E614 Rev. V. 7July 17, 2003

Gansu and Xinjiang Pastoral Development Project

Environmental Management

and Monitoring Plan

Gansu Province

July 17, 2003

HLtE COPY

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Table of Contents

Introduction.

1. Implementation Organizations and Responsibilities

1.1 Implementation Organizations

1.2 Role of PMOs and Environmental Monitors

1.3 Responsible Supervision Organizations

1.4 Environmental Management Plan

2. Gansu Environmental Monitoring Plan

2.1 Monitoring Items

2.2 Monitoring Implementer

2.3 Monitoring Report System

2.4 Pre-Implementation Monitoring (Baseline Data)

2.5 Monitoring during Implementation/Construction

2.6 Monitoring during Operation

2.7 Monitoring Budget

3. Environmental Training/Institutional Strengthening

3.1 Training Objectives

3.2 Combined Training Courses, Gansu and XAR

3.3 Specific Training Courses for Gansu

4 Gansu EMMP Budgets

5. Conclusions and Recommendations

5.1 Major Conclusions

5.1.1 Selection of Project Areas

5.1.2 Environmental Impact Analysis and Mitigation Measures

5.2 Recommendations

5.2.1 Follow-up Program

5.2.2 Public Participation

5.2.3 Further Suggestions and Environmental Requirements

List of Tables

Table I Environment Monitoring Plan, GXPDP, China

Table 2 Environmlental Management Plan, GXPDP, China

Table 3 Construction Air Quality Monitoring Program

Table 4 Noise Monitoring Program During Construction

Table 5 Cost Estimation of Environment Monitoring of Gansu

Table 6 Salary Cost of Environment Protection Staff of PMOs, Gansu

Table 7 Cost for Environment Training in Gansu

Table 8 Cost Estimate for Agrochemical Management Plan for Gansu

Table 9 Total Cost Estimate for EMMP, Environmental and AgrochemicalManagement Planning Training for Gansu

List of Figures

Figure 1 Environmental Management Organization during Construction Stage

Figure 2 Environmental Management Organization during Operation Stage

Figure 3 Monitoring Report Chart

Introduction

1. This Environmental Management and Monitoring Plan (EMMP) forms an integralpart of the Environmental Impact Analysis (EIA) of the World Bank-financed Gansuand Xinjiang Pastoral Development Project prepared by the Chinese ResearchAcademy of Environmental Sciences, and is referenced to in the World Bank's projectlegal agreements.

2. The experiences on EIA around the world has shown that even if mitigation andmonitoring plans proposed in the EIA are clearly described, the mitigation and monitoringplans may be ignored without effective and competent monitoring and enforcementprocedures to supervise and ensure the implementation. Therefore, the EMMP isdeveloped as a monitorable and enforceable plan, prior to commencement of the projectactivities as part of the overall project management operation. The EMMP identifies theresponsibilities of each organization involved in the implementation of EMMP and theproposed mitigation and monitoring activities during design,construction/implementation, and operation. For projects where International FinanceAgencies (IFAs) participate in project funding, the Loan Agreement guarantees that themonies needed for establishing and operating the EMMP would be made available as anintegral part of the project budget (not as a kind of "add on").

3. The project's influence on environment will occur during not only theconstruction/implementation phase, but also during the operation periods. In Chapter 7 ofthe EIA, all the perceived issues affecting the environment were identified and analyzed.Corresponding mitigation measures were proposed. In this document the environmentalmonitoring plan, the implementing agency and the corresponding legally responsibleagencies/institutions are identified. This orderly identification, assessment, andpresentation of mitigation measures ensures that no important issues are overlooked andthat negative impacts are prevented or reduced to minimum.

4. The project is complex, covers a vast area, and involves many environmental issues.However, the impact of the project to local environment can be effectively controlled ifthe following major environmental issues are monitored and controlled.

1. Implementation Organizations and Responsibilities

5. In China, project environmental management within each concerned ministry andcommission is organized and carried out by their respective environmental protectiondepartment under the supervision of SEPA and local EPBs.

6. The Ministry of Agriculture (MOA), one of the concerned ministries, is one of theorganizations that have responsibilities for protection and management of environmentwithin the areas of influence of the project. The institution that has direct responsibility isthe Ecological Environment Division of the Department of Science, Technology andEducation of the Ministry of Agriculture. Its main responsibilities are: (1) to ensure thatthe project adhere with the relevant environmental protection laws, regulations andstandard of China, and (2) to supervise environment protection in the agricultural sectorof the country. SEPA provides supervision and monitoring to the work of MOA. Otherorganizations such as the Livestock Bureaus and Animal Husbandry Bureaus in Gansuand XAR have similar departments and personnel for environmental protection who arealso responsible for supervision and monitoring of the project impact under the overallsupervision of the relevant EPBs.

7. Both Gansu and XAR have provincial environment monitoring stations (EMS)responsible for monitoring the environmental impact of various development activitieswithin their respective jurisdictional boundaries, and for compiling the annualenvironmental quality reports. The responsibility of these organizations include: (1)reporting to SEPA any changes in the quality of natural environment, (2) environmentalpollution control; (3) progress achieved in environmental protection; and (4) handlingapplication for discharge of important pollution source. Environment monitoring stations(EMS) at city and county levels are responsible for monitoring changes of environmentalquality of atmosphere, water, noise and natural environment and for reporting to theprovincial environmental monitoring station.

8. However, the EPB and the EMS staffs are not responsible for daily inspection andmonitoring of the environmental performance of the project. Therefore, the respectivePPMO should provide necessary organization and manpower to ensure effective andsmooth implementation of the environmental requirements of the project. The followingchapter discusses the details of implementing institutions and the proposed EMMP, itsmanpower and institutional requirements.

1.1 Implementation Organizations

9. During project implementation/construction and operation phases of the project,implementation of the EMMP is the responsibly of the respective PMOs. Gansu andXAR EPBs should be requested to:

* Collect the required data as is outlined in this document; and

* Monitor the implementation of the EMMP and check whether the mitigationmeasures of each subcomponent of the project are successfully undertaken.

10. The respective county EPBs should be requested by the respective PMOs to superviseand inspect subcomponents of the project that could have potential environmental impactfollowing the proposed EMMP procedure outlined in this section and the relevantenvironment protection laws of China.

11. The project areas will include 19 counties, two farms and one corporation (Hovill) inGansu and 24 counties and three farms in XAR. In order to ensure smoothimplementation of the project with minimum negative impact on environment, thefollowing EMMP is formulated and must be followed by the project proponents in itsentirety. The EMMP must be considered as a part and parcel of the project and must bebudgeted as a project item in the financial feasibility report and the projectimplementation plan.

12. In order to ensure successful implementation of the proposed EMMP and in line withrelevant national environmental regulations, each PMO should appoint an officer, on apart-time basis, who will have full responsibility for the successful implementation of theactivities defined in mitigation and monitoring sections of the EIA report (Chapter 7) andthe EMMP described in this document during each phase of the project implementationand at least the first five years of project implementation. The county PMOs (CPMOs)should also designate one of their staff to be trained by the project to take theresponsibility of ensuring the adoption of all EMMP activities by the project at thecounty/farm level. He/she should convey the environmental issues within the project to

2

the project implementation agencies of the PPMO and the county EPBs, responsible fordata collection and providing technical assistance to the environmental officer. Theenvironmental officers identified at PMOs at every level (province/region, prefecture,county) are responsible for the preparation of the environment protection materials anddocuments related to project implementation for review by SEPA, the World Banksupervision mission staffs and respective EPBs at various levels During operation phase,each CPMO will assist the PPMO with implementing the environmental monitoringprogram and other work included in the EMMP. However, the ultimate responsibility forensuring that all activities identified in the EMMP are implemented rest on shoulders ofthe respective provincial PMOs and they must ensure smooth flow of requiredenvironmental reports/data from the counties to the provincial/regional offices. Theenvironmental management and organizations during implementation and operationphases are diagrammed in Figure. I and Figure. 2, respectively.

PLG

|- PPMO

| Environmental Officer (PPMO)

Design Unit County PMOs designated Local governmental institutionsenvironmental Supervisors including EMS, EPBs, Forestry

Bureaus, GMS, etc.

Fig. 1 Environmental Management Organization during Construction Stage

PLG

PPMO

PPMOs, CPMOs (1 person, each)

Local governmental institutions including EMS, GMS,Provincial and County EPBs, etc.

Fig. 2 Environmental Management Organization during Operation Stage

3

1.2 Role of PMO and Environmental Monitors

13. As was discussed in 1.1, implementation of EMMP will be the responsibility of PMOsat various levels. They are responsible for ensuring the smooth implementation of themitigation measures and the monitoring plan as is detailed in the environmentalassessment report. Their major tasks include:

a. Review and implementation of mitigation and monitoring activities with commentson the activities as needed to obtain minimum acceptable environmentalperformance level in the overall project;

b. Regularly check implementation of pollution control measures in project sub-components that might have pollution problems such as beef and dairy cattledevelopment sub-component and large feedlots. Report those facilities that are notoperating properly or are discharging above SEPA's environmental standarddischarge regulation and report such violations to local EPBs;

c. Recommending, gaining approval for and carrying out any special studies, which areeither recommended by the implementing agencies or are believed necessary forreaching the minimum acceptable environmental performance;

d. In close cooperation with the project design and implementation teams, make surethat the relevant mitigation measures contained in the EMMP are reflected in thefinal project plans and that necessary conditions for project monitoring are in place;

e. Provision of necessary training of staff of PMOs and implementers of projectsubcomponent on environmental issues and environmental inspection to improve theinstitutional capacity of county and township personnel in implementation of EMMPactivities;

f. Supervise the implementation of the environmental protection measures as specifiedin the environmental mitigation plan;

g. Provide written guidelines whenever gaps in environmental performance are found,seek assistance from appropriate specialists and to take corrective measures;

h. Perform emergency response plans during environmental emergency conditions andreport any environmental accident/mishaps to the PPMO and local EPBs in a timelymanner;

i. Make sure that appropriate environmental reviews and project specific ElAs areprepared and approval is obtained for any newly proposed financially andeconomically feasible enterprise/marketing activities. Approval from the appropriateline agencies (county, prefecture, or provincial EPB and/or SEPA) as nationalenvironmental regulations dictates should be sought and permits should be obtained.Results of the environmental studies should be presented to the WB with Englishtranslation of environmental permits for approval before release of funds for suchnew activities.

j. Implement the EMMP including engaging and supervising monitoring institutionsand ensure that all sampling activities as defined in the monitoring plan arecompleted on a timely manner;

4

k. Prepare periodic reports on environmental performance of the project's activitiesrelated to implementation and operation to be availed to relevant environmentaladministrative departments/Bureaus and the World Bank Supervision missionmembers;

1. Deal with the complaints concerning the environmental aspects and accept thesupervision of the environmental protection departments;

m Arrange for the visits of the Bank Mission staff, if necessary and regulatory staff ofEPB or EMS;

n. Supervise environmental issues during project implementation/construction and urgeconstruction/implementation teams to follow relevant regulations; and

o. Be responsible for other actions needed for implementing the EMMP.

1.3 Responsible Supervision Organizations

14. The XAR EPBs, and Gansu EPBs under the guidance of SEPA are the administrativedepartments for environmental protection. They are responsible for the environmentalmanagement and supervision within the jurisdiction of the respective autonomous regionand province. The local EPBs at prefecture and county levels are the administrativedepartments of the corresponding local governments' environmental protection underrespective regional and provincial governments and are responsible for the environmentalmanagement and supervision within the jurisdiction of the local government. They willbe responsible for environmental monitoring and supervision of project sub-componentswithin their respective local government jurisdiction. EPBs and EMS offices at county,prefecture, and provincial levels should cooperate closely with clearly definedresponsibilities to accomplish monitoring work of the project. Under the jurisdiction ofeach Provincial/regional EPB, a Provincial/regional Central EMS should be establishedthat is responsible for the monitoring of environmental quality within the jurisdiction ofthe province/region. The Prefecture/county level EMS established under prefecture and/orcounty EPBs are responsible for the environmental monitoring within the jurisdiction ofprefectures. The environmental protection work of this project will be carried out underthe supervision of SEPA, provincial/regional EPBs and local EPBs within the projectareas. The environmental supervision plan is summarized in Table 1.

1.4 Environmental Management Plan

15. In order to ensure the effective implementation of the proposed environmentalmitigation measures for the project, an environment management plan has beenformulated and listed in Table 2.

5

Table 1 Environment Monitoring Plan, GXPDP, ChinaStage Organization Monitoring items Monitoring ObjectivesFeasibility Study SEPA, WB 1. Review EIA 1. Guarantee a complete environmental assessment, and appropriate subject

identification, emphasize the key points.2. Review EMMP draft

2. Make sure it reflects the possible, significant potential problems which mightbe produced by this project

3.Guarantee a concrete and practical action plan of mitigation measuresDesign & Gansu EPB, 1. Review the preliminary 1. Strictly execute EMMPImplementation XAR EPB, design for environmental

SEPA, WB protection and EMMP 2. Ensure that all national environmental laws and regulations with regards to.project construction/implementation are considered.

SEPA, WB 2. Check whether 3. Secure that sufficient environmental protection investment is in placeinvestment for environmentprotection is in place.

Gansu EPB, 3. Check selection of project 4. Check whether there are sufficient water resources in the project areas for theXAR EPB areas. development of artificial pastures, dairy farms, feedlots, breeding farms.

5. Ensure that the project areas are far away from the nature reserves buffer andcore areas, and make sure that the project will not block the migration route ofwild animals.

4. Supervise dust and noise 6. Take recommended measures in EMMP to dust and noise pollution.pollution, if found to be anissue. 7. Ensure that construction teams follow EMMP, and relevant state and local

laws and regulations.

8. If noise is found as an environmental nuisance, enforce proposed constructiontimes according to EMMP.

6

Stage Organization Monitoring items Monitoring Objectives5. Inspect whether there are 9. Protect cultural relicsunderground cultural relics.6. Inspect the discharge and 10. Ensure that solid waste and raw sewage are disposed according to relevanttreatment of daily sewage national and local regulations. Ensure that surface and groundwater are notand waste from larger contaminated.construction site such asdairy farms7. Check whether 11. Ensure erosion control measures according to EMMP, national and local lawsconstruction will cause are in place.accelerated soil erosion.

Operation Gansu EPB, .Inspect the implementation 1. Protect the environment; minimize the environmental impact during operationXAR EPB, of EMMP in operation stage phase.Local EPBs,GMS 2.Check the implementation 2. If necessary, review and amend the EMMP to overcome unforeseen impacts.

of monitoring plan3. Guarantee the sewage disposal meet the standard.

3. Verify whether it isnecessary to take further 4. Ensure that project impacts on natural resources are minimized, especially onenvironmental protection natural grasslands and water resources.measures for unforeseenenvironmental problem. 5. Make sure national laws and regulations with regards to animal numbers are

enforced.4. Ensure that grasslandmanagement/improvementmeasures are implemented.

5. Ensure that number ofanimals is not increasedabove carrying capacity.

7

Stage Organization Monitoring items Monitoring ObjectivesGansu EPB, 1. Check whether the 6. Enforce the national regulations with regards to discharge of pollutants,XAR EPB, discharge of pollutants especially sewage discharge of dairy farms and runoff from large feedlots.Local EPBs meets the national

standards. 7. Ensure that project will not cause any additional degradation of naturalgrassland. Report any wrong doing to appropriate regulatory agencies.

2. Check if project iscausing unforeseen pressure 8. Ensure that project will not cause negative impact on water resources and theiron natural grassland, and the availability for downstream users. Report any wrong doings to the appropriatewater balance in the region. regulatory agencies.

3. Check whether the 9. Prevent any potential project impact on nature reserves, rare flora and fauna byproject has any impact on enforcing the EMMP.nature reserves, rare flora orfauna. 10. Supervise and check agricultural chemicals used in rodent control,

grasshopper/locust control, and eradication of poisonous grasses in natural4. Check if project is grassland, ensure that no Category I pesticide is used and other pesticides will notcausing accelerated soil cause pollution of surface and groundwater resources.erosion.

5. Review the use ofagricultural chemicals inproject areas.

8

Table 2 Environmental Management Plan for GXPDP, China

Issues | Mitigation Policies and Control Measures Implementer Responsible

A. Design Phase

1. Optimize project design and plan to minimize its potential negative environmentalimpacts.

2. Project subcomponents should be planned and designed to avoid environmental sensitiveareas like core and buffer zones of nature reserves and wildlife habitats, to avoid naturaland cultural relics, and to reasonably arrange construction schedule to minimize landoccupancy and reduce land occupancy time.

3. Review and ensure that there is a balance between livestock number and feed in the

project areas. Make certain through monitoring that project's grassland management plans Gansu PPMO,

ensure that this project will not put additional pressure on natural grassland, and worsen XAR PPMO,

degradation of natural grassland. EMS, Water Gansu PPMO,

I.The Project Resources XAR PPMO

4. Review water balance studies in the project areas where irrigation water are used for Bureaus, Designartificial pasture development through coordinate with water resource management teams

agencies.

5. Ensure that there will not be any significant impact on water resources of the region, theminimum flow requirements, and the water requirements of downstream users. Promotethe adaptation of more efficient irrigation systems in the project areas.

6. Formulate appropriate feeding models, strengthen management on grazing. In semi-pastoral areas, the number of livestock should be determined by grass availability. Ensurethat the number of animals do not increase above the available feed in natural grasslands(grassland carrying capacity).

9

Issues Mitigation Policies and Control Measures Implementer Agency7. Strengthen GMS to enforce monitoring and regulating the number of animals withinnatural grasslands due to implementation of this project.

8. Ensure that the migration routes of wild animals and their feed sources will not beblocked by fencing, especially in the summer pastures, and ensure adequate feed supply forwild animals.

9. Respective PPMOs should provide the project plans for such project subcomponents thatare close to nature reserves and/or habitats of wild animals for approval of relevantdepartments.

10. Prepare a separate EA report for development of the dairy subcomponent of the projectin Gansu.1. If construction of limited access roads is required, they should be designed to minimizeland occupancy and avoid/minimize damage to vegetation.

2. Land Use 2. Construction of wool packing, feed plant and laboratories should use as little land as Design Units Gansu PPMO,possible. XAR PPMO

3. Artificial grassland development should not claim any new, natural grassland or forestarea.1. Review all agrochemicals that are proposed for use in the project areas and prevent useof any pesticide in WHO Category la that might be proposed for use.

3. Agricultural ~~~~~~~~~~EMO, County Gansu PPMO,ChmAgricultural 2. Promote the use of low residue agrochemicals (pesticides, insecticides, herbicides, Agricultural XAR PPMOChemicals rodenticides, and solutions used for disinfections). Extension Station

3. Alternative control measures should be selected to replace highly poisonous pesticides.

10

Environmental Mitigation Policies and Control Measures Implementer ResponsibleIssues Agency

4. Number 1. Project county GMS monitors variation of the numbers of sheep grazing on naturalVariation of Sheep pasture and selection of migration route within the project areas. Provincial and Gansu PPMO,

Stock in the county GMS XAR PPMO

Project Areas

5. Water Resource 1. Organize relevant agencies to undertake water balance studies in the project areas. Water Resources Gansu PPMO,

Utilization Bureaus or XAR PPMO___________________________________________________________________Stations_________

B. Implementation / construction phase

1. Construction machineries should be kept far away from nature reserves and wildlifehabitats. If construction activities are located in proximity of buffer areas, effort should bemade to reduce noise as low as possible

2. It is not allowed by national laws to convert forest or natural grasslands to any other use Construction1. Nature reserves including artificial grasslands. Artificial grassland development should be implemented in truction Gansu PPMO,

and wildlife present agricultural land or previously converted agricultural land with irrigation facilities. Bureaus, EMS, XAR PPMO,habitats EBuras EM,County PMOs

3. Proper disposal of wastes resulted from construction activities. Waste disposal sitesshould be located far from nature reserves and wildlife habitats.

4. Construction workers should be directed not to enter core and buffer areas of naturereserves. Hunting and damage to wild plants should be strictly prohibited.1. After the canal construction is finished, on such canals that the canals is designed in fillmaterial, vegetation planting should be arranged to cover the exposed side slope. To get the Gansu PPMO,

2. Soil Erosion best effect, the side slope plantation should be completed one month in advance to the Construction XAR PPMO,rainy season. Teams, EMO County PMOs

2. Avoid digging irrigation ditches on mountain slopes greater than 250 or on sloping land

II

Environmental ResponsibleIssues MiiainPlce n oto esrsIpeetr Agency

during rainy season. Sand bags, hay bales or straw matt should be used on the down slopeside of any cut areas to reduce soil erosion and increase in sediment load of the waterbodies.

3. After completion of construction work or development of artificial pastures, vegetativecover should be planted as soon as possible to prevent wind and water erosion, as well asrunoff.

4. The construction of large-scale dairy farm in Gansu should employ restrict soil erosioncontrol measures during construction to prevent soil erosion and increased sediment load innearby river/water bodies. As much as possible, the excavated material should be used inconstruction and any surplus should be disposed off properly according to national andprovincial environmental pollution laws.

5. The waste earth and stone chips produced during construction activities at dairy farms,feedlots, irrigation infrastructure rehabilitation and other construction activities, if cannotbe used in construction, should be piled in designated areas and be removed to dump sites.If no assigned dumpsites are available they can be compacted layer-by-layer and protectedby surrounding retaining walls, and then be covered with vegetation on a timely manner.I. If there are residential areas within 300m of the construction site, construction activitiesare forbidden at 22:00 to 6:00 at night, 12:00 to 14:00 in daytime. In XAR, the scheduleshould be postponed by two hours to reflect the local environmental conditions.

3. Noise 2. The access roads should be selected away from such sensitive locations as schools, Teams, EMO County PMOresidences and hospitals.

If access roads are within 50 meters of sensitive areas, transportation should be banned_________________ during night hours.

12

Environmental Mitigation Policies and Control Measures Implementer ResponsibleIssues Agency

3. When the construction site is close to school, no construction work with heavy noisemachines should be arranged at school time; when the construction site is close to denselypopulated residences, construction work with machinery that produce high noise levelsshould not be arranged at nighttime. In case that the above construction work has to beproceeded, consultation must be made with the residents who may be impacted or propercompensation must be paid. To reduce the noise pollution of construction machineries,mobile noise isolation can be used.

4. The construction operator's work time should be arranged in accordance with the laborhygiene standard, and personal protection measures such as wearing earplugs and helmets,etc. should be provided to the operators.i. Mixing equipment should be placed at least 300 meters from residential areas, hospitalsand schools. Sealing, vibration reducing and dust absorbing measures should be adopted.

2. According to national labor laws, labor protection measures should be provided to theoperators of the construction machineries, such as protective glasses and masks. Construction

4. Air quality Team, County County PMO3. Water should be sprayed during dry, dusty days on the construction sites and related PMOroads to prevent dust.

4. Large-scale dairy farms in Gansu should be located at least 1,000 meters away fromenvironmentally sensitive areas such as residential areas.1. Inform contractors and construction workers on recognition of cultural relics andimportance of protecting them. County Cultural

5. Natural and Relics Bureau Gansu PPMO,cultural relics 2. During construction, if cultural relics are found, construction should stop, the County PMO XAR PPMO

construction supervisor should protect the site, and concerned department should beimmediately notified to handle the find.

13

Environmental Mitigation Policies and Control Measures I mplementerResponsibleIssues ____________________________________________________________________________________ .1. ___________Agency

6. Minority 1. Respect the living style and traditional customs of minority nationalities. Construction Gansu PPMO,Nationalities ________________________________ Tearn, EMO XAR PPMO

C. Operation phase

1. Ensure that the project formulated grassland management plans are followed and thenumbers of sheep are kept below the grassland carrying capacity to ensure sustainable useof grasslands.

2. Enhance the capability of county grassland stations that are responsible for supervision County,

1. Grassland and enforcement of grassland laws. Provincial and Gansu PPMO,Resources 3. In line with the principle of balancing grass and livestock, artificial grassland and other regional GMS, XAR PPMO

feed sources should be developed to reduce pressure on natural grasslands. EMO

4. Ensure that project financed fencing activities will not produce any impediment for non-domesticated animals that also require utilizing the same natural resources. The fencingactivities should not block1. For those project areas where water resource is scarce, study on water balance should beconducted; water use quote for the project should be coordinated with water resourcesmanagement department.

2. Advanced water saving irrigation technologies such as sprinkler irrigation should be County PMOs, Gansu PPMO2. Water resources considered, especially in areas where perennial alfalfa is to be planted to reduce impact on Water Resources and EPB,XAR

water resources and availability of water resources in the lower reaches and surrounding Bureaus PPMO, and EPBareas.

3. Alternative plants to alfalfa with lower irrigation water requirement should also beconsidered in areas with potential irrigation water shortage such as sorghum, oat and vetch.

14

Environmental Mitigation Policies and Control Measures Implementer ResponsibleIssues Agency

4. Rainfed artificial grassland development should mainly use abandoned agricultural landand sloping land (as long as rainfall distribution is adequate for rainfed cropping) to reducethe pressure on irrigated grassland.-1. Project financed fencing, as much as possible, should be restricted to winter pastures.Prior to finalization of any project financed fencing plan, respective environmentprotection agencies that are responsible for wildlife and nature reserves (forestry bureaus,EPBs) should be consulted and their approval should be obtained.

2. If there are wild herbivore animals in the project areas, either no project financedfencing should be allowed in areas that are shared by both domestic and wild animals, oran area of adequate size, determined by responsible lined agencies should be allocated as County PMO, Gansu PPMO

nature reserves exclusion zone for the use of wild animals. EMO, Forestry and EPB, XARBureau, EMS PPMO, and EPB

3. Local wild grass species should be selected for supplementary sowing in naturalgrassland; the grassland stations of the project areas must supervise the selection of seedsand supplementary sowing methods.

4. No chemical fertilizer should be used on natural grassland unless recommended by theAHB or research centers. If fertilizer application is recommended, use of organic manureshould be preferred.1. Supervise and enforce grassland carrying capacity to prevent overgrazing.

EMO, Local4. Soil Erosion 2. Only flat agricultural land (less than 2% slopes) should be selected for development of PMOs, Agric. Gansu PPMO,

irrigated artificial grassland, to prevent aggravated soil erosion and non-point source Extension Officerpollution, caused by irrigation of sloping land.

5. Use of 1. PMOs and agricultural extension stations should formulate appropriate pest management Local PMOs, Gansu PPMO,agrochemicals plans to improve efficiency of agro-chemical application and to minimize negative, long- Local EPBs, XAR PPMO

term impacts of pesticides on natural environment. Agricultural

15

Environme ntal Mitigation Policies and Control Measures Implementer Agency

extension Stations2. Select pesticides and herbicides with short-term residual effect and low toxicity

3. Improve watershed management and agricultural practices based on research conductedby the national and local institutions and include them in the extension programs,especially in grassland management and artificial pasture development.

4. Promote timely and well-balanced application of farmyard manure and chemicalfertilizers.

5. Prior to pesticide application for large-scale rodent control, it must be approved by theprovince/county EPB, and relevant regulations should be strictly followed. In nocircumstances, any category la and preferably Category lb pesticides, as defined by WHO,should be used within the project areas.1. Artificial grassland development should not claim any new land. Only previouslyconverted agricultural land with available and allocated water resources should be used for Gansu PPMO,

6. Land use change development of artificial pastures. According to the national laws and decrees, no natural County PMO XAR PPMOgrasslands or forestland can be converted for any other use including development ofartificial grasslands.

.- 1. The manure and other waste, developed by dairy and beef cattle farm operations(Gansu), and large feedlots (Gansu, XAR) should be disposed off properly. Animal waste

7. Solid and liquid should be collected and composted before application to agricultural fields as farmyard7. Sohd anmanure.

sewage of large manure. Gansu PPMO,dairy farms, cattle County PMO XAR PPMOfarms and feedlots 2. Solid and liquid waste should be treated, and detailed manure management plans must

be formulated based on recommendation provided in Chapter 7, to ensure that surface andgroundwater will not be polluted.

16

Environmental I Mitigation Policies and Control Measures Implementer ResponsibleIssues _____________________________________________________________Agency

3. Sewage of the dairy farm in Gansu must be treated and satisfy the national standards fordischarge before their release or use for irrigation. _

D. Environment Monitoring

1. Monitoring the ecological environment of grassland: status of grassland degradation,status and rate of desertification, ecological environment quality change and trend analysis. Gansu/XAR

1. Natural 2. Disaster monitoring and disaster relief forecast for grassland-based livestock industry. GMS, agricultural Gansu PPMO,grassland Monitoring trends in pest and diseases within natural and artificial grasslands. extension, and XAR PPMO

EMS.3. Monitoring annual fluctuation of grassland productivity.Pre-implementation phase (baseline data collection):a. Monitoring items: pH, total P, total N, N03-N, NH3-N, COD, BOD5, fecal and totalcoliforms, and suspended solids

b. Monitoring frequency: once Gansu PPMO,2. Surface Water Local EMS XAR PPMO

c. Monitoring periods: 1-2 days.

d. Location to be monitored: medium and large-scale dairy farms, large-scale feedlots andany other areas deemed necessary upstream and downstream of potential non-pointpollution sources by the environmental protection agencies.

17

Environmental Mitigation Policies and Control Measures Implementer ResponsibleIssues Agency

Implementation/operation phase:a. Monitoring items: pH, total P, total N, N03-N, NH3-N, COD, BOD5, fecal and totalcoliforms, and suspended solids.

b. Monitoring frequency: Once every year during the implementation period of each sub-project, followed by once every year for 5 years during operation).

c. Monitoring periods: 1-2 days.

d. Location to be monitored: medium and large-scale dairy farms, large-scale feedlots andany other areas deemed necessary by the environmental protection agencies upstream anddownstream of potential non-point pollution sources, and based on observable pollutionindicators (eutrophication, foul smell, etc.).

18

Environmental Mitigation Policies and Control Measures Implementer ResponsibleIssues ______ ___ Agency

Pre-implementation phase (baseline data collection):a. Monitoring items: pH, total P, total N, N03-N, NH4-N, COD, BOD5, fecal and totalcoliforms.

b. Monitoring frequency: once

c. Monitoring periods: I day

d. Location to be monitored: Wells with 100 m diameter of medium and large-scale dairyfarms, large-scale feedlots and areas deemed necessary by the environmental protectionagencies. Implementation/operation phase:

3. Groundwater Implementation/operation phase: Local EMS Gansu PPMO,a. Monitoring items: pH, total P, total N, N03-N, NH4-N, COD, BOD5, fecal and totalcoliforms.

b. Monitoring frequency: Once every year during the implementation period of each sub-project, followed by once every year for 5 years during operation.

c. Monitoring periods: I day

d. Location to be monitored: Wells with 100 m diameter of medium and large-scale dairyfarms, large-scale feedlots and areas deemed necessary by the environmental protectionagencies.

19

2. Gansu Environmental Monitoring Plan

16. The main purpose of this section is to summarize the needs of monitoring and toprepare a sound environmental monitoring program. The main objectives of the plan are:

* To ensure that all the mitigation measures specified in the ETA will actually becarried out;

* To evaluate the monitoring data to determine whether the environmentalprotection measures as proposed (including design, implementation, andoperational procedures) are actually furnishing adequate environmentalprotections and if not, to indicate the correction measures that is needed, and

* To ensure sustainable use of natural resources (such as water, grassland and soil)by the project.

17. The proposed monitoring plan follows not only follows the Bank requirement, but isalso responsive to SEPA's monitoring requirements as are outlined in TechnicalGuidelines for Environmental Impact Assessment, General Principles, HJ/T 2.1-93, andTechnical Guidelines for Environmental Impact Assessment, Surface Water Environment,HJ/T 2.3-93.

2.1 Monitoring Items

18. The monitoring program includes monitoring for each of the individual environmentalissues as identified in Chapter 7 of the EIA.

2.2 Monitoring Implementer

19. The implementers of the monitoring plan are Gansu PPMO and respective countyPMOs. According to the jurisdictional zoning, respective PMOs at various levels willundertake their monitoring responsibilities. The Prefecture, City or county EMS willcarry out monitoring the quality of surface and groundwater, while Gansu ProvincialGMS will undertake monitoring overall grassland ecology conditions and related issues.Gansu PPMO should reach a contractual agreement with respective monitoring stationsbefore project implementation. The county PMO environmental officers are responsiblefor requesting for monitoring activities by the respective monitoring stations, according tothe requirement of EMMP and whenever emergency situation arises.

2.3 Monitoring Report System

20. The reporting system for environment monitoring is shown in Figure 1. Aftercompletion of each environmental monitoring task, the prefecture or county EMS shouldsubmit the monitoring report to the PPMO and to the higher administrative department ofenvironmental protection. During implementation/construction, and the first five years ofoperation phases, Gansu provincial PMO should prepare environmental quality report forthe first year every six months, and annually from Year 2 and submitted for review by theBank supervision mission staffs. All submitted reports should also be available to GansuEPB and to SEPA, upon their request.

2.4 Pre-implementation Monitoring (Baseline data)

21. The pre-implementation/construction monitoring program is designed to achieve twomain objectives. The first one is to check whether the mitigation measures contained in

the environment assessment report have been incorporated in the final design documentand in the construction contracts. The second is to assess the existing conditions,including seasonal variability of the various parameters. The proposed monitoring planfor each component is as outlined in Figure 3. The monitoring items and related issuescan be found in table 2.

SEA MOA ||World Bank|

E Prefecture/County EMS

Fig. 3 Monitoring Report Chart, Gansu

2.5 Monitoring during implementation/construction

22. The monitoring of implementation programs is designed to evaluate the constructionactivities and to ensure that they meet the established criteria. The construction of projectshould be monitored by the EMS, especially activities related to the construction and/orrehabilitation of irrigation infrastructure to develop the artificial pastures, construction ofmedium and large-scale dairy and beef fattening farms, milking stations, milk collectionfacilities, markets, and presently proposed and future enterprises such as slaughterhouses,wool processing, skin tannery, and to a lesser extent development of large feedlots orbreeding farm facilities and warm sheds. The cost of environmental monitoring willincrease if new enterprises or other market related sub-component with potentialenvironmental impact that are not yet proposed are included in the future as sub-component of the marketing component. Such potential livestock related enterprisesinclude, but are not limited to slaughterhouses, wool processing plants, and skin tanneryplants.

23. The construction of the project could bring about some potentially adverse impacts onenvironmental parameters including air quality, vegetation, soil erosion, acousticenvironment, public health, biological resources, etc.

Air Quality: Dust control methods implemented to reduce construction generated dustlevels will be spot checked throughout the construction period to evaluate theireffectiveness and provide the basis for additional measures (as required). Table 8-3presents air quality monitoring program for the project areas, if found necessary.

Table 3 Construction Air Quality MonitoringProgram

21

Monitoring Site Item Frequency Sampling Timing ImplementerConstruction sites TSP Twice a Once in the Ihe PPMO is responsible for thewhere large year, I to 2 morning and once implementation of this program,residential area days in the afternoon. and will entrust the correspondingwithin 100m. municipal EMS to undertake the

monitoring tasks, as needed.

Noise: The construction noise-monitoring program is designed (see Table 8-4) to monitorthe impact of construction noise on the near residents. For noise-producing constructionactivities far away (more than 200 m) from residential areas, this monitoring isunnecessary.

Table 4 Noise Monitoring Program DuringConstruction

Site Monitored Frequency Monitoring Monitoring Implementerperiod timing

Environmentally-sensitive sites At random, 1d Once/day, CPMO/ EMSwithin 200 m of construction site if required ay Once/ night

Soil Erosion and Surface Water Sediment Loading: Soil erosion could occur atconstruction sites, along areas of cut and fill such as irrigation canals and duringconstruction of medium and large-scale dairy farm activities around water conveyancemeans (weirs, rivers, waterways, etc.). Such erosion could cause increase in riversediment load that could negatively impact aquatic flora and fauna. Respective CPMOswill be responsible to identify areas that could cause such impacts and should direct thecontractor to provide adequate soil conservation measures along the slope such as hay-bale, silt fence and/or fiber mats to prevent increase in the sediment load of rivers andlakes within the project area.

2.6 Monitoring during Operation

24. The environmental impacts during project operation phase will be mainly the potentialpollution to surface and groundwater by sewage discharge from medium-scale dairyfarms and related facilities (milking centers, DHI, milking collection station, etc), large-scale feedlots (beef and sheep), and the impacts to natural grassland as a result ofimproper use of resources such as overgrazing. The main parameters that should bemonitored include:

* Surface and groundwater quality especially where dairy farms, large orconcentrated beef fattening farm operations, and/or large-scale feedlots areestablished;

* Groundwater draw down where groundwater or consumptive use of surface andgroundwater is used for irrigation of artificial pastures; and

* Number of grazing animals, and grassland degradation status.

25. More detailed and relevant information on environment monitoring parameters,implementing agencies and responsible institutions are presented in Table 2.

2.7 Monitoring Budget

22

26. An estimated budget for the implementation of the monitoring programs for Gansu islisted in Table 5. The cost of baseline surveys during pre-implementation monitoring isestimated at 60,00OYuans (RMB), 90,000 RMB during implementation phase and240,000Y during operation phase. The total cost of environmental monitoring isestimated as 390,000 RMB. This budget does not include the cost of reviewing theproject implementation plan document during pre-implementation phase or any additionalmonitoring requirement that might be needed if new enterprises are included in theproject. The additional cost of EMMP for such projects should be estimated and uponapproval of such projects, should be included as a part of the project implementation cost.

Table 5 Cost Estimation of EnvironmentalMonitoring of Gansu

Monitoring Phase Monitoring Contents Cost, Yuan

Pre- Surface Water quality (only on major rivers within project 40,000implementation influence)(once) Groundwater Quality within areas with signs of groundwater 18,000

shortageQuality of natural grassland and variation of grazing capacity 20,000'Sub-total 78,000

Implementation Surface Water quality (only on major rivers within project 80,000period (once every influence)year for 2 years) Groundwater quality (only within project areas with signs of 28,000

water deficiency)Air and Acoustic Environment (if needed) 10,000Sub-total 118,000

Operation (once Quality of surface water 200,000every year for 5 Quality of groundwater 70,000years after Quality of natural grassland and variation of grazing capacity 40,000completion of Sub-total 310,000implementationphase of each sub-project)Total 506,000

The cost of each activity during implementation and/or operation might change, depending onwhether new enterprises are included in the future phases of the project that might requireadditional air and water resources monitoring.Should be collected from GMS.

3. Environmental Training/Institutional Strengthening Plan

3.1 Training Objectives

27. The objectives of the environmental training program is to enable provincial andcounty PMO officials responsible for implementation of EMMP to further strengthentheir capabilities and to enable them to ensure successful implementation of themitigation and monitoring plans specified in the EIA report during final project design,implementation and operation of the project. The trainees could also includeenvironmental officers from Hovill Dairy Company in Gansu and breeding farms in bothGansu and XAR, but the respective groups should adsorb the transportation, food andlodging costs.

28. In order to ensure the success of the intensive training courses and the implementationof EMMP, it is required that the employees who will be assigned as the environmentalofficers to have university degrees from accredited universities in one of the relevant

23

natural resource areas (grassland management, water resources, agronomy, etc.) andshould have a minimum of four and two years of experience to be assigned asenvironmental officers for the PPMO and county PMO, respectively.

3.2 Combined Training Courses, Gansu and XAR

29. The following courses will be included in the environmental training pogrom in bothGansu and XAR:

* Understanding and applying of laws, regulations, standards and norms of theChinese government concerning environmental protection; and

* Environmental management criteria utilized by the World Bank;

30. Environmental technology and environmental monitoring techniques including:

* Status of surface waters, principles of hydrogeology, and groundwaterdistribution;

* Basic knowledge of environmental monitoring;

* Basic understanding of identifying degree of grassland degradation and differenttypes of grasslands;

* Pollution control technologies;

* Basics of water sampling and sample treatment for analysis of different elementsidentified in EMMP; and

* Preparation of reports on environmental monitoring.

31. The officers of provincial EPBs will provide training on these subjects in Lanzhouand/or Urumqi, being assisted by the scientist of the respective Grassland ManagementInstitutes, Animal Husbandry Bureaus and the Lanzhou and Xinjiang AgriculturalUniversities. In order to reduce the training cost, XAR and Gansu PMOs have the optionand could decide to arrange for combined training courses for the senior environmentalstaffs of respective PMOs, State and breeding farms and Hovill Dairy Company, using thecapabilities of both XAR and Gansu universities and scientific institutions. If the secondoption (combined option) is selected, the training program will be somewhat modifiedand will take the "training of the trainers" format.

32. In addition, it is proposed to include a training course for extension and GMS officerswho will be involved in dissemination of information to the local farmers and herders onprinciples of pest management and proper use of agrochemicals including information on:

* Best management practices in agrochemical use and application;

* Proper methods for use and application of agrochemicals, and use of protectivegears;

* Proper storage of agrochemicals and review of their toxicity levels;

24

* Use of alternative methods to highly toxic agrochemicals for pest, weed androdent control in artificial and improved pasture areas;

* Principles of integrated pest management and introduction to idea of appropriatepest management planning; and

* Health issues with respect to use and handling of agrochemicals.

33. This course should be provided by appropriate university (Gansu AgriculturalUniversity and Xinjiang Agricultural University), and should have a mixture of classroomand in the field format.

3.3 Specific Training Courses for XAR and Gansu

34. The main training requirements of XAR are almost the same as Gansu. The majordifferences in training activities include additional training requirement for XAR due topresence of more diverse ecoregions in XAR and more emphasis on semi-pastorallivestock development model. Gansu would require specific training on environmentalissues related to dairy and beef cattle operations, and proposed enterprises.

35. In all the proposed training courses, trainers should prepare a comprehensive trainingmaterial as a part of their responsibilities and the material should be distributed betweenthe training participants so that they could use the information in their future presentationto the project beneficiaries and other officers within their respective institutions (trainingof the trainer alternative).

4. Gansu EMMP Budgets

36. Table 5 presents cost estimates for implementation of EMMP in Gansu at Y 506,000.Table 6 presents estimated budget for salaries of part time environmental protection staffof PMOs at various levels in Gansu, which is 931,500 RMB (Y). Tables 7 and 8 presentprovide the estimated budgets of Y 95,300 and Y 69,800 for training programs inenvironmental management and agrochemical management plan training in Gansu,respectively. Table 9 presents the overall environmental management cost estimate forGansu amounting to Y 1, 680,030. If the incremental salary costs of the PMO employeesare not included in the total cost, the actual additional EMMP cost is Y 655,380.

Table 6 Salary Cost of Environment Protection Staffof PMOs, Gansu

Preparation Implementation Operation

Personnel (6 years) (5 years)Total Total Cost Total Total Cost Total Total Costm/m Yuan m/m Yuan m/m Yuan

PPMO 3 7,500 24 60,000 15 37,500County PMOs 396* 594,000 220* 330,000Sub total 7,500 594,000 330,000Grand total 931,500

Notes:1. This an opportunity cost. The employee is fully employed by the respective PMOs for othertechnical activities and will be assigned to EMMP for 25% of his/her time per year duringimplementation and 17% (2 months per year) for monitoring periods.2. Estimated cost of PPMO officer is 2,500 Rmb per month and county PMO officer is 1,500 Rmb permonth.

25

Table 7. Cost for Environment Training in GansuTraining Plan No. of Training Contents Time Daily Total

Personnel cost cost

1. Classroom training Days Yuan Yuan

1.1 Trainers 4 As per Environmental 6 600 14,400

1.2 PMO Personnel 1 9 Training Program 6 300 34,200

1.3 Facilities & management 10,000

Subtotal 56,8002. Field/practical training2.1 Trainer 2 5 600 6,000

2.2 PMO Personnel 19 Field Trips 5 300 28,500

2.3 Transportation 5 800 4,000

Subtotal 38,500

Total . 95,300

Table 8 Cost Estimate for Agrochemical ManagementPlan for Gansu

Training Plan No. of Training Contents Time Daily TotalIPersonnel cost cost

1. Classroom training Days Yuan Yuan1.1 Trainer (University Professor) 1 As per Environmental 4 1,000 3,000

1.2 Extension and GMS Personnel 38 Training Program 4 300 45,600

1.3 Facilities & management . 8,000

Subtotal _ 56,6002. Field/practical training .2.1 Trainer (University Professor) I 1 . 1,000 1,0002.2 Extension and GMS Personnel 38 Field Trps 1 300 11,400

2.3 Transportation . 1 800 800

Subtotal 13,200

Total 69,800

Table 9 Total Cost Estimate for EMMP, andEnvironmental and Agrochemical Management

Plannin Training in GansuItem Reference Preparation Implementation Operation Subtotal*

Yuan

Incremental staff cost Table 8-9 7,500* 594,000* 330,000* 931,500*Training Table 8-10 89,800 165,100

.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ and 8-11 .EMMP Table 8-5 78,000 118,000 310;000 506,000Sub-Total 175,300 712,000 640,000 1,527,300Contingency, 10% 17,530 71,200 64,000 152,730Total 192,830 783,200 704,000 1,680,030* The figures presented-are the assumed salaries of full-time employees (opportunity cost) of respcctivePMOs for the period that they should work on environmental issues, and not an additional cost to therespective PMO. The actual cost of EMMP, with 10% contingency is Y655,380.

26

5 Conclusions and Recommendations

5.1 Major Conclusions

37. The environmental and social analysis of the GXPDP indicated that while the projectwould have no major direct negative impact on the natural environment, its overall socialand environmental impact would be positive. The project, if successfully implemented,should improve natural grassland conditions within the project counties, should increasefood supply for livestock, and should increase farmers income and livestock production,not by increasing the number of animals, but through breed improvement and improvedmarketing systems. Hence, the economic and social well being of the farmers of theproject areas should improve in the forms of available, reliable, and fair market systemfor sale of higher quality livestock produce such as mutton sheep and fine-wool. Theproposed project, in general, will have a positive impact on the socio-economicconditions of the farming communities by improving their livelihood through increasedpurchasing power.

5.1.1 Selection of Project Areas

38. Project areas in Gansu include 19 counties (cities) in ten prefectures, one corporationand two farms managed by Gansu Provincial Agriculture and Animal Husbandry Bureau.The development of fine wool sheep will dominate Sunan and Huangcheng.Development of mutton sheep will be the main project activity in other project counties.Dingxi, Jiuquan, and Lintao Counties and Hovill Dairy Company will also focus on dairycattle and milk production.

5.1.2 Environmental Impact Analysis and Mitigation Measures

39. The potential environmental impacts of the project duringimplementation/construction phase of the project in both Gansu and XAR are temporaland limited in magnitude. There are, however, a number of unavoidable aspects ofproject implementation, which, if not well handled, may have potential adverse impactson both natural environment and social environment in some localities. The magnitude ofsuch impacts will depend on the success of and the manner in which proposed projectspecific environmental mitigation plans and programs are implemented. The temporarynegative impacts of theses impacts are believed to be minor and include potentialvegetation damage during rehabilitation of irrigation infrastructure for the development ofartificial pastures and due to temporary land occupation at the construction sites, minorsoil erosion and corresponding increase in sediment load during construction, and minorpotential noise, air, and water pollution. However, if the mitigation measures proposed inthe Report are successfully implemented, the degree of environmental impacts during thisphase of the project will be insignificant.

40. During operational phase, potential environmental issues that are identified in thereport include: (l) potential impact on water resources (surface and groundwater), (2)potential soil pollution through application of agrochemicals for control of poisonousgrass, rodents, and grasshoppers, (3) potential cumulative impact of large dairy farms andlarge feedlots on both soil and water resources (eutrophication, increase in COD,coliforms, etc.), and (4) potential impact on plant biodiversity of natural grasslands inproject areas, if chemical fertilizer application to natural grasslands practice is adopted bythe project proponents.

41. Regarding each possible adverse impact, corresponding mitigation measure isproposed for the purpose of preventing or reducing it to insignificant levels. The use of

27

better watershed management and best management practices based on the latest findingsof research and extension component of the project should guide herders, livestockfarmers, and large dairy farms and feedlot managers in use of rational andenvironmentally balanced methods to reduce point and non-point source pollution withinthe project areas. Since the project schemes are scattered and involve a large area ofGansu and XAR, effective implementation of the proposed mitigation measures would bea challenge to the project proponent.

In order to cope with the complex environmental issues, an EMMP including institutionalstrengthening, environmental training and environmental monitoring plan is developed.The EMMP should be strictly implemented to ensure that the proposed project wouldhave neither significant nor irreversible adverse impact on the natural environment of theproject area.

5.2 Recommendations

42. In order to prevent potential. negative impacts of the proposed project and to improvethe likelihood of having a successful project, it is suggested to adopt a dynamic approachto the environmental monitoring and management by further incorporating measures toinclude additional measures to reassess the EMMP if unforeseen environmental impactsare identified during project development and operation phases.

5.2.1 Follow-up Program

43. A follow-up program is recommended to analyze the overall impacts of the projectimplementation and operation. Such program will be served to verify that predictions ofimpact put forward in the planning stages are as expected, and if not, adequate and timelycorrective measures would be developed and implemented. Hence, corrective measurescan be undertaken before irrevocable impacts have occurred. Information gathered fromthese programs is also used as input to refine future design.

44. The proposed program should incorporate the monitoring plan as presented in Chapter9 of the EIA.

45. A number of interim reports should be prepared by the PPMO environmental officersof both Gansu and XAR, as outlined below, to ensure that findings of the EMMP areincorporated in the project design of future sub-projects and a dynamic approach toEMMP is followed by the project; (1) An interim report at the end of the pre-constructionprogram, to provide input to the implementation phase; (2) Interims semi-annual reports(first two years) on the completion of implementation and construction activities; (3)Annual interim reports during the monitoring of project operation; and (4) A final report,summarizing impacts and successes of mitigation measures.

46. If significant unforeseen negative impact is discerned at any stage, the schedule willallow for a re-evaluation of the situation and provide sufficient time to implement furthermeasures. Reports should be submitted to senior PPMO management, the World Banksupervision mission staffs, and various regional lined agencies, if requested, for reviewand comments.

5.2.2 Public Participation

47. The community and public involvement process was initiated during theenvironmental and socio-economic surveys when herders, livestock farmers and villagecommunities were contacted to obtain baseline information. It is imperative that these

28

processes should continue so that the project participants feel that they are involved in theproject and that their views and concerns are being adequately considered in the projectplanning process. In order for the beneficiaries to participate in the project design moreactively, it was suggested to develop detailed BPP for the projects and have been preparedby the PPMOs in Gansu and XAR. These plans detail participating activities in eachstage of project implementation and participants including herders, livestock farmers,breeding stations, large county operated farms, government organizations, NGOs andparticularly the disadvantaged groups including women and minority nationalities in theproject area. Since no specific sites and dates of participating activities are specified inthese plans, it is suggested that the PPMOs develop a concrete schedule based on theprepared plan to guarantee a smooth implementation of the plan during projectimplementation.

48. In general, the majority of livestock farmers and herders support the implementationof the project. In addition, all the cadres at grassroots units, staff of the provincial andcity project offices, staff of the livestock bureaus at provincial, city and county levels andofficers of the Ministry of Agriculture who were interviewed strongly support theimplementation of the project.

5.2.3 Further Suggestions and Environmental Requirements

49. Project beneficiaries should strictly follow the grassland management plans andcounty grassland management stations should effectively supervise the implementation ofthe grassland management plans to control/prevent overgrazing. Grazing of naturalgrasslands should follow grassland laws and animal numbers should be controlled basedon nutritional carrying capacity of available grasslands to protect the condition of naturalgrasslands and promote sustainable development of livestock industry.

50. Prior to selection of project location, detailed water balance studies must be carriedout, to ensure that the incremental water use will not damage water balance of the projectareas, and project development and consumptive water use will not cause any significantnegative impact to downstream water users and minimum flow requirements is observed.

51. Prior to finalization of the dairy sub-component in Gansu, individual environmentalassessment of medium size 100-cattle dairy farms should be completed to determinewhether the location of the dairy farms are environmentally acceptable, and whetherproposed corresponding pollution control measures are adequate for the size of theproposed operations. In the individual feasibility and design reports of these projects, thesizing and type of sewerage (mainly milk residues and washing water) treatment facilitiesand details and sizing of manure management facilities (settling ponds, manure storageareas, etc.) must be presented before final environmental approval of such plans could begranted. The same process should be followed for any newly added enterprises in bothCThnmii n,nd XAR

29