Draft Environmental Impact Assessment

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Draft Environmental Impact Assessment

Project Number: 41193July 2011

Mongolia: Western Regional Road Corridor DevelopmentProgram–Tranche 1

Prepared by SMEC Asia Ltd.

The environmental impact assessment is a document of the borrower. The views expressed herein do notnecessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary innature. Your attention is directed to the “Terms of Use” section of this website.


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CURRENCY EQUIVALENTS(As of July 2011)

Currency Unit – Mongolian Tugrug (Tg)100 Tg = $0.072$100 = 137,500 Tg

The exchange rate of the Tg is determined under a floating exchange rate system. In this report, the rate usedis the rate prevailing at the above date.

LIST OF ABBREVIATIONS USED

ADB Asian Development BankADT Average Daily TrafficAMa Absolute MaximumAMi Absolute Minimumо С Degrees of Celsiuscm CentimeterEIA Environmental Impact AssessmentEMP Environmental management PlanGOM Government of MongoliaGRM Grievance Redress Mechanismha Hectarekm Kilometerkm/h Kilometers per hourKUNNP Khar-Us Nuur National Parkm MeterMESC Ministry of Education, Science, and CultureMFF Multitranche Funding Facilitymg/m3 Milligrams per cubic meterMLEIA Mongolian Law on Environmental Impact AssessmentsMLEP Mongolian Law on Environmental ProtectionMNET Ministry of Nature, Environment and TourismMOF Ministry of FinanceMRTCUD Ministry of Road, Transport, Construction and Urban DevelopmentNAMHEM National Agency of Meteorology Hydrology and Environmental MonitoringNGO Non-Governmental OrganizationNM National MonumentsNP National ParksNR Natural ReservesNSO National Statistical OfficePIU Project Implementation UnitPRC People’s Republic of ChinaRP Resettlement PlanSE Supervising EngineerSPA Specially Protected AreaSPIA State Professional Inspection AgencyUSD US DollarUNDP United Nations Development Program

TA Technical AssistanceUB UlaanbaatarWCS World Conservation SocietyWRRC Western Regional Road CorridorWWF World Wide Fund for Nature

NOTE:(i) In this report, “$” refers to U.S. Dollars.


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TABLE OF CONTENTS

1. EXECUTIVE SUMMARY i1.1 Introduction i1.2 Critical Facts i1.3 Significant Findings ix1.4 Recommendations xvi

2. INTRODUCTION 192.1 Background 192.2 EIA Preparation 202.3 Associated Project Facilities 212.4 Report Structure 22

3. POLICY LEGAL AND ADMINISTRATIVE FRAMEWORK 243.1 Environmental Policy 243.2 Environmental Law 253.3 Environmental Impact Assessment Requirements 293.4 Administrative Framework 323.5 Project Classification 36

4. DESCRIPTION OF THE PROJECT 374.1 Type of Project 374.2 Description of the Proposed Actions 374.3 Bill of Quantities (BOQ) for the Project 394.4 Need for the Project 394.5 Project Location 444.6 Associated Project Facilities 474.7 Traffic Projections 484.8 Implementation Schedule 49

5. DESCRIPTION OF THE ENVIRONMENT 505.1 Environment of Mongolia 505.2 Assessment Process 505.3 Definition of the Project Area 505.4 Physical Resources 505.5 Ecological Resources 685.6 Biodiversity 685.7 Economic Development 785.8 Social and Cultural Resouces 80

6. ALTERNATIVES 936.1 Alternative Analysis 936.2 No-action Alternative 936.3 Location Alternatives 936.4 Technological Alternatives 93

7. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 97.1 Screening of Potential Impacts 957.2 Anticipated Environmental Impacts 967.3 Physical Environment 977.4 Ecological Resources 1057.5 Socio-Economic Impacts 1097.6 Climate Change Impacts 111 7.7 Cumulative and Induced Impacts 114


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8. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE 1158.1 Stakeholder Workshops 1158.2 Other Public Consultations 1178.3 Consultations within the Project Area 118

9. GRIEVANCE REDRESS MECHANISM 1209.1 Introduction 1209.2 Objectives of Grievance Redress Mechanism 120

9.3 Current Practice 1209.4 Proposed Grievance Redress System 1219.5 Responsibilities of the PCC 122

10. ENVIRONMENTAL MANAGEMENT PLAN 12410.1 Environmental Safeguards 12410.2 Mitigation Measures 12410.3 Implementation 12810.4 Implementation Schedule 12910.5 Environmental Cost Estimate 13010.6 Institutional Arrangements 13010.7 Capacity Building 13210.8 Environmental Monitoring 133

11. CONCLUSION 134

APPENDIXES1. Environmental Management Plan2A. Climate Variables and Air Quality Standards2B. Water Quality Standards2C. List of Flora and Fauna2D. Historical and Cultural Heritage


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1. EXECUTIVE SUMMARY

1.1 Introduction

1. Purpose of the Project. The Government of Mongolia acting through its Ministry of Roads, Transport,Construction and Urban Development (MRTCUD), has undertaken the upgrading of the Western RegionalRoad Corridor (WRRC) with several funding arrangements. The 103.3 km road section from Baga Ulaan

Davaa to Mankhan (Tranche 1) is an integral part of the said road corridor. The development of the roadsection Baga Ulaan Davaa to Mankhan (herein after referred to as the Project) has been identified for financialassistance from the Asian Development Bank (ADB) under the Multitranche Financing Facility (MFF) extendedfor the development of several sections of the WRRC.

2. Scope of work. The scope of work for the preparation of the EIA consisted of; collection of existinginformation related to the environmental conditions along the proposed road section, assessment of potentiallocation specific environmental impacts, development of preventive/mitigation measures for significant impacts,evaluation of alternative alignments and alternative technologies, economic assessment of environmentalbenefits and costs, preparing Environmental Management and Monitoring Plans, and public consultations.

1.2 Critical Facts

1.2.1 Legal and Administ rative Framework

Legal framework

3. Mongolia’s environmental legal framework is similar to international practices and is structured asshown in Table 1.1 below.

Table 1.1: Key Environmental Legislation in MongoliaName of the Law Year Adop tedThe Constitution of Mongolia 1992Law on Environmental Protection 1995, revised in 2006and 2008Law of Land Jun 2002Law on Land Cadastre and Mapping Dec 1999

Law on Land Fees Apr 1997Law on Land Possession Jun 2002Law on implementation of regulations related to Land Possession Law Jun 2002Law on Geodesy and Cartography Oct 1997Law on Special Protected Areas Nov 1994Law on Buffer Zones Oct 1997Law on Water Apr 2004Law on Water and Mineral Water Resource Fee May 1995Law on Forests Mar 1995Law on Fees for Timber and Fuel wood Harvesting May 1995Law on Prevention of Steppe and Forest Fires May 1996Law on Reinvestment of Natural Resource Use Fees for Conservation Jan 2000Law on Natural Plants Apr 1995Law on Natural Plant Use Fees May 1995Law on Protection of Plants Mar 1996Law on Hunting 2000, 2003Law on Fauna 2000Law on regulation of export and import of endangered species of flora and fauna Nov 2002Law on Hunting Reserve Use Payments and on Hunting and Trapping Authorization Fees May 1995Law on Underground Resources Dec 1994Law on Minerals 1997, revised in 2006Petroleum Law 1991Law on Air Mar 1995Law on Hydrometeorology Nov 1997Law on Protection from Toxic Chemicals Apr 1995Law on Environmental Impact Assessment 1998, revised in 2002


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Law on Tourism 1998Law on Solid Waste Nov 2003Law on prohibiting export and transportation of Hazardous Waste Nov 2000Source: UNDP. 2008. Institutional Structures for Environmental Management in Mongolia.

EIA requirements

4. The Project will be subject to the environmental requirements of both Mongolia and those of the ADB.These requirements are as follows.

5. EIA requirements of ADB. ADB Safeguard Policy Statement (SPS) sets out the policy objectives,scope and triggers, and principles for environmental safeguards, involuntary resettlement safeguards, andIndigenous Peoples safeguards. The objective of the Environmental Safeguards is to ensure the environmentalsoundness and sustainability of projects and to support the integration of environmental considerations into theproject decision-making process and requires a screening process for each proposed project, as early aspossible, to determine the appropriate extent and type of environmental assessment so that appropriatestudies are undertaken commensurate with the significance of potential impacts and risks. Subsequent to thescreening process an environmental assessment should be conducted to identify potential direct, indirect,cumulative, and induced impacts and risks to physical, biological, socioeconomic (including impacts onlivelihood through environmental media, health and safety, vulnerable groups, and gender issues), and physicalcultural resources in the context of the project’s area of influence. Therefore, all projects considered for loansand investments by ADB are subject to classification for the purpose of determining environmental assessmentrequirements. The determination of the environment category is to be based on the most environmentallysensitive component of the project. Within this system, projects are screened for their expected environmentalimpacts and assigned to one of the following four categories: (i) Category A: projects with potential forsignificant adverse environmental impacts - an environmental impact assessment (EIA) is required to addresssignificant impacts, (ii) Category B: projects judged to have some adverse environmental impacts, but of lesserdegree and/or significance than those for category A projects - an initial environmental examination (IEE) isrequired to determine whether or not significant environmental impacts warranting an EIA are likely, (iii)Category C: projects unlikely to have adverse environmental impacts - no EIA or IEE is required, althoughenvironmental implications are still reviewed, and (iv) Category FI: projects are classified as category FI if theyinvolve a credit line through a financial intermediary or an equity investment in a financial intermediary - thefinancial intermediary must apply an environmental management system.

6. EIA Requirements of Mongolia. The EIA requirements of Mongolia are regulated by the Law onEnvironmental Impact Assessment. The type and size of the planned activity determine whether theresponsibility lies with the Ministry of Nature, Environment and Tourism (MNET) or aimag government. Thereare two types of EIAs defined in the Law: General EIA and Detailed EIA.

7. Figure 1.1 below provides a simplified diagram of the EIA procedure in Mongolia.


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Figure 1.1: EIA Procedure in Mongolia

8. To initiate a General EIA, the project implementer submits a brief description of the project to theMinistry of Nature, Environment and Tourism or local authority, including the feasibility study, technical details,and drawings. The General EIA will lead to one of four conclusions: (i) no detailed EIA is necessary, (ii) theproject may be completed pursuant to specific conditions, (iii) a detailed EIA is necessary, or (iv) projectcancellation. The General EIA does not inolve any cost to the proponent and usually takes up to 12 days.

9. The scope of the detailed EIA is defined by the General EIA. The detailed EIA must contain thefollowing chapters: (i) environmental baseline data; (ii) project alternatives; (iii) recommendations forminimizing, mitigation and elimination of impacts; (iv) analysis of extent and distribution of adverse impacts andtheir consequences; (v) risk assessment, (vi) environmental protection plan; (vii) environmental monitoringprogram; and (viii) opinions of residents on whether the project should be implemented. As per Mongolian Lawon Environmental Impact Assessment requirements MNET after a General EIA has determined that the WRRCProject warrants a Detailed EIA which is similar in content and scope to an EIA required for an ADB Category AProject.

Administrat ive framework

10. Institutional Framework of the Ministry of Nature, Environment and Tourism. The Ministry ofNature, Environment and Tourism (MNET) is the agency primarily responsible for the implementation ofenvironmental policy in Mongolia.

11. MNET operates through the following departments and agencies:

Department of Sustainable Development and Strategic Planning Department of State Administration and Management Department of Environment and Natural Resources Department of Specially Protected Areas Administration and Management Department of Tourism International Cooperation Division Division of Information, Monitoring and Assessment Finance and Investments Division Ecologically Clean Technologies and Science Division National Agency for Meteorology, Hydrology and Environmental Monitoring Water Authority Forest Authority


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12. Aimag and soum governors are responsible for environmental management issues through individualenvironmental departments, with the exception of protected areas management. Aimag level inspectors reportto the State Professional Inspectors Agency.

1.2.2 Descript ion of the Project

13. Type of Project. The proposed Project is a road upgrading and paving project. The project activities

will not include significant realignments or development of long sections of new alignments in previouslyundisturbed areas.

14. Description of the Proposed Actions. The entire road section between Baga Ulaan Davaa toMankhan will be developed as a 2-lane road. The following types of road improvement options have beenproposed:

New construction: road upgrading on the existing alignment;

Pavement and shoulders: asphalt concrete overlay with an asphalt concrete regulating course,selected fills, granular material in shoulders;

Blasting works (where required) in limited areas; and

Road safety: road markings, road signs, and guide posts.

15. Total earthwork quantities for the Project are shown in Table 1.2, below.

Table 1.2: Estimated Quantities for the ProjectNo Description Quantity1.00 General Various2.00 Site Clearance 167 Ha3.00 EARTH Works 1,845,537 m4.00 Excavation for Structures 2,082 m5.00 Pipe Culverts and drainage Works (Culverts and Stone Pitching) 3,063 m6.00 Passage of Traffic 36 km7.00 Sub Base and Base 592,985 m 3

8.00 Bituminous Pavement Works 36,581 m9.00 Concrete and Piling Works 557 m10.00 Micellaneous Bridge Works 75 m11.00 Road Furniture and Traffic Markings Various

16. Need for the Project. The major goal of the Project is to contribute to the economic development andregional trade and cooperation in the Western Region of Mongolia by providing continuity to the WesternRegional Road.

17. Environmental Category of the Project. The Western Regional Road Corridor Development projectof which the present Project is a component, has been classified by ADB environmental category A.

18. Project Location. The proposed road is within the Western part of Mongolia between Baga Ulaan

Davaa to Mankhan (Figure 1.2).


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Figure 1.2: Project Location

19. Implementation Schedule. The proposed implementation schedule is presented below in Table 1.3.

Table 1.3: Project Implementation Schedule2011 2012 2013 2014 2015 2016

Indicative Act ivi ties 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4A. Design and MonitoringFrameworkA1: Road Construction WorksTranche 1A1.1: Contract RepackagingA1.2: Procurement (3 Packages)A1.3: Contract Award

A1.4: Civil Work (Package 1: Km0 - 25)A1.5 Civil Work (Package 2: Km25–75)A1.6: Civil Work (Package 3 Km75-103.3)A2: Establish DOR RoadMaintenance Unit Tranche 1A2.1: Confirm EquipmentRequirement

DEFECTS


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2011 2012 2013 2014 2015 2016Indicative Act ivi ties 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4A2.2: Procurement (forEquipment)A2.3: Contract AwardingA2.4: Equipment take-over byDORA2.4: Road Maintenance Trainingto UnitSource: Consultant TA No. 7449-MON.

1.2.3 Description of the Environment

20. Definition of the Project Area. The proposed road traverses Khovd aimag (province) with a totalpopulation of approximately 89,240 (2009). The soums within the Project Area include:

Mankhan soum which includes Botgon bagh,Tugrug gol bagh,Takhilt bagh and Bayangolbagh.

Must soum including Bayankhairkhan bagh and Davst bagh.

Physical resources

21. Topography. The project alignment will primarily follow existing roads that pass through mountainareas, hills, canyons, valleys, and plains with elevations ranging from 1,300 m to 2,900 m above sea level.

22. Geology. The project area is situated in the Mongol Altai high mountainous area. According to the geo-morphological map of Mongolia, the terrain primarily includes excessive rolling ranges, medium rolling rangesand mountains, slight rolling ranges of sloped structure, mountainous ravines, semi-level surfaces of mountainskirts, glacial valleys, mountains with sharp ridged peaks, alluvial lake valleys, delluvial - prolluvial andmountain river valleys.1

23. Soils and Permafrost. In Bodonch Canyon and high-altitude parts of Mongol Altai soils are diverseand range from semi-desert brown, desert gray brown, Govi brown, and light krasnozem (red soil) soils to highmountain steppe raw humic soils, and soils of high mountain tundra. Both perennially and seasonally frozensoils occur in the project area. High altitude parts of Mongolian Altai between exit of Bodonch Canyon andMankhan, present perennially frozen soil with the annual temperatures of 0 – -50C and an active layer of 1.0 –4.5 m.

24. Seismic Characteristics. The project area resides in the Mongol Altai and Gobi Altai seismically activezones where earthquakes with the magnitude of about 8 were registered in the past (1931 and 1957).

25. Natural Disasters. Flashfloods (mudflows) and drifting snow are distinctive features of the projectarea. Flashfloods are widespread near Baga Ulaan Pass. Drifting snow is characteristic of Bodonch Canyon.

26. Climate and Air Quality. The monthly absolute maximum and minimum air temperatures observed at

meteorological stations along the road show that July is the warmest month and January or February is thecoldest. During the last ten years, the absolute maximum air temperature reached 39 oC at Bulgan soum inKhovd Aimag in 2004 and the absolute minimum air temperature was -44oC at Mankhan soum in 2005.

27. Some 85.0 - 94.5 percent of annual precipitation falls between May and September. During the coldseason snowstorms can occur, causing the road to be closed. The stable snow cover formation date variesfrom the middle of November to the beginning of December, with snow cover completely clearing up in March.The dominant wind direction is from the west and northwest, with maximum wind speed varying from 18 to 28m/s. Air quality is good and does not exceed maximum allowable concentrations except local dust pollution

1 Government of Mongolia. 2007. EIA . Ulaanbaatar.


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caused by vehicles.

28. Hydrology and Water Resources. Water resources in the project area are represented by surfacewater (rivers, springs and lakes) and groundwater. The largest rivers include Khovd and Buyant. Spring floodsin the rivers of the project area generally begin in the middle of April, with peak flow occurring in late June andcontinuing for 110-150 days. The spring flood flow is 60 – 90 percent of total annual flow of Altai MountainRivers. The groundwater resource distribution is uneven. Moving from north to south, groundwater resourcesbecome more sporadic and mineralization increases. The water quality of all of the rivers and lakes of theProject Area was assessed as “very clean” and “clean”.

Biodiversity

29. Flora. Dominant flora in the project area is associated with specific conditions of the area. Thevegetation zones in the project area are High Mountain, Dry Steppe, Stepped Desert, Grasses-UndershrubDesert. The lists of plants found in each of the zones are given in Appendix IIC (Table 1). Some 86 species ofplants listed in the Mongolian Red Book can be found in Khovd Aimag. Among these are Red Goyo, SaussureaInvolucrate, and Shining Water Lily.

30. Fauna. The Mongolian Altai region is characterized by its rich fauna diversity. There are 360 species ofvertebrates, including 90 species of mammals, more than 250 species of birds, 11 species of reptiles, 123species of insects, 10 species of fishes, and 1 species of amphibian. Some of the rare and endangeredmammals found in Khovd aimag are Asiatic wild dog, Snow leopard and Saiga. Some migrant birds that arerare and endangered and commonly seen in these areas are Damatian pelican, Great white egret , White tailedeagle and Swan goose. Detailed lists of the rare and endangered mammals and birds are presented inAppendix IIC, Tables 2 and 3, respectively.

31. Mankhan Nature Reserve (NR). This reserve (Figure 5.10) was established in 1993 in order to protectthe population of Mongolian Saiga. The total area of the reserve is 390,071 ha. It has ecological biodiversityimportance and provides the habitat for endangered rare mammal - Mongolian Saiga Antelope (Saiga tataricamongolica). The population of Saiga within Mankhan NR is decreasing2 – the number was over 130 recorded in1982, 70 in 1993, 44 – in 1998, and, finally, in January 2007, the total population of this antelope was 15-17 aswas reported at the stakeholder meeting in Khovd. This is likely due to migration of the species to DorgonKhuren steppe located within KUNNP where about 200 Saiga were observed by rangers.

Economic Development

32. Gross Domestic Product. The GDP of Khovd Aimag amounted to 44,033.6 million Tugrug (476,500Tugrug per capita) in 2005. The most important sectors were agriculture, hunting and forestry (76.0 percent),transport and communication (5.1 percent), and education (5.1 percent). The most important sectors wereagriculture, hunting and forestry (71.7 percent), education (6.5 percent), financial intermediation (5.8 percent),and trade (4.5 percent).

33. Agricu lture. Animal breeding is the main economic sector in Khovd aimag. The contribution of thesector amounts to 76.0 percent of aimag GDP (33.4 billion Tugrug) in Khovd Aimag. The number of livestock inboth aimags is constantly increasing. Crop production is of less importance in the agricultural sector of Khovd.

34. Mining. Mining activity in Western Mongolia is associated with a number of mines operating and othersites that are being planned for coal, gold, silver extraction.35. Water supply systems. The water supply system in Khovd provides centralized drinking waterdistribution to office buildings and urban residential area. Daily water supply is 4,600 m3 water from 9groundwater wells. Traditional dwellings (ger ) in Khovd are supplied with water from 8 water distributionstations, 4 deep wells and 3 hand water pumps. The water consumption is 388,300 m 3 water per day. Some2,133 wells are used for water supply in rural areas. Surface water is the main source of water for livestock.

2 Khar Us Nuur National Park Management Plan 2006-2010. KUNNP Administration & WWF, Hovd, p.37, 2006.


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36. Electricity distribution systems. Khovd aimag is largely served with electricity from Russia, becauseenergy capacity at local level is limited. A 110 kV transmission line links Russia and Olgiy town of Bayan-OlgiiAimag and Miyangad soum of Khovd Aimag. Khovd town, Duut and Erdeneburen soums of Khovd Aimag areconnected to this line with a 35 kV transmission line.

37. Land Use. Agriculture has been the dominant land use in the aimag, occupying more than 77 percentof the total land in each aimag. The land used for “transportation and network” occupies 0.31 percent of thetotal territory in Khovd aimag. The proposed road would follow the existing earthen tracks, thereby slightlyreducing the land use for “transportation and network.”

Table 1.4: Land Area by Classification

Land classificationKhovd AimagArea(,000 ha)

Percent of total(%)

Agricultural lands 5,885,0 77Cities, villages and other settlements 28,405 0.3Transportation and network land 21,128 0.2Forest resource land 464,851 6.1Water resource land 43,117 0.5State special use land 1,163642 15.2Total area 7,606,038 100Source: Land management report of Khovd and Bayan-Olgii Aimags, 2005.

38. Tourism. Ecotourism dominates in the region. There were 19 tourist camp sites, visited by a total of8,247 international and domestic tourists in Khovd Aimag, in 2006. A recreational center, spa-resort, andchildren’s camp are attractions for several hundred tourists per year along with biological resources.

39. Health Services. Khovd Aimag: Some 14 medical clinics, 2 intersoum medical clinics, and 6 hospitalsfor families provide basic service to local residents and herders. A hospital in Khovd city plays a major role as aregional hospital to serve patients from the western region. In total, there are 569 hospital beds. Additionally,there are 16 private hospitals and 6 pharmacies. Some 128 physicians, 11 pharmacists, 235 nurses, and 115medical assistants work in medical services of the aimag. On the whole, there are 14 physicians, 12 medicalassistants, 38 mid-level medical personnel, and 61 beds per 10,000 persons.

40. Noise and Vibration. The road corridor runs largely through a remote area with almost no settlementsand the only sensitive area is the Mankhan Nature Reserve which may be affected by high noise levels duringconstruction.

Social and cu ltural resources

41. Social Resources. The population of Khovd Aimag is 91,687, and the aimag center 32,351.Population density in Khovd is 1.09. Mongols dominate the population in Khovd (82 percent).

42. Historical and Cultural Heritage. Human settlement in the project area can be traced back to as earlyas the Paleolithic and Neolithic eras as evidenced by the following sites: Petroglyphs, Deer Stones andKhirigsuurs (stone-mound). However, the project road will not traverse across the sites.

1.2.4 Alternatives

43. No-action alternative. Failure to develop the project road section (No Action Alternative) would resultin continued impediments to travel and transport of people, goods and a substantial constraint to futureimprovements in the economy of local communities. Using multi-track earth roads will continue to affect pasturelands and habitats, flora and deteriorate air quality with dust. Improving the accessibility to environmentallysensitive protected areas located close to the road may result in increased poaching and transmission ofdiseases. However, these adverse impacts can largely be avoided or mitigated by careful planning andimplementation of an environmental management plan. Accordingly, it has been determined that the “No ActionAlternative” is not a reasonable option.


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44. Location Alternatives. Although the proposed road traverses through the Mankhan Nature Reserve(MNR) the consultations at the Khovd Aimag Centre with the Deputy Governor, Head of EnvironmentalDepartment and Supervisor of Environment and Tourism Center and Biodiversity and Specially Protected AreaSpecialist and the local office of the WWF discouraged the need for considering an alternative alignment thatbypasses the MNR. Their concerted view was that an alternative road to bypass the MNR would be a burdenconsidering the cost and it may also have potentially adverse impacts (vide item 9.2 under Section 9: PublicConsultation and Information Disclosure).

45. Technical Alternatives. Given the projected traffic flow, sub- grade strength, and extreme climateconditions, two road surfacing alternatives are possible: double bituminous surface treatment (DBST) orasphalt concrete (AC). AC pavement has the advantage of strength and durability, with a longer design life ofmore than 30 years with appropriate routine and periodic maintenance. DBST pavement is less strong anddurable and its application generally has a design life of up to 20 years with appropriate maintenance. DBSTpavement is vulnerable to the progressive loss of cover aggregate and the deepening and expansion ofpotholes. Accordingly, the maintenance costs for DBST is higher than AC pavement.

46. The decision on pavement selection will be made considering costs (capital and recurrent) and inconsultation with a cold climate pavement specialist.

1.3 Significant Findings

1.3.1 Anticipated environmental impacts

47. It has been recognized that the most efficient and cost-effective way to ensure that construction worksare environmentally sound is to include these requirements in the construction contract provisions.

Physical environment

48. Topographic Characteristics and Soils. Impacts: Impacts of the Project on land will be positive dueto reduced land degradation by diversion of traffic from earth tracks to a hard surface road. Provided erosionprevention measures in the construction and operational phases are taken, no substantial adverse impacts onsoils are foreseen. No contamination of soil is foreseen during construction. Significant environmental impactson soils are not anticipated during the operation of the road. Mitigation: No mitigation actions related topotential loss of agricultural soil and contamination of soil are warranted.

49. Impact: Degradation of ice-rich permafrost due to natural causes or anthropogenic activities (roadconstruction) can trigger a process called thermokarst. Activities such as construction of roads andremoval/disturbance of vegetation cover in permafrost areas can severely affect the topography leading tosubsidence and disruption of engineering structures and modification of drainage patterns. Mitigation:Contracts will contain provisions to avoid adverse impacts due to altered road embankments, borrow pits andprovisions for quarry operations. Adequate anti-erosion measures such as minimizing the area of soilclearance, selection of less erodible material and good compaction, placement of gabions and riprap will beimplemented, as described below in Table 1.5. A preventive approach will be followed to avoid permafrostdegradation where possible. It implies detour of areas with poor cryogenic and hydrogeological conditions andproviding good engineering design measures.

Table 1.5: Erosion Control Measures

Potential Erosion problem Mitigation MeasuresUse of spoil and borrow pits All available spoil will be used for structural fill for access roads and

embankments before borrow pits are excavatedLocation of borrow pits Borrow pits will be centrally located to serve more than one siteLocation of spoil and borrowpits

Spoil and borrow pits will be sited far from industrial, agricultural, residential,historic and ecological sites

Top soil from borrow pits Top soil from borrow pits will be removed and set aside. When the Project iscompleted the areas will be regarded, the top soil replaced and the areareseeded. Intercepting ditches will be constructed on the high side of therestored pit to minimize erosion


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Potential Erosion problem Mitigation MeasuresSpoil disposal Soil will be spread on the lowest yielding, least productive land availableSoil disposal When soil is spread on slopes for permanent disposal it will be buttressed at

the toe by a retaining wall. The surface of the slope will be stabilized withshotcrete, riprap or laid rubble as necessary, prior to seeding

Steep cuts All steep cuts will be flattened and benchedNatural watercourses Watercourses will not be blocked and temporary soil and rock stockpiles will

be designed so that runoff will not induce sedimentation of waterwaysSource: Adapted from EIA 2007.

50. Climate and Air Quality. Impacts: Potential moderate, temporary air quality impacts during theconstruction stage of the Project can be anticipated due to fugitive dust generation. Minor increases in the levelof nitrogen oxides (NOx) and sulphur oxides (SOx) from construction plants and machinery are expected. Nosignificant environmental impacts on air quality are anticipated during operation of the road. Moreover, theimproved road would reduce dust emissions caused by driving on the earth tracks. No significant air qualityimpacts warranting mitigating actions in the operational phase are anticipated. Mitigation: Contracts will containprovisions to avoid adverse impacts on air quality such as: trucks carrying earth, sand or stone will be coveredto avoid spilling, operators will be required to install emission controls. Routine air quality monitoring will alsobe required in areas of high potential impact (asphalt plants, construction camps) during the life of the Project.

51. Surface and Groundwater Hydrology. Impacts: No impacts on water quality or the availability ofwater for domestic or agricultural use are anticipated. As groundwater in the project area is relatively deep (> 5m), no impacts on groundwater resources are anticipated in either the construction or operation phases of theProject. No wells / hand pumps are located in the area of potential impact. There will be no net loss of wateraccess points. However, fuel and chemical substances used for road construction could contaminategroundwater and surface water if they are not properly stored and disposed. Mitigation: The Contractor willdevelop and implement contingency plans for control of oil and other dangerous substance spills (SpillManagement Plan); Fuel storage, maintenance shop and vehicle cleaning areas would be stationed at least300 m away from the nearest water body; Stormwater drainage and retention basins would be constructed anda silt trap (where a river/stream is nearby) would be installed prior to commencement of construction to controlrunoff water and sediment and prevent entry of contaminants into a water body; Oil and grease are likely to bedischarged in the construction vehicle parking area, vehicle repair area, and workshops. All wastewater wouldbe directed into an oil interceptor prior to discharge; Mitigation measures for minimizing construction impactshould be considered for implementation during road maintenance, especially during major road maintenance.

52. Noise. Impacts: Noise is not a significant problem along the route, since it does not intersect any maintown or fixed settlements. However, construction noise could adversely affect the Saiga population in theMankhan nature Reserve. Significantly high noise will be generated from blasting at Bodonch Canyon.Mitigation: Noise impacts during the construction phase will be mitigated through the use of source controls,site controls, and time and activity constraints.

Biodiversity

53. Flora. Impacts: No threatened or endangered flora species are located within the right of way (ROW).No adverse impacts to such species are likely to occur due to construction activities. Plant species presentwithin the ROW are native species, which are highly tolerant of grazing, compaction, and other physicaldisturbances. Moreover, construction of the paved road will have moderate positive impact on flora byexcluding the use of multiple earth tracks that affect flora. Mitigation: None.

54. Fauna. Impacts: Impacts were assessed in regard to the following issues:

Habitat Loss and Wildlife Migration Patterns . No significant habitat loss is anticipated;moreover, habitat gain is anticipated as a result of construction of an asphalt road instead ofmultiple earthen tracks running in parallel throughout the width of the alignment. Potentialwildlife crossing zones were identified by experts of Specially Protected Area AdministrationDepartment in Bayan-Olgiy, WCS and WWF Mongolia Programme Office as shown in Figure1.3 below. Discussions with experts of Specially Protected Area Administration Department in


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Ulaanbaatar and Bayan-Olgiy, WCS and WWF and observations during field trips provideevidence that the magnitude of adverse impacts to wildlife patterns will likely be insignificantbecause:

o The road alignment under development is an existing one that has been usedfor many years. Although the traffic volume is presently low, the existing alignment hasmultiple earthen tracks with widths up to 500 m which causes disturbance to a largerarea than the paved road will.o The projected volume of traffic is quite low: less than 700 vehicles per day byyear 2013 and a bit more than 2000 by year 2022. Such traffic intensity will have onlyminor effects on fauna and migration patterns.o Construction activity will be short-term and mitigation measures will beimplemented, there will not be any substantial negative impacts.

Poaching. Poaching presents a threat to wildlife in the project area along with natural factors,such as unfavourable weather conditions (severe winters and drought summers) and foodshortage. The WWF representative in Mongolia noted that the network of poachers and illegalwildlife traders in the project area has been terminated. The activity of this network wasweakened by a new WWF project aimed at conservation of the Saiga Antelope. This hasassisted in arresting the poaching in the area. Currently WWF supports 8 rangers equippedwith radio-communication responsible for Saiga conservation. The rangers work in closecontact with two anti-poaching brigades also supported by WWF, whose duties include controlof poaching. The Customs officials at the Mongolian/Chinese and Mongolian/Russian borderreported no illegal trade cases over many years.

Aquatic Fauna. No substantial impacts on aquatic fauna are anticipated.

Figure 1.3: Migration Patterns of Wildlife in the Project Area

Source: Adapted from EIA 2007.

55. Site specific impacts :

Bodonch Canyon. Potential impacts on fauna in Bodonch Canyon may be linked toconstruction activities. Intensive cut and fill and blasting operations makes this site a source ofphysical disturbance for wildlife. Measures have been included in the EMP to mitigate theimpact of construction activities.

Mankhan Nature Reserve. The existing road traverses the Mankhan Nature Reserve.Although the Mankhan Nature Reserve (MNR) was delineated to protect the habitat, the Saigapopulation having moved towards the west of the reserve. The boundaries of the MNR should


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be updated according to the WWF and Khovd Aimag officers responsible for the reserve. Thediscussions with the concerned officers (vide item 9.2 under section 9) brought out the fact thata bypass could not be justified as the Saiga are now adapted to motor vehicles since the roadhas been in existence for a long period and the Saiga population has drifted to other areas.Construction impacts will be temporary and confined to the ROW and operation impactsinsignificant due to the low volume of traffic. Further though there are legislative restriction forindustrial development which alters the environment road construction has not been specifiedas a prohibited activity within the nature reserves.

56. Fauna. Mitigation: Mitigation measures are as follows:

Habitat Fragmentation and Wildlife Migration Patterns. A number of prevention and mitigationstrategies have been considered to reduce habitat fragmentation and avoid wildlife migrationpatterns.

Overpasses, underpasses and at-grade crossings were assessed as expensive or potentiallyineffective structures for the Project, at least in the initial stage of the Project operation. Theprojected volume of traffic is low enough not to recommend these measures. For example,Recommendations on Environment Protection Measures for Highways and Bridges of theRussian Federation (1995) suggests installation of wildlife fencing and corridors in caseswhere traffic volume exceeds 2,000 vehicles per day, a traffic volume that will be reached on

the Project Road after 2020. Therefore, the proposed structure of mitigation measures willinclude:o Using warning signs and wildlife reflectors in the initial stage of the Projectoperation phase;o Capacity building of the Administrations of Specially Protected Areas in Hovdand Bayan-Olgiy aimags. They will be responsible for collection of additionalinformation on wildlife migration routes and behavior of animals to providerecommendations on feasible mitigation measures when the traffic increases in closecooperation with WWF and WCS; ando As traffic volumes increase, the database should be sufficient to provide aframework to assess whether additional mitigation measures (e.g., overpasses,underpasses, at-grade crossings) are warranted.

Anti-Poaching . Local environmental protection authorities and international organizations aremaking a major effort to control poaching in the project area. However, their potential is stilllimited. Improved accessibility as a result of road construction will require additional measuresto be taken. The mitigation measures will include two major options:

o Strengthening anti-poaching units. This task is currently addressed by WWFwith assistance of other NGO’s.

o Preventing illegal trade. The capacity of Customs at the Russian/Mongolianborder and especially the Mongolian/China border should be strengthened to notallow poachers and illegal traders to smuggle Saiga horns, skins of rare animals,and similar articles. The training course for customs and border officers should beorganized as supplement to CITES and include such issues as the Saiga hornillegal market, identification of Saiga horns, identifying and prosecuting illegaltraders and creating awareness.

Mankhan Nature Reserve: Preparation and implementation of a Protected area ManagementPlan for Mankhan Nature Reserve would assist in mitigating impact of road operation on theReserve and saiga population in particular.

Socio-Economic impacts

57. Relocation. No permanent structures including houses have been reported from the ROW or close tothe ROW. Stone structures that can be disassembled and rebuilt could be located close to the ROW in theinterim period between this report and construction. However, the impermanent nature of these structures


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facilitate these being relocated further back from the alignment without any significant impact.

58. Non-transport Infrastructure. Potential impacts to non-transport infrastructure include:

Water Supply Systems. The Project will have no direct impact on area water supply systems.

Sewerage Systems . The Project will have no direct impact on sewerage systems.

Energy Systems. The Project will have no direct impact on area energy systems. Thecoordination with local authorities will be required where construction works can affect powerlines close to town areas.

Waste Disposal. Potential waste disposal impacts could occur due to the improper disposal ofconstruction waste, waste oil and solvents, and human waste from construction camps.

59. Mitigation. Mitigation related to potential non-transport infrastructure has been assessed as follows:

Water Supply Systems. Project contract documents will contain provisions requiring pre-construction monitoring of existing water quality to provide a baseline for the measurement ofimpacts during the construction period. Routine water quality monitoring will also be required inareas of high potential impact (river crossing sites, construction camps, and other areas withpotential to contaminate runoff) during the life of the Project.

Sewerage Systems . None required other than coordination with local officials.

Energy Systems. None required other than coordination with concerned officials.

Waste Disposal. Contractual requirements for the Project will include enforceable provisionsfor the proper disposal of waste. Implementation and enforcement of the provisions will be theresponsibility of the Supervising Engineer.

60. Site-Specific Considerations. No site-specific measures with regard to infrastructure beyond thoserecommended for incorporation in the Project and detailed above are required.

61. Potential Impacts on Transport Infrastructure. There will be some impact on road transport duringthe construction period due to detours and traffic inconveniences. After construction, the primary transport

impact of the Project will be improving the performance of the transport sector and greatly facilitating the flow oftraffic, goods, and travellers.

62. Mitigation. As included in the EMP care will be taken during the construction period to ensure thattraffic disruptions are minimized. No mitigation actions related to transport, other than those actions alreadyincorporated in the Project, are required.

63. Potential Impacts on Historical and Cultural Heritage. Some impacts on archaeological and culturalheritage locations could be encountered during the construction period, especially if new sites are encounteredduring construction.

64. Mitigation. The Contractor will prepare a Cultural Heritage Management Plan to manage any sites thatmay be encountered during construction. If a historical, cultural, or archaeological relic is encountered along

the project alignment, all construction activities will halt and the established action plan will be implemented(notification of soum/district governor, Institute of Archaeology, and local police). Work will recommence onlyafter appropriate measures have been taken as requested by the appropriate authorities and confirmation isreceived that work may resume.

65. Health Impacts. Human health risks associated with the Project during construction or operationphases can include:

Facilitation of the transmission of diseases. During construction, there will be an increased riskof work crews spreading socially transmitted diseases such as HIV/AIDS. Improvement of the


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road section and the resultant increase in traffic densities would supply improved conduits forthe transmission of such diseases.

Contamination of local water supplies. Potential impacts to local water supplies include thepossibility of contamination by the water supply and wastewater disposal systems associatedwith the labour camps during the construction period. Contract provisions to ensure that thesefacilities are properly sited should be incorporated in all project bid documents.

Air quality decline. No significant impacts on air quality and consequently public health areanticipated from the Project. The construction of the paved road will contribute to decreasingdust concentrations in ambient air.

Noise Pollution. No significant impacts on sensitive receptors with health consequences areanticipated.

Safety. Improved road will result in increased traffic speeds. Engineering efforts has beenundertaken to reduce the likelihood of accidents and users will be educated about the risks ofhigh speed. Traffic laws will be enforced.

66. Impact on Livelihoods. It was established that the new road formation would not be a barrier to freeroaming of herds in pasturelands.

67. Greenhouse Gas. The low volume of traffic is not expected to generate greenhouse gases toadversely impact climate change.

68. Construction Camp Impacts and Management. Potential effects of construction camps arecompetition for local sources of water, sewerage facilities, energy systems; solid and liquid waste generation,poaching and illegal trade, spilling of lubricants, hazardous materials, etc. Before the construction activities willcommence the Contractor will prepare and submit a Construction Camp Management Plan that will proposepreventive/mitigation measures for environmental impacts of the construction camp, construction yard includingfuel storage, filling station and vehicle washing sites.

69. Safety. Impacts: The upgraded road will allow for increased speeds, which generally increases thepossibility of accidents and fatalities. Mitigation: It is recommended that the three Es be applied – Engineeringto reduce the likelihood of accidents, Education of road users on the risks of high speeds, and Enforcement.The road has already been engineered for accident prevention and warning signs and road markers will beused as appropriate.

70. Cumulative Impacts. Cumulative and induced impacts identified are associated with the developmentof the mining industry and tourism. Synergetic impacts of global warming and anthropogenic effects topermafrost areas such (road construction activities) can pose risks of accelerated permafrost thawing anddevelopment of thermokarst processes.

1.3.2 Economic Assessment

Benefits

71. Environmental benefits associated with the Project are related mostly with regaining pastureland,decreasing the occurrence of erosion processes, reducing dust and noise, decreasing the number of vehiclebreakdowns, decreasing pollution of rivers due to avoidance of direct crossing of watercourses, and reducingvehicle fuel use and emissions.

72. Pastureland regained. Table 1.6 provides an assessment of the amount of pasture land regained as aresult of the elimination of earth tracks. The assessment is prepared for multi track areas of the road section.


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Table 1.6: Assessment of Land Regained with Elimination of Multitrack

Section Lengthof

multi-track

Estimatedaverage

number oftracks

Averagewidth of alltracks (m)

Landregained(ha/km)

Estimate oftotal land

regained, (ha)

Baga Ulaan Davaa -Mankhan

70 20 100 10 700

Note: With the assumption that the width of track is 5 m.

73. Reduction in Erosion. As mentioned above, the presence of earthen multi-track leads to erosion ofpastureland and thermal erosion processes especially in areas with rolling topography or permafrost. Olonuur(an area of many lakes between Khovd and Olgiy) is one of the identified areas where the elimination of multitrack can stop triggering erosion processes 3. However, a quantitative assessment of this benefit has not beenattempted due to lack of data.

74. Dust and Noise Reduction. A great quantity of dust in is generated by vehicles traveling on the earthroads. Although, it is difficult to quantify the amount of dust generated by existing traffic, it is anticipated that thepaved road will significantly contribute to the reduction of dust generation. It is anticipated also that there willalso be some decrease in noise pollution per individual vehicle due to improvement of physical characteristicsof road surface and road geometry.

75. Vehicle Breakdowns. It is anticipated that the number of vehicle breakdowns occurring along theproject road will decrease as a result of improved road conditions. A smoother road will reduce vehicleoperating costs and the availability of rest areas will avoid accidents due to fatigue.

76. Vehicle Emission and Fuel Consumption Reduction. Decrease in vehicle emissions and fuelconsumption per vehicle are expected as a result of improving the physical characteristics of road surface androad geometry. Travel times between locations will decrease, thereby lowering the overall amount of vehicleemissions and fuel consumed.

Environmental Costs

77. The environmental costs of the Project have been estimated as US$ 396,100. The costs includemitigation measures, monitoring, collection of detailed information and capacity building.

1.3.3 Public Consultation and Disclosure

78. Two rounds of public consultations have been held for the entire road corridor of the Western RegionalRoads Project during the preparation of the EIA in 2007.4 These consultations were conducted for the full 748.4km length of the Western Regional Road Corridor. They were held mainly in Khovd and Oligii and includedpublic from the project affected area of the present project from Khovd to Buraatyn Davaa.

79. During the preparation of this EIA the Consultants conducted public consultation and informationdissemination with stakeholders of the Baag Ulaan Davaa-Mankhan section. Discussions were also held withthe PIU, Aimag and local government authorities and WWF local branch.

80. Community around the Mankhan Soum was consulted at a community meeting at the Bayangol BaghCenter where 21 local residents including 06 women participated with Citizen Representative and Khural HeadPurevdashTserendorj in the chair. Ger community along the road and herdsmen were also consulted duringfield visits in May, 2011.

3 Government of Mongolia. 2007. EIA . Ulaanbaatar.4 Government of Mongolia. 2007 . EIA . Ulaanbaatar.


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81. The view of the community was that while they appreciated the benefits of road development the roadimpacts on 46 ha of agriculture and pasture land should be avoided. The agricultural land are beside thepresent alignment and the use of multi tracks has been adversely affecting the lands. It was explained that theroad formation narrower that the land take by the mutitracks would avoid the impact on their agricultural lands.Further, as it is better to avoid natural risks such as road closing from heavy snow fall in winter time in the highslopes of Baag Ulaan davaa area.

82. At the meeting held at Khovd Deputy Governor’s Office where the Deputy Governor, Tumendemberel,Head of Environmental Department, Ts.Gantulga, Supervisor in Environment and Tourism Center and A.Nansalmaa Environmental officer and Biodiversity and Specially Protected Area Specialist participated, thefollowing observations were made.

83. When queried the need for a new alternative alignment around the western boundary of the MankhanNature Reserve they did not believe that an alternative alignment is required. Although the reserve boundarywas delineated for the purpose of protecting natural habitat of Saiga Antelope the Saiga population has movedtowards the West of the reserve and do not fully accommodate the current population distribution of SaigaAntelope. Ts.Gantulga has been involved in Mankhan NR boundary defining process in 1993. The Saigapopulation in the reserve is isolated from other populations in the region and is very small in numbers; roughlyestimated as 10-25 individuals. Further, the Saiga are already adapted to traffic movement and noise fromunpaved earth road existing in the area over 30 years. Saiga can be observed on both sides of current earthroads. And during their breeding season saiga move to other places Tsagaan Burgasnii Saari and Taliin KharUul area located outside of Mankhan NR.

84. At the consultation with the Khovd Branch head of WWF, D.Tseveenravdan, it was pointed out that onlyabout 30 Saiga survive in the Mankhan Natural Reserve area now and they are adapted to crossing the road.However, care should be taken to ensure that the road embankment height will not be a barrier for Saiga toroam across the road freely in this area.

1.4 Recommendations

1.4.1 Environmental Management Plan

85. The main objective in formulating the Environmental Management Plan (EMP) is to recommend a setof environmental safeguard measures to address the adverse environmental and social impacts of the project.In addition to establishing mitigation measures and implementation responsibility the EMP will also includemonitoring mechanisms to ensure compliance with EMP requirements and environmental regulations of thecountry. The detailed EMP is included in Appendix I.

86. Institutional Arrangements. Key players involved in environmental management of the project are asfollows:

The Ministry of Roads, Transportation, Construction and Urban Development (MRTCUD)will be the Executing Agency for the Project and through its Department of Roads (DOR)ensure that environmental management is implemented as required and report to the SteeringCommittee and ADB.

The Steering Committee will include representatives of different Ministries and Agencies such

as Ministry of Finance, Ministry of Health, MNET, and MRTCUD. The Chairperson of theSteering Committee is the State Secretary of MRTCUD.

The Project Implementation Unit (PIU) will reside within the DOR with on-site offices. ThePIU through the SE will be responsible for overall contract administration and day-to-dayproject supervision including environmental management.

The Supervising Engineer (SE) will perform the following duties:o supervise site environmental management system of the contractors, and provide

corrective instructions;o review the EMP implementation by the contractors; and


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o report EMP implementation status to the PIU/DOR on environmental inspection andmonitoring results.

The Contractor. In the technical specification for the civil works contract, activities to protectenvironment will be described. During construction, contractors will strictly implement theContractor’s EMP and undertake self-check activities and fully cooperate with the externalenvironmental inspections.

87. Figure 1.4 below presents the implementing and reporting structure for the EMP:

Figure 1.4: Organizational Chart for Implementing the EMP

88. Capacity Building. It was found that the capacity of PIU to undertake responsibilities for carryingenvironmental management and monitoring is limited. There is little experience in the implementation andmanagement of EMPs and skilled technical staffs are not available at either the national or aimag levels. Thus,it will be necessary to embody a program of institutional strengthening and training through the provision oftechnical assistance and procurement of laboratory equipment and supplies. This will be considered incombination with a proposal on new organizational structure.

89. Environmental Monitoring. The monitoring framework for the Project is summarized in Appendix I.Monitoring activities include site supervision, verification of permits, monitoring environmental impacts such asnoise, air and water pollution as well as wildlife migration routes.

90. It is recommended that construction contracts include that instrumental monitoring of air quality, waterquality and noise levels should be carried out prior to commencement of construction to establish a baselineagainst which impacts can be measured. The locations for baseline monitoring may be determined inconsultation with SE and MNET and local government environmental inspectors. Contingency provisionsshould be included for additional air and water quality, as well as noise monitoring at the request of theSE/MNET if warranted by events.

1.4.2 Grievance Redress Mechanism

91. A grievance redress mechanism (GRM), consistent with the requirements of the ADB Safeguard PolicyStatement (2009) will be established prior to construction to prevent and address community concerns, reducerisks, and assist the project to maximize environmental and social benefits.

92. In addition to serving as a platform to resolve grievances, the GRM has been designed to help achievethe following objectives: (i) open channels for effective communication, including the identification of newenvironmental issues of concern arising from the project; (ii) demonstrate concerns about communitymembers and their environmental well-being; and (iii) prevent and mitigate any adverse environmental impactson communities caused by project implementation and operations. The GRM is accessible to diverse membersof the community, including more vulnerable groups such as women and youth. Opportunities for confidentiality


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and privacy for complainants are to be honoured where this is seen as important.

1.4.3 Conclusion

93. The Project will have some negative and positive, direct and indirect environmental impacts onphysical, ecological and socio-economic environment during the road construction and operation phases. Mostof the alignment traverse on or along existing tracks and it is on these tracks that the road construction will be

carried out. Further, the adverse impacts during construction are temporary and could be minimized by properplanning, good construction practices and implementation of the proposed mitigation measures and monitoringprograms. Thus, these impacts are not expected to pose any threat to the environment.

94. Assuming effective implementation of the mitigation measures and monitoring requirements as outlinedin the Environmental Management Plan (Appendix1), the Project is not expected to have significant adverseenvironmental impacts.


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2. INTRODUCTION

2.1 Background

95. Mongolia’s landlocked location between the People’s Republic of China (PRC) and the RussianFederation and its remoteness from developed international and domestic markets are major constraints

to international development. The Government of Mongolia has identified increasing investment in roadconstruction and rehabilitation as a means to reduce Mongolia’s isolation from world markets and improvethe accessibility of isolated communities within the country. This emphasis on road rehabilitation andconstruction has been included as one of the main issues to be addressed in the Economic GrowthSupport and Poverty Reduction Strategy.5 The improvement of the Western Regional Road Corridor willbe a large step forward in reducing geographical isolation within the region.

96. The improvement of the Western Regional Road Corridor (WRRC) will assist the Government tomeet the objectives identified within its Comprehensive National Development Strategy for Mongolia thatis based on Millennium Development Goals. Among these objectives are: expanding and developing theauto road network and connecting aimag and regional centers and the capital city by paved roads;improving the care and maintenance of the national and local roads; and reducing the negative impacts ofautomobiles on the surrounding environment, population, and traffic movements.6 These goals andstrategies are also in line with the transportation sector strategy for Mongolia developed with theassistance of the ADB.7

97. The Government of Mongolia, with the objective of improving its internal transport network andincreasing trade and transit links between Mongolia and its neighbouring countries, the People’s Republicof China (PRC) and the Russian Federation, has undertaken the upgrading of the Western RegionalRoad Corridor through its Ministry of Road, Transport Construction and Urban Development (MRTCUD).The 784.4 km WRRC connecting Yarant at the Mongolia/China border and Ulaanbaishint at theMongolia/Russia border (Figure 2.1) is strategically important for the socioeconomic and regionaldevelopment of Mongolia, as well as improving relationships with neighbouring countries.

98. The outcome of the proposed project will be an efficient and safe regional transport route that isdeveloped in the Western Region of Mongolia, linking Xinjiang Autonomous Region in the PRC and theSiberia region of the Russian Federation by way of Khovd and Bayan-Olgii aimags of Mongolia. WRRCalso includes a section of Asian Highway 4 (AH4), an internationally designated road by the UnitedNations Economic and Social Commission for Asia and the Pacific (UNESCAP).

99. The total road length of 784.4 km of WRRC has been divided into 9 sections for financingarrangements, as shown in Figure 2.2. The section under consideration for ADB funding and examined inthis environmental assessment consists 103.3 km from Baag Ulaan Davaa to Mankhan. The project roadsection is located within the western aimag of Khovd which has a population of approximately 89,240(2009). The poverty incidence in this region was 51 percent in 2003, higher than the national average of36 percent.

5 Government of Mongolia.2004. Economic Growth Support Poverty Reduction Strategy. Ulaanbaatar.6 Government of Mongolia. 2007. Millennium Development Goals (MDGs)-based Comprehensive National Development

Strategy of Mongolia. (Draft) Ulaanbaatar.7 ADB 2007. National Transport Strategy for Mongolia. Manila.


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Figure 2.1: Western Regional Road Corridor

100. Other sections are to be funded by the Mongolian Government, ADB, Peoples Republic of Chinaand ADB/ Government of Mongolia co financing.

2.2 EIA Preparation

101. This Environmental Impact Assessment (EIA) has been prepared for the proposed road section of103.3 km from Baga Ulaan Davaa to Mankhan (the Project). The EIA describes the baselineenvironmental conditions, including physical, ecological and socio-economic resources along the road,assesses the environmental impacts of the intended road development, and provides remedial/mitigationmeasures. The EIA has been prepared in accordance with ADB’s Safeguard Policy (2009) and Guidelinesfor EIA, as well as Mongolian environmental impact assessment legislation.


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102. This EIA is a stand-alone document for the Project. The detailed design has been prepared forthe Project and is being reviewed by the Consultant.8 The Economic and Financial Analysis and Socialand Poverty Impact Assessment are also being updated by the Consultant.

2.3 Asso ciated Project Facilities

103. The total 784.4 km length of the road corridor alignment has been divided to 10 sections ofvarying lengths and these are at different stages of development as presented in Figure 2.2. All thesesections together with the ADB proposed project consist the Western Regional Road DevelopmentProject and were considered in the Environmental Impact Assessment9 prepared in 2007.

104. Table 2.1 below presents the road section lengths and funding arrangements for the othersections which are associated with the present Project identified for ADB funding.

Table 2.1: Other Road Sections and Funding SourcesRoadSection

YaranttoBulgan264 km

next64km

nextsection upto BaagUlaanDavaa110.8 km

Mankhan toKhovd85.3km

KhovdtoBuraatinDavaa147.9 km

76kmsectionafterBuratiinDavaa

Nextsectionof 30km(northof Olgii)

Next 40kmsection

Last 25.8km toUlaanbaishint

Fundedby

GOM GOM GOM PRC ADB PRC GOM GOM Underconsideration by ADB

8 Consultant TA 7449-MON: Regional Transport Development Project Component 1-Prparing the Western Regional Road IIProject.

9 Government of Mongolia. 2007. EIA. Ulaanbaatar.


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Figure 2.2: Road Sections of the Western Regional Road Corridor

Source: Adapted from EIA 2007.

2.4 Report Structure

105. This Environmental Impact Assessment Report has been prepared by the Consultant on behalf ofthe Government of Mongolia. It is based on the Environmental Impact Assessment10 of the project forPreparing the Western Regional Road in Mongolia. This project EIA also includes work results of theConsultant and the Detailed Design11 for the Baag Ulaan Davaa to Mankhan section of WRRCdevelopment project.

106. The EIA Report has been prepared following the Safeguard Policy Statement (2009), theSafeguard Requirements 1: Environment. It also complies with Government of Mongolia requirements. In

addition, the first chapter - Introduction, has been included to provide background information andlocation of the proposed project section in relation to the total road alignment of 784.4 km, and toestablish its importance in association with the development of the other sections of the alignment.Accordingly, the report is organized as follows:

10 Goverment of Mongolia/ADB. 2007. Feasibility Study EIA Ulaanbaatar.11 MCPC. 2008. Detailed Engineering Design for Olgii-Khashaat Pass Section and Khashaat Pass to Hovd Section. Ulaanbaatar.


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3. POLICY LEGAL AND ADMINISTRATIVE FRAMEWORK

3.1 Enironmental Policy

114. Mongolia has enacted a comprehensive policy and legal framework for environmentalassessment and management. It has policies, legislation and strategies in place to manage the protected

estate, to satisfy its international obligations, and to protect the quality of the environment for the healthand well-being of its citizens. The hierarchy of policies and legislative provisions for environmentalmanagement in Mongolia comprises five layers ranging from the Constitution to international treaties, andto environment and resources protection laws.12

115. The main policy documents are the National Environmental Action Plan of 1996, the StateEnvironmental Policy of 1997, the National Plan of Action to Combat Desertification, the BiodiversityConservation Action Plan, and the National Plan of Action for Protected Areas, all developed under theMinistry of Nature Environment and Tourism (MNET) auspices, as well as the Mongolian Action Programfor the 21st Century with subordinated aimag development plans developed by the National Council forSustainable Development.13 The National Environmental Action Plan was updated in 2000 and theNational Action Plan for Climate Change was added in the same year. Several program documents (e.g.National Water Program, National Forestry Program, Program of Protection of Air, EnvironmentalEducation, Special Protected Areas, and Protection of Ozone Layer) were also completed at the turn ofthe decade. State policy on Environmental Impact Assessment was in place in 1998. In addition, otherguidance documents with important environmental repercussions were developed under the auspices ofother ministries and these include the Roads Master Plan, the Power Sector Master Plan, the TourismMaster Plan, and the Renewable Energy Master Plan. 14 Other documents, such as the annual HumanDevelopment Reports have increasingly incorporated environmental aspects.

116. A fundamental principle of the Mongolian state environmental policy is that economicdevelopment must be in harmony with the extraction and utilization of natural resources and that air,water and soil pollution will be controlled. In April 1996, Mongolia’s National Council for SustainableDevelopment was established to manage and organize activities related to sustainable development inthe country. The country’s strategy is designed for environmentally friendly, economically stable andsocially wealthy development, which emphasizes people as the determining factor for long-termsustainable development.

117. The health of Mongolia's natural ecosystems and populations of wild species is of both nationaland global importance. The country forms an important part of the global ecosystem in the ecologicaltransition zone in Central Asia, where the great Siberian taiga, the Central Asian steppe, the high AltaiMountains, and the Gobi desert converge. In recognition of its global responsibilities, Mongolia hasacceded to a number of international environmental conventions and the key ones are tabulated below.Each of these conventions places obligations on signatory governments ranging from the provision of alegislative basis for implementation, to adherence to the requirements and conditions of each convention,to monitoring implementation performance on a regular basis, to reporting on a regular basis and to theconference of parties.

Table 3.1: International Environmental Conventions Signed by MongoliaConvention Year of

AccessionConvention on Biological Diversity (CBD) 1993UN Framework Convention on Climate Change (UNFCCC) 1994Kyoto Protocol 1999UN Convention on Combating Desertification (UNCCD) 1996Convention on the Protection of Wetlands of International Importance (Ramsar) 1998

12 UNDP. 2008. Institutional Structures for Environmental Management in Mongolia. Ulaanbaatar and Wellington.13 Ibid. p15.14 Ibid. p15.


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CONVENTION YEAR OF ACCESSION

Vienna Convention for the Protection of the Ozone Layer 1996Montreal Protocol (regulating substances that deplete the ozone layer) 1996Convention on International Trade in Endangered Species of Fauna and Flora(CITES)

1996

Convention on the Transboundary Movement of Hazardous Waste (Basel) 1997Rotterdam Convention on the Prior Informed Consent Procedure for CertainHazardousChemicals and Pesticides in International Trade

2000

Stockholm Convention on Persistent Organic Pollutants (POPs) 2004World Heritage Convention 1990

3.2 Environmental Law

118. The Government of Mongolia undertook a major environmental law reform in 1990 including thelaw of the land, protected areas, water, forest, wildlife, and native flora resources. The legislation base isextensive as evidenced by the following table of key environmental legislation.

Table 3.2: Key Environmental Legislation in MongoliaName of the Law Year Adop tedThe Constitution of Mongolia 1992Law on Environmental Protection 1995, revised in 2006 and2008Law of Land Jun 2002Law on Land Cadastre and Mapping Dec 1999Law on Land Fees Apr 1997Law on Land Possession Jun 2002Law on implementation of regulations related to Land PossessionLaw Jun 2002Law on Geodesy and Cartography Oct 1997Law on Special Protected Areas Nov 1994Law on Buffer Zones Oct 1997Law on Water Apr 2004Law on Water and Mineral Water Resource Fee May 1995Law on Forests Mar 1995Law on Fees for Timber and Fuel wood Harvesting May 1995Law on Prevention of Steppe and Forest Fires May 1996Law on Reinvestment of Natural Resource Use Fees forConservation Jan 2000Law on Natural Plants Apr 1995Law on Natural Plant Use Fees May 1995Law on Protection of Plants Mar 1996Law on Hunting 2000, 2003Law on Fauna 2000Law on regulation of export and import of endangered species offlora and fauna Nov 2002Law on Hunting Reserve Use Payments and on Hunting andTrapping Authorization Fees May 1995Law on Underground Resources Dec 1994Law on Minerals 1997, revised in 2006Petroleum Law 1991Law on Air Mar 1995Law on Hydrometeorology Nov 1997


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Name of the Law Year Adop tedLaw on Protection from Toxic Chemicals Apr 1995Law on Environmental Impact Assessment 1998, revised in 2002Law on Tourism 1998Law on Solid Waste Nov 2003Law on prohibiting export and transportation of Hazardous Waste Nov 2000

3.2.1 Law on Environmental Protection

119. The Mongolian Law on environmental protection is the umbrella law for all environmental andnatural resource legislation in Mongolia. It governs the land and subsoil, mineral resources, waterresources, plants, wildlife and air, and requires their protection against adverse effects to preventecological imbalance. The environmental protection law regulates the inter-relations between the state,citizens, economic entities and organizations, with a guarantee for the human right to live in a healthy andsafe environment. It aims for an ecologically balanced social and economic development, the protectionof the environment for present and future generations, the proper use of natural resources, including landrestoration and protecting land and soil from adverse ecological effects. There are provisions that enablethe development of state and local rights on environmental protection; environmental protection rights andobligations of citizens; environmental carrying capacity; to specify the maximum level of natural resourcesuse; to provide for ecological training and education; to specify state environmental guidelines andprinciples and to provide for environmental assessment, databases and research and financing. Nationalpolicy to protect ecologically significant aspects of the environment and to restore natural resources isprepared under the Law on Environmental Protection.

3.2.2 Law on Air

120. The purpose of this law is to regulate actions in order to protect air quality, particularly with regardto issues related to the health of the country’s population and minimizing greenhouse gas emissions. Thefollowing administrative bodies are primarily responsible for the Law on Air:

The Central Administrative Body responsible for Nature and the Environment: developsan air protection national action plan and submits it to the Cabinet of Ministers forapproval; organizes air quality and monitoring measurements; and develops standardsand norms related to air protection and submits them to the appropriate institutions forapproval.

The Central Administrative Body responsible for Health Care develops the nationalstandards on permissible levels of air pollutants and has these standards approved bythe appropriate agency.

121. Article 11 of the Law on Air describes the air protection requirements during construction.Standards for permissible limits on the amount of air polluting substances and hazardous impacts shallserve as the basis for the selection of the site, design and construction, commencement of operations,and expansion or renovation of equipment and technology for any building for industrial, service or otherpurposes.

122. An Environmental Impact Assessment (EIA) shall be completed prior to construction of aneconomic entity or organization engaged in activities which discharge air polluting substances or causehazardous impacts.

3.2.3 Law on Water

123. The main purpose of this law is to prevent water pollution by prohibiting littering andcontamination through toxic components near estuaries of water bodies, riverbanks and protection zones.


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3.2.4 Law on Water and Mineral Water Use Fees

124. The Law on Water and Mineral Water Use Fees is designed to regulate fees for the use of waterand mineral water and incorporate these fees into the state budget.

125. Mongolian citizens, foreign citizens, persons with no citizenship, economic entities and

organizations that use water, mineral water and/or riparian zones in Mongolia for any purposes, arerequired to pay the fees.

126. Fee rates for water use shall be determined by the Cabinet of Ministers, based on the limits setout in Clause 1 of Article 6 of the law or determined by aimag or Capital City Citizens RepresentativeKhural based on Clause 2 of Article 6 of this law.

3.2.5 Law on Specially Protected Areas

127. The purpose of this law is to regulate the use and procurement of land for state protection, tofoster scientific research, and to preserve and conserve the land’s original condition in order to protectspecific characteristics, unique formations, rare and endangered plants and animals, historic and culturalmonuments, and natural beauty. The law establishes four protected area categories, each managing landfor a different purpose under a separate management directive. These include Strictly Protected Areas(SPA), National Parks (NP), Nature Reserves (NR) and National Monuments (NM).

128. Strictly Protected Area is the most restrictive category of the protected areas in Mongolia.Strictly Protected Areas (SPAs) are classified further into three zones: Pristine Zone, Conservation Zoneand Limited Use Zone. Only conservational activities and research studies, such as observation, areallowed in Pristine Zones. Activities such as digging, the use of explosives, extracting sand and stone,harvesting wood or constructing a road are prohibited in Conservation Zones. According to Article 12.1 ofthe Law on SPA, it is not prohibited to construct a road in Limited Use Zones.

129. National Park is the second level of protected areas and has a more user-oriented designation.National Parks (NPs) are classified into Special Zones, Travel and Tourism Zones and Limited Use Zones.According to this law, NPs consist of areas that have “relatively preserved” natural features, historical,cultural, educational and ecological importance. Only conservation activities, research studies undertakenby means that do not negatively impact nature, rehabilitation of soil, creation of conditions to reproduceplants and animals, and an elimination of damage from natural disasters are allowed in Special Zones.Activities such as road construction are prohibited in Special Zones and Tourism Zones. According toArticle 17 of the Law on SPA, it is not prohibited to construct a road in a Limited Use Zone.

130. Nature Reserve is the area taken under state special protection for the conservation,preservation, and restoration of natural features, natural resources and wealth. Natural Reserves (NRs)are classified into Ecological Reserves, Biological Reserves, Paleontological Reserves and GeologicalReserves. In any NR, it is prohibited to undertake activities for industrial purposes that change the naturaloriginal condition or activities which are likely to have a negative impact on the environment such asconstruction of buildings, excavation of land, the use of explosives, or exploration and mining for anyresources.

131. National Monuments consist of land taken under state special protection for the purpose ofpreserving the heritage of natural unique formation as well as historical and cultural traces in their naturalstate. Natural Monuments are classified into Natural, Historical and Cultural Monuments. It is prohibited toconstruct buildings, plow or dig land, use explosives, or mine natural resources within 0.1 km to 3.0 km ofNatural, Cultural and Historical Monuments.


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3.2.6 Law on Buffer Zones

132. The purpose of this law is to regulate determination of Specially Protected Area Buffer Zones andactivities therein.

3.2.7 Law on Fauna133. The purpose of the Law on Fauna is to regulate the protection and breeding of fauna, whichpermanently or temporarily reside in soil, water or on land within Mongolia. Article 7 (Protection of VeryRare and Rare Fauna) lists the very rare fauna as “Asiatic Wild Dog (Cuon alpinus ), Snow Leopard(Uncia uncial ), Eurasian Otter (Lutra Lutra ), Gobi Bear (Uros Arctos gobiensis ), Przewalski horse (Equusprzevalski ), Wild Bactrian Camel (Camelus Bactrianus ferus ), Musk deer (Moschus moschiferus ),Reindeer (Rangifer tarandus valentinae ), Moose ( Alces alces pfizenmayeri ), Saiga Antelope (Saigatatarica tatarica ), Mongolian Saiga (Saiga tatarica mongolica ), Central Asian Beaver ( Castor fiber birulai ),Whooper Swan (Cygnus cygnus ), Ring-necked Pheasant ( Phasianus colchius ), Hooded Crane (Crusmonacha ), White-naped Crane (Crus vipio ), Siberian Crane (Crus leucogeranus ), Houbara Bustard(Chlamydotis undulate ), Dalmatin Pelican (Pelicanus crispus ), Relict Gull (Larus relictus ), Baikal Sturgeon( Acipenser baeri baicalensis ), Amur sturgeon ( Acipenser schrenki ), Tench (Tinca tinca ), Amur Sculpin(Mescottus haitej ), and Emperor Moth (Etudia pavonia ).15

134. A list of rare and endangered fauna species is provided in the Mongolia National Red Book. Theaimag Citizen Representative Khural shall approve measures for protection of very rare and rare faunawithin their territory and exercise control over the implementation.

3.2.8 Law on Flora

135. The Law on Flora coordinates activities related to protection, sustainable use and rehabilitation ofplants, excluding cultivated plants and forest. As part of this law, the Mongolian Government has createda list of rare and endangered flora species.

136. Article 8 of this law mandates that the use of plants for industrial use within 2 km of an estuary ofriver, natural springs or riverbank or in the area where vegetation cover is degrading is strictly prohibited.

3.2.9 Law on Forest

137. The Law on Forest regulates actions related to the protection and sustainable use of forestresources. The forest area is classified according to its ecological and economic values as follows:

Special Forest Zone (alpine forest, pristine and conservation zones of SPA and specialzone of national park). Protection and use of this zone is controlled under the law ofSpecially Protected Areas.

Protected Forest Zone (other forest areas of SPA, green belt area, saxsaul forest andforest growing on 30 degree slope).

Forest Use Zone. Any forest area that is not included in the above zones.

3.2.10 Law on Protec tion of Cultu ral Heritage

138. The purpose of this law is to coordinate all activities related to research of cultural heritage, andregistration, study and classification, valuing, preservation and protection, advertisement and renovation,and issues related to ownership and use of cultural heritage.

15 Government of Mongolia. 2007. EIA .Ulaanbaatar.


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139. The law identifies a number of heritage relics, places and sites according to their scientific,historical and cultural importance. Some ancient tombs/burial sites and calligraphy are also recognized asheritage items.

140. Article 17 of Chapter 6 of this law states that if subsoil exploration activity discovers any historicaland cultural heritage items, operations should stop and the governor and police of the aimag or soum,

along with relevant research institutes shall be informed. It is prohibited to move any historical andcultural item without the permission of the Ministry of Education, Culture and Science.

141. The investigation of cultural heritage shall be implemented by the Professional Inspection Agency,state inspectors, or governors of aimag and soum. The State Professional Inspection Agency shall carryout this investigation in accordance with various laws on protection of cultural heritage, norms, regulationand standards.

142. The Ministry of Education, Science and Culture (MESC) is responsible for determining the statusof historical, architectural and memorial sites of archaeological significance.

3.2.11 Law on Land

143. The purpose of this law is to regulate the possession and use of land by citizens, economicentities and organizations of Mongolia. The law contains a number of provisions which set substantiveand procedural land conservation requirements that prohibit activities that are harmful to human health,environmental protection or environmental balance. The law allows local governments to use an“appropriate part” of land fee revenues for land conservation activities.

3.2.12 Law on Hunting

144. The purpose of this law is to regulate the hunting and trapping of game animals and the properuse of hunting reserves. Hunting requires a special permit and can take place during prescribed seasons.Contact permits and special permits for the hunting and trapping of game animals shall be issued by theState Administrative Central Organization. Article 13 describes these issues. Article 14 lists the prohibitedhunting and trapping methods such as the use of chemical substances and explosives, digging pits,placing triggered guns and arrows o

Documents

Draft Environmental Impact Assessment