E4479 Tajikistan Ministry of Agriculture TAJIKISTAN AGRICULTURE COMMERCIALIZATION PROJECT Environmental Management Framework Dushanbe, March 4, 2014 1 Content Executive Summary 4 Introduction 6 1. National Environmental Assessment Policy and Regulatory Framework 6 2. Country’s Environmental Management Institutional System 6 3. World Bank Environmental Assessment requirements 12 4. The comparison of National and WB EA requirements 17 5. Project description 19 6. Analysis of Potential Environmental Impacts 20 7. Environmental Guidelines 24 8. Environmental monitoring and reporting 29 9. Sub-projects’ Environmental Assessment Disclosure and Consultation 30 10. Pest Management and mineral fertilizers usage issues 30 11. Institutional Arrangements for Environmental Management Framework implementation 35 12. Capacity Building 36 13. Budget 36 13. Environmental Management Framework’s Disclosure and Consultation 38 Annexes 39 Annex A. Environmental Screening Checklist 40 Annex B. Content of the Environmental Management Plan 59 Annex C. Impacts, Causes, Consequences and Mitigation measures for subprojects in Agricultural Production Sector 65 Annex D. Impacts, Causes, Consequences and Mitigation measures for subprojects in Agro-processing & Food production Sectors 90 Annex E. List of registered pesticides in Tajikistan 104 Annex F. Recommended structure of a Pest Management Plan 106 Annex G. Report on Consultation on the Draft Environmental Management Framework with interested parties 108 2 Acronyms ADB Asian Development Bank ATC Agricultural Training Center CAWMP Community Agriculture and Watershed Management Project CEP Committee for environmental Protection under the Government of Tajikistan CPS Country Partnership Strategy DATs Debt Audit Teams DRMU Debt Resolution Management Unit EAP Environmental Action Plan EA Environmental Assessment EMF Environmental Management Framework EMP Environmental Management Plan EIA Environmental Impact Assessment EMMP Environmental Management and Monitoring Plan FFS Farmer Field Schools FIAS Farmer Information Advisory Service FPSP Farm Privatization Support Project GBAO Gorno-Badakhshan Autonomous oblast GDP Gross Domestic Product GOT Government of Tajikistan ICG International Crisis Group IPM Integrated Pest Management JDCs Jamoat Development Committees LRCSP Land Registration and Cadastre System for Sustainable Agriculture Project MAC Maximum Allowable Concentrations MIGA Micro Investment Government Agency MIWR Ministry of Irrigation and Water Resources MOA Ministry of Agriculture MOF Ministry of Finance MOH Ministry of health NGO Non-governmental Organization OP Operational Policy PAU Poverty Assessment Update PIU Project Implementation Unit PMP Pest Management Plan POP Persistent Organic Pollutants RIRP Rural Infrastructure Rehabilitation Project RRS Rayon under Republican Subordination SEE State Ecological Expertise SCLM State Committee of Land Management SPV Special Payment Vehicle UNDP United Nations Development Program WB World Bank WUA Water User Association WHO World Health Organization 3 Executive Summary 1. Project objective. The project development objective is to increase the commercialization of farms and agribusinesses in selected areas of Tajikistan. This will be achieved by improving the performance of selected value chains and providing financial and capacity building services to the project beneficiaries. The direct beneficiaries of the project would include (i) commercially-oriented producer associations and farmers, agro- processors, agri-business enterprises and agro-input dealers engaged in the value chains supported by the project; (ii) participating financial institutions; and (iii) public and academic institutions. 2. Project description. The project consists of 3 Components which will increase the commercialization of agriculture using a coherent and complementary approach, addressing all the main aspects of this effort, by: increasing the capacity of farmers, traders, agri-business and agro-processors to engage in agricultural markets through access to knowledge and technical assistance; improving access to investment finance; and strengthening critical elements of the institutional framework and sector’s academic knowledge base required to support commercial activity. Particular emphasis will be given to strengthening the ability of the new generation of small-scale, private farmers to engage in market activity. Measures to boost private sector activity will be the project focus, but measures to strengthen public capacity will be included where they complement private sector activity. 3. Location. The grant and sub-project locations will be chosen during the implementation phase. The project will be located in rural areas where agricultural potential is high and agriculture is critical for rural livelihoods. While the project will be implemented countrywide, it is expected most of beneficiaries will be from Khatlon, Sugd and the Rayons of Republican Subordination (RRS) 4. Project category. In accordance with the Bank’s safeguard policies and procedures, including OP/BP/GP 4.01 Environmental Assessment, the project category is B. As during appraisal it is not possible to identify which subproject or grant will be financed, it is necessary to prepare an Environmental Management Framework (EMF) which would specify all rules and procedures for the subprojects EA. 5. Purpose of Environmental Management Framework. The purpose of the EMF was to provide the World Bank’s and national rules and procedures for project Environmental Impacts Assessment (EIA), identify potential environmental impacts of the project (both positive and negative), to outline rules and procedure for the sub- projects environmental screening and to specify appropriate preventive actions and mitigation measures (including appropriate monitoring plan) to prevent, eliminate or minimize any anticipated adverse impacts on environment. The EMF was prepared by a local consultant hired by the Client based on the following: (i) analysis of the existing national legal documents, regulations and guidelines; (ii) World Bank safeguard policies, as well as other WB guiding materials; (iii) exisiting EMFs for similar World Bank projects; and (iv) results of consultations with the representatives of stakeholders and all interested parties. 6. EA Institutional capacities to perform environmental safeguards. The evaluation of the EA institutional capacity has shown that national institutions and implementing entities although have basic capacities to perform their duties concerning EA and enforcing the EMF provisions, there is need for additional capacity building activities. In this regard the Project will support additional information dissemination and training activities to ensure the environmental requirements and the EMF provisions would be fully implemented. A special attention will be paid to training of PFIs and PIU which should play a major role in grants and subprojects EA. 7. Potential environmental impacts. The project will support mostly various types of agricultural production and agro-processing subprojects, mentioned in the point 2 above. None of them will cause significant environmental impacts which may fall under the Category A projects and for which a full EIA would be required (it was decided none of category A subprojects will be supported under the proposed new credit line). However, the majority of sub-projects/grants might cause adverse environmental impacts that would fall under the Category B projects in accordance with the Bank OP/BP 4.01 (small scale agro-industries; small scale rehabilitation, 4 maintenance, and upgrading of various premises, storages; animal production; fish farming; plantation of new orchards and/or vineyards, etc), for which the Bank requires a simple and/or a partial Environmental Assessment and/or preparing an Environmental Management Plan. It is also expected that many of supported grants and subprojects will not have environmental impacts and will fall under the Category C (especially those related to purchasing of new agricultural machinery) for which would be required only environmental due diligence procedure. Furthermore, it is expected the selected grants and subprojects will not be located in protected areas, critical habitats or culturally or socially sensitive areas, as well as will not have impacts on international waterways, - this will be ensured during the subprojects screening and EA, excluding them from the project financing. The potential adverse environmental impacts of proposed types of grants and subprojects might be summarized as follows: (a) agricultural production: soil erosion, loss of soil productive capacity, soil compaction, soil pollution, surface and underground water pollution, health and environmental risks associated with agro- chemicals use, loss of biodiversity; (b) agro-processing: contribution to surface water pollution, wastes generation, odor; (c) small scale construction and/or rehabilitation of the existing premises: soil and air pollution; acoustic, construction wastes, and potential asbestos issues, etc. All these impacts are expected to be easily mitigated through good projects design and implementation practices. 9. Potential social impacts. The grants and sub-projects to be implemented under the access to finance component will generate a great number of both direct and indirect positive impacts. Direct positive impacts will be generated by increased production, products and goods which would result in creation of new jobs and respectively, more employment and increased income. Indirect positive impacts will relate to overall improving of business environment, introduction of advanced agricultural technologies and techniques, contribution to poverty reduction and food safety. Potential indirect adverse social impacts can be related to increase water pollution and health risks due to more usage of chemicals in agriculture. A separate social assessment is currently under preparation and aims to identify social issues to be addressed throughout the project implementation. Once finalized the SIA report will be disclosed for all interested parties. 10. Environment Management Framework (EMF). The document outlines environmental assessment procedures and mitigation requirements in line with both national and Bank policies for the grants and subprojects which will be supported by the project. It provides details on procedures, criteria and responsibilities for subprojects preparing, screening, appraisal, implementing and monitoring. The document also includes Environmental Guidelines for different types of proposed subprojects providing analysis of potential impacts and generic mitigation measures to be undertaken for subprojects in agricultural production and agro-processing sectors at all stages - from identification and selection, through the design and implementation phase, to the monitoring and evaluation of results. The EMF includes also a section describing both measures which will be used to ensure compliance with national laws and WB requirements relating to pesticide purchase and use, and measures to promote Integrated Pest Management (IPM) approaches and safe pesticide handling and disposal practices to reduce human and environmental exposure. Additionally the EMF includes a list of eligible pesticides in the country and guidance on their use. The project also will support training, technical assistance and demonstration in support of the IPM program. Lastly, the EMF provides an analysis of the EA institutional capacity of the implementing agencies along with the proposed technical assistance to adequately implement the EA requirements for the grants and subprojects to be supported. 11. EMF disclosure and consultation. The Project Implementation Unit (PIU) has disseminated the draft summary EMF to the Ministry of Agriculture, Committee for Environmental Protection, and other relevant ministries for their review and comments, and also, on February, 18, 2014, the Executive Summary of the document was posted on websites of the Regional Environmental Centre for Central Asia (www.carecnet.org) for its access to wide public. On February 28, 2014, the PIU has organized a consultation on Draft Environmental Management Framework. After the consultation, draft EMF document was revised to consider inputs from consulted parties. The final EMF will be posted on the website of the Ministry of Agriculture and disclosed in the World Bank Infoshop on March 14, 2014. 5 1. Introduction 1. Project Background. The original project development objective is to increase the commercialization of agriculture using a coherent and complementary approach, addressing all the main aspects of this effort, by: increasing the capacity of farmers, traders, agri-business and agro-processors to engage in agricultural markets through access to knowledge and technical assistance; improving access to investment finance; and strengthening critical elements of the institutional framework and sector’s academic knowledge base required to support commercial activity. Particular emphasis will be given to strengthening the ability of the new generation of small-scale, private farmers to engage in market activity. Measures to boost private sector activity will be the project focus, but measures to strengthen public capacity will be included where they complement private sector activity. The project will further the twin goals of the World Bank to reduce poverty and promote shared prosperity. People in rural areas, the major locus of poverty in Tajikistan, will benefit from access to the wider range of farming, business and employment opportunities generated by increased agricultural commercialization, raising incomes and reducing poverty. The rationale for increasing the commercialization of agriculture is also recognized in the comprehensive new Agrarian Reform Program prepared recently by the government and donors as the basis for future reform and investment. Among its priorities, this strategy identifies the need to strengthen agricultural input and output markets and to increase agricultural productivity through improved access to seed, credit and extension services. In line with these strategic objectives, the Government of Tajikistan has requested Bank support for a project to increase commercialization of the sector, strengthen the links between producers and processors, and support producer associations. Thus, the direct beneficiaries of the project would include (i) commercially-oriented producer associations and farmers, agro-processors, agri-business enterprises and agro-input dealers engaged in the value chains supported by the project; (ii) participating financial institutions; and (iii) public and academic institutions. The project will focus on farms with up to 2 ha of arable land per shareholder, with most of beneficiaries expected to be from Khatlon, Sugd and the Rayons of Republican Subordination (RRS). 2. Proposed Project Activities. Project consists of next three components: 1) Component I: TA Support to Commercialization; 2) Access to Finance for Commercial Farms and Agribusinesses; and 3) Component III: Institutional Capacity Building and Project Management. 3. Project Environmental Assessment. In accordance with the Bank’s safeguard policies and procedures, including OP/BP/GP 4.01 Environmental Assessment, the project is classified as Category B for which an Environmental Assessment (EA) with Environmental Management Plan (EMP) is required. As before Appraisal it is not possible to identify which subproject will be financed the appropriate EA instrument is the Environmental Management Framework (EMF) which would specify all rules and procedures for the subprojects Environmental Assessment (EA). The purpose of the EMF is to provide the World Bank’s and national rules and procedures for project Environmental Impacts Assessment (EIA), identify the significant environmental impacts of the project (both positive and negative), to outline rules and procedure for the sub- projects environmental screening and to specify appropriate preventive actions and mitigation measures (including appropriate monitoring scheme) to prevent, eliminate or minimize any anticipated adverse impacts on environment. II. National Environmental Assessment Policy and Regulatory Framework A. Legal framework for environmental protection 4. Overview. Tajikistan has developed during last decade most of the needed environmental laws and regulations (see table 1). Table 1: Selected environment-related legislation 6 Air quality  Law on Air Protection  Law on Hydrometeorological Activity Mineral resources  Law on Mineral Waters  Water Code Land management  Land Code  Law on Land Administration  Law on Land Valuation Forests  Forestry Code Animals and factories  Law on Protection and Use of Animals  Law on Protection and Use of Factories  Law on Factories Quarantine Health and safety  Law on Securing Sanitary and Epidemiological Safety of the Population  Law on Veterinary Medicine  Law on Salt Iodization  Law on Quality and Safety of Food  Law on Industrial Safety of Hazardous Installations  Law on Radiation Safety Waste and chemicals management  Law on Production and Consumption Waste  Law on Production and Safe Handling of Pesticides and Agrochemicals These laws along with the Regulations approved by the GoT create a favorable legal framework for environmental protection in the country as well as for usage and protection of its natural resources. 5. Framework environment law. The “framework environment law”/Law on Environment Protection was adopted in 2011 (21 July, 2011, № 208). The previous Law on Nature protection was adopted in 1993 and amended in 1996, 2002, 2004 and expired in 2011. The Law stipulates that Tajikistan's environmental policy should give priority to environmental actions based on scientifically proven principles to combine economic and other activities that have an impact on the environment with nature preservation and the sustainable use of resources. The Law defines the applicable legal principles, the protected objects, the competencies and roles of the Government, the State Committee for Environment, the local authorities, public organizations and individuals. The Law stipulates also measures to secure public and individual rights to a safe and healthy environment and requires a combined system of ecological expertise and environmental impact assessment of any decision on an activity that could have a negative impact on the environment. The Law also defines environmental emergencies and ecological disasters and prescribes the order of actions in such situations, defines the obligations of officials and enterprises to prevent and eliminate the consequences, as well as the liabilities of the persons or organizations that caused damage to the environment or otherwise violated the Law. The Law establishes several types of controls over compliance with environmental legislation: State control, ministerial control, enterprise control and public control. State control is affected by the Committee for Environment Protection, the Sanitary Inspectorate of the Ministry of Health, the Inspectorate for Industrial Safety and the Mining Inspectorate. Public control is carried out by public organizations or trade unions and can be exercised with respect to any governmental body, enterprise, entity or individual. The Law has also several articles related to agriculture. They regulate, for instance, the use of fertilizers and pesticides, the use of 7 biological and chemical substances and protection against such contamination in food, soil protection and the rational use of land, and protection against pollution from livestock farms. 6. Water Code. The Water Code (2000) stipulates the policies on water management, permitting, dispute resolution, usage planning and cadastre. It promotes rational use and protection of water resources exercised by all beneficiaries and defines the types of water use rights, authority and roles of regional and local governments for water allocations among various users, collection of fees, water use planning, water use rights and dispute resolution. The Code delegates Water User Associations to operate and maintain on-farm irrigation and drainage infrastructure. 7. Land Code. The current Land Code (1992) defines the types of land use rights, the authority and the role of regional and local governments for land allocation, collection of land taxes, land use planning, land use right mortgaging and settlement of land disputes. It defines the rights of land users and lease holders, and also defines the use of a special land fund for the purpose of land privatization and farm restructuring. The law does not provide for purchase or sale of allotted land. The Land Code regulates land relations and it is directed at the rational “use and protection of land and fertility of the soil…1 .” The land may be used in a rational manner only and the Code allows local authorities to decide what constitutes “rational” land use. It includes also mechanisms that make it possible to take the land-use permit away from farmers, including in situations where land use causes land degradation. This decision is taken by the rayon administration. 8. Land Administration (2001). The Law obliges the authorities to map and monitor the quality of land, including soil contamination, erosion and water logging. 9. Regulation of agrochemicals usage. Pesticides and fertilizers handling, use, transportation and storage are regulated by a number of legal documents (see table 2). Table 2. Laws and regulations related to agrochemicals usage in Tajikistan  Law on Environment Protection (2011);  Law on Ecological Expertise (2011);  Law on the Factories Quarantine Law (N5, 12.05.2001), of 2001, revised in 2003.  Law on Production and Safety Implications of Pesticides and Agro-chemicals law dated April 22, 2003.  The Decree on Factory Quarantine (N38, 4.02.2002) concerning creation of the Government Inspection (service) on factories quarantine of 2002. 10. The Law on Environment Protection indicates the necessity of applying the minimum permissible standards of agro-chemicals in agriculture and forestry to ensure compliance with the minimum permissible amounts in food, soil and water. The specially adopted law in the domain (Law on Production and Safety Implications of Pesticides and Agro-chemicals) prohibits use of biologically and environmentally persistent pesticides and products known to be carcinogenic, mutagenic, teratogenic, embryo- and gonad toxic in compliance with the International List of potentially toxic chemicals of the UN Environmental Program. This law also regulates distribution, use, and disposal of pesticides. 11. The Law on Ecological Expertise (2011) and the Resolution on the Establishment of the Commission for Chemical Safety (2003) set up the legal framework for the registration and use of pesticides and other chemicals. These substances and compounds should undergo mandatory State testing in laboratories and production (field) facilities to assess their biological, toxicological and environmental characteristics. If the testing results are positive, the substance or compound must be registered with the Commission for Chemical Safety and included in the List of Chemical Substances and Biological Compounds that are permitted for Use. The Commission 1 Land Code (1992) 8 manages the system of registration, testing and control of pesticides2. It is chaired by a deputy Prime Minister and includes representatives of, among others: the Committee for Environmental Protection, the Ministry of Health and the Ministry of Agriculture. A working group prepares the meetings of the Commission. The Commission approves a list of pesticides upon application from producers or distributors. A new list of chemicals is being prepared. 12. Quarantine3. In 2001, a technical review workshop on Union of Independent Governments (countries of former Soviet Union) and Baltic’s countries published data about quarantine and phytosanitary conditions in the countries of the former Soviet Union. The agreement about coordination in field of factories quarantine for indicated above countries was signed on November 13, 1992 in Moscow. In 1997 during the 6 th Conference countries agreed to accept a unified list of pests to be quarantined, to common quarantine rules for import, export and transit of goods, and provide information data about distribution of pests on countries territory. Not much changed since then. In 2001 Government of Tajikistan enacted a Factories Quarantine Law (N5, 12.05.2001), and in 2002 – a decree on measures on factory quarantine (N38, 4.02.2002) – for Government Inspection (service) on factories quarantine. 13. The qualifying requirements for physical and legal entities of the Republic of Tajikistan operating with application of the pesticides by aerosol and fumigation methods are4:  Application and handling are regulated in terms of the availability of special machinery and equipment for the pesticides application ensuring the safety and quality of chemical treatment;  the availability of special storages for the pesticides complying with the sanitary and epidemiologic rules and norms,  construction norms and rules,  requirements of fire safety;  compliance with environmental requirements,  sanitary and epidemiologic rules and norms,  safety and labor protection; individual protective facilities,  fire extinguishing equipment;  qualified staff with corresponding education and training having experience of practical work on the pesticides application by aerosol and fumigation methods. 14. For storage and disposal, special landfills are used to dispose expired and banned pesticides and their packaging. The state environmental control authority is responsible for issuing the permit to construct the landfills and neutralize the pesticides. Neutralization of the pesticides procured at the expense of the state budget is the responsibility of the MoA and local state authority (local budget). Legal and physical entities the activities of which are linked with the state phytosanitary control objects are obliged to neutralize the pesticides. However in Tajikistan there are only 2 sites formally approved by the Committee for Environmental protection for storage or disposal of unused pesticides or their packaging in Vahksh and Konibodom. 15. International environmental treaties to which Tajikistan is a party. Tajikistan became party to a series of international treaties and in particular:  Rotterdam Convention on Prior Informed Consent (PIC) procedure on September 28, 1998, ratification pending; 2 UN Economic Commission for Europe: Tajikistan Environmental Performance review, 2004 http://www.unece.org/env/epr/studies/Tajikistan/welcome.htm 3 WB Tajikistan Community Agriculture and Watershed Management Project. (CAWMP), Pest Management Plan. 2004. 4 WB Tajikistan Farm Privatization Support Project (FPSP) Integrated Pest Management Plan, 2005 9  Signatory of the Stockholm Convention on Persistent Organic Pollutants on May 21, 2002, ratification pending;  Convention on Biological Diversity on 29 October 1997 and to its Cartagena Protocol on Biosafety on 12 May 2004;  Convention for the Protection of the World Cultural and Natural Heritage (1992);  The United Nations Convention to Combat Desertification (1997);  The United Nations Framework Convention on Climate Change (1998);  The Ramsar Convention (2000); and  The Convention on the Conservation of Migratory Species of Wild Animals (2001). Taking into consideration international treaties have the superiority under the national legislation, mentioned above Conventions constitute also a legal basis in the relevant areas of environmental protection in the country. B. Legal framework for EA, environmental licensing and permitting 16. Basic EA Laws. There are two laws in the country that stipulate all aspects of the EA: (a) Law on Environment Protection; and (b) Law on Ecological Expertise. The Chapter V, Articles 35-39 of the Law on Environment Protection (2011), introduces the concept of state ecological review (literally, state ecological “expertise” – SEE) which seeks to examine the compliance of proposed activities and projects with the requirements of environmental legislation and standards and ecological security of the society. The mentioned laws stipulate the mandatory cross-sectoral nature of SEE, which shall be scientifically justified, comprehensive, and objective and which shall lead to conclusions in accordance with the law. SEE precedes decision-making about activities that may have a negative impact on the environment. Financing of programs and projects is allowed only after a positive SEE finding, or conclusion, has been issued. The following activities and projects subject to state ecological review: a) draft state programs, pre-planning, pre-project, and design documentation for economic development; b) regional and sectoral development programs; c) spatial and urban planning, development, and design; d) environmental programs and projects; e) construction and reconstruction of various types of facilities irrespective of their ownership; f) draft environmental quality standards and other normative, technology, and methodological documentation that regulates economic activities; g) existing enterprises and economic entities, etc. The laws stipulate that all types of economic and other activities shall be implemented in accordance with existing environmental standards and norms and shall have sufficient environmental protection and mitigation measures to prevent and avoid pollution and enhance environmental quality. The EA studies analyzing the short- and long-term environmental, genetic, economic, and demographic impacts and consequences shall be evaluated prior to making decisions on the sitting, construction, or reconstruction of facilities, irrespective of their ownership. If these requirements are violated, construction will be terminated until necessary improvements are made, as prescribed by the Committee for Environmental Protection and/or other duly authorized control bodies, such as sanitary, geological, and public safety agencies. 17. Environmental Impact Assessment. An Environmental Impact Assessment (EIA) study is a component of the State Ecological Expertise, as set out in the 2011 amendments to the Environmental Protection Law and in the Law on the State Ecological Expertise (2011). The EIA is the responsibility of the project proponent. The State Ecological Expertise for all investment projects is the responsibility of the Committee for Environmental Protection under Government of Tajikistan (CEP) and its regional offices. Furthermore, according to the 2011 Law on the State Ecological Expertise, all civil works, including rehabilitation, should be assessed for their environmental impacts and the proposed mitigation measures reviewed and monitored by the CEP. 18. Types of Ecological Expertise. According to the 2011 Law on Ecological Expertise, ecological expertise is intended to prevent negative impacts on the environment as a result of a proposed activity, forecast impacts from activities that are not considered as necessarily damaging to the environment and create databases on the state of the environment and knowledge about human impact on the environment. This Law and the Law on Environment Protection envisage two types of ecological expertise – State ecological expertise and public ecological expertise, which are not given equal importance. While State ecological expertise is a prerequisite for 10 beginning any activity that may have an adverse environmental impact, public ecological expertise becomes binding only after its results have been approved by a State ecological expertise body. The State Ecological Expertise is authorized to invite leading scientists and qualified outside specialists to participate in the review. Approval should be issued within 30 days, unless the project developer agrees to an extension, and remains valid for two years, if the decision is positive. For very complicated projects the term of consideration and approval can be extended till 60 days. According to the Law on SEE the public ecological expertise of economic activities or other activities implementation of which can negatively impact the environment of population which live in relevant area can be carried out by any public organization and citizen. They have right to sent the proposals to the responsible government bodies concerning environmental issues of implementation planned activities; to receive information on results of conducted state ecological expertise from relevant responsible bodies. The materials reflecting the public expertise delivered to the experts’ commissi on should be taken into consideration under preparation of conclusion of state ecological expertise and decision making on realization of expertise object. The public ecological expertise is carried out under the state registration of application of public organization. The registration can be done by local executive authorities (during 7 days) in place where the expertise activities are planned. The public organizations which are organizing this expertise, should inform the population of initiation of expertise and then on its results. 19. Screening categories. The laws on Environment Protection and EE stipulate the Government will approve a list of activities for which the full Environmental Impact Assessment is mandatory. Currently there is no EIA categorization system in place and environmental impacts of most construction activities are reviewed on a case by case basis. According to the existing laws, the Project should not be required to prepare any EIA, however, as soon as the Project is approved, it will be necessary to consult with the CEP experts and receive further guidance on the SEE compliance requirements. 20. EA administrative framework. The Environmental Protection Law states that a SEE should be conducted by the CEP, which is designated as a duly authorized state environmental protection body. It has a comprehensive mandate that includes policy formulation and inspection duties. The CEP has divisions at oblast (region), city and rayon (district) level, in the form of Departments of Environmental Protection (DEPs), within the Hukumat (local administration) at each city or rayon. A small unit in the ministry is entrusted with guiding and managing both EIA and SEE. EIA preparation is the responsibility of the proponents of public- and private-sector projects, who, in addition to complying with various environmental standards, procedures, and norms, shall meet the standards of other sectors and environmental media line agencies, such as sanitary-epidemiological, geological, water, etc. 21. Public participation. Article 12 of the Environment Protection Law proclaims the right of citizens to live in a favorable environment and to be protected from negative environmental impacts. Citizens also have the right to environmental information (Article 13), as well as to participate in developing, adopting, and implementing decisions related to environmental impacts (Article 13). The latter is assured by public discussion of drafts of environmentally important decisions and public ecological reviews. Public representative bodies have an obligation to take into consideration citizens’ comments and suggestions. The Law on the EE also provides the rights to the citizens to conduct a Public Environmental Expertise (art. 7). On 17 July 2001 Tajikistan acceded to the 1998 Aarhus Convention, the provisions of which have priority over domestic law that also stipulates the rights for Public EE. 22. Licenses. Licenses are legal instruments to regulate certain potentially hazardous activities where minimal qualifications and strict adherence to rules are required to ensure that they are carried out efficiently, safely and do not result in potentially very significant and irreparable damage to the environment and human health5. In particular, licenses are required for handling hazardous waste; for activities in industrial safety, sources of ionizing radiation, production and handling of pesticides and other agrochemicals. They are issued by the 5 United Nations Economic Commission for Europe: Environmental Performance Review of Tajikistan. Review, 2012 (see: www.unece.org/index.php?id=31560) 11 relevant industry regulator (ministry or committee) or an entity to which it has delegated such right. Licensing is also used to ensure the most efficient and sustainable use of natural resources. For example, licenses are required for prospecting, collecting or extracting mineral resources, or for constructing underground facilities not related to mining. 23. Environmental permits. Permits are meant to ensure the sustainable use of natural resources. There are two types of permits: (a) permits to use natural resources; and, (b) permits for emissions or discharges. The natural resources use permits allow their holders to take a certain number or amount of a particular natural resource within a defined territory and time period. They are issued both to individuals (e.g. to hunt a particular species of animal or harvest particular factories) and to organizations (e.g. permits to extract ground or surface water for a particular use). By law, permits are needed for any commercial use of any resource. The authority that issues the permit and the legislation (government resolution) that applies depend on the resource. Permits to discharge polluted matter are issued by the relevant inspectorate departments of CEP (e.g. Water Department (Inspectorate) or Air Department (Inspectorate) of the Committee’s local environmental protection departments to industrial or agricultural enterprises and municipal utilities that release by-products into the environment. The permits allow releasing a certain amount of polluted matter (gases, liquids, solid waste) into the environment. The permits are normally granted for one year and indicate the maximum allowed concentration of the pollutants in the released matter, the maximum volume of the polluted matter and the pollutants allowed. 24. Environmental norms and standards. Norms are set for air and water pollution, noise, vibration, magnetic fields and other physical factors, as well as residual traces of chemicals and biologically harmful microbes in food. The exceeding of their thresholds results in administrative action, including financial sanctions. Several ministries determine environmental quality standards, each in its field of responsibility. For example, admissible levels of noise, vibration, magnetic fields and other physical factors have been set by the Ministry of Health. 25. Implementation and compliance. A number of legal acts establish liability for violations of environmental laws, which can be enforced by several State bodies. In particular, the 2010 Code of Administrative Violations establishes administrative liability for organizations, their officers and individuals for a range of violations, from the careless treatment of land to violation of the rules for water use or water protection or failure to comply with a State ecological expertise. The administrative sanctions for environment related violations can be imposed by the administrative commissions of hukumats, courts, the CEP’s inspectors, the Veterinary Inspectors of the Ministry of Agriculture, and the State Committee for Land Management and Geodezy. The most common administrative sanction is a fine of up to 10 minimal monthly salaries for individuals and up to 15 minimal salaries to officers of organizations. The 1998 Criminal Code covers crimes against ecological safety and the environment, such as violations of ecological safety at work, poaching, and spoiling land, violation of rules for the protection and use of underground resources. The maximum fine is up to 2,000 minimal monthly salaries and the maximum sentence is up to eight years in prison. III. World Bank Environmental Assessment Requirements 26. Overview. The Bank undertakes environmental screening of each proposed project for which it will provide funding in order to determine the appropriate extent and type of environmental assessments (EA). The Bank classifies a proposed project into one of four categories, depending on the type, location, sensitivity and scale of the project and the nature and magnitude of its potential environmental impacts. The four EA Categories are A, B, C, and FI. Category FI is applied to all proposed projects that involve investment of Bank funds through a participating financial intermediary (PFI) to be used for sub-projects of which the environmental impacts cannot be determined during appraisal of the World Bank project. 27. World Bank’s Safeguard Policies and their relevance to project. There are key 10 Environmental and Social World Bank Safeguard Policies which are intended to ensure that potentially adverse environmental and social consequences of projects financed by Bank are identified, minimized and mitigated. World Bank Safeguard Policies have a three-part format: Operational Policies (OP) - statement of policy objectives and operational principles including the roles and obligations of the Borrower and the Bank, Bank Procedures (BP) - mandatory 12 procedures to be followed by the Borrower and the Bank, and Good Practice (GP) - non-mandatory advisory material. World Bank’s Safeguard Policies and their relevance to sub-projects to be funded under the Competiveness Enhancement Project’s New Credit Line Component are indicated in the Table 3 below. Table 3. World Bank’s Safeguard Policies and their relevance to sub-project Safeguard Policies Relevance Environmental Assessment (OP/BP 4.01) Yes. (refer to the description below) This Policy aims to ensure that projects proposed for Bank financing are environmentally and socially sound and sustainable; to inform decision makers of the nature of environmental and social risks; To increase transparency and participation of stakeholders in the decision-making process Natural Habitats (OP/BP 4.04) Not triggered by the project as there will be no This Policy aims to safeguard natural habitats and important wildlife and wildlife habitats in the vicinity their biodiversity; avoid significant conversion or of the projects activities. The project would support degradation of critical natural habitats, and to investments only in the settlements or on existing ensure sustainability of services and products which agricultural lands. The EMF provides guidance and natural habitats provide to human society criteria for grants and subprojects screening on this OP and all those which might trigger the policy will be excluded from the project financing. Forestry (OP/BP 4.36) No. (no sub projects that might trigger this policy will This Policy is to ensure that forests are managed in be supported – no commercial wood harvesting a sustainable manner; significant areas of forest are subprojects or those which might affect the status of not encroached upon; the rights of communities to forests) use their traditional forest areas in a sustainable manner are not compromised Pest Management (OP 4.09). This policy is to This OP 4.09 is triggered as the project may finance ensure pest management activities follow an purchasing of pesticides and proposed project activities Integrated Pest Management (IPM) approach, to and/or lead to their increased usage. The EMF includes minimize environmental and health hazards due to a section describing both measures which will be used pesticide use, and to contribute to developing to ensure compliance with national laws and WB national capacity to implement IPM, and to regulate requirements relating to pesticide purchase and use, and and monitor the distribution and use of pesticides also measures to promote Integrated Pest Management (IPM) approaches and safe pesticide handling and disposal practices to reduce human and environmental exposure. Additionally the EMF will include a list of eligible pesticides in the country and guidance on their use. Physical Cultural Resources (OP/BP 4.11) No. (as the project will be implemented on agricultural This policy is to ensure that: Physical Cultural lands there will be no physical cultural resources in Resources (PCR) are identified and protected in their vicinity) World Bank financed projects; national laws governing the protection of physical cultural property are complied with; PCR includes archaeological and historical sites, historic urban areas, sacred sites, graveyards, burial sites, unique natural values; implemented as an element of the Environmental Assessment 13 Indigenous Peoples (OP/BP 4.10) No. (this Policy is not applicable for Tajikistan). IP – distinct, vulnerable, social and cultural group attached to geographically distinct habitats or historical territories, with separate culture than the project area, and usually different language. The Policy aims to foster full respect for human rights, economies, and cultures of IP, and to avoid adverse effects on IP during the project development. Involuntary Resettlement (OP/BP 4.12) No. Under Component 2 the project will provide This policy aims to minimize displacement; treat finance credit lines for medium-term investment resettlement as a development program; provide loans/leases, support to value chains through PFIs, and affected people with opportunities for participation; commercialization grants. The credit line may be used assist displaced persons in their efforts to improve to finance investments in technological plants, their incomes and standards of living, or at least to equipment, expansion of orchards, and greenhouses. restore them; assist displaced people regardless of However, these activities will take place on privately legality of tenure; pay compensation for affected held land. The project will not finance activities that assets at replacement cost; the OP Annexes include result in the involuntary taking of land resulting in (i) descriptions of Resettlement relocation or loss of shelter; (ii) loss of assets or access Plans and Resettlement Policy Frameworks to assets; (iii) loss of income or means of livelihood whether or not there is physical displacement. In addition, the project will not finance activities which will result in the involuntary restriction of access to legally designated parks and protected areas. The project will only finance sub-projects where the Sub- borrower has a title to the land and the land is not being used or occupied by any third party. An Environmental Management Plan (EMP) checklist which will be part of operational procedures for the PFIs will be used to screen out projects with OP 4.12 impacts. Safety of Dams (OP/BP 4.37) No. (the project will not support any activities which This Policy is to ensure due consideration is given might have impact on dams safety) to the safety of dams in projects involving construction of new dams, or that may be affected by the safety or performance of an existing dam or dams under construction; important considerations are dam height & reservoir capacity Projects on International Waterways (OP/BP 7.50) No. (the project not finance any subprojects which may The Policy aims to ensure that projects will neitheraffect international waterways including: irrigation affect the efficient utilization and protection of projects; projects involving discharging waste waters international waterways, nor adversely affect directly in the international waterways; abstraction or relations between the Bank and its Borrowers and diversion of international waters; projects related to between riparian states discharging waste materials in a location that could impact on international waters; construction of any dams that might affect international waters hydrological regime). These requirements represent screening criteria to be applied by the FIs. Disputed Areas (OP/BP 7.60) No. (the project will not support any activities in The Bank may support a project in a disputed area disputed areas) if governments concerned agree that, pending the settlement of the dispute, the project proposed for one country should go forward without prejudice to the claims of the other country 14 Disclosure Policy (BP 17.50) supports decision Yes. (the EMF have been disclosed and consulted in the making by the borrower and Bank by allowing the country before appraisal and will be also disclosed in public access to information on environmental and the WB Infoshop) social aspects of projects and has specific requirements for disclosure 28. World Bank Screening Categories and Environmental Assessment Procedures. Environmental Screening is a Mandatory Procedure for the Environmental Assessment 4.01 OP/BP. The Bank undertakes environmental screening of each proposed project for which it will provide funding in order to determine the appropriate extent and type of the Environmental Assessment to be conducted. The Bank classifies a proposed project into one of four categories, depending on the type, location, sensitivity and scale of the project and the nature and magnitude of its potential environmental impacts6. These four Categories are A, B, C, and FI. Category A projects is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may be sensitive, irreversible, and diverse, with attributes such direct pollutant discharges large enough to cause degradation of air, water, or soil; large-scale physical disturbances of the site and/or surroundings; extraction, consumption, or conversion of substantial amounts of forest and other natural resources; measurable modifications of hydrological cycles; hazardous materials in more than incidental quantities; and involuntary displacement of people and other significant social disturbances. The impacts are likely to be comprehensive, broad, sector-wide, or precedent-setting. Impacts generally result from a major component of the project and affect the area as a whole or an entire sector. They may affect an area broader than the sites or facilities subject to physical works. The EA for a Category A project examines the project's potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the "without project" scenario), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. For a Category A project, the borrower is responsible for preparing a report, normally a full Environmental Impact Assessment (or a suitably comprehensive regional or sectoral EA). Category B projects has potential adverse environmental impacts on human populations or environmentally important areas - including wetlands, forests, grasslands, and other natural habitats - which are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigation measures can be designed more readily than for Category A projects. The scope of EA for a Category B project may vary from project to project, but it is narrower than that of Category A assessment. Like Category A, a Category B environmental assessment examines the project's potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. The findings and results of EA for Category B projects are described in the Project Appraisal Document. Category C. An EIA or environmental analysis is normally not required for Category C projects because the project is unlikely to have adverse impacts; normally, they have negligible or minimal direct disturbances on the physical setting. Professional judgment finds the project to have negligible, insignificant, or minimal environmental impacts. Beyond screening, no further EA action is required. Category FI. A Category FI project involves investment of Bank funds through a financial intermediary, in subprojects that may result in adverse environmental impacts. The Bank reviews the findings and recommendations of the EA to determine whether they provide an adequate basis for processing the project for Bank financing. When the borrower has completed or partially completed EA work prior to the Bank's involvement in a project, the Bank reviews the EA to ensure its consistency with 6 See: Environmental Assessment Update Sourcebook, Environmental Department April 1993. The World Bank 15 this policy. The Bank may, if appropriate, require additional EA work, including public consultation and disclosure. General examples of projects that fall under Categories A, B, and C are provided in the Table 4 below. However, this list is just a good starting point and framework for the screening decision. Because of other factors involved such as project sitting, the nature of impacts, and the need for the EA process to be flexible enough to accommodate them, the lists should not be used as the sole basis for screening. Table 4. Types of projects under the World Bank’s Categories A, B, and C Category A Projects Category B Projects Category C Projects (projects/project components (projects/project components which (projects which are unlikely to which may have diverse and may have diverse and significant have direct adverse impacts – no significant impacts – normally impacts – more limited EIA is required) require a full EIA) environmental assessment is appropriate)  Dams and reservoirs;   Agro-industries (small scale); Family planning;   Forestry production projects; Electrical; transmission;  Nutrition;   Irrigation, drainage and flood  Irrigation and drainage (small Institutional development; control (large scale); scale);  Technical assistance;  Industrial plants (large  Renewable energy;  Most human resource scale*) and industrial estates,  Rural electrification; projects including major expansion,  Tourism; rehabilitation, or modification;  Rural water supply and  Aquaculture and mariculture sanitation; (large scale);  Watershed projects  Land clearance and leveling; (management or rehabilitation);  Mineral development  Rehabilitation, maintenance,  Port and harbor development; and upgrading projects (small-  Reclamation and new land scale); development;  Protected areas and  Resettlement and all projects biodiversity conservation; with potentially major impacts on Rehabilitation or modification people; of existing industrial facilities  River basin development; (small scale);  Thermal and hydropower  Rehabilitation of highways or development; rural roads;  Manufacture, transportation, Energy efficiency and energy and use of pesticides or other conservation hazardous and/or toxic materials Note: *Large scale here is defined as enterprises with annual sales of US$ 3 million or more equivalent 29. Screening criteria. The selection of the category should be based on professional judgment and information available at the time of project identification. If the project is modified or new information becomes available, Bank EA policy permits to reclassify a project. For example, a Category B project might become Category A if new information reveals that it may have diverse and significant environmental impacts when they were originally thought to be limited to one aspect of the environment. Conversely, a Category A project might be reclassified as B if a component with significant impacts is dropped or altered. The option to reclassify projects relieves some of the pressure to make the initial decision the correct and final one. Projects in Category B often differ from A projects of the same type only in scale. In fact, large irrigation and drainage projects are usually Category A, however, small-scale projects of the same type may fall into Category 16 B, the same relates to aquaculture projects and many others. Projects entailing rehabilitation, maintenance or upgrading rather than new construction will usually be in Category B. A project with any of these characteristics may have impacts, but they are less likely to be “significant”. However, each case must be judged on its own merits. Many rehabilitation, maintenance and upgrading projects as well as privatization projects may require attention to existing environmental problems at the site rather than potential new impacts. Therefore, an environmental audit/or environmental due diligence may be more useful than an impact assessment in fulfilling the EA needs for such projects. The selection of a screening category often depends also substantially on the project setting, while the “significance” of potential impacts is partly a function of the natural and socio -cultural surroundings. There are a number of locations which should cause to consider an “A” classification:  in or near sensitive and valuable ecosystems - wetlands, natural areas, habitat of endangered species;  in or near areas with archaeological and/or historical sites or existing cultural and social institutions;  in densely populated areas, where resettlement may be required or potential pollution impacts and other disturbances may significantly affect communities;  in regions subject to heavy development activities or where there are conflicts in natural resource allocation;  along watercourses, in aquifer recharge areas or in reservoir catchments used for potable water supply; and  on lands and in waters containing valuable natural resources (such as fish, minerals, medicinal plants; agricultural soils). The World Bank’s experience has shown that precise identification of the project’s geographical setting at the screening stage greatly enhances the quality of the screening decision and helps focus the EA on the important environmental issues. 30. WB Public Consultation and Disclosure requirements. For all Category A and B projects proposed for WB financing, during the EA process, the borrower consults all involved parties, including project-affected groups and local nongovernmental organizations (NGOs) about the project's environmental aspects and takes their views into account. The borrower initiates such consultations as early as possible. For Category A projects, the borrower consults these groups at least twice: (a) shortly after environmental screening and before the terms of reference for the EA are finalized; and (b) once a draft EA report is prepared. In addition, the borrower consults with such groups throughout project implementation as necessary to address EA-related issues that affect them. For meaningful consultations between the borrower and project-affected groups and local NGOs, the borrower provides relevant material in a timely manner prior to consultation and in a form and language that are understandable and accessible to the groups being consulted. For a Category A project, the borrower provides for the initial consultation a summary of the proposed project's objectives, description, and potential impacts; for consultation after the draft EA report is prepared, the borrower provides a summary of the EA's conclusions. In addition, for a Category A project, the borrower makes the draft EA report available at a public place accessible to project-affected groups and local NGOs. Any Category B EIA report for a project proposed for WB financing is made available to project-affected groups and local NGOs. Public availability in the borrowing country and official receipt by the Bank of Category A reports for projects proposed for WB financing, and of any Category B EA report for projects proposed for WB funding, are prerequisites to Bank appraisal of these projects. IV. The comparison of National and WB EA requirements 31. Overview. While the basic provisions of the National EA rules and procedures are to some extent similar to the WB requirements, there are several important differences. These differences are related primarily to the following: (a) project environmental screening categories; (b) Environmental Management Plan; (c) EA disclosure and public consultation; and (d) EA reviewing process. 32. Differences in screening categories. As mentioned above in the point 19, currently there is no clear EIA categorization system in Tajikistan. The SEE law stipulates all projects with a potential environmental impact should have in the project design an assessment of the potential impacts as well as a set of mitigation measures. 17 Thus, as the project will support agricultural and agro-processing activities which have more or less significant environmental impacts, all of supported subprojects would require environmental assessment and respectively - ecological expertise. The projects which do not require an EA mainly correspond activities which are expected to have minor impacts on environment and therefore do not need to be passed through the formal procedures of EIA and SEE (subprojects that propose purchasing agricultural machinery, - WB Category C projects). The scale of the project EA is decided in each concrete case by the SEE/Ecological Inspectors during the preliminary approval of the project location and of its technical specifications. In the case where World Bank and national categorization/EA requirements differ, the more stringent requirement will apply. This refers mostly in the case of deciding about Category C subprojects - the national EA legislation doesn’t refer to small scale activities, including construction and rehabilitation of various buildings. In these cases the client will apply the WB criteria. 33. Differences concerning EMP. While the national legislation requires for all projects with potential environmental impacts relevant mitigation measures, it does n’t require a special EMP which should specify, along with the proposed mitigation activities a monitoring plan and reporting requirements, institutional arrangements for EMPs implementation as well as doesn’t require needed capacity building activities an d necessary expenses in this regard. Similarly, in the case of Category B grant and subprojects, the beneficiaries will be required to apply WB rules and prepare not a list of mitigation measures but EMPs. 34. Differences concerning reviewing and approval of EA studies. As mentioned above, the national EA reviewing process relates to the SEE, while according the WB requirements is a part of the whole EA process. The SEE seeks to examine the compliance of proposed activities and projects with the requirements of environmental legislation and standards and ecological security of the society. The mentioned laws stipulate the mandatory cross-sectoral nature of SEE, which shall be scientifically justified, comprehensive, and objective and which shall lead to conclusions in accordance with the law. SEE precedes decision-making about activities that may have a negative impact on the environment. Financing of programs and projects is allowed only after a positive SEE finding, or conclusion, has been issued. The SEE is conducted by a special Unit within the SCEPF. In compliance with World Bank policy, all EAs for sub-project financed under the Credit component will go through the more stringent review and approval process of the World Bank 35. Differences with regard to disclosure and public consultation. Conducted analysis shows there is no harmonization between World Bank and national requirements in this regard. According to national legislation, the EA disclosure and public consultation is not mandatory. At the same time, per the SEE law the public might organize at its own initiative a public ecological expertise. Public expertise is being conducting on the basis of NGO’s written request toward local public authority. While organizing such expertise, within seven days, the local public authorities should inform public association about taken decision concerning permission to do so. Public associations conducting ecological expertise are obliged to inform broad local public about beginning of expertise and its results. These associations have the right to obtain planned and project documentation as well as documentation on EIA and get acquainted with normative-technical documentation on conducting of the state ecological expertise. The results of public ecological expertise are delivering to the bodies conducting the state ecological expertise and to the bodies which make decision of implementation of activity – the subject of expertise. The results and conclusion of public ecological expertise have recommendation character and can have the juridical power only after their approval by the responsible state body in field of ecological expertise. The results of public ecological expertise can be published in mass-media, deliver to the local public authority, other stakeholders. In the case of World Bank EA policy, the Sub-borrower is responsible for conducting at least one public consultation for all Category B projects to discuss the issues to be addressed in the EMP or to discuss the draft EMP itself. Therefore, for the Sub-project, the PIU will review any documentation of the public consultation conducted in the preparation of any national EA documentation to determine if it is consistent with the World Bank requirements. If the Tajik public consultation is satisfactory, there would be no further consultation requirement. However, if no public consultation was conducted or the PIU determines that the Tajik public consultation documentation is not adequate, the sub-borrower will be required to perform at least one public consultation to discuss the environmental issues of concern to the locally affected communities and include these issues in the content of the EMP. Documentation for the consultation should be submitted to the 18 PIU as part of the Sub-project file. Tajik/Russian language version of the EMP and the record of the public consultation should be located at in public location near the project site and, if available - on the sub-borrower website. Category B EA sub-project would be made available to project-affected groups and local NGOs in an easily accessible PFI and/or PIU website. V. Project Description 36. Project development objectives and activities. The project development objective is to increase the commercialization of farm and agri-business products in selected areas of Tajikistan, by improving the performance of selected value chains and providing financial and capacity building services to project beneficiaries. The project will increase the commercialization of agricultural products by using a coherent and complementary approach, addressing all the main aspects of this effort, by: increasing the capacity of farmers, traders, agri-business and agro-processors to engage in agricultural markets through access to knowledge and technical assistance; improving access to investment finance; and strengthening critical elements of the institutional framework and sector’s academic knowledge base required to support commercial activity. Particular emphasis will be given to strengthening the ability of the new generation of small-scale, private farmers to engage in market activity. The project will have the following components: Component I: TA Support to Commercialization will support training program to value chain participants. For farmers, the project will support three main types of training : (i) extension services and technological advice, on as needed basis, to farmers on specific subjects of agricultural production and processing; (ii) training activities to all value chain participants, on the benefits of participation in a value chain, and duties and responsibilities of the various participants; and (iii) to very small farmers, to increase their commercialization potential, on the benefits, duties and responsibilities of establishment and participation in productive partnerships. For agro- processors and agri-business enterprises the potential (demand-based) training activities will include: strategies for improving links with producers and producer organizations; strengthening aggregation activities; business management, marketing and quality control; improvements to product quality along the value chain; sources and use of market information; market studies and test marketing, roundtables, attendance at trade fairs and mentoring services to help participants understand market requirements. The support would be provided to agro- processors, agri-business enterprises, agro-input dealers and commercially oriented farmers and producer associations to develop business plans and investment proposals for productive linkages, and guidance on how to finance the necessary investment. Capacity building in the country’s consulting sector, through transfer of global knowledge and good practices, on how to support agribusiness sector development and value chain/productive linkage development activities will ensure that such capacity remains in the country after the project closes. Component II: Access to Finance for Commercial Farms and Agribusinesses will promote to potential investments which include: improved on-farm technology, storage, processing, new products, marketing, quality enhancement and food safety. In frame of this component to address the current market failure to provide medium-term credit for investment, a credit line will be provided to government to support medium-term lending and leasing for investment activities by agro-processors and other agri-businesses involved both in the selected value chains, but also to other credit-worthy agri-businesses. This credit line will be for loans or leases of up to 7 years, for investment in modern technological plant and equipment. Also matching grants will be provided in the following two types of support: (i) to complement the commercial credit line described above and (ii) to provide the start-up capital of the productive partnerships created under Component 1, which target the smaller and poorer farmers, the partnerships will be eligible to receive a matching grant for investment purposes (procurement of small-scale equipment, building of storages, etc.). Given the novelty of the medium-term investment lending and value chain financing concepts, the Project will implement a capacity building program for the financial institutions involved in the Project. The PFIs will receive training in two subjects: (i) Appraisal of agricultural investment loans and leases, (ii) Financial Products for financing of value chains. Management and minimizations of the risks associated with these new products will be part of the training program; and (iii) Conducting subprojects EA. 19 Component III: Institutional Capacity Building and Project Management will strengthen the capacity of public institutions responsible for relevant services and policies; and the capacity of the Ministry of Agriculture to manage this and other donor projects for following aspects: a) Market Information for farmers and agribusinesses; b) Upgrading of the technological skills in the agro-processing sector; c) Support to the policy and regulatory reform for input use and marketing; and d) Project Management. 38. Sub-Projects Coverage and Potential Activities. The project will support various agricultural production, agro-processing activities, and small scale construction/reconstruction of new buildings. The project facilities will not be located in protection areas and critical habitats as well as in cultural heritage areas. Activities not supported by the World Bank will include: tobacco growing/ processing; production and processing of genetically modified organisms (GMOs), use of banned pesticides, use of species provided in Appendix 1 to the Bonn Convention on International Trade in Endangered Species of Wild Fauna and Flora, etc. 39. Implementing arrangements. Responsibility for implementing of the project, including access to finance component will lie with the PFIs and the PIU. The PIU environmental specialist will supervise and monitor issues related to environment requirements. His/her major roles and responsibilities will be to monitor use of the Access to Finance Component, to collate information on the operational activities and specifically to closely monitor the environmental and social covenants of the grants and subsidiary loan agreements. He/she should have environmental background and professional experience, being subordinated to the PIU Chairman. The Environmental Specialist will receive the reporting outputs from the PFIs and will be responsible for producing monthly, quarterly and annual reports for the PIU, and IDA. He/she will be selectively doing all the sub-project screening and ensuring that all EA requirements are met. PFIs from their side also will do all the sub-project screening and ensuring that all EA requirements are met. The details of the institutional arrangements and responsibilities for the EMF implementation are presented below in the section XI of the document. 40. Operational modalities. Detailed operational modalities, rules and regulations for the management of the grants and subprojects EA, together with the detailed instructions and guidance to the PFIs and other stakeholders will be provided in the Financing Guidelines. These guidelines will be part of the revised Project Operational Manual and constitute an integral part of the Subsidiary Credit Agreements to be signed between the Recipient and each of the PFIs. VI. Analysis of potential environmental impacts 41. Important Environmental Components. The environmental components which may be adversely affected by projects at their construction, operation and decommissioning stages generally are grouped as physical, biological and socio-economic ones. Examples of the environmental components which might be of a different levels and attributes are presented in the Table 5 below. Table 5. Environmental Components Physical Components Biological Components Socioeconomic Components  Physical component of  Fauna  Human health ecosystems (habitats)  Flora  Settlements  Air  Vegetation communities/  Cultural heritages  Soil (quality, structure, forests  Employment fertility, erodibility)  Animals’ and plants’  Demography  Land populations (number,  Income  Water resources (surface abundance, distribution, etc.)  Poverty water &, underground water:  Biological component of  Gender quality, availability, hydrological forest, aquatic, meadow,  Education regime); steppe and other ecosystems  Migration 20  Landscape/ Aesthetics, etc. (as a whole), etc.  Micro-organisms, etc 42. Subprojects’ potential impacts. The impacts associated with the different types of grants and sub-projects might be positive and negative. Positive impacts attribute mainly to socio-economic environment. Negative impacts attribute to water, air and soil pollution, additional water and energy consumption (if more goods are produced), noise, odor, health risks, loss of biodiversity and habitats, etc. Measures to be taken to minimize potential negative environmental impacts depend on their type, magnitude, combination and distribution. 43. Subprojects’ potential risks. The sub-projects’ environmental risk is generally evaluated mostly moderate. In most of the cases potential impacts generated by sub-project activities are expected to be easily mitigated through good project design and implementation practices, so the risk from them is expected to be insignificant . Furthermore, the project would support additional TA activities to strengthen the existing institutional capacities to ensure that effective EAs are conducted, EMPs are implemented properly and monitoring systems are put in place. Of particular attention would be those activities resulting in water, soil and air pollution, and soil erosion. Sustainable agricultural techniques which are to be supported through the access to finance component will contribute to better environmental protection. Recommended basic environmental training of both PIU staff and loan officers will also further reduce environmental risks. The project does not entail any direct social risks as its implementation doe not presume any job losses/ relocations. On the contrary, the project will make agricultural and agro-processing activities easier to pursue and will likely increase demand for labor in more competitive enterprises. 44. Potential Positive Impacts. Sub-projects to be implemented under the project activities will generate a great number of both direct and indirect positive impacts. Direct positive impacts will be generated by increased agricultural production and agro-processing activities which would result in higher yields, creation of new jobs and respectively, more employment and increased income. Indirect positive impacts will relate to overall improving of agricultural production and business environment, introduction of advanced agricultural technologies and techniques, enhancement competitiveness of domestic production and products, contribution to poverty reduction and food safety, improvement of country’s socio-economic conditions and others. Some positive direct and indirect impacts/ benefits generated by activities within concerned sectors and direct inputs from loans are presented in the Tables 6 & 7 below. Table 6. Project’s Positive impacts Sector Positive impacts/ Benefits Agriculture: Annual Crop & Plantation Crop Introduction of advances agricultural techniques, use of Production; advanced machinery & equipment, increased crop and plantation crop production, mammalian livestock and poultry production; creating new jobs, contribution to ensuring of food security, contribution to poverty reduction in rural area and generally, to improvement of socio- Meet & Poultry Production economic conditions in rural areas, etc. Agro-processing: Storage, Dairy, Meat and Introduction of new technologies & quality standards at Poultry Processing, Vegetable Oil Processing, Bee enterprises, use of advanced machinery & equipment, keeping, etc. providing additional value to produced agricultural production, providing more food thus ensuring country’s food safely; creating new jobs and increased incomes, contribute to improvement of socio-economic conditions urban and rural areas, etc. Table 7 Positive Impacts generated by direct loan inputs 21 Input Positive Impact Seeds - Agriculture: for Annual Crop & Plantation Increased agricultural production; increased rural income; Crop Production, including orchards and improvement of rural economy; contribution to country’s vineyards food security, etc. Fertilizers - Agriculture: for Annual Crop & Improved soil quality, increased agricultural production; Plantation Crop Production increased rural income; rural economy improved; contribution to country’s food security, etc. Pesticides - Agriculture: for Annual Crop & Increased agricultural production; increased rural income; Plantation Crop Production; Agro-processing: rural economy improved; contribution to country’s food Mammalian Livestock & Poultry Production security, etc. Mammalian Livestock & Poultry Production Fewer animals required for the same production volume; improved quality of production and respective products for markets, including foreign ones; increased farm income; improved rural economic situation, etc. Animals for dairy - Agro-processing: Meet & Improved farm income & rural economic situation; Poultry Processing contribution to country’s food security, etc. Machinery and other equipment – Agriculture, Reduced labor burden for rural employees; improved Agro-processing, farms’ efficiency; increased production volume, improved soil preparation, improved rural economic conditions, etc. In fact, for primary processing equipment the positive impact will be additional value to agricultural production resulting in improved local economic situation through more jobs provided; improved farm income; reduction of n transportation costs and fuel consumption, etc.. Vehicles – all sectors Improved labor efficiency resulting in improved profits Storage facilities – all sectors In fact, for fuel, grain and other products, the positive impact will be: easy fuel and lubricants handling, avoidance of fuel spills, decease of fuel wastage; decrease spoilage of crops and grains resulting in improved economic efficiency and higher farm incomes 45. Potential negative impacts. Negative impacts mainly relate to physical and biological environmental components and are linked to water, air and soil pollution, soil erosion, loss of biodiversity and habitats, health risks, energy and water consumption as well as solid waste management. The major agricultural impacts are related to livestock and poultry production, both on the small farm holding and the large commercial farm. This may result in increased volumes of animal waste, including contaminated by pesticides affecting soil, groundwater (through leach ate from septic tanks) and surface water quality, human health and biodiversity, as well as soil degradation/ compaction due intensive pasturing, loss of agricultural biodiversity, etc. In agro- processing sector the main impacts are related to surface water pollution through increased concentrations of pollutants in wastewater effluents and emissions to air, mostly dust and odor, emissions to air (dust/ particulate matter, often toxic substances), acoustic, vibration, water and energy consumption. During construction/reconstruction activities which may have a relevance to all above sectors, the main negative impacts are generated during construction phase and relate to soil erosion, soil and water pollution through waste generation, air pollution, acoustic and aesthetics and asbestos issues. 46. The most common potential negative impacts from agricultural production, agro-processing activities and construction/rehabilitation of existing buildings activities and their significance are summarized in the Table 8 below. Table 8. Potential negative impacts Enterprise Category Potential Impacts Level of Significance 22 Enterprise Category Potential Impacts Level of Significance Agro-processing:  Water and energy consumption High  Water pollution High  Soil pollution Moderate  Odor High  Air emissions Moderate Agriculture Production  Soil degradation (soil erosion, loss of High productive capacity, compaction, etc.)  Soil pollution (e.g., by pesticides) High  Surface (through runoffs) and High underground (though infiltration) water pollution High  Loss of agricultural biodiversity (due to cattle grazing) High Construction/reconstruction  Soil erosion Moderate  Soil pollution Moderate  Land degradation High  Air pollution Moderate  Acoustic High  Water pollution Moderate  Asbestos High More detailed description of impacts which may arise from each probable activity as per sectors of concerns are presented in the Environmental Guidelines and all these impacts are expected to be easily mitigated through good projects design and implementation practices (see annex C and D). 47. Potential Cumulative Impacts. Cumulative impacts are not likely to be an issue as the Project distributes its loan activities more or less evenly throughout the country. In the agricultural production sector, if there is a concentration of loans for the purchase of a large number of livestock in one particular watershed, without effective waste management, the main river of the watershed could become heavily polluted as a result of a high concentration of livestock. Some activities may require additional water consumption thus contributing to lowering of groundwater table, or contribute to water pollution though additional polluted effluents thus contributing to deterioration of surface water quality and respectively, loss or degradation of aquatic habitats, biodiversity degradation, etc. Pesticide and chemical fertilizer use in agricultural production may have a severe cumulative effect. Enterprises in a single small watershed could cumulatively have a significant effect on surface water bodies, resulting in damaged of aquatic ecosystems and affecting water quality downstream, sometimes in adjacent countries. Similarly, the impact on water quality of a common river used by several processing plants could be significant. The regular analysis of water and soil which routinely is done by analytical laboratories of the State Hydro meteorological Service and of CEP as part of national environmental monitoring will provide the necessary data about the trends in water and soil pollution in the country. Based on this data the MoA PIU will take measures to mitigate and prevent the possible pollution and negative impacts. 48. Residual Impacts. Residual impacts are those that remain after all mitigation has been carried out. Assuming that all mitigation as indicated in the guideline tables are implemented appropriately, the residual effects, even cumulatively on all sub-projects, should not be significant. Expert judgment on expected residual impacts from agricultural production and agro-processing activities within sub-projects implementation once all mitigation measures are taken is presented in Annexes C and D. Summary of probable residual impacts generated by the proposed activities is presented in the Table 9 below. Table 9. Summary of probable residual impacts 23 Activity Probable Residual Impact Significance Agriculture Surface water & underground water pollution, soil pollution, Low-moderate soil erosion Agro-processing Surface and underground water pollution, air pollution Low Construction/rehabilitation Surface water pollution, soil erosion, generation of solid Low of small scale buildings wastes, asbestos 49. Indirect Impacts. Indirect (or secondary) impacts are those arising from activities associated with direct activities implementing within the project implementation. These might be positive and negative social, economic, or environmental impacts of agricultural production, and agro-processing. In fact, in agricultural production and agro-processing sectors may relate to purchase of more goods (e.g., fertilizers and pesticides for agricultural production), more transportation service, more fuel, utilities, labor, etc.). Negative indirect environmental impacts resulted from activities of the supported subprojects have to be considered during the EA process and relevant mitigation has to be suggested. VII. Environmental Guidelines 50. Purpose of Environmental Guidelines. The purpose of the project Environmental Guidelines is to assist the PFI loan officers, PIU staff, sub-borrowers in determining the potential environmental impacts of grants and sub-projects and specific conditions to each of the sub-project loans to ensure that potential impacts are minimized, if not entirely avoided. The Guidelines provide the anticipated sub-project activities and the impacts that they may have on environmental components as well as mitigation measures to be undertaken to minimize or even prevent impacts on environment. In particular, the PFIs, PIU and loan officers will use three sets of tables presented in the Annexes C and D, which will assist them in determining of environmental impacts that can be expected from different types of projects in various sectors. Knowing the impacts to be expected from various types of grants and subprojects, the loan officer as well as the subproject designer/beneficiary can define the mitigation measures required as a condition for the loan. These Guidelines may be also be used for the purpose of environmental monitoring of sub-projects. Since these are only guidelines and the information contained within is generalized, in some instances, the officers would be advised to seek local professional opinion (e.g. CEP, agricultural extension staff, research officers, designers, etc.) for more specific information and advices. 51. Content of Environmental Guidelines. The Environmental Guidelines provide the following: (a) Rules and Procedures for grants and sub-projects environmental screening to be funded under the access to finance component; (b) Environmental Screening Checklists (presented in the Annex A (Forms 1-4), including for existing facilities and EMP Checklist-type for small scale construction/rehabilitation subprojects; (c) Content and format for the Environmental Management Plan to be complied for sub-projects and format for Environmental Monitoring Plan to be follow to achieve environmental protection requirements under the loan (Annex B); as well as, (d) Tables that describe potential environmental impacts that may occur as a result of sub- project activities as well as needed mitigation measures two main sectors: Agricultural Production (Annex C) and Agro-processing (Annex D), which may be financed by the credit. 52. Rules and Procedures for Sub-projects Environmental Screening. Screening of each proposed project for funding is to be undertaken in order to determine the appropriate extent and type of Environmental Assessment as well as which one of World Bank’s Policies will be triggered. The attribution of the project type to WB’s EA category and respectively, environmental risk that might be generated (i.e., high risk – by the Category A projects; from moderate to low risk – by the Category B projects, and from low to no risk - by the Category C projects) is to some extent, an expert judgment. Generally the significance of impacts and the selection of screening category accordingly, depend on the type and scale of the project, the location and sensitivity of environmental issues, and the nature and magnitude of the potential impacts. 24 In terms of type and scale of the projects. Usually the following projects are considered as having “significant” impacts and respectively should be qualified as category A projects: (a) significantly affect human populations or alter environmentally important areas, including wetlands, native forests, grasslands, and other major natural habitats; (b) “significant” potential impacts might be also considered the following: direct pollutant discharges that are large enough to cause degradation of air, water or soil; (c) large-scale physical disturbance of the site and/or surroundings; (c) extraction, consumption, or conversion of substantial amounts of forest and other natural resources; (d) measurable modification of hydrologic cycle; (e) hazardous materials in more than incidental quantities; (f) and involuntary displacement of people and other significant social disturbances. It is expected the supported sub projects will be not related to mentioned above circumstances and respectively will not have significant environmental impacts. In the case such project will be presented for financing, they will be rejected. In terms of location: There are a number of locations which should be considered while deciding to qualify the project as category “A”: (a) in or near sensitive and valuable ecosystems — wetlands, wild lands, and habitat of endangered species; (b) in or near areas with archaeological and/or historical sites or existing cultural and social institutions; (c) in densely populated areas, where resettlement may be required or potential pollution impact and other disturbances may significantly affect communities; (d) in regions subject to heavy development activities or where there are conflicts in natural resource allocation; along watercourses, in aquifer recharge areas or in reservoir catchments used for potable water supply; and on lands or waters containing valuable resources (such as fisheries, minerals, medicinal plants, prime agricultural soils). Similarly as above, the project will not support any projects located in the proximity of mentioned areas. In terms of sensitivity. This is in the case when the project might involve activities or environmental features that are always of particular concern to the Bank as well as to the borrower. These issues may include (but are not limited to): conversion of wetlands, potential adverse effects on protected areas or sites, involuntary resettlement, impacts on international waterways and other transboundary issues, and toxic waste disposal. In terms of magnitude. There are a number of ways in which magnitude can be measured, such as the absolute amount of a resource or ecosystem affected, the amount affected relative to the existing stock of the resource or ecosystem, the intensity of the impact and its timing and duration. In addition, the probability of occurrence for a specific impact and the cumulative impact of the proposed action and other planned or ongoing actions may need to be considered. Taking into account the scale of the proposed subprojects it is expected the magnitude of their environmental impacts will be also quiet low and thus they usually will be considered as category B projects. Examples of projects that fall under Categories A, B, and C are provided in the Table 4 above. However, this list is just a starting point and framework for the screening decision. Because of other factors involved such as project sitting, the nature of impacts, and the need for the EA process to be flexible enough to accommodate them, the lists should not be used as the sole basis for screening. Types of sub-projects that will be not supported by the project. The project does not support sub-projects, and will be excluded from the sub-project financing, that do not fall within one of its environmental conditions summarized below: (i) in the case some of the sub-projects may cause significant impacts for which it would be necessary a full EIA (Category A sub-projects); (ii) any investments related to wood harvesting (Ref: OP/BP 4.36 Forestry); (iii) production and processing of Genetically Modified Organisms (GMOs); (iv) the sub-projects located in protected areas, critical habitats or culturally or socially sensitive areas (Ref.: OP/BP 4.36 Forestry, OP/BP 4.04 Natural Habitats, OP/BP 4.11 Physical Cultural Resources); (v) any sub-loans used to invest in a business which would require the involuntary displacement of existing occupants or economic users of any plot of land, regardless of its current ownership, or loss of or damage to assets including standing crops, kiosks, fences and other (Ref.: OP/BP 4.12 Involuntary 25 Resettlement); (vi) purchasing pesticides (Ref.: OP 4.09 Pest Management); (vii) large scale irrigation systems and sub-projects involving discharging waste waters directly in the international waterways, abstraction or diversion of international waters, sub-projects related to discharging waste materials in a location that could impact on international waters, construction of any dams that might affect international waters hydrological regime, etc. (Ref.: OP/BP 7.50 Projects on International Waterways). The CEP II will also not support other types of subprojects that are specified in the Project Exclusion List (Table 11). Table 10. The Project Exclusion List  Production or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements, or subject to international bans, such as pharmaceuticals, pesticides/herbicides, ozone depleting substances, PCB, wildlife or products regulated under CITES.  Production or trade in weapons and munitions.*  Production or trade in alcoholic beverages (excluding beer and wine).*  Production or trade in tobacco.*  Gambling, casinos and equivalent enterprises.*  Production or trade in radioactive materials. This does not apply to the purchase of medical equipment, quality control (measurement) equipment and any equipment where IFC considers the radioactive source to be trivial and/or adequately shielded.  Production or trade in unbonded asbestos fibers. This does not apply to purchase and use of bonded asbestos cement sheeting where the asbestos content is less than 20%.  Drift net fishing in the marine environment using nets in excess of 2.5 km. in length.  Production or activities involving forced labor**/harmful child labor.***  Production or trade in wood or other forestry products other than from sustainably managed forests.  Production, trade, storage, or transport of significant volumes of hazardous chemicals, or commercial scale usage of hazardous chemicals. Hazardous chemicals include gasoline, kerosene, and other petroleum products.  Production or activities that impinge on the lands owned, or claimed under adjudication, by Indigenous Peoples, without full documented consent of such peoples. Notes: * This does not apply to project sponsors who are not substantially involved in these activities. "Not substantially involved" means that the activity concerned is ancillary to a project sponsor's primary operations. ** Forced labor means all work or service, not voluntarily performed, that is extracted from an individual under threat of force or penalty. *** Harmful child labor means the employment of children that is economically exploitive, or is likely to be hazardous to, or to interfere with, the child's education, or to be harmful to the child's health, or physical, mental, spiritual, moral, or social development. 53. Proposed subprojects environmental categorization. Based on the information presented above it is proposed to assign the following environmental category for the potential types of subprojects as presented in the table 11. Table 11. Subprojects environmental category7 Types of subprojects Environmental Remarks category 7 Based on national legislation and EBRD environmental guidelines and procedures for local Banks which are applied in Tajikistan 26 Mammalian livestock production B Up to 750 capita Poultry production B Up to 40 000 capita Fertilizers usage B Pesticides usage B Construction/Rehabilitation of buildings for crop stock, B New construction require a site machinery and other agricultural needs assessment and a simple EMP; Building rehabilitation – requires an EMP Checklist Vehicles C Annual crop production & plantation crop, including new B and/or C Larger than 500 ha of new plantations of orchards and vineyards orchards and vineyards are category B, the rest – category C Seeds purchasing C Bee keeping C Agricultural machinery (tractors, winnowers, sowing C machines, etc.) Poultry & meet processing8 B Dairy B Vegetable oil processing B Vegetable processing and canning B Flour milling C Warehousing C During environmental screening it is necessary to take into consideration the following:  The proposed subprojects which might have significant impacts and located in or in the vicinity of environmentally sensitive areas and habitat of endangered species; in or near archaeological, historical, cultural sites and socially vulnerable areas are considered as Category A. As mentioned above, all types of Category A subprojects will be not supported within this project.  To Category B projects may be attributed all activities which may have some adverse impacts the environment, - mainly those which involve livestock production, usage of mineral fertilizers and pesticides, large scale orchards and vineyards plantations, and/or construction and full rehabilitation of buildings, as well as agro-processing enterprises.  To the Category C projects will be mainly attributed those which are expected to have minor impacts on environment and therefore are not needed to be passed through the formal procedures of EIA and SEE (mainly those related to purchasing agricultural machinery and bee keeping. For Category C projects beyond screening, no further EA action is required. Should the PFIs meet difficulties with WB categorization of projects it should consult the PIU environmental specialist. The screening process and criteria outlined in the above will be used to determine which sub-projects are Cat B and C. They are generally in line with both national and WB rules and procedures. At the same time in the case where WB and national categorization/EA requirements differ, the more stringent requirement will apply. This refers mostly in the case of deciding about Category C subprojects - the national EA legislation doesn’t refer to small scale activities, including construction and rehabilitation of various buildings. In these cases the client will apply the WB criteria. 8 Depends on scale and location, could be “A” in some cases, but taking into account the scale of financing which is less that 200 000 USD these are category B projects 27 54. Sub-projects Environmental Assessment. After the environmental screening for the Category B projects it is required to conduct some Environmental Assessment (site specific EIA and EMP and/or prepare a simple EMP and/or a EMP checklist) in order to identify, evaluate and prevent potential environmental impacts and identify mitigation measures that may be incorporated into the project design. The purpose of the EMP is to predict potential effects and improve the environmental aspects of projects by minimizing, mitigating or compensating for negative effects. The project’s applicant is responsible for conducting this study and to prepare the EMP. 55. Impacts Prevention/ Mitigation. Based on the existing WB and national EIA rules and procedures, all potential impacts from planned economic activities have to be identified and the set of mitigation measures has to be outlined. Furthermore, since preventive measures are favored over mitigation or compensatory measures, the Project will provide capacity building to all involved parties and especially to the PIU, PFIs to avoid or minimize potential environmental impacts through applying a set of good practices directed to sub-borrowing enterprise through providing guidance on environmental sustainability matters when advising on agricultural production and agro-processing activities. The project will also support environmentally sustainable agriculture technologies, including organic farming, and provide stakeholders by education on environmentally sound practices. In relation to sectors to be covered by sub-project activities, the generated negative environmental impacts and environmental issues might be such as: surface and underground water pollution, including by hazardous chemicals; soil and water pollution due to wastes generation and improper disposal; as well as use and storage of hazardous materials; air pollution due to emission; soil and land degradation; loss of biodiversity and habitats; water and energy consumption; noise, odor and others; which may affect various environmental components. Description of potential impacts which may arise from sub-projects from agricultural production, and agro- processing sectors as well as typical measures to be taken to prevent and mitigate impacts are presented in the point 5 of the Annex A form 1 and with more details in Annexes C (Agricultural Production & Aquaculture), and D (Agro-processing & Food Production). The full set of preventive and mitigation measures for activities in Agricultural and Agro-processing sectors were developed by the World Bank Group in 2007 in its Environmental, Health, and Safety Guidelines9, as well as outlined in the Best Available Techniques to the EU Integrated Pollution Prevention Control Directive10, documents which could be consulted while conducting the EIA studies and preparing the Environmental Management Plans. 56. Steps to be followed while performing sub-projects EIA. The steps to be followed while performing category B sub-projects EIA, along with the responsibilities of the various concerned institutions are presented in Table 12 below. Table 12. Steps to be followed while performing the sub-projects EIA Step 1 a) The potential sub-borrower prepares an initial sub-project concept and submits it to PFIs. Notes: i) The sub-borrower is responsible for obtaining appropriate permits and approvals that may be required for the particular type of activity to be financed, and are issued by the local authorities responsible for environmental issues. It should be noted also that a construction permit would be required in case of new construction or essential reconstruction; ii) At this time the sub-borrower may initiate preliminary discussions, if needed, with the respective environmental authorities to determine requirements for environmental review. Step 2 a) If the project receives preliminary endorsement of PFIs, the sub-borrower completes Part 1 of the Environmental Screening Checklist (Annex A/Form 1); b) PFIs, based on the Environmental Checklist, determines the environmental category, and makes a 9 See: http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines 10 See: http://europa.eu/legislation_summaries/environment/waste_management/l28045_en.htm 28 conclusion what kind of EIA is to be conducted – an EIA and an EMP and/or partial EIA, or an EMP Checklist, including or not an environmental site assessment and informs sub-borrower. Step 3 a) PFIs completes Part 2 of the Environmental Screening Checklist (Annex A/ Form 1); b) In the case of a project which require an EIA and EMP and/or an environmental site assessment the PFIs organizes a field site visit and completes the Field Site Visit Checklist (Annex A/ Form 2); c) after a field site visit, PFI completes a Final Environmental Assessment Checklist provided in Annex A/Part 1/Form 3 d) in the case of sub-projects on upgrading of existing facilities the sub-borrower, PFI and PIU complete the Environmental Screening Checklists for existing facilities (Annex A/Form4/Part 1; Annex A/Form4/Part 2; Annex A/Form4/Part3 ) Step 4 a) If the applicant decides to follow further, she/he arranges preparation of Environmental Assessment of a required level and an Environment Management Plan. b) For that PFIs provides the sub-borrower the type of EA documents (partial EIA, including site assessment and Environmental Management Plan for category B projects; Site Assessment and EMP checklists for small scale category B projects) to be prepared and suggest on what environmental issues is needed to focus. c) At sub-borrower’s request, an authorized institution prepares the Environmental Impact Assessment and Environment Management Plan. Notes: i) Category B projects which presume new construction, substantial technological modernization, application of new technologies, change of land use patterns is a subject of the State Ecological Expertise. ii) In the case of small scale construction and reconstruction activities it is necessary to apply a generic Environmental Management Checklist, proposed by the WB to address potential environmental impacts; this document is provided in Annex A/ Form 3; iii) Content and Description of the Environmental Management Plan are presented in Annex B/ Form 1/ Parts 1 & 2, respectively; Environmental Management Plan Format is presented in Annex B/ Form 2; iv) Measures to mitigate impacts which may be generated by sub-projects from Agricultural Production and Agro-processing sectors are provided in Annexes C and D, respectively. Step 5 a) When the EIA is conducted, the sub-borrower organizes its disclosure and public consultation, involving NGO’s, community representatives, affected groups, etc. and records input from the public Formal Minutes records the participants as well as issues raised toward EIA, and recommended activities to further address stakeholders’ concerns. Note: In the case of small scale projects which require only an EMP Checklist the sub borrower organize its disclosure with a virtual public consultation. b) The sub-borrower prepares and submits to PFI the Environmental Impact Assessment and the EMP and/or EMP Checklist together with other documents needed for environmental approval as well as other relevant documentation upon PMU’s request, when needed; b) The PFI reviews the submitted documentation and completes Part 3 of the Environmental Screening Checklist (Annex A/ Form 1). Notes: i) PFI may suggest some revisions and/ or clarification (which the applicant has to provide upon PFI’s request), the environmental management plan and accompanied all necessary permits (the applicant is responsible for obtaining appropriate permits, clearances and approvals which may be required by other local authorities). ii) PFI may return the EIA documents in case they didn’t correspond to specified requirements. Step 6 a) After the consultation and PFIs review and approvals, the sub-borrower incorporates the received recommendations as well as those received during the review and clearance by other public authorities into the sub-project technical design documentation (and environmental management plan) and submits it for conducting of the State Ecological Expertise. 29 Note: The projects which require only an EMP Checklists are not needed to be presented to the SEE. b) When required, sub-borrower gets also from the State Ecological Inspectorate the final permit on use of the natural resources which is issued on the base of permits obtained from core institutions responsible for management of these resources (Ministry of Water Resources Energy , CEP , etc.), and permit on environmental pollution on the basis of newly established by SEI for this particular activity (e.g., building of an agro-processing factory, etc.) maximum allowable emissions into environment (i.e., limits of pollutants’ concentration in waste water effluents and in emissions into air) Step 7 a) Sub-borrower submits full set of environmental assessment documents to PFI for their consideration and further decision on funding. b) PFI shall inform the sub-borrower in writing regarding approval or rejection of loan. 57. EA for existing enterprises. For expansion of existing facilities or where change of technology is proposed, an environmental audit may be required, and/or environmental due diligence procedure, depending on the nature of the sub-project. Such procedure would include collecting and checking relevant information and documents regarding environmental performances of selected enterprise (see Table 13). In this case it is necessary to fill out the templates from Annex A form 4. Table 13 - Environmental Eligibility Checklist for the Existing Enterprise No. Criteria N/A Yes No Comments 1 Does the enterprise have a valid If no, (a) all required operating permit, licenses, licenses/permits/approvals approvals etc.? etc. must be obtained prior to project approval, or (b) the project investment must include funds to obtain them 2 Does the enterprise meet all If no, (a) the facility must take Tajik environmental regulations corrective measures to meet all regarding air emissions, water environmental regulations prior discharges and solid waste to project approval, or (b) the management? investment must include funds to meet them. 3 If the enterprise has any If the enterprise has significant outstanding outstanding liabilities, it must environmental fees, fines or take corrective measures to penalties or any other remove them prior to project environmental liabilities (e.g. approval. pending legal proceedings involving environmental issues etc.) will the investment be used to correct this condition? 4 If any complaints were raised by If yes, the PFIs should examine local affected groups or NGOs the nature of the complaints regarding conditions at the and actions taken to address facility, will the investment be them. If there are significant used to remedy these unresolved complaints, the complaints? PFIs should consult with the WB regarding appropriate actions. 30 58. WB EAs prior review. While the main responsibilities in conducting the subprojects EIA lies with the PFIs and PIU, taking into account the lack of experience in this area of these institutions, the Bank will require the prior review from each PFI for at least three Category B subprojects (outside of those which would require only an EMP Checklist) in the beginning of the project implementation. 59. Environmental Management Plan (EMP). A project’s environmental management plan consists of the set of mitigation, monitoring, and institutional measures to be taken during implementation and operation to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels (see Annex B). An EMP is a key element of an EA report for all Category B subprojects. 60. EMP Checklists. In the case when the project would involve typical small scale (re)construction activities it is proposed to be used a generic EMP checklist-type format (“EMP Checklist”), developed by the World Bank to provide “pragmatic good practice” and designed to be user friendly and compatible with safeguard requirements (see it presented in the Annex A/Form 3). The checklist-type format attempts to cover typical preventive and mitigation approaches to common civil works contracts with localized impacts. It is anticipated that this format provides the key elements of an Environmental Management Plan to meet Environmental Assessment requirements of the World Bank (under OP/BP/GP 4.01). The EMP Checklist includes the environmental and social screening and mitigation measures in a simple Yes/No EMS format. VIII Environmental Monitoring and Reporting 61. Monitoring. Environmental monitoring during the subprojects implementation, which is to be performed by the project beneficiaries and the PIU has to provide information about key environmental aspects of the subprojects, particularly the project environmental impacts and the effectiveness of taken mitigation measures. Such information enables to evaluate the success of mitigation as part of project supervision, and allows corrective action(s) to be implemented, when needed. The EMF identifies monitoring objectives and specifies the type of monitoring, and their link to impacts and mitigation measures. Specifically, the monitoring section of the EMP provides: (a) a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and, (b) monitoring and reporting procedures to: (i) ensure early detection of conditions that necessitate particular mitigation measures, and (ii) furnish information on the progress and results of mitigation. An example for a Monitoring Plan for a small scale construction project is presented in Annex B/ Form 3. 62. Supervision. If approved, during the sub-project’s operation phase, PFIs and PIU, along with the local (rayon) representative of the State Ecological Inspectorate and other environmental agencies, when required, perform environmental supervision and monitoring to control compliance with agreed design and mitigation measures to ensure that it is in full compliance with the management plan. 63. Reporting. The status of compliance with agreed environmental mitigation measures is to be reported by the PFIs and the PIU in their regular (quarterly) reports on project implementation. In the case of non-compliance, the PFI officers (with Environmental Inspectorate and PIU assistance) investigate the nature and reason(s) for non-compliance, and a decision has to be made on what is needed to bring a sub-project into compliance, or whether financing should be suspended. The PIU makes available information on monitoring of environmental management plans and mitigation measures in its routine reporting on sub-project implementation to the World Bank and during periodic Bank supervision missions. 31 IX. Sub-projects’ Environmental Assessment Disclosure and Consultation 64. EIA disclosure and consultation. Disclosure of the EIA documents for category B projects is mandatory, and is to be done at a public place accessible to project-affected groups & local NGOs. This might be at the beneficiary web site/office, local authority offices and/or the central State Ecological Inspectorate or its district sub-division. Furthermore, the sub-borrower provides a forum or hearing for consultation and comment by project-affected groups and local non-governmental organizations during the environmental assessment process and takes their views into account before finalizing project design and submission of the project to the PFI and to PIU for final approval. The sub-borrower provides any relevant materials (process descriptions, maps, building plans, etc.) to participants in a timely manner and in a form and language that are understandable to the group being consulted and records and describes details of consultations held in the project screening form. The subprojects consultation can be done at the stage when the draft EIA report is ready. In the case of new small construction, insignificant reconstruction, change of machinery and equipment on a new, more ecological one, purchase and application of small amount of fertilizers, purchase of a small quantity of cattle or poultry for production and processing and some others which will not significantly affect the environment, public consultation can be done virtually, providing relevant information to all interested parties about these activities virtually by posting it on the web or in local public administrations. In the case of construction/reconstruction activities the project beneficiaries should also install a notice plate placed in the site of project site. X. Pest management and mineral fertilizers issues 65. General remarks. The pest management issues which can be potentially raised by the project may relate to possible direct purchasing or indirect effect of stimulating greater use of agro-chemicals associated with more intensive cultivation and/ or higher crop value. The objective of EMF in this regard is to encourage adoption of Integrated Pest Management approach and increase beneficiaries’ awareness of pesti cide-related hazards and good practices for safe pesticides use and handling. 66. Principles of the Integrated Pest Management11. The primary aim of pest management is to manage pests and diseases that may negatively affect production of crops so that they remain at a level that is under an economically damaging threshold. Pesticides should be managed to reduce human exposure and health hazards, to avoid their migration into off-site land or water environments and to avoid ecological impacts such as destruction of beneficial species and the development of pesticide resistance. One important strategy is to promote and facilitate the use of Integrated Pest Management (IPM) through preparation and implementation of an Integrated Pest Management Plan (PMP). The IPM consists of the judicious use of both chemical and nonchemical control techniques to achieve effective and economically efficient pest management with minimal environmental contamination. IPM therefore may include the use of: a) Mechanical and Physical Control; b) Cultural Control; c) Biological Control, and d) rational Chemical Control. Although IPM emphasizes the use of nonchemical strategies, chemical control may be an option used in conjunction with other methods. Integrated pest management strategies depend on surveillance to establish the need for control and to monitor the effectiveness of management efforts. 67. Alternatives to Pesticide Application. Where feasible, the following alternatives to pesticides should be considered:  Rotate crops to reduce the presence of pests and weeds in the soil ecosystem;  Use pest-resistant crop varieties;  Use mechanical weed control and / or thermal weeding;  Support and use beneficial organisms, such as insects, birds, mites, and microbial agents, to perform biological control of pests; 11 This section is based on the World Bank Group in the Environmental, Health, and Safety Guidelines prepared in 2007. 32  Protect natural enemies of pests by providing a favorable habitat, such as bushes for nesting sites and other original vegetation that can house pest predators and by avoiding the use of broad-spectrum pesticides;  Use animals to graze areas and manage plant coverage;  Use mechanical controls such as manual removal, traps, barriers, light, and sound to kill, relocate, or repel pests. 68. Pesticide Application. If pesticide application is warranted, users are recommended take the following actions:  Train personnel to apply pesticides and ensure that personnel have received applicable certifications or equivalent training where such certifications are not required;  Review and follow the manufacturer’s directions on maximum recommended dosage or treatment as well as published reports on using the reduced rate of pesticide application without loss of effect, and apply the minimum effective dose;  Avoid routine “calendar-based” application, and apply pesticides only when needed and useful based on criteria such as field observations, weather data (e.g. appropriate temperature, low wind, etc.),  Avoid the use of highly hazardous pesticides, particularly by uncertified, untrained or inadequately equipped users. This includes:  Pesticides that fall under the World Health Organization Recommended Classification of Pesticides by Hazard Classes 1a and 1b should be avoided in almost all cases, to be used only when no practical alternatives are available and where the handling and use of the products will be done in accordance with national laws by certified personnel in conjunction with health and environmental exposure monitoring;  Pesticides that fall under the World Health Organization Recommended Classification of Pesticides by Hazard Class II should be avoided if the project host country lacks restrictions on distribution and use of these chemicals, or if they are likely to be accessible to personnel without proper training, equipment, and facilities to handle, store, apply, and dispose of these products properly;  Avoid the use of pesticides listed in Annexes A and B of the Stockholm Convention, except under the conditions noted in the convention and those subject to international bans or phase outs;  Use only pesticides that are manufactured under license and registered and approved by the appropriate authority and in accordance with the Food and Agriculture Organization’s (FAO’s) International Code of Conduct on the Distribution and Use of Pesticides;  Use only pesticides that are labeled in accordance with international standards and norms, such as the FAO’s Revised Guidelines for Good Labeling Practice for Pesticides;  Select application technologies and practices designed to reduce unintentional drift or runoff only as indicated in an IPM program, and under controlled conditions;  Maintain and calibrate pesticide application equipment in accordance with manufacturer’s recommendations. Use application equipment that is registered in the country of use;  Establish untreated buffer zones or strips along water sources, rivers, streams, ponds, lakes, and ditches to help protect water resources;  Avoid use of pesticides that have been linked to localized environmental problems and threats. A copy of the national pesticide registration list is attached below in Annex E. 69. Pesticide Handling and Storage. Contamination of soils, groundwater, or surface water resources, due to accidental spills during transfer, mixing, and storage of pesticides should be prevented by following the hazardous materials storage and handling recommendations. These are the following:  Store pesticides in their original packaging, in a dedicated, dry, cool, frost-free, and well aerated location that can be locked and properly identified with signs, with access limited to authorized people. No human or animal food may be stored in this location. The store room should also be designed with spill containment measures and sited in consideration of potential for contamination of soil and water resources;  Mixing and transfer of pesticides should be undertaken by trained personnel in ventilated and well lit areas, using containers designed and dedicated for this purpose. 33  Containers should not be used for any other purpose (e.g. drinking water). Contaminated containers should be handled as hazardous waste, and should be disposed in specially designated for hazardous wastes sites. Ideally, disposal of containers contaminated with pesticides should be done in a manner consistent with FAO guidelines and with manufacturer's directions;  Purchase and store no more pesticide than needed and rotate stock using a “first -in, first-out” principle so that pesticides do not become obsolete. Additionally, the use of obsolete pesticides should be avoided under all circumstances; a management plan that includes measures for the containment, storage and ultimate destruction of all obsolete stocks should be prepared in accordance to guidelines by FAO and consistent with country commitments under the Stockholm, Rotterdam and Basel Conventions.  Collect rinse water from equipment cleaning for reuse (such as for the dilution of identical pesticides to concentrations used for application);  Ensure that protective clothing worn during pesticide application is either cleaned or disposed of in an environmentally responsible manner  Maintain records of pesticide use and effectiveness. 70. Pest Management Plan (PMP). The content of the Pest Management Plan should apply to all the activities and individuals working. It should be emphasized also that non-chemical control efforts will be used to the maximum extent possible before pesticides are used. The Pest Management Plan should be a framework through which pest management is defined and accomplished. The Plan should identify elements of the program to include health and environmental safety, pest identification, and pest management, as well as pesticide storage, transportation, use and disposal. Management Plan is to be used as a tool to reduce reliance on pesticides, to enhance environmental protection, and to maximize the use of integrated pest management techniques. The Pest Management Plan shall contain pest management requirements, outlines the resources necessary for surveillance and control, and describes the administrative, safety and environmental requirements. The Plan should provide guidance for operating and maintaining an effective pest management program/ activities. Pests considering in the Plan may be weeds and other unwanted vegetation, crawling insects and other vertebrate pests. Without control, these pests provoke plants’ deceases. Adherence to the Plan will ensure effective, economical and environmentally acceptable pest management and will maintain compliance with pertinent laws and regulations. The recommended structure of a Pest Management Plan is presented in the Annex F. 71. Reviewing and approving Pest Management Plan. A PMP should be prepared in all cases of direct purchasing and usage of pesticides by all subprojects beneficiaries. The draft PMP should be reviewed by the PFIs loan officers as well as by the PIU environmental specialist, who will provide its approval. These documents are also subject to WB prior review for the first two such types of subprojects from the each PFI. 72. Safety issues in mineral fertilizers usage and handling. Similarly as in the case of usage of pesticides, fertilizers usage may provide important benefits, they also pose certain risks associated with accidental expose of environment and of farmers during their inappropriate handling and usage. To avoid adverse environmental impacts while using mineral fertilizers it is necessary to comply strictly with a series of requirements, stipulated in the existing legal documents as well as in the fertilizers Guidelines for their handling. The rules and procedures of production, storage, transportation and usage of the mineral fertilizers are reflected in a relatively small number of documents, and most of them were adopted at the time of the USSR. 73. Main requirements while using mineral fertilizers. The usage of different mineral fertilizers should be done depending on such factors as type and quality of the soil, type of the crop, system of crop rotation, weather and climate conditions, ways and terms of their application. 74. Provisions with regard to fertilizers storage:  Keep stocks of fertilizers, and soil amendment materials to the minimum required.  Ensure that the storage facility is appropriately secured. 34  Fertilizers and soil amendment materials are not to be stored in contact with ground surfaces.  Storage areas/facilities are to weather-proofed and able to exclude runoff from other areas.  Do not store in close proximity to heat sources such as open flames, steam pipes, radiators or other combustible materials such as flammable liquids.  Do not store with urea.  Do not contaminate fertilizers, and soil amendment materials with other foreign matter.  In case of fire flood the area with water.  If augers are used to move the material ensure that any residue(s) in the immediate area is cleaned up.  Dispose of empty bags in the appropriate manner. 75. Provisions with regard to fertilizers field usage:  Keep fertilizer amounts to a minimum and covered to avoid unnecessary expose to open air.  Keep spreaders and air seeders that are left in the field overnight covered.  Cover spreader and air seeders between jobs.  Ensure that the drill, air seeder and/or fertilizer box is completely empty at the end of each day. If the drill, air seeder and/or fertilizer box cannot be fully emptied fill to capacity prior to storage for the night.  Do not store dry urea with dry ammonium nitrate. 76. Ensuring minimization of hazards associated with inappropriate handling and usage of fertilizers: The Table 14 below provides information about typical hazard scenarios that that may arise in conjunction with the procurement, handling and storage of fertilizers as well as the recommended measures to control the potential risks. Table 14. Typical hazard scenarios and recommended measures Likely Hazard Recommended Control Strategy Scenario Spillage  Ensure all storage areas and/or facilities are secure and appropriate.  Ensure all fertilizer products can be contained within the storage area and/or facility selected.  Provide appropriate equipment and materials to clean up a spillage Transportation and  Cover any loads of fertilizer products whilst in transit. delivery of goods  Ensure that deliveries of fertilizer products are made at appropriate times.  Do not accept any containers of fertilizer products that are damaged and/or leaking.  Ensure that any spillages that occur during delivery are cleaned up appropriately. Drift of dust from  Keep fertilizer products covered and/or sealed. storage areas and/or  Clean up spillages promptly. facilities  Keep “in use” stocks to the minimum required.  Staff responsible for storage areas and/or facilities to will ensure that the drift of dust beyond the perimeter is kept to a minimum. Storage areas -  Keep floor surfaces swept clean of fertilizer to prevent tracking by people and/or Floors vehicles beyond the perimeter.  Sweep up and dispose of spillages in a timely and appropriate manner. Cross contamination Keep each fertilizer product will in a separate storage container and/or position within of product the facility and/or area.  Confusion of Product Maintain an accurate storage manifest/register.  Keep products and blends are segregated at all times. 35  Ensure all storage bays and bins are clearly labeled.  Ensure all storage, loading and blending plant and equipment is cleaned from all residues when changing from one product to another.  Do not store product in bags that are not correctly stamped. Occupational Health Contact between fertilizer products, people and livestock will be minimized. and Safety Risk Assessments  Risk Assessments are required to be conducted on the procurement, storage and handling of fertilizer products. Contact with people  Managers will develop, implement and monitor the effectiveness of hazard and livestock management procedures.  All persons using fertilizer products are to adhere to the hazard management procedures and adopt safe working practice and ensure that direct contact with fertilizer and the inhalation of fertilizer dust is minimized.  Managers are to ensure that staff is made aware of any national and industry regulations which have to be observed. Personal Protective  Staff must be provided with appropriate PPE when using fertilizer products. Equipment Lack of appropriate  Managers must ensure that appropriate safety warning signs and/or information is warning safety displayed/ available regarding nature of hazards and risk control measures. signage and information Poor housekeeping  All staff is responsible for implementing sound housekeeping practices in storage and/or routine areas and arranging regular routine maintenance for all equipment used. maintenance Defective &/or  Conduct regular inspection & testing of equipment and infrastructure to identify unserviceable plant & what maintenance requirements equipment Incorrect or Fertilizer blends to be prepared using the right raw materials in the appropriate inappropriate proportions. All products will be loaded into spreaders etc in the right condition to the mixtures of product right weight. No training  Staff will undertake appropriate training. Lack of appropriate  All relevant records and documentation to be kept and maintained e.g. training records &/or records, risk assessments, maintenance schedules, recipes for fertilizer blends, documentation MSDS’s etc. 77. Reviewing and approving subprojects which involve purchasing and usage of mineral fertilizers. As handling and usage of mineral fertilizers might cause harm to the environment and to the farmers’ health, in the case of such types of subprojects the beneficiaries have to attach to the subproject proposal a short memo, including the following information: (a) types of fertilizer and its amount; (b) storage conditions; (c) ways of field usage; (d) measures to be undertaken to control possible hazard scenarios; and (e) responsible person. The subproject proposal along with this memo will be reviewed by the PFIs and by the PIU Environment Specialist who will provide his approval. The first two such subprojects from each PFIs will be also subject to prior review by the WB. XI. Institutional Arrangements for the EMF implementation 78. General Remarks. The project involves in its implementation a series of actors: Participating Financial Intermediaries, represented by several Commercial Banks; Environmental Specialist of the Project Implementation Unit; and grants beneficiaries and sub-borrowers. Their good cooperation is crucial for the success of the project. 36 79. Participating Financial Institutions. The PFIs will play the major role in implementing EMF provisions and will be required to ensure that borrowers conduct an appropriate EIA and where necessary prepare an EMP, for each sub-project. The PFIs will be involved in the process of project implementation from the very beginning, at the project’s appraisal stage. It evaluates project proposals to attribute them to the WB Category and determines type of Environmental Assessment to be conducted for project, reviews the set of documents prepared by sub- borrowers (sub-projects’ Information Sheet or Project Summary Sheet as well as all necessary permits and clearances needed for project implementation) completes Environmental Screening Checklist and makes a final decision on project’s financing. In case of non-compliance with presumed mitigation measures during project implementation, the PFIs can make a decision on suspending of funding. The environmental assessment documentation for the first three Category B subprojects from each PFI will be subject to prior review and approval by the PIU and World Bank. PFIs capacity building activities will be initiated prior to PFI approving of any subprojects and would be completed before prior review by the World Bank ceased. During sub-project appraisal PFIs will have to ensure that proposed sub-projects are in compliance with all environmental laws and standards of the RoT, as certified by the relevant local or national authorities of the Republic, and the Environmental Guidelines. All relevant documents and permits should be kept in each sub- borrower document file maintained by the PFI, and be made available for review by PIU, IDA representatives and PFI auditors. 80. PIU. The main objectives of the PIU is to facilitate smooth implementation of the Access to finance Component by (i) liaising between the IDA, and PFIs and (ii) conduct overall project monitoring and supervision of compliance according to applicable guidelines and IDA regulations. With regard to EA, among their tasks will be also the following: (a) conduct selection inspections of PFIs periodically to assure the compliance of sub-loans with EMF requirements concerning subprojects EA; and (b) include in their quarterly reports on status/progress of the project implementation brief information with regard to subprojects’ EA, including compliance with the requirements concerning EIA&EMP. 81. PIU Environment Specialist. The PIU monitors the compliance with the credit agreement regarding the EA process, including conducting periodic monitoring of the screening process of applications for EA requirements. The PIU ES will assist the PFIs and beneficiaries in all aspects and is responsible for reporting to both the Government and the World Bank. The role of the PIU environmental specialist will be following: i) to provide assistance to the PFIs to determine the exact impacts that can be generated by proposed activities for which loans are being sought as well as prescribing in specific terms the required mitigation actions to be taken; ii) to conduct screening and ensure EA for the selected matching grants; and, iii) to monitor and report on a regular basis the effects on the environment that activities financed through the access to finance component may provoke and to ensure that mitigation is carried out. The PIU Environmental Specialist will also have to selectively visit sub-loans, screen those submitted for a prior review, and ensure proper monitoring for all Cat B - both sub-loans and matching grants. 82. Main EA responsibilities of the Environmental Specialist. Environmental Specialist would provide guidance and backstopping to the PFIs on projects’ environmental screening procedures, and along with loan officers (to whom he/she would provide advice), will be responsible for ensuring an efficient screening of proposed grants and sub-projects. The objective of the Environmental Specialist’s task would be also raisi ng awareness on environmental issues and strengthen capacity of project stakeholders toward ensuring that potential environmental impacts could be recognized, avoided or at least minimized through mitigation. In this regard among the tasks to be performed by Environmental Specialist would be: design the environmental training programs on national environmental legislation, World Bank Safeguard Policies, Environmental Impact Assessment, etc; organize preparing a reference manual for the lending staff of the PFI, which would include the list of national environmental legislation, list of economic activities requiring permits, compliance procedures and/or compliance inspections; organize delivery of training through a series of seminars to the target audience; conduct environmental monitoring and assessment. Besides, Environmental Specialist would ensure that 37 applicable national standards and guidelines are being followed and achieved within both providing matching grants and sub-loans. Where multiple grants and sub-projects are being carried out in geographical proximity, the specialist would assess the possible cumulative or residual effects on the environment (particularly, on natural habitats, forests, soil, and air and water resources). XII. Capacity Building 83. Training for the PIU Environmental Specialist. In order to ensure successful implementation of the EMF requirements it is necessary to provide a series of capacity building activities. In particular, it is proposed the PIU environmental specialist should have training course on EA techniques and procedures. For that purpose he/she might visit a similar WB project in other countries in the region (Moldova, Armenia) and/or to hire an international consultant who might provide on the job training. 84. PFIs and IMU training. The main function of commercial banks, which have been selected as PFIs in the project is administration of loans’ processing. As the PFIs will be responsible not only for assisting the sub borrowers in preparing the environmental screening form and respectively in identifying potential sub projects environmental issues, but also for approving the EA reports and ensuring their implementation, the EMF recommends that each participating PFI would designate a staff which would be trained on environmental issues to designated further environmental assessment responsibility. In this regard, a special training program would be designed involving representatives from the PFIs. The training program should be practical and include work with realistic case studies, based on actual loan proposals and types of business activities supported by the Project. It should also cover an explanation and practical application of the environmental standards and forms designed for use by the participating financial institutions. The training will cover the following issues: (a) national and World Bank requirements for environmental assessment; (b) screening and scoping procedures including checklists of potential environmental impacts of the agricultural production and agro-processing activities; (c) main provisions of environmental management plans for proposed sub projects, including mitigation and monitoring requirements. Field studies also may be included. Such training will enable these target groups to recognize and assess potential negative environmental impacts and set of measures to mitigate them. 85. Training for sub-borrowers. Next the most critical group to be exposed to the importance of the environment concerns includes entrepreneurs from agricultural and agro-processing sectors who will be receiving the grants and loans, and whom should be provided advices on use better available techniques to prevent/ mitigate impact and promote sustainable agriculture and agro-processing technologies. The workshops for this group would include environmental awareness and a practical exercise to observe and learn about sustainable agricultural practices and best available techniques in agro-processing activities. XIII. Budget 87. Requested expenses. At the project design stage, the funds to be spent for preparing grants and sub projects Environmental Impact Assessments, obtaining of necessary permits and other relevant activities are the responsibilities of sub-borrowers. They will depend on the nature of project proposal, its complexity, scale, etc. At the construction and operation stages, the funds to be spent for installations and other activities to ensure mitigation measures against the environmental impacts from proposed activities is also the responsibility of sub- borrowers. These funds will depend on particular techniques and technologies used for implementing mitigation measures as well as on their scale, number, variety and other factors. At the same time, in order to ensure successful EMF implementation, a series of capacity building activities are necessary for which the project has to provide adequate funding. Estimate budget for proposed capacity building activities and trainings is presented in the Table 15 below. Table 15. Estimate budget for proposed capacity building activities 38 Training Required Purpose No of participants/ Total funds and Target Group No of days for the workshop/ No of workshops Environmental issues, aspects of EIA, environmental guidelines and EMP 1.Environmental To ensure that PIU staff, IMU and PFI loan officers 1 workshop, 2000 USD awareness workshop for aware about importance of the environment and PIU staff, and PFIs loan know how to recognize the impacts that various officers funded activities may have on the environment. 2. PIU environment To provide PIU environmental consultant with Study tour 3500 specialist knowledge on the screening of the projects, EIA USD/month process and EIA review/study tour 3. PIU environmental To provide PIU staff/ or PIU environmental 1 workshop 1500 specialist and PFIs consultant with knowledge on environmental USD/month monitoring techniques and procedures 4 PFI Loan officers Familiarizing with environmental aspects of 1X2 days trainings 6000 USD from commercial banks development projects and environmental analysis to enable them to recognize the potential negative environmental impacts and outline set of measures to mitigate impacts 5. Sub Environmental awareness and a practical exercise 3X 2days trainings 15000 USD borrowers/project to observe and learn about sustainable agricultural beneficiaries practices and best available techniques and industry and agriculture 6. PIU, PFIs and loan Training on use of environmental guideline how to 3x2 trainings 15000 USD officers identify sub projects that may fall into one of the Bank’s environmental categories, and in which case will require a full and/or a partial EIA, and, to identify activities that may affect the environment and in organizing the subprojects EIAs On IPM Trainings 8. Representatives of Pest characteristics 3 workshops 15000 USD rayon agricultural departments; participating farmers (Sub-borrowers/project beneficiaries) 9. Representatives of Control measures, including IPM approaches, 3 workshops 15000 USD rayon agricultural involving agricultural, physical, biological, and departments; chemical control methods participating farmers (Sub-borrowers/project beneficiaries) 9. Representatives of Safety issues (for pest handling, transportation, 3 workshops 15000 USD rayon agricultural usage and storage) departments; participating farmers, Local environmental inspectors (Sub- borrowers/project beneficiaries) Field demonstrations with improved pesticides usage and IPM technologies Representatives of Field demonstrations on Pest problems diagnosed 3 workshops 15000 rayon agricultural and related IPM opportunities, pest management departments; practices, including agricultural, physical, 39 participating farmers biological and chemical control methods (Sub-borrowers/project beneficiaries) Preparing and disseminating information materials One comprehensive Preparing and publishing a special publication on 25000 publication ad a series Pest Management and IPM of small leaflets on Pest Management and IPM TOTAL 158000 USD XIV Environmental Management Framework’s Disclosure and Consultation 88. EMF Disclosure. The Ministry of Agriculture on February, 18, 2014 has disseminated the draft summary EMF in its institutions and to other relevant ministries for review and comments, also posting it for wide public on the web-page of the Regional Environmental Centre for Central Asia (website – www.carecnet.org) - also by disseminating through local electronic networks. 89. EMF Public consultation. On February, 28, 2014, the PIU has conducted a public briefing and consultation on this document (see Annex G with the minutes of consultation). Outside of participants from the interested state institutions in the meeting took part also representatives from environmental and agricultural NGOs, local representatives of the government bodies, such as CEP, MoA, MEWR, and others. During the consultation, the PIU has presented a summary of a draft Environmental Management Framework to public. Particularly, the audience was informed about screening of the projects, types of Environmental Assessment for Category B projects, potential impacts which may by generated by agricultural production and agro-processing activities as well as measures to be taken to prevent/mitigate potential impacts. The consultation meeting’s attendees actively participated in discussions which were mainly focused on WB environmental screening procedure, implementing arrangements, rules and procedures for agro chemicals use and capability of environmental authorities to perform monitoring of sub-projects. The meeting concluded that the draft EMF document covered practically all potential impacts and possible mitigation measures. The draft EMF was revised after the meeting taking into account inputs from the consultation. The final version of the EMF was officially submitted to the World Bank for disclosure in English in Infoshop; this final document will be used by the government agencies in the project implementation. The Russian translation of full EMF report will be provided to the CEP (State ecological expertise), MoA and also posted on its web-sites. 40 Annexes Annex A. Environmental Screening Checklist Annex B. Content of the Environmental Management Plan Annex C. Impacts, Causes, Consequences and Mitigation measures for subprojects in Agricultural Production Sector Annex D. Impacts, Causes, Consequences and Mitigation measures for subprojects in Agro-processing Sector Annex E. Recommended Structure of a Pest Management Plan Annex F. Report on Consultation on the Draft Environmental Management with interested parties 41 Annex A/ Form 1 ENVIRONMENTAL SCREENING CHECKLIST Part 1 (to be completed by Sub-borrower) 1. Project Name: 2. Brief Description of Sub-project to include: nature of the project, project cost, physical size, site area, location, property ownership, existence of on-going operations, plans for expansion or new construction. 3. Will the project have impacts on the environmental parameters listed below during the construction or operational phases? Indicate, with a check, during which phase impacts will occur and whether mitigation measures are required. Environmental Component Construction Operational Mitigation Phase Phase Measures Terrestrial environment Soil Erosion: does the project involves crop agriculture? If so, which crops? Is agricultural field is located on the slopes and/or on the plain areas? ill the project involve ploughing/plant cultivation on the slopes? Habitats and Biodiversity Loss: Will the project involve use or modification of natural habitats (pasturing on and ploughing up the steppe areas, cutting or removal of trees or other natural vegetation, etc.) Soil pollution: Will the project applies pesticides? If yes which types and their amount? Land, habitats & ecosystems degradation: Is the area which is to be used currently a natural (not converted) habitat (forest, wetland, natural grassland, etc.)? Land degradation: Will the project involve land excavation? Generation of solid wastes – what type of wastes will be generated (various types of construction wastes, wastes from agro- processing activities, livestock manure) and their approximate amount Generation of toxic wastes – what types of toxic waste will be generated (obsolete and unusable pesticides and mineral fertilizers; chemicals used in agro-processing activities; asbestos) and their approximate amount. Biodiversity and Habitats Loss: Will the project 42 located in vicinity of protected areas or other sensitive areas supporting important habitats of natural fauna and flora? Is it planned enlargement of area under agricultural crop production based on transformation of natural habitats? Underground water pollution - if the project involves production of stall fed livestock does it has a manure platform? Construction Air quality Will the project provide pollutant emissions? Which types of pollutants (SOx, NOx, solid particles, dioxins, furans, etc) Aquatic environment Water Quantity: will the project involve water use? Which volumes and from which water source (centralized water supply system and/or from water reservoir) ? Water Quality/Pollution: Will the project contribute to surface water pollution – what will be the approximate volumes of waste water discharge? Does the project involve discharges of waste waters in water reservoirs and/or in centralized sanitation network/septic tank? Loss of Biodiversity: Will the project involve introduction of alien species (in case of aquaculture projects)? Loss of Biodiversity: Will the project located in vicinity of protected area or wetlands? Degradation of natural aquatic ecosystems – if the project involves discharges in water courses and reservoirs of solid wastes; pesticides; cutting of protective shelterbelts. Weeds, pests, diseases: will the project contribute to spreading of weeds, pests and animal and plant diseases? Sedimentation of water bodies – will the project contribute to sedimentation of water bodies due to soil erosion ? Socio-economic environment Social impacts – does the project involve the following: (a) occupational safety issues; (b) health hazards; (c) involuntary land acquisition or displacement of third parties using land; (d) loss of access to sources of income; (e) loss of physical and/or economic assets; and (f) disturbance of residents living near the project area. Does the project per national legislation require public consultation to consider local people 43 environmental concerns and inputs? Will the project assure non-deterioration of human health, occupational safety and non- disturbance of residents living near project area? If no, is it possible by applying proposed mitigation measures to reduce the project environmental and social impacts to admissible levels? 4. For the environmental components indicated above, and using the information provided in the table below describe the mitigation measures that will be included during the construction (C) or operational (O) phase of the project or both (B). Typical mitigation measures could be found in the point 5 and Annex C and D below. Environmental Phase Mitigation Measures Component (C, O or B) 5. Examples of Mitigation Measures (for more detailed description of listed below and other potential mitigation measures refer to Annexes C and D). Environmental Component Mitigation Measures Soil Erosion: does the project involves crop 1) Ploughing across the slope agriculture? If so, which crops? Is agricultural 2) Contour tillage field is located on the slopes and/or on the plain 3) Avoid creation of new terraces since it is linked with areas? Does the project involve ploughing/plant loss of topsoil, etc. cultivation on the slopes? 4) Appropriate crop rotation: fallow land – wheat – maize – sunflower – Lucerne – Lucerne (2 years long) – legumes (pea, haricot, etc.) / wheat maize, etc. 5) On lands which are subject to erosion preferable cultivation of plants with require dense sawing (e.g. wheat, rye, etc.) and avoid cultivation of tilled crops (e.g., maize, sunflower), 6) Orchards: creation of grass strips between the rows, deep cultivation between the rows, 7) Where possible, to use the branch of field crops with the branch of cattle-breeding and gardening, etc. Habitats and Biodiversity Loss: Will the project 1) Avoiding use of remained natural or semi-natural involve use or modification of natural habitats steppe areas for pasturing and crop production (pasturing on and ploughing up the steppe areas, 2) Avoid, where possible, cutting of trees and other cutting or removal of trees or other natural natural vegetation, etc. vegetation, etc.) 3) Minimize loss of natural vegetation/ Protection of vegetation during construction activities Soil pollution: Will the project applies 1) Use of less harmful (non-persistent) pesticides pesticides? If yes which types and their amount? 2) Not to apply more pesticides than needed 3) To ensure appropriate pesticides handling to avoid polluted surface runoff, etc. 44 Land, habitats & ecosystems degradation: Is the 1) Not to exceed pastures’ capacity (on degraded lands area which is to be used currently a natural (not this is 0,3-0,5 conv. cap/ ha; on good lands – 1,5 conv. converted) habitat (forest, wetland, natural cap/ per ha) and avoid overgrazing grassland, etc.)? Does the project involve 2) Where possible, use of stabling production of livestock? If so, what type and 3) Where possible, do develop sawn pastures how many? Will the animals be stall-fed, 4) Where possible, fencing the grazing areas to use pastured or free-ranging? them subsequently, giving to others possibility to restore, etc. 5) Not to graze in natural areas in early spring and late autumn, etc. ) 6) Use natural meadows and grasslands rather for mowing than grazing, etc. Land degradation: Will the project involve land 1) Removal of topsoil to adjacent agricultural lands excavation? Generation of solid wastes – what type of 1) Separation of wastes, their usage and recycling wastes will be generated (various types of 2) Disposal on authorized landfills construction wastes, wastes from agro- 3) Full utilization of manure as organic fertilizers processing activities, livestock manure) and their approximate amount Generation of toxic wastes – what types of toxic 1) Clearly marking toxic wastes on the project site as waste will be generated (obsolete and unusable hazardous material and securely enclose them inside pesticides and mineral fertilizers; chemicals closed containments, as well as label them with details used in agro processing activities; asbestos) and of composition, properties and handling information; their approximate amount. 2) Disposal on special toxic wastes disposal sites. 3) Usage of specially licensed carriers for transportation and disposal of toxic wastes 4) Ensure containers with hazardous substances are placed in an leak-proof container to prevent spillage and leaching; 5) Ensure the asbestos is not reused Biodiversity and Habitats Loss: Will the project 1) Consideration of alternative locations, where located in vicinity of protected areas or other possible sensitive areas supporting important habitats of 2) Careful timing of works and work seasonally, as natural fauna and flora? Is it planned appropriate: no construction during breeding season enlargement of area under agricultural crop 3) Where possible, to fence the area under construction production based on transformation of natural to lessen even occasional disturbance on habitats and habitats? biodiversity 4) Inform personnel about importance of adjacent environmentally important area, if any 5) Where possible, to plant (or maintain) green corridors to ensure movement of terrestrial fauna Underground water pollution – does the project 1) Fuel and lubricants: use of specially arranged sites involve usage of fuel and lubricants? if the (with concrete floor) for fuel and lubricants handling project involves production of stall fed livestock and storage to avoid their leakages into the soil and does it has a manure platform? runoff into water bodies 2) Pesticides: see above 3) Use of special platforms and tanks with a waterproof bottom for accumulation of manure and preparing of organic fertilizers, etc. Construction 1) Careful selection of location for and planning of the project 2) To minimize construction site’s size and design 45 work to minimize land affected, 3) Where possible, to execute construction works during dry season to avoid excessive contaminated runoff 4) Properly arranged waste disposals 5) Cleaning of construction site, replacing lost trees, boundary structures, re-vegetation of work area Air quality Will the project provide pollutant emissions? 1) Use of approved methods and techniques to prevent Which types of pollutants (SOx, NOx, solid and control emissions (e.g. absorption) particles, dioxins, furans, etc) 2) Where possible, enclosure of dust producing equipment, and use of local exhaust ventilation 3) Arrange barriers for wind protection (if raw material is stored in open piles 4) Where possible, use of fuels with a low sulfur content, such as natural gas or liquefied petroleum gas and use of low-sulfur raw material 5) Where possible, installation of dedicated filtration systems, etc 6) Selection of materials or processes with no or low demand for VOC-containing products 7) Where possible, to install and modify equipment to reduce solvent use in manufacturing process 8) To execute strict primary and secondary control of air emissions, etc. Water Quantity: will the project involve water 1) To ensure natural flow of water/ minimum use? Which volumes and from which water disruption of natural streams flows source (centralized water supply system and/or 2) To install water meters to control and minimize from water reservoir)? water use 3) Avoid or minimize surface water abstraction in case of downstream the wetland is situated, etc. Water Quality/Pollution: Will the project 1) a. For small rural enterprises: to install local contribute to surface water pollution – what will wastewater treatment facilities (e.g., septic tanks) be the approximate volumes of waste water b. For big enterprises: not to exceed established limits discharge? Does the project involve discharges of pollutants in effluents of waste waters in water reservoirs and/or in 2) To minimize water and mud collection centralized sanitation network/septic tank? 3) Renovation of existing sewerage system/ connection to municipal sewerage system 4) Properly arranged waste disposals 5) Where possible, to plant at least bush vegetation down slope to reduce pollutants runoff into surface water bodies Loss of Biodiversity: Will the project involve 1) Where possible, to avoid introduction of alien introduction of alien species (in case of species aquaculture projects)? 2) In case of use of already introduced alien species to ensure their non-coming into natural ecosystems, e.g., during water discharge from ponds, etc. Loss of Biodiversity: Will the project located in 1) Not to exceed established limits of pollutants in vicinity of protected area or wetlands? effluents and emissions 2) To avoid or minimize construction and operational activities during breeding and migration periods, etc. Degradation of water ecosystems 1) Avoid application of pesticides in the strip with 46 width of 300 m along the natural surface water bodies, 2) Avoid cutting of trees and other natural vegetation along the water bodies 3) Avoid coming of alien species into natural water bodies, 4) Properly arranged waste disposals sites, etc. Weeds, pests, diseases: will the project 1) Avoid cultivation of plant mono-culture on contribute to spreading of weeds, pests and agricultural lands animal and plant diseases? 2) Appropriate pest management 3) Giving the priority to the agro-technical and biological measures for the control of weeds, pests, and diseases, 4) In cattle farms, to adhere carefully established rules to prevent or minimize animal diseases, etc. Sedimentation of water bodies – will the project 1) To avoid excessive soil erosion: see above contribute to sedimentation of water bodies due 2) Minimize soil processing to soil erosion ? 3) Provide retention/ sedimentation ponds, as necessary 4) To control reed harvesting ( to avoid over- harvesting) Socio-economic environment Social impacts – does the project involve the Appropriate project design: location, methods of following: (a) occupational safety issues; (b) construction, use of safe technologies during operation health hazards; (c) involuntary land acquisition period, work timing, careful decommissioning, etc. or displacement of third parties using land;; (d) loss of the access to sources of income; (e) loss Projects which result in involuntary land acquisition or of physical and/or economic assets; and (f) displacement of third parties using land; relocation or disturbance of residents living near the project loss of shelter, loss of assets or access to assets, or loss area. of income sources or means of livelihood whether or not there is displacement will not be financed by the project. Does the project per national legislation require If yes, anticipated public concerns, e.g., project public consultation to consider local people location, waste disposal sites, harmful emissions into environmental concerns and inputs? environment, and aesthetic arrangement of constructed sites? etc. Will the project assure non-deterioration of 1) To ensure collective and individual protective human health, occupational safety and non- measures (work clothes, masks, shoes), when needed. disturbance of residents living near project area? 2) To adhere established occupational safety If no, is it possible by applying proposed requirements as well as simple rules, e.g.: mitigation measures to reduce the project a. water spaying twice a day during construction to environmental and social impacts to admissible avoid dust levels? b. ventilation of internal areas during and post construction c) timing of work 3) To conduct regular instructing of employees on health and occupational safety requirements 4) To restrict vehicle speeds and trough-traffic in residential areas, especially trucks, using signing and appropriate design 5) Restrict trough-traffic in residential areas 6) Work timing to minimize disturbance/ restrict 47 construction to certain hours, 7) Restrict movement of hazardous materials in residential areas/ regulation of transportation of materials; apply any load restriction required during and post construction periods, 8) Incorporate safety and environment protection requirements in the project contract documents, etc. 48 Annex A/ Form 1 Part 2 (to be completed by the PFIs based on the findings of the environmental screening and scoping process) 5. Project Environmental Category (B or C) _____ 6. Environmental Assessment required (yes or no) _____ 7. Type of Environmental Assessment (for Category B projects - partial EIA and/or EMP checklist) _________________________________________________________________________ 8. Types of EA documents (partial EIA, including site assessment and Environmental Management Plan for category B projects; Site Assessment and EMP checklists for small scale category B projects) _________________________________________________________________________________ 9. What environmental issues are raised by the sub-project? __________________________________________________________________________________________ __________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________ Environmental Screener: Date: 49 Annex A/ Form 1 Part 3 Final Environmental Assessment Checklist (to be completed by the PFIs (in consultation with PIU Environmental Specialist and/or State Committee for Environmental Protection and Forestry) based on review of the mitigation proposed and the environmental assessment (if required). Was an Environmental Assessment needed? (Y or N) ___ If yes, was it done? ___ Was an Environmental Management Plan prepared? (Y or N) ________ Are the mitigation measures to be included in project implementation adequate and appropriate? (Y or N) ________ Will the project comply with existing pollution control standards for emissions and wastes? (Y or N) _____ If no, will an exemption be sought? _____ ______ Is an Environmental Monitoring Plan necessary? (Y or N) ___ If so, has it been prepared? (Y or N) __Approved by the PFIs? ___________ What follow-up actions are required by the proponent, the PFIs or the PIU Environmental Specialist? _______________________________________________________________________________ _______________________________________________________________________________ _______________________________________________________________________________ Were public consultations held concerning potential environmental impacts of the proposed sub-project? (Y or N)_______Were minutes recorded? (Y or N)_____ Annex 1: minutes of consultation _____________________ __________________________________________________________ _____________________ __________________________________________________________ _____________________ __________________________________________________________ Project Officer: Date: Environmental Screener: Date: 50 Annex A/Form 2 FIELD SITE VISIT CHECKLIST12 Project Name: Date/time of Visit: Raion: Visitors: Current activity and site history  Who is the site contact (name, position, contact information)?  What is the area of the site to be used for project activities?  What are current uses of the site? Are there any structures on the site?  What were previous uses of the site (give dates if possible)? Environmental Situation  Are there sensitive sites nearby (nature reserves, cultural sites, and historical landmarks)?  Are there water courses on the site?  What is the terrain or slope?  Does the site experience flooding, water logging or landslides? Are there signs of erosion?  What are the neighbouring buildings (e.g. schools, dwellings, industries) and land uses? Estimate distances.  Will the proposed site affect transportation or public utilities? Licenses, Permits and Clearances  Does the site require licenses or permits to operate the type of activity proposed? Are these available for inspection?  What environmental or other (e.g., health, forestry) authorities have jurisdiction over the site? Water Quality Issues  Does the proposed activity use water for any purposes (give details and estimate quantity). What is the source?  Will the proposed activity produce any effluent? (estimate quantity and identify discharge point)  Is there a drainage system on site for surface waters or sewage? Is there a plan available of existing drainage or septic systems?  How waste water is managed (surface water courses, dry wells, septic tanks)? Soils  What is the ground surface (agricultural land, pasture, etc.)?  Will the project damage soils during construction or operations?  Will the project affect the landscape significantly (draining wetlands, changing stream courses) 12 This checklist will be completed specifically for each sub-project site as not all these aspects are relevant to all types of projects 51 Biological environment  Describe vegetation cover on the site.  Is there information about rare or threatened flora and fauna at or near the site? If yes, would the project have an impact or increase risk to the species?  Obtain a list of vertebrate fauna and common plants of the site (if available).  Note potential negative impacts on biota if project proceeds. Visual Inspection Procedures  Try to obtain a site map or make a sketch to mark details.  Take photos, if permitted.  Walk over as much of the site as possible, including boundaries, to note adjacent activities.  Note any odours, smoke or visual dust emissions, standing water, etc.  Note any signs of recent destruction of crops or physical structures. Confirm that there has been no loss of physical and/or economic assets, that no informal land users have been displaced in preparation for the project. This can be done through visual inspection, discussions with the project proponent and nearby individuals, as necessary. 52 53 Annex A/ Form 3 Environmental Management Plan Checklist (for small scale construction/rehabilitation subprojects) ENVIRONMENTAL /SOCIAL SCREENING Will the site Activity Status Additional references activity A. Building rehabilitation [ ] Yes [ ] No See Section B below include/involveB. New construction [ ] Yes [ ] No See Section B below any of the C. Individual wastewater treatment system [ ] Yes [ ] No See Section C below following: D. Historic building(s) and districts [ ] Yes [ ] No See Section D below E. Acquisition of land or loss of assets13 [ ] Yes [ ] No See Section E below 14 F. Hazardous or toxic materials [ ] Yes [ ] No See Section F below G. Impacts on forests and/or protected areas [ ] Yes [ ] No See Section G below H. Handling / management of medical waste [ ] Yes [ ] No See Section H below I. Traffic and Pedestrian Safety [ ] Yes [ ] No See Section I below ACTIVITY PARAMETER MITIGATION MEASURES CHECKLIST A. General Notification and Worker (a) The local construction and environment inspectorates and communities have been notified Conditions Safety of upcoming activities (b) The public has been notified of the works through appropriate notification in the media and/or at publicly accessible sites (including the site of the works) (c) All legally required permits have been acquired for construction and/or rehabilitation (d) All work will be carried out in a safe and disciplined manner designed to minimize impacts on neighboring residents and environment. (e) Workers will comply with international good practice (always hardhats, as needed masks and safety glasses, harnesses and safety boots) (f) Appropriate signposting of the sites will inform workers of key rules and regulations to follow. B. General Air Quality (a) During interior demolition use debris-chutes above the first floor Rehabilitation (b) Keep demolition debris in controlled area and spray with water mist to reduce debris dust and /or (c) Suppress dust during pneumatic drilling/wall destruction by ongoing water spraying and/or Construction installing dust screen enclosures at site Activities (d) Keep surrounding environment (side walks, roads) free of debris to minimize dust 13 The project will support construction of new buildings only when the construction will not result in the taking of land resulting in: involuntary land acquisition or displacement of third parties using land; loss of assets or access to assets; or loss of income osurces or means of livelihood, whether or not the affected persons must move to another location. Investors will be required to have landownership title as well as has to prove the land at the moment of subprojects application is not occupied or used even illegally. 14 Toxic / hazardous material includes and is not limited to asbestos, toxic paints, removal of lead paint, etc. 54 (e) There will be no open burning of construction / waste material at the site (f) There will be no excessive idling of construction vehicles at sites Noise (a) Construction noise will be limited to restricted times agreed to in the permit (b) During operations the engine covers of generators, air compressors and other powered mechanical equipment should be closed, and equipment placed as far away from residential areas as possible Water Quality (a) The site will establish appropriate erosion and sediment control measures such as e.g. hay bales and / or silt fences to prevent sediment from moving off site and causing excessive turbidity in nearby streams and rivers. Waste management (a) Waste collection and disposal pathways and sites will be identified for all major waste types expected from demolition and construction activities. (b) Mineral construction and demolition wastes will be separated from general refuse, organic, liquid and chemical wastes by on-site sorting and stored in appropriate containers. (c) Construction waste will be collected and disposed properly by licensed collectors (d) The records of waste disposal will be maintained as proof for proper management as designed. (e) Whenever feasible the contractor will reuse and recycle appropriate and viable materials (except asbestos) C. Individual Water Quality (a) The approach to handling sanitary wastes and wastewater from building sites (installation or wastewater reconstruction) must be approved by the local authorities treatment (b) Before being discharged into receiving waters, effluents from individual wastewater system systems must be treated in order to meet the minimal quality criteria set out by national guidelines on effluent quality and wastewater treatment (c) Monitoring of new wastewater systems (before/after) will be carried out D. Historic Cultural Heritage (a) If the building is a designated historic structure, very close to such a structure, or located in building(s) a designated historic district, notify and obtain approval/permits from local authorities and address all construction activities in line with local and national legislation (b) Ensure that provisions are put in place so that artifacts or other possible “chance finds” encountered in excavation or construction are noted, officials contacted, and works activities delayed or modified to account for such finds. E. Acquisition (a) If the activity will result in the taking of land resulting in: involuntary land acquisition or of land or loss Activity will not eligible displacement of third parties using land; loss of assets or access to assets; or loss of income sources of assets or means of livelihood, whether or not the affected persons must move to another location it will not be financed. (b) F. Toxic Asbestos management (a) If asbestos is located on the project site, mark clearly as hazardous material Materials (b) When possible the asbestos will be appropriately contained and sealed to minimize 55 exposure (c) The asbestos prior to removal (if removal is necessary) will be treated with a wetting agent to minimize asbestos dust (d) Asbestos will be handled and disposed by skilled & experienced professionals (e) If asbestos material is be stored temporarily, the wastes should be securely enclosed inside closed containments and marked appropriately (f) The removed asbestos will not be reused Toxic / hazardous waste (a) Temporarily storage on site of all hazardous or toxic substances will be in safe containers management labeled with details of composition, properties and handling information (b) The containers of hazardous substances should be placed in an leak-proof container to prevent spillage and leaching (c) The wastes are transported by specially licensed carriers and disposed in a licensed facility. (d) Paints with toxic ingredients or solvents or lead-based paints will not be used G. Affects Protection (a) All recognized natural habitats and protected areas in the immediate vicinity of the activity forests and/or will not be damaged or exploited, all staff will be strictly prohibited from hunting, foraging, protected areas logging or other damaging activities. (b) For large trees in the vicinity of the activity, mark and cordon off with a fence large tress and protect root system and avoid any damage to the trees (c) Adjacent wetlands and streams will be protected, from construction site run-off, with appropriate erosion and sediment control feature to include by not limited to hay bales, silt fences (d) There will be no unlicensed borrow pits, quarries or waste dumps in adjacent areas, especially not in protected areas. H. Disposal of Infrastructure for medical (a) In compliance with national regulations the contractor will insure that newly constructed medical waste waste management and/or rehabilitated health care facilities include sufficient infrastructure for medical waste handling and disposal; this includes and not limited to:  Special facilities for segregated healthcare waste (including soiled instruments “sharps”, and human tissue or fluids) from other waste disposal; and  Appropriate storage facilities for medical waste are in place; and  If the activity includes facility-based treatment, appropriate disposal options are in place and operational I Traffic and Direct or indirect hazards to(b) In compliance with national regulations the contractor will insure that the construction site Pedestrian public traffic and pedestrians is properly secured and construction related traffic regulated. This includes but is not limited to Safety by construction activity  Signposting, warning signs, barriers and traffic diversions: site will be clearly visible and the public warned of all potential hazards  Traffic management system and staff training, especially for site access and near-site heavy traffic. Provision of safe passages and crossings for pedestrians where construction traffic interferes. 56  Adjustment of working hours to local traffic patterns, e.g. avoiding major transport activities during rush hours or times of livestock movement  Active traffic management by trained and visible staff at the site, if required for safe and convenient passage for the public.  Ensuring safe and continuous access to office facilities, shops and residences during renovation activities, if the buildings stay open for the public. 57 Annex A/Form 4 ENVIRONMENTAL SCREENING CHECKLIST For existing facilities Part 1 (to be completed by Sub-borrower) 1. Subproject title ____________________________________________________________ 2. Brief Description of sub-project (nature of the project, project cost, physical size, site area, location, facility history, operational/production activities, technological processes etc.) _____________________________________________________________________ _____ _____________________________________________________________________ _____ _____________________________________________________________________ _____ 3. Inputs, output (products) and waste stream (row materials, natural resources (e.g. water) and energy used in operational/production activities, final products, effluents and technological wastes, secondary materials, waste disposal etc.) _____________________________________________________________________ _____ _____________________________________________________________________ _____ _____________________________________________________________________ _____ 4. Key Environmental, Health and Safety aspects of the facility’s operation (potential impacts and risks caused by operational activities (e.g. industrial solid wastes, contaminated waste waters, air emissions, noise pollution), mitigation measures during operational/technological processes, preventive actions etc.) _____________________________________________________________________ _____ _____________________________________________________________________ _____ _____________________________________________________________________ _____ 5. Regulatory Compliance Status (per local environmental and sanitary inspection conclusions) _____________________________________________________________________ 58 _____ _____________________________________________________________________ _____ _____________________________________________________________________ _____ 6. Environmental authorizations, licenses and permits (as requested by the national legislation and relevant to proposed sub-project activities: check  and specify if any) a. State Ecological Expertise b. Special water use and waste water discharge authorization c. Air emissions authorizations d. Waste disposal permit e. License for special type of activity (specify) f. License for mineral resources usage g. Permit for usage of wild fauna and flora h. Sanitary operational authorization i. Sanitary and veterinary operational authorization j. Other as per national legislation (specify) 7. Environmental expenditures (for Environmental management and Environmental pollution and/or for Natural resources usage; please fill a table) Expenditure Item Total Calculated per Year, MDL Last payment, Date/MDL 1. 2. Sub-borrower: ________________ Signature: ________________ Date: _________________ 59 Annex A/Form 4 For existing facilities Part 2 (to be completed by the FI) 1. Sub-project category (B or C) 2. Environmental compliance with environmental standards (yes / no) 3. Environmental Auditing (conducted or not) 4. Environmental authorizations, licenses and permits (check  and specify if any) a. State Ecological Expertise b. Special water use and waste water discharge authorization c. Air emissions authorizations d. Waste disposal permit e. License for special type of activity (specify) f. License for mineral resources usage g. Permit for usage of wild fauna and flora h. Sanitary operational authorization i. Sanitary and veterinary operational authorization j. Other as per national legislation (specify) 5. Facility’s Environmental and Sanitary inspections (main conclusions regarding EHS compliance) 6. Payments for the environmental pollution (done or not) Project officer: _________________ Signature: _______________ Date: ______________ 60 Annex 4/FORM 4 For existing facilities Part 3 (to be completed by the PIU Environmental Specialist) 1. Was an Environmental Auditing conducted? (yes / no) [ Da] 2. Was an Environmental Action Plan prepared? (yes / no) [Da ] 3. Will the project comply with existing pollution control standards for emissions and wastes? (yes / no) [Da ] If “no”, will an exemption be sought? [Da ] 4. Is an Environmental Monitoring Plan necessary? (yes / no) [Da ] If so, has it been prepared? (yes or no) [Da ] Approved by the PIU Environmental Consultant? [Da ] 5. Are all relevant environmental authorizations, licenses and permits obtained? (yes / no) [Da ] 6. Is the facility in compliance with the environmental standards? (yes / no) [Da ] 7. What follow-up actions are required by the proponent, the PFI or the PIU? _____________________________________________________________________________________ ________ _____________________________________________________________________________________ ________ _____________________________________________________________________________________ ________ 8. Conclusions: _____________________________________________________________________________________ ________ _____________________________________________________________________________________ ________ ______________________________________________________________________________ PIU Environmental Consultant: _____________ Signature: __________ Date: __________ 61 Annex B/ Form 1 Part 1 Environmental Management Plan Content General Remarks. An Environmental Management Plan (EMP) should outline the mitigation, monitoring and administrative measures to be taken during project implementation to avoid or eliminate negative environmental impacts. (Description of Environmental Management Plan is provided in Annex B/ Form 1 below). The Environmental Management Plan format provided in Annex B/ Form 2 below. It represents a model for development of an EMP. The model divides the project cycle into three phases: construction, operation and decommissioning. For each phase, the preparation team identifies any significant environmental impacts that are anticipated based on the analysis done in the context of preparing an environmental assessment. For each impact, mitigation measures are to be identified and listed. Estimates are made of the cost of mitigation actions broken down by estimates for installation (investment cost) and operation (recurrent cost). The EMP format also provides for the identification of institutional responsibilities for "installation" and operation of mitigation devices and methods. To keep track of the requirements, responsibilities and costs for monitoring the implementation of environmental mitigation identified in the analysis included in an environmental assessment a monitoring plan is necessary. A Monitoring Plan format is provided in Annex B/ Form 3 below and includes a row for baseline information that is critical to achieving reliable and credible monitoring. The key elements of the matrix are:  What is being monitored?  Where is monitoring done?  How is the parameter to be monitored to ensure meaningful comparisons?  When or how frequently is monitoring necessary or most effective?  Why is the parameter being monitored (what does it tell us about environmental impact)? In addition to these questions, it is necessary to identify the costs associated with monitoring (both investment and recurrent) and the institutional responsibilities. When a monitoring plan is developed and put in place in the context of project implementation, the PIU will request reports at appropriate intervals and include the findings in its periodic reporting to the World Bank and make the findings available to Bank staff during supervision missions. 62 Annex B/ Form 1 Part 2 Description of the of the Environmental Management Plan The Environmental Management Plan (EMP) identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. Specifically, the EMP (a) identifies and summarizes all anticipated significant adverse environmental impacts (including those involving indigenous people or involuntary resettlement); (b) describes--with technical details--each mitigation measure, including the type of impact to which it relates and the conditions under which it is required (e.g., continuously or in the event of contingencies), together with designs, equipment descriptions, and operating procedures, as appropriate; (c) estimates any potential environmental impacts of these measures; and (d) provides linkage with any other mitigation plans (e.g., for involuntary resettlement, indigenous peoples, or cultural property) required for the project. Monitoring 3. Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures. Such information enables the borrower and the Bank to evaluate the success of mitigation as part of project supervision, and allows corrective action to be taken when needed. Therefore, the EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EA report and the mitigation measures described in the EMP. Specifically, the monitoring section of the EMP provides(a) a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and (b) monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures, and (ii) furnish information on the progress and results of mitigation. Capacity Development and Training 4. To support timely and effective implementation of environmental project components and mitigation measures, the EMP draws on the EA's assessment of the existence, role, and capability of environmental units on site or at the agency and ministry level. 3 If necessary, the EMP recommends the establishment or expansion of such units, and the training of staff, to allow implementation of EA recommendations. Specifically, the EMP provides a specific description of institutional arrangements - who is responsible for carrying out the mitigation and monitoring measures (e.g., for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and staff training). To strengthen environmental management capability in the agencies responsible for implementation, most EMPs cover one or more of the following additional topics: (a) technical assistance programs, (b) procurement of equipment and supplies, and (c) organizational changes. Implementation Schedule and Cost Estimates 5. For all three aspects (mitigation, monitoring, and capacity development), the EMP provides (a) 63 an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and (b) the capital and recurrent cost estimates and sources of funds for implementing the EMP. These figures are also integrated into the total project cost tables. Integration of EMP with Project 6. The borrower's decision to proceed with a project, and the Bank's decision to support it, is predicated in part on the expectation that the EMP will be executed effectively. Consequently, the Bank expects the plan to be specific in its description of the individual mitigation and monitoring measures and its assignment of institutional responsibilities, and it must be integrated into the project's overall planning, design, budget, and implementation. Such integration is achieved by establishing the EMP within the project so that the plan will receive funding and supervision along with the other components. Resource: OP 4.01, Annex C - Environmental Management Plan. http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUAL 64 Annex B/ Form 2 Environmental Management Plan Format Phase Environmental Mitigating Cost Institutional Remarks Impact Measure(s) Responsibility Install Operate Install Operate Construction         Operation          Decommissioning        65 Annex B/ Form 3 Example of an Environmental Monitoring Plan for small scale construction WHEN HOW WHY WHAT WHERE is the is the PHASE parameter to is the parameter COST RESPONSIBILITY is the parameter to be is the parameter to parameter to be being monitored? be monitored? be monitored? monitored? monitored?? (frequency)? Prior Recommended approval for Design project for Review of due to national Implementation of EMP construction Should be CEP construction, elaborates and legislation guidelines as part of part of the Designing reconstruction and adaptation requiring a Designer, Contractor (RECOMMENDATIONS) project Project adaptation. designs. construction monitoring permit. program. Regular review A part of During stipulated in the regular Included in Supervision Parameters given in construction Law, and if any inspection by the Engineer, construction permit - all and prior to public complaint Construction Main Project the Ministry of construction inspectorate of the special conditions of issuance of is sent to the documentation Environment phase, costs CEP and construction issued by the Ministry of and the of Construction different bodies Operation Environment, or Construction Contractors Inspection permit the Construction Inspection Inspection. 66 WHEN HOW WHY WHAT WHERE is the is the PHASE parameter to is the parameter COST RESPONSIBILITY is the parameter to be is the parameter to parameter to be being monitored? be monitored? be monitored? monitored? monitored?? (frequency)? Expenditure of the Supporting A part of Ministry Supervision documents for regular After Needed in Environment Engineer, waste, which is inspection by Construction waste reporting on accordance with and the inspectorate of the submitted to the the Ministry management (including waste the waste-related Construction CEP and competent Environment hazardous) management regulations Inspection Construction communal Construction and low Inspection enterprise Inspection costs for the Contractor Based on the After Should be Costs of the supporting reporting to monitored in line project Project beneficiary, documents for Reports to the the Ministry with the beneficiary competent Waste management waste, which is Ministry of of Operation regulations on and the communal company submitted to the Environment Environment waste Ministry of and the CEP Ministry of on waste management. Environment Environment management. 67 Annex C15 Impacts, Causes, Consequences and Mitigation measures for sub-projects in Agricultural Production Sector C-1 Mammalian livestock production* C-2 Poultry production* C-3 Annual crop production & plantation crop production, including orchards and vineyards* C-4 Seeds C-5 Fertilizers application C-6 Pesticides application C-7 Agricultural machinery (tractors, winnowers, sowing machines, etc.) C-8 Vehicles C-9 Buildings for crop stock, machinery and other agricultural needs *Resource: Environmental, Health, and Safety Guidelines. World Bank Group, 2007. http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines 15 Mitigation measures presented here will be complemented by relevant monitoring activities once the specific EMP for a sub-project will be developed. 68 Table C-1. Mammalian livestock production Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Overall Potential Impact: MODERATE TO HIGH Contribution to soil, Animal wastes can be Damage to environment Wastes should be managed Animal waste surface water and either liquid, slurry, or and disposed appropriately management systems groundwater pollution solid, depending on the involve the from generated wastes solids content collection, transport, Solid waste includes waste storage, treatment, and feed, animal waste, and utilization (rather than carcasses. disposal) of the waste to reduce such adverse  Waste Feed Livestock feed includes To maximize the efficiency impacts hay, grain and silage. of the operation and minimize Other wastes include wasted feed various kinds of packaging, used cleaning materials, and sludge from septic tanks Most of the animal waste is generated at housing, feeding, and watering  Animal Waste locations Migration of contaminants to and - To arrange manure storage pollution of surface facilities to prevent soil, Manure may be used as a water, groundwater and surface water and fertilizer on agricultural air groundwater pollution land after careful - Minimize the surface area assessment of potential of manure in storage impacts due to the -Locate manure stacks away presence of hazardous from water bodies chemical and biological - Place dry manure or litter constituents 69 in a covered or roofed area; - Check for storage systems leakage regularly (e.g. inspect tanks for corrosion of seams) -Conduct manure spread only as part of well planned . Ensure that manure is strategy that considers applied to agricultural land potential risks to health only during periods that are appropriate for its use as plant nutrient Animal Carcasses (generally just before the Mammalian meet start of the growing processing -Reduce mortalities through season) proper animal care and disease Animal carcasses should prevention; be properly managed and -Store carcasses until quickly disposed to collection, using cooling if prevent the spread of necessary to prevent odors putrefaction; - Where no authorized collection of carcasses is available, on-site burial may be one of the only viable alternatives, if allowed by the competent authorities Contribution to surface Livestock operations Effluents due to runoff To reduce discharges to Techniques for treating and underground water generate on-point source from livestock housing, surface water and industrial process pollution/ Wastewater Some facilities may also feeding, and watering, groundwater from wastewater in this sector include point sources waste management mammalian livestock include: which typically require facilities, and areas of operations: - Sedimentation for collection and treatment land application of - Reuse water used for suspended solids reduction 70 prior to final discharge manure cleaning milking equipment - Biological treatment, to clean typically anaerobic the milking parlor; followed by aerobic - Reduce water use and spills treatment, for reduction of from animal watering by soluble organic matter preventing overflow (BOD); -Implement buffer zones to - Biological nutrient surface water bodies, removal for reduction in avoiding nitrogen and land spreading of manure phosphorus; within these areas; - Chlorination of effluent - To reduce water when disinfection is consumption, especially required where it may be a limited natural resource Air pollution/ Air Air emissions include Ammonia gas has a sharp - Consider the sitting of new The livestock account for Emissions ammonia, methane, odors, and pungent odor can act facilities taking into account 9% of anthropogenic CO2 and dust (e.g. form feed as an irritant when distances to neighbors and emissions (mostly from storage, loading, and present in high enough the propagation of odors; deforestation / land use unloading) concentrations. - Control the temperature, changes for grazing and humidity, and other pasture for feed crops), environmental factors of 37% of anthropogenic manure storage to reduce methane emissions emissions; (mostly from enteric - Consider composting of fermentation by manure to reduce odor ruminants), and 65 percent emissions; of anthropogenic nitrous - Reduce emissions and oxide emissions, the odors during land majority of which from application manure. activities by applying a few Methane has 23 times the centimeters below the soil global warming potential surface and by selecting (GWP) of CO2, while 71 favorable weather conditions nitrous oxide has 296 (e.g. wind blowing away times the GWP of CO2. By from inhabited areas); improving livestock - If necessary, apply production efficiency, chemicals (e.g. urinase producers can both inhibitors) weekly to reduce increase profits and reduce conversion of nitrogen to methane emissions. ammonia Methane can also be - Control the temperature, produced from microbial humidity, and other action in manure environmental factors of manure storage to reduce methane and nitrous oxide emissions;. - Implement pasture/grazing management techniques to Dust reduce visibility, reduce nitrous oxide and  Dust cause respiratory methane emissions; problems, and - Install dust-collection facilitate the transport of systems at dusty operations, odors and diseases such as feed grinding; - Prevent overgrazing of pastureland; - Implement fugitive-dust- control measures, such as wetting frequently traveled dirt roads, as necessary Soil and water pollution/ Pesticides may be applied Pesticides and their - Pesticides should be Integrated Pest Pesticides directly to livestock or to degradation products may managed to avoid their Management infra-structures. enter groundwater and migration into off-site land (IPM) inter alia include: Pesticides can also be used surface water in solution, or water environments by - Maintain structures to to control predators in emulsion, or bound to establishing their use as part keep out pests (e.g. plug 72 soil particles. of an integrated pest holes, seal gaps around Some are s known to management. doors and windows); cause chronic or acute - Use mechanical controls health hazards for - If the application of to kill, relocate, or repel humans as well as pesticides is warranted, spill pests; adverse ecological prevention and control - Use predators to control impacts measures consistent with the pests recommendations applicable to pesticides and other potential hazardous materials should be followed. - Use of less harmful (non- persistent) pesticides; - Not to apply more pesticides than needed; - To ensure appropriate pesticides handling to avoid contaminated surface runoff, etc. Other impacts  Environmental Livestock access to creeks, Contaminating the water - Prevent animals’ access to damage rivers, and other natural with animal waste, surface water bodies using water sources; destroying riparian fences, buffer strips or other habitat, eroding the physical barriers; stream banks  Overgrazing Alteration of the -Prevent overgrazing of vegetation composition Soil losses and a pastureland through use of: and associated organisms reduction in soil o Rotational grazing systems 73 in rangelands productivity based on seasonal and local ecosystem resilience (e.g. riparian zones); o through properly evaluated pasture capacities, which are from 0,3 conv. cattle capita per ha on degraded lands to 1,5 conv. cattle capita on good lands; - Use of stabling; - Not to pasture in early  Soil erosion spring and late autumn; - Use of livestock trails to reduce soil trampling and gully formation  Loss of Biodiversity -Prior or more intensive land use for livestock production, survey the area to identify natural and modified habitat types and ascertain their biodiversity value; - Ensure that any natural or modified habitat to be converted to livestock production does not contain critical habitat, - Ensure minimum disturbance to surrounding areas when managing livestock Animal diseases Animal diseases can enter Some diseases can - Control farm animals, 74 a weaken or kill large equipment, personnel, and facility with new animals, numbers of animals at an wild or domestic animals on equipment, and on or infected facility entering the facility; people - Vehicles that go from farm to farm should be subject to special precautions such as limiting their operation, etc. - Sanitize animal housing areas; - Identify and segregate sick animals and develop procedures for adequate removal and disposal of dead animals Residual Impact Assuming Full Mitigation: LOW– MODERATE; Risk: LOW Table C-2. Poultry production Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Overall Potential Impact: MODERATE TO HIGH Soil, groundwater and Solid waste generated Contribution to soil surface water pollution/ during poultry production pollution, surface water Wastes includes waste feed, and groundwater animal waste, carcasses, pollution and sediments and sludge from on-site wastewater treatment Other wastes include various kinds of packaging, used cleaning materials, etc - Protect feed from exposure Contamination of storm to rain and wind during 75  Waste Feed Poultry feed primarily water runoff, primarily processing, storage, consists of corn and soy, due to organic matter transport and feeding; although other grains, content - Maintain feed storage , pulses, root crops, and transport and feeding substances of animal systems in good working origin The feed is condition; typically supplemented fertilizer; with amino acids, - For waste feed which enzymes, vitamins, cannot be recycled due to mineral supplements, and potential may contain hormones biosecurity issues, antibiotics, and heavy alternative disposal methods metals should be secured in consultation with Collection, transport,  Animal Waste local health authorities storage, treatment, Air emissions of utilization and ammonia and other gases - Match feed content to the disposal of the waste. Manure contains - a potential risk of specific nutritional Manure is sometimes ammonia, nitrogen, contamination to surface requirements of the birds in composted, but can also be phosphorus, and other or groundwater resources their different production / stored in stacking sheds, excreted substances such through leaching and growth stages; roofed storage areas, as hormones, antibiotics, runoff - Ensure that manure storage outside and either covered and heavy metals, as well Pollution soil, water and facilities are arranged to or uncovered, or as bacteria and pathogens food resources prevent manure occasionally in ponds until contamination of surface it is ready for transport to water and ground water (e.g. a disposal site or land use of concrete floors, etc.) application area. - Keep waste as dry as Manure may be used as a possible, including by fertilizer on agricultural minimizing amount of water land after careful used during cleaning ; assessment of potential - Minimize the surface area impacts due to the of manure in storage; presence of hazardous 76 - Locate manure piles away chemical and biological from water bodies, constituents - Check for leakage regularly (e.g. inspect tanks for  Poultry Carcasses corrosion of seams), - Place dry manure or litter in a covered or roofed area; Poultry carcasses should be properly and quickly Land spread manure managed as they are a directly after batch significant source of disease cleaning and only during and odors, and can periods that are attract vectors. appropriate for its use as - Reduce mortalities through plant nutrient (generally proper animal care and just before start of the disease growing season) prevention; - Where no authorized collection of carcasses is available, on-site burial may be one of the only viable alternatives, if allowed by the authorities Contribution to surface Runoff from poultry Contamination of surface -Reduce water use and spills Possible techniques for and groundwater pollution/ housing, feeding, and water and groundwater from animal watering by wastewater treatment: Wastewater watering; with nutrients, ammonia, preventing overflow - Sedimentation for from waste storage and sediment, pesticides, - Install vegetative filters to suspended solids reduction Application of manure, pathogens, and feed trap sediment; - Biological treatment for may additives, such as heavy - Install surface water reduction of soluble generated non-point metals, hormones, and diversions to direct clean organic matter (BOD); source effluents due to antibiotics. runoff - Chlorination of effluent runoff Effluents from poultry around areas containing when disinfection is 77 operations typically have waste required; a high content of organic - Implement buffer zones to - Dewatering of residuals material, as well as surface water bodies, as and composting or land nutrients and suspended appropriate to local application of wastewater solids conditions and requirements; treatment residuals of - Avoiding land spreading of acceptable quality manure close to water bodies -To reduce water consumption, especially where it may be a limited natural resource Air pollution/ Air Include primarily To minimize emissions Emissions ammonia, Odors and dust Ammonia gas deposition - Consider the sitting of new  Ammonia and into surface waters may facilities taking into account Odors contribute to distances to neighbors and euthrophication. the propagation of odors; Release of ammonia gas - Consider composting of also reduces the nitrogen manure to reduce odor content and, therefore, the emissions; fertilizer value of the - Reduce emissions and manure odors during land application activities by applying a few centimeters below the soil surface and by selecting favorable weather conditions (e.g. wind blowing away from inhabited areas); - If necessary, apply chemicals (e.g. urinase inhibitors) 78 weekly to reduce conversion Reduce visibility, cause of nitrogen to ammonia  Dust respiratory problems, and facilitate transport of odors - Implement fugitive dust- and diseases control measures (e.g. wetting vehicle parking lots and frequently traveled dirt roads, as necessary) Water and soil pollution/ Pesticides may be applied Pesticides and their - Maintain structures to keep Pesticides should be Pesticides use directly to birds or to degradation products may out pests (e.g. plug holes, managed to avoid their infra-. Pesticides can also enter groundwater and seal migration into off-site land be used to control surface water in solution, gaps around doors and or water environments by predators. in emulsion, or bound to windows); establishing their use as soil particles. Pesticides - Use mechanical controls part of an Integrated Pest may, in some instances, (e.g. traps, barriers, light, Management (IPM) impair the uses of surface and waters and groundwater. sound) to kill, relocate, or Some pesticides are repel pests; known to cause - Use predators to control chronic or acute health pests. -Protect natural hazards for humans as enemies of well as adverse ecological pests by providing a impacts favorable habitat (e.g. bushes for nesting sites and other indigenous vegetation) that can house pest predators; - Use good housekeeping practices; - Consider covering manure piles with geotextiles (which 79 allow water to enter the pile and maintain composting activity) to reduce fly populations; - If pesticides are used, identify in the IPM plan the need for the pesticide and evaluate their effectiveness, to ensure that the pesticide with the least adverse impact is selected Animal Diseases Animal diseases can enter Some diseases can To minimize the a weaken or kill large potential for the spread of facility with new animals, numbers of animals at an poultry pathogens: or equipment, and on infected facility. Both - Establish sound biosecurity people. poultry manure and protocols for the entire carcasses contain poultry pathogenic organisms operation that control which can infect humans, animals, feed, equipment, for example viruses such and personnel, as Avian Influenza (strain entering the facility HN51), and parasites - Prevent the interaction of such as parasitical worms wild birds with feed, as this interaction could be a factor in the spread of avian influenza from sparrows, crows, etc. - Vehicles that go from farm to farm (e.g. transport of veterinarians, farm suppliers, buyers, etc.) should be subject to special 80 precautions such as limiting their operation to special areas - Sanitize bird housing areas; - Identify and segregate sick birds and adequately remove and dispose dead birds Residual Impact Assuming Full Mitigation: LOW– MODERATE; Risk: LOW Table C-.3. Annual crop production & plantation crop production Overall Potential Impact: MODERATE Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Water Consumption Water intake for irrigation: Stress on water resources - Select crops compatible Water management for with water availability in the annual crop production area; should aim to optimize - Maximize the use of crop yield, while available precipitation (“rain conserving the quantity harvesting”), where feasible, and quality of water by: resources o Reducing runoff by methods such as conservation tillage, terraces, and raised ridges that follow the land contour o Reduce seepage losses in channels o Control weeds on inter- row strips and keep them dry o Avoid over and under- irrigation to decrease 81 potential for soil salinization o Maintain border vegetation in canals and drainage systems Soil erosion and loss of Poor management Soil degradation Soil loss prevention productive capacity especially Soil erosion may be practices: due to excessive use of enhanced by heavy rain - Use crops suited or adapted machinery and over- falls, to the local climate and soil intensive farming practices storms, and steep or long conditions; slopes, and may - In areas with steep slopes, contribute to subsequent carefully consider planting sedimentation of surface zones and the direction of water bodies planting in relation to land contours to avoid erosion caused by precipitation or irrigation; - Use stone barriers, vegetative cross-slope barriers, terraces, or drainage and diversion canals to prevent wind and water erosion; - Use appropriate machinery to avoid soil compaction caused by excessively heavy equipment; - Use plant cover or intercrops and shelterbelts to reduce erosion from wind and heavy rain; - Increase the organic matter 82 content in the soil by applying organic matter such as crop residues, compost, and manure to protect the soil physically from sun, rain, and wind and to feed soil biota; - Consider adding lime to soil maintain stable pH levels Soil, groundwater and Application Contamination of soil, The preference should be Pesticides should be surface water pollution/ groundwater and surface given to alternative pest managed to avoid their Pesticides water by pesticides/ management strategies, with migration into off-site land impact on human health the use of synthetic chemical or water environments and biodiversity pesticides as a last option. Pesticide Application If pesticide application is warranted, then the following measures are recommended: -Train personnel to apply pesticides; -Review the manufacturer’s directions on maximum recommended dosage or treatment, and apply the minimum effective dose; -Avoid the use of banned and obsolete pesticides - Use only pesticides that are labeled in accordance with 83 international standards and norms; - Use certified application equipment; - Establish untreated buffer zones or strips along water sources, rivers, streams, ponds, lakes, and ditches to help protect water resources -Store pesticides in their original packaging, in a dedicated, dry, and well aerated location ; - Mixing and transfer of pesticides should be undertaken by trained personnel in areas, dedicated for this purpose; - Purchase and store no more pesticide than needed Surface water pollution/ Nutrients input from area Eutrophication of surface - Balance nutrient Nutrients under the crop production water/ dissolved oxygen application, including (mainly from mineral depletion considering the use of fertilizers) reduced or no soil tillage techniques, nutrient recycling, one-pass soil preparation and sowing; - Use crop rotation methods to enable cultivation of leguminous plants with nitrogen fixation capabilities; 84 - Use plants to cover the soil, especially during a fallow period to reduce loss of nutrients; - Incorporate organic waste materials into soils rather than burning; - Avoid excess fertilization; - Assess soil acidity, which is important for achieving maximum uptake of phosphates; - Not to apply solid or liquid manure directly onto grazing areas or edible crops Loss of biodiversity Soil degradation, Loss of Genetic - Where possible, maximize fragmentation and Resources and Variability reuse of residue from the disturbance of habitats, previous crop on the soil etc. surface; - Reduce soil preparation to maintain the structure of soil Ecosystems; - Utilize field borders to provide wildlife corridors around fields used for annual crop production; - Provide buffer zones on farmland bordering natural or semi-natural habitats; - Ensure protection of the natural enemies of pests by providing favorable habitats, 85 such as hedges, nesting sites, and original vegetation, to house pest predators; and - Promote the use of organic agricultural practices to the extent feasible Soil pollution/ Crop Often relate to pesticide -Recycle crop residues and residues and other solid containers and other organic materials by waste obsolete, expired leaving the materials in the pesticides fields, plowing, and / or composting; -Manage expired and unwanted pesticides as hazardous wastes Air pollution/ Air Fuel combustion by- -Manage emissions from emissions products resulting from the mechanized farm equipment operation of mechanized both mobile and stationary; equipment or from - Reduce particulate matter combustion by-products emissions by avoiding from the disposal or burning; destruction of crop - Avoid unintended residues. emissions of persistent organic pollutants (POPs) which may arise from open burning of pesticide treated agricultural wastes Residual Impact Assuming Full Mitigation: LOW– MODERATE; Risk: LOW 86 Table C-4. Seeds Overall Potential Impact: MODERATE Potential Impacts Causes Consequences Mitigation/prevention Remarks required Soil, groundwater and Surface water pollution by Avoid excess fertilization (for surface water pollution/ nutrients resulting in water other fertilize-related measures Use of chemical bodies eutrophication refer to Table B-.3 Annual Crop fertilizers, and pesticides Water and soil pollution by Production & Plantation Crop pesticides/ impact on Production); human health and -Avoid the use of banned and biodiversity obsolete pesticides - Use only pesticides that are labeled in accordance with international standards and norms (for other pesticide- related measures refer to Table B-3 Annual Crop Production & Plantation Crop Production) Risk for introduction ofTransfer of introduced Genetic drift into other - Use certified crop seeds that do genetically modified genes to other species areas where GMOs are not not contain seeds from plant seed (possibly weedy or wanted invasive alien species; invasive), unanticipated -The introduction of GMO crops impact on beneficial should be assessed for insects, or increased pest compliance with the existing resistance. Another concern host country regulatory related to framework for such the introduction or export introductions of plants and plant products is the potential for introduction of pests Residual Impact Assuming Full Mitigation: LOW– MODERATE; Risk: LOW 87 Table C-5. Fertilizers application Overall Potential Impact: MODERATE TO HIGH (cumulative impact) Direct Impacts Causes Consequences Mitigation Required Remarks Soil degradation/ Reliance on chemical Modified soil structure and -Apply organic matter, such To develop application Reduction in soil organic fertilizers which do not reduction in soil moisture as manure, to replace rates and best land content have an organic component holding capacity; increase chemical husbandry and crop – less reliance on compost in soil acidity. In the long fertilizers to the extent rotation plans material and manure for run, possible loss of practical; meeting soil fertility productivity as a result of -Incorporate manure into requirements. insufficient soil moisture; the soil or apply between loss of soil’s natural growing fertility crops to improve plant utilization of nutrients and thereby reduce nutrient loss, etc. Air pollution Emission of greenhouse Contribution to global - Where feasible, use gases from chemical warming resulting in biofuels instead of fossil fertilizers. climate change energy to reduce net GHG emissions; - Adopt reduced tillage options to increase the carbon storage capacity of soils Water pollution Nutrient enrichment of Eutrophication of water -Time the application of To develop and water bodies from fertilizer bodies crop nutrients using implement the most runoff Modified aquatic meteorological appropriate to the area ecosystems information to avoid, where land and crop practices . feasible, application during Impact form a single or husbandry will not be close to precipitation significant but events; cumulatively, -Use appropriate technical over many husbandries equipment for spraying within the same 88 manure; watershed the impact -Establish buffer zones, could be significant strips, or other “no- treatment” areas along water sources, rivers, streams, ponds, lakes, and ditches to act as a filter to catch potential runoff from the land Probable Residual Impact Assuming Full Mitigation: LOW – MODERATE Table C-6. Pesticides application* Significance of Overall Potential Impact: HIGH (cumulative impact) Potential Impacts Causes Consequences Mitigation Required Remark Diseases/ Illness Improper handling, Increased healthcare costs; Proper handling and use of application and storage of lost work time; lost family pesticides; pesticides. income. Proper storage of Consumption of crops with pesticides; high levels of pesticide Use only approved residues pesticides; Sanitary measures (proper cleaning, washing, etc.) (for other pesticide-related measures refer to Table B- 3) 89 Soil contamination Residual pesticides in soil. Loss of soil productivity; Use of approved pesticides long term loss / altered soil and recommended micro-fauna important to application rates, soil / plant relationships. scheduling and mode of application (for other pesticide-related measures refer to Table B-3) Loss of biodiversity Pesticide ingestion by Loss of fauna Use of approved pesticides fauna. and recommended application rates, scheduling and mode of application (for other pesticide-related measures refer to Table B-3) Water pollution Ground and surface water Impaired health of local Use of approved pesticides International waterways contamination. and downstream water and recommended may be affected. consumers; increased application rates, Pesticide use not likely health costs; lost work scheduling and mode of significant on a single time; lost family income application (for other husbandry but Damage to aquatic pesticide-related measures cumulatively on many ecosystems refer to Table B-3) farms within the same Loss of biodiversity. watershed, impact could be significant Probable Residual Impact Assuming Full Mitigation: MODERATE; Risk: HIGH * Note: More detailed description of the pesticides application and handling is presented in the Table C-.3. Annual crop production & plantation crop production of current volume and Chapter “Pest Management Issues” in Volume I. 90 Table C-7. Agricultural Machinery (tractors, winnowers, sowing machines, etc.) Significance of Overall Potential Impact: MODERATE TO HIGH Potential Impacts Causes Consequences Mitigation Required Remarks Soil and water pollution Contamination from Loss of soil productivity Good practices to be carried This is a minor impact and machine fuels and Decrease of crop out by equipment operators awareness to operators to lubricants. production Agricultural machinery refuel under safe Deterioration of potable should be kept in good conditions is all that would water quality conditions Fuels and be required. lubricants are to be stored and handled in devoted areas, etc. Air pollution CO2 releases Contribution to To ensure that all greenhouse gasses and machinery engines are global warming. efficient and well maintained Soil erosion Increase surface runoff Tillage against the contour Tillage on the contour To advise farmers on contributing to increased proper tilling techniques surface water bodies with tractors alluviation Reduced soil percolation capacity, etc. Soil compaction Use of heavy machinery Soil erosion and Ensure equipment of a size Large farms require more alluviation of water bodies that suitable for soil machinery Poor water permeability of conditions the soil profile/ decrease of soil moisture, etc. Probable Residual Impact Assuming Full Mitigation: LOW Table C-8. Vehicles Potential Overall Impact: LOW Potential Impacts Causes Consequences Mitigation Required Remarks Air pollution CO2 emissions Contribution to global Efficient engines 91 warming/ climate change. Where possible, to use- biofuel Soil and water pollution Use, handing and storage Leakages into soil and To maintain engine a good of fuel and lubricants groundwater conditions to avoid machine oil leakages To use specially organized sites for handling and storage of fuel and lubricants For other measures refer to Table C-13. Fuel & Lubricants’ Storage and Handling Probable Residual Impact Assuming Full Mitigation: LOW; Risk: LOW Table C-9. Buildings for crop stock, machinery and other agricultural needs Potential Overall Impact: LOW Potential Impacts Causes Consequences Mitigation Required Remarks Soil degradation/ Loss of Improper location of Reduced income from Location of buildings in This is not likely to be an productive topsoil buildings lower amount of crop sites with low soil important consideration production productivity; Proper design to minimize area under construction For other measures refer to Table E-1 Construction activities Residual Impact Assuming Full Mitigation: LOW; Risk: LOW 92 Annex D16 Impacts, Causes, Consequences and Mitigation measures for sub-projects in Agro-processing & Food production Sectors D-1 Poultry & meet processing* D-2 Dairy* D-3 Vegetable oil processing* D-4 Vegetable processing and canning* D-5 Flour milling D-6 Warehousing *Resource: Environmental, Health, and Safety Guidelines. World Bank Group, 2007. http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines 16 Mitigation measures presented here will be complemented by relevant monitoring activities once the specific EMP for a sub-project will be developed. 93 Table D-1. Poultry & meet processing Overall Potential Impact: HIGH (due to human health threat) Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Soil, groundwater and Slaughtering and Poultry: the carcass yield Poultry: Provision of surface water pollution/ rendering activities is, on average, 75% of the adequate slurry storage Solid organic wastes and live bird weight capacity for by-products excreta until it is transported for disposal or for use as Meet: Waste products and agricultural fertilizer by-products of Meet: continuously collect slaughtering processes by-products dry and The quantity of by- segregated from each other, products from cattle often along the length of the exceeds slaughter-line and 50%of the animal’s live throughout animal by- weight, and 10 to 20% for products treatment; optimise pigs bleeding and the collection Special Risk Materials of blood; use sealed, storage, (SRM handling and charging . facilities for animal by- products Animal and birds diseases Birds: Highly Pathogenic Batch of birds delivered to Other birds and human Poultry: Birds must be Avian Influenza (HPAI) the slaughterhouse is diseases. stored separately to avoid suspected of infection with contact with healthy birds Highly Pathogenic Avian - HPAI should be suspected Influenza (HPAI) when the dead-on-arrival frequency is abnormally high, and in connection with 94 other symptoms ( - If HPAI is confirmed, the entire carcass of the dead birds should be handled as high risk material and transported safely to a rendering facility. - The slaughterhouse should be cleaned and disinfected, and a minimum operational Livestock: bovine shutdown of 24 hours should spongiform be applied, etc. encephalopathy (BSE), etc. Livestock: should be separated and transported to external facilities in separate containers for treatment and final disposal. - Tissue of a livestock treated as Special Risk Material should be destroyed through incineration with a minimum gas temperature of 850oC; - Collecting animals not approved by veterinary inspection and segregating them from animal materials sent by the slaughterhouse for off-site rendering Soil and water pollution/ Poultry and meat Surface water, Poultry: Sludge Treatment and processing operators groundwater and soil - Reuse of high-quality, low Disposal pollution risk by-products; 95 - Disposal of fat at landfills if it cannot be used for biogas production Livestock: -Reuse materials that may be separated from pretreatment processes in the manufacture of high-quality by-products (e.g. pet food or technical fat for manufacturing); -If no other alternatives are feasible, dispose of fat at landfills Surface and groundwater Poultry processing Poultry & Meet: Poultry: pollution/ Wastewater activities Effluents with high - Organic materials to collect content of organic matter, separately for recycling; nitrogen, phosphorus, -Ensuring that leakage from residues of chemicals, animal by-product storage pathogens containers is avoided; -Use of dripping trays to collect blood to transport to the blood tank rather than into the wastewater stream; Application of appropriate tank and equipment cleaning procedures -Choosing cleaning agents and application rates that do not have adverse impacts on the environment, or on 96 wastewater treatment processes and sludge quality for Meet process activities agricultural application Meet: - Prioritize the removal of solid waste before it enters the wastewater stream; - Collect blood for use in food, feed or in the pharmaceutical industry; -Prevent direct runoff to water courses, especially from manure storage areas, etc Water Consumption Poultry & Meet Stress on water resources - Optimizing water processing operations consumption for rinsing and cooling without jeopardizing food safety; -Prefer a dry cleaning process areas before cleaning with water Air pollution/ Air Poultry & meet processing Poultry: emissions -Maintenance of clean live  Odor bird handling areas by removing fecal matter and dead birds on a daily basis; -Reducing the inventory of 97 raw carcasses, waste, and byproducts and minimizing any storage to short periods of time in a cold, closed, well- ventilated area. - Dead birds, waste, and byproducts should not be Meet: singeing, scalding, Meet: Odor may often be stored in open spaces, where lair age, wastewater the most significant form possible treatment and rendering of air pollution Meet: -Consider the location of new facilities, taking into account proper distances to neighbors and the propagation of odors; Pasteurize organic material before processing it to halt biological processes that generate odor;  Dust -Clean pens and livestock yards on a timely basis; -Empty and clean fat traps frequently Meet: -Clean and maintain a sufficient level of humidity in pens and livestock yards; Reduce fugitive dust by 98 minimizing surface areas with exposed soil surfaces, and by planting hedges or erecting fences to minimize wind turbulence, etc. Energy Consumption Heating of water and Stress on natural Poultry & Meet: producing steam for resources - Control of water process applications, levels and recirculation of cleaning purposes and water; operation of mechanical - Improvement in cooling and electrical equipment, efficiency by insulating refrigeration, and air refrigeration room / areas compressors and doors; installation of an automatic door closing mechanism, etc. Probable Residual Impact Assuming Full Mitigation: LOW Table D-2. Dairy Overall Potential Impact: HIGH (primarily due to human health threat) Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Contribution to surface Silk solids (e.g. protein, Significant organic To prevent contamination of water pollution/ fat, content, wastewater: Wastewater carbohydrates, and high salinity levels; other -Avoid milk, product, and lactose) pollutants: acids, alkali, by-product losses; Salting activities during and detergents, etc. as -Install grids to reduce or cheese well as pathogenic avoid the introduction of microorganisms and solid viruses materials into the wastewater drainage system; 99 -Adopt best-practice methods for facility cleaning systems, using approved chemicals and / or detergents with minimal environmental impact and compatibility with subsequent wastewater treatment processes Soil, groundwater and Production processes Nonconforming products -Where possible and subject surface water pollution/ and product losses, grid to sanitary requirements, Solid Waste and filter residues, sludge segregate solid process from waste and non-conforming centrifugal separators and products; wastewater treatment, and -Optimize product filling packaging waste and packaging equipment to avoid product- and packaging- material waste; -Optimize the design of packaging material to reduce the volume of waste - Plastic waste from packaging cuttings can be reused, or should be sorted as plastic waste for off-site recycling or disposal, etc. Air Pollution/ Air Dairy processing activities Fine milk powder Installation of exhaust Emissions residues in the exhaust air ventilation equipped with from the spray drying dry powder retention  Dust systems and bagging of systems (e.g. cyclones or Dairy processing product bag filters 100  Odor facilities are related to on- -Ensure wastewater site wastewater treatment treatment facilities are facilities, in addition to properly fugitive odor emissions designed and maintained for from filling/emptying milk the anticipated wastewater tankers and storage silos load; - Keep all working and storage areas clean; - Empty and clean the fat trap frequently (e.g. daily emptying and weekly cleaning); -Minimize stock of waste and by-products and store for short periods in cold, closed, and well-ventilated rooms Energy consumption Dairy processing facilities Stress on natural -Reduce heat loss by : Approximately 80% of the consume considerable resources - Using continuous, instead energy requirements are amounts of energy of batch, pasteurizers; for thermal uses to - Partially homogenizing generate hot water and milk to reduce the size of produce steam for process heat applications (e.g. exchangers; pasteurization, - Improve cooling efficiency evaporation, and milk drying) and cleaning purposes. The remaining 20% is used as electricity to drive processing machinery, refrigeration, ventilation, and lighting Probable Residual Impact Assuming Full Mitigation: NONE 101 Table D-3. Vegetable oil processing Overall Potential Impact: LOW Environmental issues/ Sources/ causes Consequences Prevention/ mitigation Remarks impacts required Soil, groundwater and Vegetable oil processing -Use uncontaminated sludge The amount of waste surface water pollution/ activities generate and effluent from on-site generated depends on the Solid waste and by- significant quantities of wastewater treatment as quality of the raw products organic solid waste and fertilizer in agricultural materials and the use or by-products. applications; reprocessing of the . Other solid wastes from -Dispose of contaminated discarded materials into the vegetable oil sludge from wastewater commercially viable by- manufacturing process treatment at a sanitary products include soap stock and landfill or by incineration. spent acids from chemical - Reduce product losses refining of crude oil; spent through better production bleaching earth containing control (e.g. monitor and gums, metals, and adjust air humidity to pigments; deodorizer prevent product distillate from the losses caused by the steam distillation of formation of molds on edible refined edible oils; materials) mucilage from degumming; and spent catalysts and filtering aid from the hardening process Contribution to surface Oil washing and -Use emulsion breaking water pollution/ neutralization (waters techniques to segregate high Wastewater contain organic, high BOD and COD oils from content of suspended wastewater; solids, organic nitrogen, - Use grids to cover drains in and oil and fat, and may the production area and to 102 contain pesticide residues prevent solid wastes and from the treatment of the concentrated liquids from raw materials entering the wastewater stream; - Select disinfection chemicals to match the cleaning operation being applied on the process equipment to the type of problem; - Apply cleaning chemicals using the correct dose and application; -When feasible, replace phosphoric acid with citric acid in degumming Water consumption Vegetable oil facilities Stress on water resources - When economically viable, require significant consider the use of physical amounts of water for crude refining instead of chemical oil production (cooling refining to reduce water water), chemical consumption; neutralization processes, - Recover condensate from and subsequent heating processes and reuse; washing and deodorization - Close the cooling water circuit and re-circulate cooling waters Air pollution/ Air Vegetable oil processing Combustion byproducts To prevent and control dust: Emissions Dust: - from processing such as NOx, SOx, PM , - Ensure proper maintenance  Particulate matter of raw materials, including volatile organic of cleaning, screening, and cleaning, screening, and compounds crushing equipment to crushing (VOCs), and greenhouse reduce emissions of fugitive gases (CO and CO2) dust; 103 - Reduce odor emissions with a caustic, alkaline, or Use of oil-extraction ozone scrubber system  Volatile Organic solvents, normally hexane To prevent and control Compounds (VOCs) .. VOCs: - - Ensure the efficient recovery of solvent by distillation of the oil from the extractor;  Exhaust Gases - Management strategy is a reduction in energy demand, use of cleaner fuels; - Application of emissions controls, where required, etc. Water and energy Heating of water and Stress on water and other To use energy and water consumption producing steam for natural resources save technologies and process applications machinery (especially for soap splitting and deodorization) and cleaning processes Refrigeration and compressed air Illness Cold pressed oil contains Severe diseases resulting Use alternative pressing high amounts of fatty in lower labor efficiency process acids and pesticide and income residues. Injuries Open machinery Lost productivity, work Safety instructions; safety days and income. clothing where appropriate (e.g. hard hats); protective guards on all machinery. Probable Residual Impact Assuming Full Mitigation: NONE 104 Table D-4. Vegetable processing and canning Overall Potential Impact: LOW Potential Impacts Causes Consequences Mitigation Required Remarks Water pollution Residue from vegetable and Damage to aquatic Compost vegetative waste. fruits allowed to be dumped ecosystems (high organic into surface waters. resulting in dissolved oxygen depletion). Soil, groundwater and Raw material, canning Recycle metal back to surface water pollution/ material scrap, etc metal processor. Solid waste Diseases/ illness Canning uses lead solder Lead (Pb), a carcinogen, is Use tin (Sn) for soldering for can seams cumulative in humans or adopt other appropriate sealing methods. Injuries Open machinery Lost labor efficiency Safety instructions; safety &income clothing where appropriate (e.g. hard hats); protective guards on all machinery. Residual Impact Assuming Full Mitigation: NONE; Risk: LOW Table D-5. Flour milling Overall Potential Impact: LOW Potential Impacts Causes Consequences Mitigation Required Remarks Soil and water pollution/ Wheat husks left from Recover bran; Solid waste milling dumped at Use for animal feed municipal disposal site Injuries Open machinery. Lost of labor efficiency and Safety instructions; safety clothing income. where appropriate (e.g. hard hats); protective guards on all machinery. Illness Flour dust Respiratory irritation Provide masks to workers Residual Impact Assuming Full Mitigation: NONE; Risk: LOW 105 Table D-6. Warehousing Overall Potential Impact: LOW Potential Impacts Causes Consequences Mitigation Required Remarks Only those during sitting, construction and decommissioning phases. Residual Impact Assuming Full Mitigation: NONE; Risk: LOW 106 Annex E. List of registered and prohibited pesticides in Tajikistan Insecticides and acaricides Aktellik (pirimiphosmethyl) Dimilin (diflubenzuron)DNOK Sulfur Omite 30%, 57% (propargit) Fenrio 20% (phenvalerat) Ambuf (permethrin) (Dinitroortokrezol) Oil Fozalon 35% (fozalon)Phosphoamid Anthio (25%) (phormotion) Zolon 35%, 30% (fozalon) Ripcord 40% (cipermethrin) 40% (dimethoat) Apollo (clophentyzin) Incegar 25% (phenoxycarb) Rovikurt 25% (permethrin)Sunmite Furi 10% (zetamethrin) Applaud (buprophezin) Karate 5% (lyambdacyhalothrin) 20% (piridaben) Khostakvik 50% (heptenophos) Arrivo (cypermethrin) Carbofos 50% (malathion) Sonet 10% (gexafluron) Simbush 25% (cypermethrin) Benzophosphate (30%) (fozalon) Croneton 50% (ethiophencarb) Sumi-Alfa (esphenvalerat) Siperkil 25% (cypermethrin) Be–58 (dimetoat) Mavric 2E 25% (fluvalinate) Sumiticin (phenvalerat) Sitkor 25% (cypermethrin) Vismethrin (permethrin) Calcium Polisulphide Talstar 10% (biphenthrin) Sherpa 25% (cipermetrine) Volaton (foxym) Mezox 25%, 50% Tiodan 35%, 50% (endosulfan) Aim 12% (chlorfluazuron) Gexasulfan (endosulfan) (metoxychlorin) Trebon 30% (etophenprox) Ecamet 50% (etrinphos) Danitol (phenoropathrin) Mitak 20% (Amitras) Festak 10% (alfamethrin) Endosel 35% (endosulphan) Decis (deltamethrin) Neoron 50% (Brompromilate) Fenval 20% (phenvalerat) Dilor (betadihydrogeptachlorine) Nossoran 10% (gexyithiazox) Nitrafen 60% (nitroalkilphenolat) Fungicides Alto 40% (cyprokonazol) Karatan FN-57b8b 25% (dinocap) Oxichom (oxadixil + copper Scor 25% (diphenconazol) Arcerid 60% KMAX 50% (2- oxychloride) Sportak 45% (prochloraz) (metalaxyl+policarbicin) carbometoxiaminochinazol) Sulfur Tilt 25% (propiconazol) Afugan 30% (pirazophos) Copper sulphate 98% (copper Polichom 80% (policarbacyn 60% + Topaz 10% (penconazol) Byleton 25% (triadimeffon) sulphate) copper oxychloride) Topcin-M 70% (thyophanatemethyl) Boricid 70% (sulfur+policarbycin) Green vitriol (iron sulphate) Ridopolichom 60% (metalaxyl + Copper oxychloride 90%, 50% Vitaxid 70% (oxadixil+polikhol) Calcium polysulphide policarbicin) Euparen 50% (dichlofluand) Derozal 50% (carbedazim) Sulfatimis + calcium hydroxide Saprol 20% (triforin) DNOK 40% (Dinitriortokrezol) Nitraphen 60% (cytroalkilphenolate) Chemicals for seed treatment Agrocit 50% (benomal) Bronotac 12% (bronopol) Derozal 50% (carbendazim) Sumi-8 2% (diniconazol) Apron 35, 38, 9% (metalaxyl) Vandidat 98% (potassium Nitrafen 60% (nitroalkilphenolate) TMTD 80% (thiram) Baytan 15% (triadimenol) viniloxyethildithiocarbamate) Policarbicin 80% (complex of salts of Formalin 40% (formaldehyde) Botran 75% (dichloran) Vitavax 75% (carboxyn) ethilenbisdithiocarbamin + Fundazol 50% (benomil) ethilenthyuramdisulphate, 1:8) Biological chemicals 107 Agri 50% (deltaendotoxycin bisilusa Gomelin (bisilusa turingisa) Lepidocid (bisilusa turingisa, kurstaki Turingin-1 (exotoxyn bisilusa turingisa, turingisa) Dendrobacillin (bisilusa turingisa, variety) turingensis variety) Baktospein (bisilusa turingisa) dendrolimus variety) Trichodermin (trichoderma, trichodermin, Turingin-2 10% (exotoxyn bisilusa Bitoxybacillin (exotokcin bisilusa Dipel (bisilusa turingisa, kurstaki veridin, glitoxyl) turingisa, turingensis variety) turingisa) variety) Trichodermin-BL (--»--) uricid (bisilusa turingisa) Virin-OS (granulez virus + poliedroz virus of autumn warm) Herbicides Alirox 80% (ERTS) 72% + antidot Zenkor 70% (methribuzin) Proemetrin 50% (promethrin) Fluometuron 80% (fluometuron) AD-67) Kotoran 80% (fluometuron) Pripinat 85% (dilapon) Fuzilad 25% (fluaziphonbutil) Acenit 50% (acetochlorus) Kotofor 80% (dipromethrin) Risan 50% (benthiocarb) Eradican 6E 72% (ERTS 72% + Bazagran 48% (bentazon) Kuscid 97% (monochloracetate Rozalin 50% (5-chlor-2- antidot) Banvel 48% (dikamba) diethilenglycolium) methilbenzimidazol) Yalan 60%, 10% (molinat) Basta 20% (ammonium Nitran 30% (thrifluralin) Saturn 50% (benthiocarb) Sherpa 25% (cypermethrin) gluphosinate) Olitref 25% (thrifluralin) Sonalan 33% (etalfluralin) Aim 12% (chlorfluazurin) Gazargard-50, 50% (promethrin) Ordam 6E 72% (molinate) Stomp 33% (pendimetalin) Ekamet 50% (etrimphos) Dalapon 85% (dalapon) Pakhton 80% (dipromethrin) Totril 22,5% (ioxynil) Endosel 35% (endosulphan) Dual 96% (metalochlorus) Penitran 33% (pendimetalin) Treflon 24% (thryfluralin) Zellek 12,5% (galoxyphonetoxetyl) Zellek super, 12,5% (galoxyphonetoxyetyl) Defoliants and desicants Basta 14% (gluphosinate Gemetrel 60% (derivatives of Threecarbamide chlorate of sodium Magnium chlorate 60% Calcium chlorate- ammonium) chloretylphosphone acid) Khayot 85% chloride 42%, 62% Butylcaptax 80% (butilcaptax-2-n- Dropp 50% (tidiazuron) (diaquatetracarbamidechlorate of butilbenzotianazol+MSF+magnium Drop-Turbo 20% (tidiazuron) calcium) chlorate) Harveid 25 F (dimedipin) Annex E. Table 1. High toxicity pesticides prohibited to use in Tajikistan Aldicarb - Алдикарб Chlorophacinone – Fjnofos- фонофос Parathion-methyl- nаратион метил Brodifacoum -Бродифакоум хлорофацинон Hexachlorobenzene -гексахлорбензен Phenylmercury acetate - фенилацетат Bromadiolone -Бромодиолон Difenacoum- дифенакоум Mercuric chloride- хлорид ртути ртути Вromеthаlin - Брометалин Difethialone- дифетиалон Mevinphos- мевинфос Phorate - форат Calcium суаnidе-цианид Калция Diphacinone- дифацинон Parathion- паратион . Phosphamidon- фосфамидон Captafol- каnтафол Disulfoton- дисулфотон Sodium f1uoroacetate фтороацетат Chloretрoxyfos – Хлорэтоксифос Ethoprophos- этоnрофос натрия Chlormephos- хлормефос Flocoumafen- флокоумафен Sulfotep- сулbфотеn Tebupirimfos -тебуnиримфос 108 Terbufos- тербуфос Annex E. Table 2. Medium toxicity pesticides prohibited for use in Tajikistan Acrolein Demetol1-S-methyl Isoxathion Рindоnе Allyl alcohol Dichlorvos Lead arsenate Pirimiphos-ethyl Аzinphos-еthуl Dicrotophos Mecarbam Propaphos Аzinphs-mеthуl Dinoterb Mercuric oxide Propetamphos Blasticidin-S Еdinofenphos Methamidophos Sodium arsenite Butocarboxim Ethiofencarb Methidathion Sodium cyanide Butoxycarboxim Famphur Methiocarb Strychnine Cadusafos Fenamiphos Methomyl Tef1uthrin Calcium arsenate Fluсythrinаtе Monocrotophos Thallium sulfate Саrbоfuran Fluoroacetamide Niсоtinе Thiofanox Chlorfenvinphos Formtanate Omethoate Thiometon 3-Chloro-l,2-propanediol Furathiocarb Oxamyl Triazophos Coumaphos Heptenophos Oxydemeton-mеthуl Vamidothion Coumatetralyl Isazofos Paris green {С} Warfarin Zeta-cypermethrin Isofenphos Pentachloropheno1 Zinc phosphide Annex E. Table 3. Moderate toxicity pesticides prohibited for use in Tajikistan Alanycarb Суnаlоtlhrin Рhеnthоаtе Methasulfocarb Anilofos Суреnnеthrin Phosalone Methyl isоthiосуаnаtе Azaconazole Аlрha-суреmlеthrin Phoxim Metolcarb Azocyclotin Сурhеnоthrin Piperophos Меtribuzin Bеndiосаrb Dеltаmеthrin Pirimicarb Molinate Bеnsulidе Diаzinоn Рrаllеthfin Nа b а m Bifеnthrin Difenzоquаt Рrofеnоfоs Naled Bilаnаfоs Dimetoate Propiconazole Pyroquilon Biоаllеthrin Dinоbutоn Propoxur Quinalphos Brоmохуnil Diquat Prosulfocarb Quizalofop-p-tefuryl Brоbuсоnаzоlе Endosulfan Prothiofos Rоtеnоnе Brоnороl Еndоthаl-sоdium Pyraclofos Sodium fluoride Butаmifоs Esfenvalerate Pyrazophos Sodium hexafluorosilicate Butуlаminе Еthiоn Руrеthrins Sрiroхаminе Carbaryl Еtrimfоs Fuberidazole Sulprofos Саrbоsulfаn Fеnitrоthiоn Gаmmа-НСН Теrbumеtоn 109 Cartap Fеnоbuсаrb Guаzаtinе Теtrасоnаzоlе Chloralose Fеnрrорidin Haloxyfop Thiacloprid Сhlоrdаnе Fеnрrораthrin Heptachlor Thiobencarb Сhlоrfеnаруr Fenthion Imаzаlil Тhiосусlаm Сhlоrрhonium chloride Fеntin acetate Imidacloprid Тhiodicarb Сhlоrpyrifоs Fеntin hydroxide Iminосtаdinе Тriаzаmаtе Сlоmаzоnе Fenvalerate Ioxynil Тriсhlоrfоn Copper sulfate Fipronil Ioxynil осtаnоаtе Tricyclazole Cuprous oxide Fluхоfеnim Isoprocarb Тridеmоrрh Суаnаzinе Fоrmоthiоn Lаmbdа-суnаlоthrin Vemolate Cyanophos Paraquat Mercurous chloride Xylylcarb Суflutllrin Pebulate Metaldehyde Bеtа-суfluthrin Permethrin Меtаm-sоdium Methacrifos 110 111 Annex F. Recommended Structure of a Pest Management Plan Following review of the Environment Screening Checklist submitted by the applicant for a sub-project loan, the PFI Loan Officer and/or PIU Environmental Specialist will determine if the applicant needs to prepare a PMP. This determination would be made on the basis of toxicity of the pesticides to be used and the environmental risks posed by the activity. When, a determination is made that a PMP is to be prepared by the sub-project loan applicant, a two stage process would be applied towards the preparation of the PMP. Stage A: Additional Information Request The applicant would provide the following information: 1. Types and application of pesticides (i) What are the pesticides that are to be purchased, including name of product, type of formulation, concentrations of the active ingredient? (ii) Where are the pesticides to be purchased from, including name of store and location? (iii) What are the quantities of pesticides to be purchased and the package sizes and quantities in each package? (iv) What type of equipment is to be used to apply the pesticides (v) Are applicators trained in the proper and safe use of the pesticides? 2. Purpose and appropriateness of pesticides (i) What crops to you plan to use the pesticide? (ii) What pests and/or diseases are to be controlled by the pesticide? (iii) What non-chemical pest control measures have been used in the past to control the pests and/or diseases mentioned in (ii) above? (iv) How often is the pesticide to be applied and in what quantities in any given application? (v) How will the timing of the application of the pesticide be decided? (vi) Have you been trained or received advice on non-chemical pest control or integrated pest control (IPM)? (vii) If not trained, how do you plan to obtain assistance, advice or training in pesticide application quantities and methods; calibration of spraying equipment; use of protective gear; storage and disposal methods, etc. 3. Handling, storage and disposal of pesticides (i) How will the pesticides be transported to the project site? (ii) Where will the pesticides be stored in the farm? (iii) Will the storage location of the pesticide be secured / locked and who will have access to these stores? (iv) How will animals, children and unauthorized persons be excluded from access to the storage areas? (v) Where will mixing of pesticides happen and what precautions will be taken to keep the storage and pesticide mixing areas away from grain stores and production areas? (vi) How will excess unused and mixed pesticide products be disposed of? (vii) How will empty pesticide containers be disposed of? 112 (viii) How will pesticide records in terms of purchase, use and disposal be maintained? 4. Environmental Aspects (i) Are pesticide application areas near water bodies, wetlands or areas of known natural habitats? (ii) Are there know natural pollinators found in the vicinity of the application areas? If so what precautions would be used to ensure that non-target beneficial species are not harmed? Stage B: Preparation of Pest Management Plan Based on the information provided by the subproject loan applicant, the PFI Loan Officer (if necessary, in consultation with PIU Environmental Officer) will identify the risks associated with the application of the pesticide and the more important and most practical mitigation measures that need to be applied, including any complementary measures using non-chemical control measures. The PFI Loan Officer will advise the applicant on the scope and nature of the PMP to address potential impacts of the subproject activities. If needed, the PFI Loan Officer and/or PIU Environmental Specialist can advise the loan applicant on professional services that could be obtained for completion of the subproject specific PMP. Typically the outline of the PMP would be the following: (a) Purpose of Activity provides information on extent and severity of pest and diseases in the crops to be grown (b) General Information of Area which should provide data on land use and soil, water resources, layout of facilities, etc. (c) Review of Existing Pest Management Practices and Capacity which should provide data on current practices (chemical and non-chemical) in control of the particular pests and diseases, constraints and track record and extent to which pest and diseases of fruit and agricultural crops have been managed and controlled; and reasons for enhanced pesticide applications through the proposed subproject loan. (d) Types, amounts and application of Pesticides provides information on the types, amounts and nature of the pesticides to be purchased and used and the current and proposed handling, application, storage and disposal methods for the pesticides (e) Capacity, training and knowledge of the safe application and use of pesticides provides information on existing knowledge and capacity of staff and personnel in the safe use and application of pesticides and identification of gaps in training and knowledge for improving capacity. (f) Potential risks and hazards associated with application and use of pesticides in subproject loan would provide information on the environmental and human health impacts associated with the handling, application, storage and disposal of pesticides under the subproject loan, including potential impacts on non-target beneficial species, soil and water and natural habitats. (g) Mitigation Measures to avoid and manage potential pesticide impacts that would provide information on the following:  Mechanical and physical control, cultural and biological control measures, if any that can be used in conjunction with or without pesticide applications to suppress or reduce the severity of the target pest or disease to be controlled;  Chemicals and chemical procedures that will be used to control pests and diseases, conditions under which the chemicals will be used, including climatic conditions, vegetation conditions, timing of applications, to improve the effectiveness of the pesticide and reduce its environmental impacts as well as specific measures to be employed to protect sensitive ecosystems, aquatic systems and ground water; 113  Management of health and safety aspects that would define measures to ensure safe handling, transport, application, storage and disposal of pesticides so as to reduce environmental and health risks;  Measures that would be introduced for public safety and protection during pesticide applications;  Measures to track and monitor pesticide use and effectiveness in controlling desired pests;  Measures to be undertaken to create awareness, improve information flow and improve capacity of farm workers on the hazards on the unsafe use, handling and storage of pesticides and measures for reducing such risks, as well as options for integrated pest management;  Measures to be taken to obtain technical support for pest management and safe use and application of pesticides, when necessary;  Budget estimate for implementation of the PMP. The PFI Loan Officer and/or PIU Environmental Specialist would review and approve the PMP prior to the approval of the Sub-project loan. The PFI Loan Officer will monitor the implementation of the PMP. 114 Annex F Report on Consultation on the Draft Environmental Management with interested parties Date: February 28 2014 Venue: Ministry of Agriculture, Dushanbe (Rudaky Avenue, 44) Location Objective Invitees Participants Summary, conclusions and comments / venue Ministry To describe The invitation, Nabiev M. - On the meeting, there were made of the project as well as a Chief agriculture specialist of presentations on: Environmental Agricult objectives hard copy of MoA, Management Framework. ure and the EMF Zoirov N. – Representative of All participants concluded the EMF is Conferen activities, Executive MoA, Miraliev A. – well prepared, takes into account all ce room; including Summary was Representative of MoA, Bekov aspects of potential environmental EMF and sent to Behrus – Specialist of impacts of various types of sub projects Environmen interested Information centre MoA, to be supported by the new credit line, tal institutions and Asenova Z. - Specialist of and proposes relevant mitigation Guidelines persons. International relations measures and its implementation will and solicit Additionally Department of MoA, have mostly positive impacts on the feedback the full EMF Jalilov Dilshod – Coordinator country agricultural sector. document was of NGO “Centre for posted on the innovation development”, website of Blagoveshenskaya Svetlana – MoA and is NGO “Kuhiston”, available to all Rahmatillaeva G. – interested representative of National parties association of small and medium business, Shukurov I.Sh. – Representative of the Committee for environment Protection under the Government of Tajikistan, Burhoniddiniva T.Sh. – Specialist of the Ministry of energy and water resources, Sokiev Khomid – Specialist of the Ministry of justice, Rahmatillaev Rakhmonkul – professor, Tajik Agrarian University Nazarova Salomat – Consultant of the “Environmentally friendly land use Project (CEP), Ergashev Murod – Chief researcher, Institute of soil sciences, Tajik Academy of agricultural sciences Gaforov Bahrom. – Deputy Chairman of the Agency of 115 land reclamation and irrigation, Komilzoda D. – Tajik Academy of agricultural sciences, Sharipov Aizbek – Chairman of the National Association of farmers, Saidov Ibragim – Head of department of the Institute of energy, environment and water problems, Academy of sciences, Alihanova Tatiana - expert on sustainable development, Burhanova Muazamma -Director of NGO “Support fund for Civil society initiatives”, Shoev Shohin – Representative of the State Committee for land management and geodesy, Bedoriev S. - Head of department, Agency of land reclamation and irrigation, Juraev D. – Specialist of the MoA, Khudoiberdiev Kh. – General Director of the TTU, Babadjanova Malika – Environmental Specialist, Kamilova Larisa NGO « Kuhiston » Yusupjanov Farruh – NGO « Tajik Ecological Fund» Dadobaev Dilshod – Director of NGO « Kuhiston », Maskaeva N. – NGO « Kuhiston », Nazrieva R. – social and resettlement issues expert Photo report on EMF public consultation Opening of consultations and presentation of EMF document 116 Participants of consultations Discussions, comments during the consultations 117