.2       Environmental Monitoring Data and Safeguard Related Activities
9.     The PIU's Environment Specialist recruitment (CS-07) was organized in August
2020 and has been appointed by Order B-120 of the Ministry of Food, Agriculture and Light
Industry. An environmental action plan for 2020-2026 was developed and approved by the
Project Director.

10.    Relevant documents on project's environmental assessment from Ministry of
Environment and Tourism and related stakeholders were reviewed. Based on the
environmental documents including the project IEE, three EBAs developed in 2019, PAM
and other relevant documents, Environment Specialist is compiling environmental
monitoring data.

11.    The Environment Specialist is developing the project specific Grievance Redress
Mechanism (GRM) in collaboration with the Social and Gender specialist. GRM will serve
as a key document for the project because local stakeholders or project affected people and
businesses can freely compile and submit their grievances if the project activities expose
negative impact on the living environment, health and safety or overall livelihoods. PIU is
working to finalize GRM two months prior to the project construction phase at soums.

12.    The technical proposal and financial proposal were evaluated by the Evaluation
Committee meeting on September. As a result, JV of “Green Nature Land” LLC, “Ecos” LLC
and “New Green World” LLC has been chosen for the CS-15 Consultant for the
Environmental Impact Assessment (EIA) and the Detailed Environmental Impact
Assessment (DEIA) of the 12 irrigation systems under the project.

13.     As mentioned above, a qualified National Partnership for EIA (CS-15) has been
selected and they have been introduced with CS-16 Consultant of “10 IS Design” and CS-
14 consultant for ecological research and impact assessment for the “Okhindiin tal” sub-
project. Environment Specialist also supported and facilitated consultation and information
sharing process among these consultants.

14.   In addition, National Biodiversity Consultant conducted an autumn study to assess
the impact on biodiversity and birds in “Okhindiin tal” subproject of Zuunburen soum,
Selenge aimag, from September 25 to October 15. The PIU supported the consultant in

2   Extracted from PAM

                                                                                          5
liaising with ADB and the Executing Agency, reviewing the progress of local ecological
research, and providing guidance and advice. The first phase survey report was approved
in December by MOFALI, ADB, and PIU. Parties agreed to conduct a bird survey in winter
for a week in February 2021.

15.      Due to the subprojects are numerous and dispersed, to timely clarify irrigation
systems subprojects’ environment behaviors and performances, PIU organized a series of
field visits, periodical document review, surveys, and data collection. Project Environment
Specialist has conducted field work in Okhindiin Tal and Iven river irrigation systems. In this
fieldwork, environment related surveys were conducted by focus group and individual
interview methods. The intention of this work was to identify the major environmental
concerns. The outcome was duly informed back to PIU, MOFALI and ADB. Also, this
information was shared with DEIA consulting company.

16.    Due to the Covid-19 travel restriction3 the field studies for development of 12 sub-
projects EBA, DEIA and DEDs of 9 sub-projects was delayed for a month period, thus
making related works such as detailed designs expertise, EBA, DEIA approvals, and bid
arrangements might be postponed, which is reflected on 2021 annual work plan as directed
by the PSC.

17.    Environment Specialist developed relevant maps for the irrigation system
construction sites throughout the country. The maps were developed to show locations for
the twelve construction sites of the irrigation systems as well as rehabilitation of the regional
seed centers infrastructure including their irrigation systems, both in Mongolian and English.

18.       Environment Specialist completed the below additional activities:
          i)     To support bidding and contract documents, all the issues to be included in
                 the EIA agreement and the provisions for relevant agreements were
                 prepared and presented;
          ii)    Within the framework of the project’s renovation of the irrigation systems of
                 the Plant and Agricultural Institutes, the terms of reference and budget for
                 EBA and EIA consultancies were developed. This activity was not planned
                 and identified as one of the potential risks in the future if these institutes do
                 not have effective DEIA/ EMP or do not have sufficient to conduct.

19.     The project IEE was developed in November 2019 and this document includes EMP
and monitoring plan covering whole project lifetime. This EMP is inserted in the Appendix
No.1 which contains the comprehensive table for project activities, potential environmental
impacts and issues thereof together with mitigation measures, and the implementation
status indicated in the last column was added accordingly.
2.3       Environmental Capacity Building and Training
20.    Environmental Safeguard concerns indicated in the project IEE of and as well as
environmental requirements of GoM for the project were shared with following project
stakeholders and related consultants. The key issues included following:
    i) Protecting river basin and limiting impact on flow rates in the rivers that will provide

3   PPR dated January 15, 2021

                                                                                                 6
main water sources for the irrigation systems indicated in the EMP in the IEE;
    ii) Globally critical habitat for endangered bird species in “Okhindiin tal” subproject (the
         EMP in the IEE); and
    iii) Need for collaboration with the local government, projected areas and river basin
         administrations etc.,
Overall, seven companies, local government officials from seven aimags and twelve soums,
MOFALI and PIU staff was involved in this capacity building activities. All environmental
safeguard related concerns were duly to informed to these stakeholders and used for their
operations and related reports. List of stakeholders attended in the environmental capacity
building and training activities is included as Appendix No.5.

                    3   Conclusion, Recommendations and Next steps
21.     Overall Environment The consultants could not effectively plan and conduct local
trips were due to the COVID 19 pandemic thus it has paralyzed the consultancy as well as
project activities, especially in the local level. However, the project and consultant team
efficiently use web-based video conferencing tools (Teams, zoom, viber etc.,) for
communications with the stakeholders.

22.      MOFALI in cooperation with the VPIA project recruited the consultant for EBA and
EIA on November 4th and the consultants only managed to visit few project target areas for
irrigation systems but not all of them, because for the lockdown caused by the COVID 19.
However, the project has coordinated with the DED consultant to share their soil samples
with EIA consultant as the DED consultant was contracted early, thus managed to complete
all the project areas.

        i)  The overall challenge for the environmental safeguards work is following:Timely
            completion of the EBAs and DEIAs along with EMPs for the twelve irrigation
            systems could be problematic due to COVID 19 condition, field trip limitations,
            hardship with local communication with local officials through internet;
        ii) Due to environmental sensitivity issues related to Okhindiin tal, which described
            in detail below to change to consider change the subproject implementation site

3.1    Okhindiin tal subproject
23.     Regarding irrigation schemes sub project in Okhindiin tal, the relevant studies and
EBA results have indicated that that area has high biodiversity values especially in terms of
the globally critical habitat for endangered bird species including steppe eagle, sacred
falcon and of great bustard (Asian sub species). Therefore, the project might consider the
option to relocate the sub project site to another area to avoid potential negative impact on
the local ecosystem.

24.     The autumn phase one survey cannot describe all significance of biodiversity and
ecosystem services of the IBA and the subproject site. Next year, a study on the population,
location and breeding of Great Bustard and other threatened species will be conducted
again at the subproject site in phase two survey during spring of 2021. If Great Bustards are
nested or summering at the subproject site, a biodiversity offset study must be conducted.
Because no project activity will be implemented in this critical site according to the SPS of

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ADB without comprehensive mitigation and offset plans that mitigating the impact on
threatened birds such as Great Bustard, Saker Falcon and Steppe Eagle.

25.     Mongolia is a member of the International Conventions on Biological Diversity,
Migratory Species and Ramsar; and the issues related to the regulation of these
international conventions have in the subproject site. Also, the current results suggest that
the subproject has fewer impact issues with mammal species, but it has potential impacts
on the habitat loss of Great Bustard, Saker Falcon and Steppe Eagle and other threatened
water birds.

26.     Winter survey (February – March 2021): During the autumn study, we observed that
the subproject area has suitable habitat with good storm shelters and foraging sites for
wintering animals. We recommended organizing a winter survey for a week in the
subproject site and the IBA. During the winter survey, we could collect a comprehensive list
of all resident species and also winter visitors with their population numbers. This winter
data will help to complete the project impact assessment and assessing the significance of
biodiversity.

27.    Okhindiin Tal subproject survey results shall be integrated with the EBA and DEIA
as well as the DED of the subproject. Moreover, the PIU is planning to conduct joint
consultation meetings including the National Biodiversity Consultant in “Okhindiin tal”
subproject EIA (CS-15) and DED (CS-15) consultants to better share information and
properly develop the relevant EMP for this subproject area.

28.     Another highly worrisome issue is related to anthrax disease. The outbreak of this
disease occurred in Zuunburen soum, Selenge aimag in 2010. Infected and diseased
livestock was buried in the site Okhindiin tal whereas the burial site covered 1,200 ha.
Therefore local soum governor issued resolution A/1430 on the 1st July 2010 on prohibiting
use this area for crops and vegetables farming. Thus, it is extremely questionable to use
this area for the vegetable production.

The photo of the sign board in the area and GIS location is pinned on the map of the
subproject as shown in above.

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4    APPENDICES

4.1     APPENDIX I. EMP and Monitoring Implementation Progress
               Potential
 Item          impacts /    Mitigation measures                                                                              Implement     Supervise    Status
               issues
A. DESIGN AND PRE-CONSTRUCTION PHASES
Detailed     Institutional   Before recruitment of firms to prepare the detailed engineering designs and detailed           PIU            MOFALI      Completed
design stage strengthening   environmental impact assessments, recruit PIU environment safeguard officer;
             for EMP         At least 2 months before any works, establish the project GRM, including contact                                          Ongoing
             implementation details and training for project agencies;

                                Organize and conduct training on EMP for relevant agencies.                                                            Ongoing
              Preparation of    Prepare EBAs for the irrigation subprojects for which EBAs were not prepared during         PIU (for admin PIU, MET    Ongoing
              Environmental     the project processing;                                                                     procedures)                Three EBAs
              Baseline                                                                                                       , certified               submitted to
              Assessments                                                                                                   domestic firm              MET
                                Ensure General EIA Letters are issued for the EBAs;                                         (for                       Ongoing
                                                                                                                            EBAs,
                               Assess the requirements in the General EIA Letters, including the need to prepare            Detailed EIAs)             Not due
                               Detailed EIAs for the irrigation subprojects
                             PROJECT SAFEGUARD PERFORMANCE INDICATOR:                                                                                  Not due
                             • No civil works for any subproject will proceed until all domestic environmental
                               approvals are completed; the findings are provided to ADB; the project EMP is
                               updated as needed; and the updated EMP is included in all relevant project tenders
                               and bidding documents (see also below).
              Detailed       Recruit domestic certified firm to prepare DEIAs;                                              Certified     PIU, MET,    Ongoing.
              Engineering    • PIU environment safeguard specialist will: (i) facilitate recruitment and coordination of    domestic firm MOFALI       Ongoing
              Designs and      firm; (ii) review final decisions of MET and any safeguard conditions or mitigation
              Preparation of   measures; (iii) assess whether EMP needs updating;                                           For cold
              Domestic       • Conduct the Detailed EIAs as needed                                                          storage -                  Not due
              Detailed EIA                                                                                                  Goods
                             • Prepare detailed engineering designs;                                                        provider                   Not due
                             • For the output 2 subproject - support to IPAS research facility in Darkhan - which will      (and PIU for               Ongoing
                               include the provision of cold storage facilities, the cooling systems will be designed for   tender
                               the use of “R32”, “R290” or other coolants with low-impacts to greenhouse gases. The
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Potential
Item    impacts /      Mitigation measures                                                                   Implement     Supervise    Status
        issues
                        designs will not use the coolant “R134a”                                           specification
                                                                                                           s)

                    For all subprojects:
                      ‐ The weir central section length for each subproject will be adjusted based on sub
                         project specific assessment of peak flow, to ensure that river flows are maintained
                         as close to their natural flow as possible.
                      ‐ This will avoid a very narrow weir length which would increase average velocity
                         above flows against which fish will unlikely be able to swim upstream (3m/s).
                    For all subprojects:
                      ‐ The weir central section length for each subproject will be adjusted based on sub
                         project specific assessment of peak flow, to ensure that river flows are maintained
                         as close to their natural flow as possible.
                      ‐ This will avoid a very narrow weir length which would increase average velocity
                         above flows against which fish will unlikely be able to swim upstream (3m/s).
                    PROJECT SAFEGUARD PERFORMANCE INDICATOR:                                                                           Ongoing
                    • The engineering designs and DEIAs are prepared in close coordination.
                    • Safeguard issues, especially projected low flows and e-flow requirements, are                                    Ongiong
                      incorporated into the detailed engineering designs for the sluice gates and intake
                      gates and weir height and depth, tailored to the individual flow regimes for each
                      subproject river.
       Updating EMP • Assess whether the General EIA Letters, Detailed EIAs, and/or MET instructions,        PIU, MET      MET, ADB    if required
                      present new findings and/or require new mitigation or monitoring measures which are
                      not already included in this project EMP. Submit these findings, including the
                      translated General EIA Letter and other MET approvals, including for the Detailed EIA,
                      to ADB for review.
                    • Update the project EMP as needed with these additional domestic requirements based
                      on final detailed designs and DEIAs;
                    • Submit the updated EMP to ADB for review;
                    • In case of major changes of project location and/or additional physical components,
                      determine whether the change is minor or major and consult with ADB.

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Potential
 Item         impacts /     Mitigation measures                                                                           Implement    Supervise    Status
              issues
Construction Environmental • Prior to construction, hire an Environmental Management Agency (EMA), to conduct            PIU hires    MOFALI
Preparation monitoring       environment monitoring in accordance with the EMP monitoring plan;                          EMA
             plan          • This will include water quality monitoring for 7 subprojects: for surface water quality –
                             4 subprojects (Dulaanii Tal, Iven Gol, Sugnugur, Erdeneburen); and groundwater
                             quality – 3 subprojects (Tsul-Ulaan, Khuren Tal, Nogoon Khashaa) (Table EMP-3)
             Bidding and   • Incorporate EMP mitigation measures into all bidding documents;                             PIU          MOFALI
             contract      • Define spoil disposal sites and borrow pit locations in the construction tender
             documents       documents;
                           • Bidding documents are sent to ADB for review;
                           • Ensure that the contractors recruited conform with, and implement, the domestic
                             Environmental Safeguard Clauses for Civil Works Contracts; including that each
                             contractor shall have a qualified environment specialist on the team, especially for
                             contractors implementing any road works.
                           • Ensure that the contractors fulfill any additional domestic safeguard requirements that
                             are not otherwise covered in this EMP.

              EMP training    • Provide training on construction environmental management, implementation, PIU                        MOFALI       Ongoing
                                supervision, to contractors and the Capacity Development consulting firm, in
                                accordance with the training plan in this EMP.

              Establish GRM • Responsibility for GRM implementation is assigned to PIU environment and social            PIU          MOFALI       Ongoing
                               specialists and soum government focal points;
                            • All agencies aware of, and trained in, the GRM, and will help support the
                               environmental and social specialists when necessary;
                            • Key contact details for the GRM (phone number, fax, address, email) provided on the
                               MOFALI, PIU and/or soum government public websites, and information boards at
                               construction sites.
              Location of     • Prior to any works, identify specific site locations for camps and assess these for  Contractor       PIU          Not due
              work camps        adequacy of construction requirements and to minimize ecological and social impacts,
                                especially to avoid sites along rivers or other environmentally sensitive areas

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Potential
 Item       impacts /        Mitigation measures                                                                        Implement    Supervise         Status
            issues
           Reconfirmation • Based on the finalized quantities of spoil needed calculated in the DEDs, identify the     Contractor   PIU               Not due
           of borrow and      sites to be used and ensure they have sufficient capacity to provide the volumes
           spoil sites        needed;
                           • Obtain MET and soum governments approval for the required material volumes (rock,
                              gravel) and site use.
B. CONSTRUCTION PHASE
Topography Earthwork, soil • Construct intercepting channels to prevent construction runoff entering waterways;        Contractor   PIU, Capacity
and Soils  erosion, soil   • Divert runoff from sites to sedimentation ponds or existing drainage;                                  Development
           contamination • Limit construction and material handling during periods of rains and high winds;                         consulting firm
                           • Stabilize embankments, and other erosion-prone areas during works;
                           • Minimize open excavation areas and use compaction techniques for pipe trenches;
                           • Properly store petroleum products, hazardous materials and wastes on impermeable
                             surfaces in secured and covered areas;
                           • Rehabilitate all spoil disposal sites and construction sites;
                           • Site rehabilitation will only use native plant species of local source; and/or sterilized
                             seedlings (to avoid weed invasion);
                           • Situate construction camps and storage areas to minimize land area required;
                           • Remove construction wastes from the site to the approved disposal sites;
                           • For soil protection: preserve existing soil layer where practicable; if soil removal is
                             required, strip and stockpile topsoil and cover (with geotechnical cloth) in accordance
                             with Mongolian legislation; reuse topsoil for site rehabilitation; seed grass as soon as
                             possible to minimize duration of ground exposure; use only sterilized seedlings (to avoid
                             weed invasion);
                           • Limit construction and material handling during periods of rains and high winds;
                           • Properly slope or re-vegetate disturbed surfaces e.g. pipeline trenches and cut banks;
                           • Establish site-specific emergency preparedness and response procedures for each
                             subproject. This will include: provision of cleanup equipment at each construction site;
                             selection and training of workers to operate this equipment; disposal of the spilt
                             materials; and, special emphasis on works within and adjacent to the river channel, for
                             construction of the rock barriers and weirs;
                           • Stabilize earthwork areas within 15 days after earthworks have ceased at the sites

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Potential
 Item          impacts /         Mitigation measures                                                                         Implement     Supervise        Status
               issues
Ambient Air   Dust              • Water will be sprayed on active construction sites including where fugitive dust is        Contractor   PIU, Capacity
              generated by        being generated daily, and more frequently during windy days, if settlements will be                    Development
              construction        affected.                                                                                               consulting firm
              activities,       • Transport vehicles will be limited to low speeds in construction sites especially close to
              gaseous air         settlements
              pollution (SO2,   • Loads will be covered during truck transportation to avoid spillage or fugitive dust
              CO, NOx) from       generation. Fine materials will be transported in fully contained trucks.
              construction      • Construction site roads will be well maintained and watered and swept on an as-
              machinery           needed basis. Construction site road entry points will be equipped with the truck drive
                                  through wash ponds.
                                • Transport routes and delivery schedules will be planned to avoid densely populated
                                  and sensitive areas and high traffic times in aimags and soums, if required.
                                • Store petroleum or other harmful materials in appropriate places and cover to
                                  minimize fugitive dust and emission.
                                • Provide regular maintenance to vehicles to limit gaseous emissions (to be done off-
                                  site).
                                • Construction spoil and other construction materials will be temporarily stored using
                                  containers, but they may the potential to generate dust. Thus, containers will be
                                  covered and/or watered if necessary.
                                • Muddy or dusty materials on public roads outside the exits of works areas will be
                                  cleaned immediately.
                                • The disturbed sites will be revegetated as soon as possible.
                                • Dust suppression near sensitive receptors e.g. schools, hospitals, residential areas.
                                • Ensure vehicle and machinery emissions comply with Mongolian standards.
                                • Timely monitoring of TSP, and machinery inspections, during construction.
                                • Regular consultations will be held with residents prior to, and during, works, to discuss
                                  the dates and timing of works and to receive feedback on air-related issues

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Potential
 Item          impacts /      Mitigation measures                                                                          Implement     Supervise        Status
               issues
Noise and     Noise          • Construction activities will be planned in consultation with local authorities and Contractor            PIU, Capacity
vibration     generated from communities so that activities with the greatest potential to generate noise and                           Development
              construction     vibration are planned during periods of the day that will result in the least disturbance.               consulting firm
              activities     • When undertaking construction planning, simultaneous high-noise activities will be
                               avoided. High-noise activities will be scheduled during the day rather than evening
                               hours. Similarly, the construction sites will be planned to avoid multiple high-noise
                               activities or equipment from operating at the same location.
                             • Low-noise equipment will be selected as much as possible. Equipment and machinery
                               will be equipped with mufflers and will be properly maintained to minimize noise.
                             • Noise protective equipment will be provided to workers to meet the requirements in
                             • occupational exposure limits for hazardous agents in the workplace according to EHS
                               Guidelines.
                             • Transportation routes and delivery schedules will be planned during detailed design to
                               avoid densely populated and sensitive areas and high traffic times.
                             • Vehicles transporting construction materials or waste will slow down and not use their
                               horn when passing through or nearby sensitive locations, such as residential
                               communities, schools and hospitals.
                             • Special attention will be paid to protect sensitive sites near the subproject sites: high
                               noise construction activities will be positioned as far away from sensitive sites as
                               possible.
                             • Installation of sound barriers around the construction site will be decided during the
                               detailed design phase for residential areas, if required. During peak construction, daily
                               consultations with residents, led by the PIU safeguard officer, and attended by the
                               construction supervision companies and contractors, shall be conducted.
                               high vibration activities, such as compaction operations will be prohibited at night from
                               18.00 to 08.00; (ii) communities will be consulted prior to large earthworks to ensure
                               they are informed, and, to avoid sensitive timing e.g. exams at nearby schools or
                               festivals. Vibration impacts are not considered a key risk due to the relatively limited
                               scope of works
Hydrology     Impact of      • Ventilated improved toilets (VIPs) will be established at all works sites. These will be   Contractor,   PIU, Capacity
and/or        works on water located at least 200 m from the nearest river, stream channel, or wetland. The VIP           EMA           Development
surface water quality and/or   toilets will meet Mongolia’s Law on Hygiene and relevant Mongolian National Standard                     consulting firm
pollution     hydrology of     (MNS) requirements. VIP toilets are safer and provide better management of sewage
              project rivers   compared to simple, unimproved pit latrines, which will not be permitted. For all project
                               works less than 200 m from waterways, portable toilets will be provided. These will be
                                                                                                                                                           14
Potential
Item   impacts /    Mitigation measures                                                                             Implement   Supervise   Status
       issues
                     regularly emptied into the VIP toilets.
                   • Construction wastewater will be disposed at least 300 m from waterways.
                   • Drainage channels and geotextile barriers will be established around all machine
                     washdown sites, chemical (e.g. vehicle oils, fuels) and worker camps to capture any
                     pollutant runoff (especially during rainfall) and prevent entry to waterways.
                   • Construction waste (e.g. cement, discarded materials) will be stockpiled and protected
                     from wind and removed regularly. Domestic waste (e.g. food waste from workers) will
                     be confined to bins and regularly transported to landfill.
                   • Maintenance of construction equipment and vehicles will only be conducted off-site, at
                     established service shops, to reduce the risk of accidental release of pollutants to soil
                     and water.
                   • Oil traps will be installed at parking areas. Oil-water separators will be installed for oil
                     containing wastewater, if required.
                   • Storage facilities for fuels, oil, and other hazardous materials will be within secured
                     areas on impermeable surfaces. Storage sites will be contained within bunds and
                     cleanup kits will be installed at each site in the event of leakage.
                   • Contractors’ fuel suppliers will be properly licensed, follow proper protocol for
                     transferring fuel.
                   • For all channel works: strict on-site supervision to ensure compliance with these
                     mitigation measures.
                   • Water quality monitoring for in-channel works: in February and March, the time of the
                     in channel works, virtually all waterbodies will be frozen and no monitoring will be
                     possible. In the event that any river flow is occurring during the channel works, water
                     turbidity will be measured 50 m downstream of the works, at least once a day during
                     the works, by construction supervision personnel, using a simple hand-held Secchi
                     disk or turbidity meter.
                   Additional measures for construction of the rockwall barriers (10 subprojects):
                   • Timing of works. All works will only be conducted in February and March, the time of
                     no or lowest flow. At this time, rivers will dry or frozen, helping to significantly reduce
                     the risk of downstream impacts to water quality, ecology, or settlements;
                   • Strictly demarcated lines of entry and exit from the river channel for all machinery and
                     personnel will be established. This will minimize impacts to adjacent sections of
                     channel and habitats;
                   • Temporary diversion channels will be used where appropriate to maintain continued
                     water flow while works are conducted;
                                                                                                                                             15
Potential
Item   impacts /    Mitigation measures                                                                           Implement   Supervise   Status
       issues
                   • Emergency response procedures will be established to address the risk of accidental
                     spills or leaks from machinery during in-channel works. This will ensure quick cleanup
                     of oils or other materials from the frozen river and soil surfaces;
                   • Temporary silt traps and fences will be placed at the downstream end of all works
                     sections, and along the nearby channel banks, to reduce silt dispersion;
                   • The channel works will be conducted in short, discrete, and strictly controlled sections.
                     Construction supervision personnel will be on-site at all times to oversee operations;
                   • All machinery to enter the channel will be cleaned, and checked for leaks, prior to
                     entry, to minimize the risk of pollutants entering the channels.
                   Additional measures for dredging for Tsul-Ulaan subproject:
                   • Technical requirements and mitigation measures for dredging will be included in the
                     bidding documents and construction contracts.
                   • Timing. Dredging will only occur in February and March when minimum flows are as
                     low as 3.3 m3/s in the source channel.
                   • Dredging will be conducted in discrete sections to minimize disturbance.
                   • After removal from the channel, the top layer of sediment will be transferred to existing
                     cleared land on the channel banks adjacent to the dredge sites, where it will be placed
                     on top of a simple textile layer (to protect the ground) for dewatering and drying. The
                     dredging period coincides with the minimum rainfall period and low earth berms only
                     will be needed to prevent washing away from rainfall.
                   • On-site storage limited. Earth berms or drainage channels will be constructed around
                     the perimeter of the dredge sediment storage and disposal sites to prevent washing
                     away from rainfall. On-site storage will be limited to de-watering; the sediment will then
                     be transported to the re-use sites.
                   • Re-use. The excavated spoil will be re-used in the reformation of the main canal.
                     Transport from the dewatering stockpile to sites on embankment formation will be less
                     than 1 km and within the construction area.
                   • All other measures described above for the rock wall barriers will also be implemented
                     at this site.

                                                                                                                                           16
Potential
 Item           impacts /      Mitigation measures                                                                          Implement    Supervise        Status
                issues
Solid Waste   Solid     waste • Temporary spoil storage sites will be identified, designed, and operated to minimize       Contractor   PIU, Capacity
              generated by      impacts. Spoil sites will be restored after storage activities.                                         Development
              construction    • Spoil will be reused on-site to the maximum extent feasible as fill. Excess spoil that                  consulting firm
              activities and    cannot be used on-site will be transported to the landfills listed in Section IV.C, which
              from workers’     are confirmed to have the capacity to receive the spoil; or, will be provided to other
              camps             construction projects within the soum.
                              • Waste construction material (e.g. residual concrete, asphalt) will be reused or recycled
                                to the extent possible.
                              • Excavated soil will be backfilled onsite.
                              • Littering by workers will be prohibited.
                              • Covered litter bins will be situated at works sites for the collection of food waste and
                                other domestic solid waste.
                              • Construction waste dumpsters will be provided at all construction sites.
                              • Domestic solid waste, and construction waste comprising wood, concrete, plastic, or
                                other non-hazardous materials, will be transported by the contractor the nearest soum
                                landfill. Transport will be in sealed containers to avoid spillage.
                              • Hazardous waste, including waste fuels, oils, vehicle batteries, and other materials,
                                will be managed separately (see below).
                              • There will be no final waste disposal on site.
                              • Contractors will be held responsible for the proper removal and disposal of any
                                significant residual materials, wastes, spoil, that remain on the site after construction.
Hazardous     Inappropriate • A hazardous material handling and disposal protocol that includes spill emergency Contractor,             PIU, Capacity
materials     transportation,   response will be prepared and implemented;                                                IPP           Development
              storage, use    • Storage facilities for fuels, oil, chemicals and other hazardous materials will be within               consulting firm
              and spills        secured areas on impermeable surfaces provided with dikes with a 110% volume, and
                                at least 200 m from drainage structures and important water bodies. A standalone site
                                within the storage facility will be designated for hazardous wastes;
                              • Signs will be placed at chemicals and hazardous materials storage sites to provide
                                information on the type and name of chemicals and hazardous materials (paint,
                                solvent, lubricants);

                                                                                                                                                           17
Potential
 Item         impacts /       Mitigation measures                                                                          Implement     Supervise      Status
              issues
                           • Suppliers of chemicals and hazardous materials must hold proper licenses and follow
                             all relevant protocols and Mongolian regulations and requirements;
                           • For hazardous waste disposal, implement the following actions before works begin:
                             prepare list of hazardous materials and waste to be used or generated from the
                             subproject works; install on-site equipment and worker safety clothing to collect the
                             waste; provide sealed containers on-site to transport the waste; identify the waste
                             disposal site; alert the disposal site in advance before delivering waste materials; and,
                             confirm these procedures with the aimag and soum environment inspectors.
                           • Laboratory chemicals of the Institute for Plant Protection: (i) will be stored in a
                             specified and locked room, with limited access; (ii) handling of the chemicals will be by
                             qualified staff only; (iii) waste chemicals will not be discharged into drains but will be
                             collected in closed containers and stored in the locked chemicals room; and (iv) the
                             full containers will be periodically collected by a certified agency for hazardous waste
                             collection, which will also treat and dispose the liquid waste in accordance with
                             national procedures.
Ecological   Protection of • Construction machinery and construction workers shall be strictly assigned to work           Contractor, PIU, Capacity
values       flora     and   areas and access corridors as part of site planning and without occupying land               Capacity    Development
             fauna           randomly;                                                                                    Development consulting firm
                           • Construction machinery and construction materials will not be placed in naturally            consulting
                             vegetated areas;                                                                             firm, PIU
                           • Construction materials (e.g. brick, stone, sand, cement) shall be transported to the
                             work site in batches to meet demand so that stockpiles do not overflow onto naturally
                             vegetated areas;
                           • After completion of works, cleaning and greening work shall be carried out;
                           • Prior to any works, on-site inspections will be made to check for any terrestrial fauna,
                             especially burrows of Siberian Marmot (which may indicate a breeding population is
                             present). If this species is detected within a work site: (a) clearly demarcate the site;
                             (b) delay, or halt, any works in the vicinity; (c) report the observation to the PIU
                             Environment Safeguard Specialist, who will follow up with the MET and local
                             authorities to ensure protection and relocation of any individuals present. In the event
                             of relocation, any individuals will be captured, relocated, and released nearby, within
                             the same day. No individuals will be kept in captivity or killed;
                           • Immediately inform PIU in case any injured animal is found;
                           • For three subprojects requiring tree removal (Nogoon Khashaa, Sugnuger, Iven Gol),
                             removal will be conducted on an individual basis. There will be no clear-felling,
                                                                                                                                                         18
Potential
Item   impacts /       Mitigation measures                                                                             Implement   Supervise   Status
       issues
                        bulldozing, or burning of vegetation. To minimize damage to the bankside or channel:
                        (a) prior to removal, each tree will be numbered and marked. An inventory will be
                        established and every tree removed will be documented, including non-target trees
                        damaged or removed by accident; (b) a clear route for workers to access the tree and
                        remove, will be delineated; (c) upon removal, the tree will be cut into branches and
                        made available locally for fuel; (d) for each tree cut, at least 10 trees will be planted,
                        using only native species of local provenance; and (e) the new trees will be planted as
                        close as possible to the sites of the original trees;
                   •    All planting activities under the project, including rehabilitation of construction sites,
                        will: (a) only use plant species which are native (i.e. naturally occurring) to the project
                        sites and sourced from local stock (i.e. local provenance); (b) will be monitored by the
                        contractors and/or government to ensure a survival rate of at least 70% until at least
                        the end of the first year of operation; (c) to avoid soil and water pollution, no pesticides
                        and no top-dressing fertilizers will be used for any of the re-vegetation, planting, or
                        landscaping activities under the project;
                   •    For the subprojects requiring the construction of rockwalls and weirs: (a) construction
                        will be scheduled for the 2 month period when the river or anabranch is lowest or not
                        flowing; (b) unstabilized sediments will be stopped from transport downstream by the
                        erection of geotextile barriers on the downstream side of construction; and (c)
                        disturbance of bank vegetation minimized by the clear identification and control of
                        construction access ways;
                   •    Strictly prohibit the hunting, killing, consumption, and/or trade of native flora and fauna
                        (including native rodents) by all staff;
                   •    For all works adjacent to vegetation, prior to construction, demarcate vegetation e.g.
                        vegetated roadsides, trees, riverbanks;
                   •    As far as possible avoid clearance of any vegetation;
                   •    Pre-inspection of trees to be removed, to ensure no nesting fauna are present;
                   •    Soil stabilization after tree removal, to avoid local erosion;
                   •    If local communities or residents are not interested in obtaining the cut trees, transport
                        cut vegetation to approved waste landfill within 2 days;
                   •    Conduct offset planting to replace the trees removed, at a ratio of 1:10, as close as
                        possible to the affected site
                   •    Use only native plant species of local provenance (i.e. sourced locally) for all
                        revegetation;
                   •    Maintain the planted seedlings until the start of project operation and then hand over

                                                                                                                                                19
Potential
 Item        impacts /      Mitigation measures                                                                          Implement    Supervise       Status
             issues
                             responsibility for maintenance to the soum government;
                           • Maintain strict speed limits (maximum 50 km/h) for work vehicles;
                           • Restrict construction activity and project vehicle activity between 18.00 and 06.00 to
                             minimize the risk of collisions with fauna at night;
                           • To reduce the risk of spreading weeds, pest animals, and/or soil-based organisms, the
                             project will allow only use of native plant species;
                           • All re-vegetation activities under the project, including for the rehabilitation of
                             construction sites, and for landscaping, will be subject to operation and maintenance
                             procedures after planting, to ensure the planted vegetation is adequately protected
                             and maintained;
                           • To avoid soil and water pollution, no pesticides and no top-dressing fertilizers will be
                             used for any of the re-vegetation, planting, or landscaping activities under the project;
                           • For the 10 subprojects with rockfill barriers and weirs, ensure that the weirs are
                             constructed strictly in accordance with the detailed designs, in order to maintain as
                             natural river flow as possible;
                           • Ensure that in years when the water level flows below the lowest level of the weir,
                             and/or during fish migration, the sluice gate adjacent to the weir (this gate extends
                             almost to the river bed) is fully open, enabling fish passage;
                           • Inform all construction workers that hunting and collection of any natural resources is
                             strictly prohibited.
                           • Okhindin Tal subproject: works will not proceed until an ecological assessment of
                             biodiversity values and potential impacts of the subproject has been completed.
                           • Subproject scope and/or components may need to be revised

Socio-      Protection of • Implement the following chance-find procedure at all sites, if an artefact is found:     Contractor       PIU, Capacity
economic    physical      • Stop works immediately; notify soum government, park administration, PIU, Ministry of                    Development
resources   cultural        Education, Culture and Science; isolate site; document and photograph it; await specific                 consulting
            resources and instructions from Ministry of Education, Culture and Science on how to manage the site                     firm, Ministry
            sacred areas    and for approval to proceed with works                                                                   of Education,
                                                                                                                                     Culture and
                                                                                                                                     Science

                                                                                                                                                       20
Potential
Item     impacts /         Mitigation measures                                                                     Implement     Supervise       Status
         issues
       Community          • Information disclosure. Villagers, residents and businesses will be informed in advance Contractor   PIU, Capacity
       health and           through community consultations, media, and information boards of the construction                   Development
       safety; and          activities, dates, duration, an locations of expected disruption;                                    consulting
       potential          • Prior to works, re-confirm the planned construction schedule and site EMP actions;                   firm
       interruptions to   • Install signs at construction sites informing people of the project GRM, potential dangers
       power supply         (e.g. moving vehicles, hazardous materials, excavations) and safety issues;
       or other public    • Implement the following traffic management procedures, to minimize disturbance to
       services             local communities:
                             (i)    Select routes to reduce disturbance;
                             (ii) Post billboards about road/lane closure, traffic rerouting plan at strategic places,
                             at least 1 week prior to works;
                             (iii) Install speed limit signs and ensure all project vehicles drive at maximum speed
                             of 40 km/hour through resident areas
                             (ii) Post traffic (flag) persons during entire working hours, especially at crossings;
                             (iii) Spread out the schedule for materials delivery in non-peak hours;
                             (iv) Efficient management of truck arrival/ departure;
                             (v) For any sections of public road that needed to be temporarily closed, reopen to
                             the public as soon as possible.
                          • In case of accidental interruption, immediately inform affected communities and assist
                            with water supply until the issue is resolved;
                          • Heavy machinery will not be used at night;
                          • All sites will be secured from unauthorized public access.
                          • Public consultations on work phasing and schedules, anticipated access blocking,
                            provisions for safe access for blocked properties and temporary parking for blocked
                            garages/driveways;
                          • Provision of safe access, if needed, to blocked properties, e.g., steel planks of
                            adequate grade, width and length, and if necessary, with guide rail;
                          • For power utilities, coordinate with soum governments and power substations as
                            needed and establish contact arrangements and procedures in case of accidental
                            damage to power lines.
                            In case of accidental interruption, immediately inform affected communities and assist
                            with water supply until the issue is resolved.

                                                                                                                                                  21
Potential
 Item        impacts /      Mitigation measures                                                                              Implement    Supervise       Status
             issues
            Occupational   • Ensure clean and sufficient supply of fresh water for construction sites, camps, offices;       Contractor   PIU, Capacity
            health and     • Install sufficient latrines and garbage collection facilities at construction sites and work                 Development
            safety           camps; and ensure regular emptying of latrines and garbage facilities;                                       consulting
                           • Nominate at least two on-site staff as safety coordinators;                                                  firm
                           • Provide safety clothing to workers as needed (e.g. boots, helmets, gloves, goggles, ear
                             protection) in accordance with health and safety regulations;
                           • Designate a first aid station (e.g. one of the office rooms) at all work sites and install a
                             first-aid kit. Ensure these are maintained and stocked;
                           • Identify the nearest clinics and hospitals and the fastest transport route to these;
                           • Install a map at each work site providing the transport route to the nearest clinic and
                             hospital, and, their contact details;
                           • Inform the clinic and/or hospital of the pending works and types of activities involved,
                             and exchange details of key contact personnel;
                           • Establish a records management system for occupational accidents, diseases,
                             incidents. The records will be reviewed during compliance monitoring and audits;
                           • Safety communication. Ensure that occupational health and safety matters are given a
                             high degree of publicity to all persons on-site. Display posters prominently;
                           • Training, awareness and competence. Train all workers in basic sanitation, health and
                             safety matters, and work hazards. Implement awareness and prevention program for
                             HIV/AIDS and other diseases – target the local community and construction workers;
                           • Core labor standards will be implemented. Civil works contracts will stipulate priorities
                             to: (i) employ local people for works; (ii) ensure equal opportunities for women and
                             men; (iii) pay equal wages for work of equal value and pay women’s wages directly to
                             them; and (iv) not employ child or forced labor;
                             CONTRACTOR PERFORMANCE TARGET: Camps clean, emergency response plans
                             in place, and 100% of workers aware of emergency response procedures.
            Community      • Hold meetings with residents at construction sites prior to the start of any works;            Contractor, MET
            consultation   • Document community feedback and solutions to any concerns raised;                              Capacity
                           • Update contractor site plans as needed to incorporate the solutions, including revisions       Development
                             in work schedules, daily working hours, construction methods, and/or mitigation                consulting
                             methods;                                                                                       firm, PIU
                           • Revise monitoring schedules and criteria as needed to reflect the updated contractor
                             site management plans.
C. OPERATION PHASE

                                                                                                                                                           22
Potential
 Item        impacts /             Mitigation measures                                                                         Implement     Supervise    Status
             issues
Operation   Routine            •   Conduct capacity building of project agencies responsible for O&M of project facilities;   Soum          MOFALI,
and         maintenance        •   Prepare O&M procedures for each project-funded facility;                                   government    soum and
maintenance and repair         •   Integrate O&M maintenance activities into existing work program of the agencies;                         aimag
                               •   Ensure all preparations for timely handover of facilities from the contractors to the                    government,
                                   agencies are ready at least 2 months before expiry of the Defect Liability period                        LASI
Water          Unsustainable • There will be no use of groundwater extraction for any subproject.                             Hydrology     MET,
availability   abstraction   • For all subprojects, the water allocation extraction volumes calculated for each irrigation    Center of     MOFALI, PSC
and            from rivers     scheme, and the environmental flow volumes, will be distributed to all relevant soum           Soum
sustainability                 agencies and will be strictly followed. The allocation volumes are given in Appendix 5 of      government,
                               the EIA.                                                                                       RBA – gate
                                                                                                                              operations
                               • The soum government will undertake monthly readings of water extraction at the water
                                 intake of each subproject to ensure that the allocation volumes are not exceeded, and
                                 therefore that environmental flow requirements are maintained. This information will be
                                 included in the semi-annual environment progress reports to ADB.
                               • The water extraction volumes for each subproject will be reviewed once per year by the
                                 River Basin Administration. In the event that environmental flow requirements are not
                                 being met, the soum government and PIU will immediately discuss this with the aimag
                                 government, River Basin Administration, and MOFALI and will inform ADB. Corrective
                                 time-based actions will be developed. If needed, active operation of the subproject
                                 intake gates (and sluice gates) will be undertaken during low water availability to ensure
                                 environmental flow allocations are complied with.
                               • If needed, active operation of the subproject intake gates will be undertaken during low
                                 water availability to ensure environmental flow allocations are complied with.

                                                                                                                                                           23
Potential
 Item         impacts /         Mitigation measures                                                                          Implement     Supervise   Status
              issues
Ecology     Protection of • Water supply during years of lowest flows. Gates will be installed on each of the 10            Operators of
            ecological          subproject weirs to ensure that in years of low flow when the weir blocks flow, the gate facilities, soum
            values              can be opened to ensure compliance with environmental flow requirements and                 government,
                                downstream uses                                                                             RBA,
                              • Maintaining fish passage above and below weirs. The weirs are designed to be
                                passable in all but the low flowest years; and in these, gates will be opened manually
                              • Fundamental and permanent change in the character of the landscape: for at least 3
                                subprojects the weirs represent the first in-channel structures and first modification
                                (albeit limited) of flows. Community consultations confirmed local support for the project.
                                Consultations will be continued throughout operations and including prior to any works
                              • Okhindiin Tal subproject. Pending the results of the ecology survey (see Pre-
                                Construction Phase mitigation measures), the design and mitigation measures
                                endorsed by the Government and ADB for this subproject will be implemented. These
                                may include the preparation and implementation of a biodiversity action plan, allocation
                                of resources
                                or community conservation activities, exclusion of sites from any works to protect
                                ecological values, and site-specific operational measures
Non-point   Pollution of soil • Project designs are intended to minimize the use of chemicals – farmer training, drip       Farmers,      MOFALI,
source      and/or water irrigation, and conversion from chemical to organic fertilizers;                                   Soum          MET, LASI
pollution   from              • No pesticides or other chemicals classified as “hazardous” or restricted-use by WHO or government,
            agricultural        the government will be used for the project. This includes omethoate and                    PIU, MET
            chemicals           methamidophos (pesticides) and bromadolion (a rodenticide)
                              • Use of chemical fertilizers and pesticides by the project farmers will be routinely
                                checked by PIU Environment Safeguard Specialist (during the project) and soum
                                government agriculture technical officers (during and after the project);
                              • As part of the project training, farmers will be requested to immediately inform the PIU
                                and soum governments in the event of a disease outbreak and/or that farmers wish to,
                                or are using, agricultural chemicals;

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