Initial Environmental Examination

Project Number: 45125 September 2011 Draft

KGZ: University of Central Asia

Prepared by: SENES Consultants Limited and University of Central Asia for the Asian Development Bank.

This report is made publicly available in accordance with ADB’s Public Communications Policy (2011). It does not necessarily reflect the views of ADB.

Initial Environmental Examination Report

Submitted to Asian Development Bank

University of Central Asia , Kyrgyz Republic Campus

Prepared by:

SENES Consultants Limited 121 Granton Drive, Suite 12 Richmond Hill, Ontario, Canada, L4B 3N4

On behalf of: University of Central Asia 138 Toktogula Street Bishkek, 720001, Kyrgyz Republic

September, 2011 University of Central Asia Initial Environmental Examination Naryn Campus

ABBREVIATIONS

ADB Asian Development Bank AKDN Aga Khan Development Network BOD Biochemical Oxygen Demand COD Chemical Oxygen Demand EEC European Economic Community EHS Environment, Health and Safety EHSO Environment, Health and Safety Office EIA Environmental Impact Assessment EMEF Environmental Monitoring and Evaluation Framework EMO Environmental Management Office EMP Environmental Management Plan EU European Union GOST State Standard (GOsudarstvennyy STandart) GRM Grievance Redress Mechanism IEE Initial Environmental Examination ISWMP Integrated Solid Waste Management Plan MAC Maximum Allowable Concentration MPC Maximum Permissible Concentration MSDS Material Safety Data Sheets OHS Occupational Health and Safety SOP Standard Operating Procedure SPCE School of Professional and Continuing Education TSS Total Suspended Solids UCA University of Central Asia US United States USEPA United States Environmental Protection Agency WHO World Health Organization WB World Bank WWTP Wastewater Treatment Plant

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Executive Summary

Introduction

1. The University of Central Asia (UCA) was established by an International Treaty and Charter signed by His Highness the Aga Khan and the Presidents of Kazakhstan, the Kyrgyz Republic and Tajikistan. UCA’s mission is to promote the socio-economic development of Central Asia’s mountain societies, while also helping the diverse peoples of the region to draw upon their rich cultural traditions and heritages as assets. UCA consists of three campuses to be located in Naryn (Kyrgyz Republic), Khorog (Tajikistan), and Tekeli (Kazakhstan). The University will offer a range of internationally recognized programmes including undergraduate and graduate programs. UCA’s School of Professional and Continuing Education (SPCE) has been operational since 2006 and provides formal, university-based, non-degree educational programmes in a number of disciplines.

2. From an environmental developmental perspective, all three UCA campuses, including the Naryn campus in the Kyrgyz Republic, have been rated as Category B projects. Consequently, in accordance with the 2009 Safeguard Policy Statement of the Asian Development Bank (ADB), an Initial Environmental Examination (IEE) is required and provided by means of this document.

3. This IEE builds upon the UCA Naryn Campus Detailed Design: Environmental Protection (Zlatograd, 2009) report completed in 2009 as well as the 2010 study by TATA Consulting Engineers on energy options (TATA Consulting Engineers, 2010) and the UCA Infrastructure Systems Concept Design Report (UCA, 2006), with particular attention to the elements required under ADB’s Safeguard Policy Statement.

4. The report consists of the following sections:

A. Introduction and Overview B. Description of the Project C. Description of the Existing Environment D. Anticipated Environmental Impacts and Mitigation Measures E. Public Consultations and Disclosure and Grievance Redress Mechanism F. Environmental Management and Evaluation Framework G. Conclusion and Recommendations

Project Need, Project Approvals and Environmental Standards

5. Efforts to promote and improve higher education in the Kyrgyz Republic have been based on the vision of maintaining past successes as well as facilitating reforms that allow higher education institutions to integrate into the global educational environment. Although a long-term educational strategy to 2025 was laid out by the Educational Doctrine, the economic crisis following independence in 1991 has adversely affected higher education programs. Existing standards have not enabled students to respond quickly to changes in the labour market. There has also been a need for greater research at universities, as advocated by the Education Development Strategy 2009-2011. Priority sectors that have been identified include sciences, technology and environmental sciences related to the natural resource sector, such as

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forestry, mining and hydroelectric power. UCA aims to fill this gap in tertiary education by offering academic programming designed to create competent and competitive graduates that can become productive members of society.

6. UCA’s emissions levels and environmental management practices are based on requirements of domestic legislation as well as best practices and international standards such as the World Bank’s Environment, Health and Safety (EHS) standards and regulations and policies in place in the European Union (EU) and in the United States (US). World Health Organization (WHO) ambient air quality guidelines, World Bank EHS guidelines, and the EU Directive for urban wastewater treatment (91/271/EEC) have also been consulted for setting acceptable standards for air emissions and liquid effluents. Noise limits are also established in accordance with Kyrgyz requirements and World Bank Occupational Health and Safety (OHS) standards. In developing policies for the university laboratory practices, international standards such as the US 40 CFR 262 standards relevant to academic laboratories were consulted.

Description of Project

7. Each UCA campus includes the following infrastructure:

• Infrastructure facilities and buildings • Electrical systems • Roads • Power supply and distribution • Potable water supply • Street lighting • Water supply for firefighting/irrigation • Telecommunications • Wastewater treatment plant • Heating systems • Solid waste management

8. In the process of conceptual design, a number of alternatives were investigated with respect to water supply, wastewater management options, the heating system, solid waste management and snow removal for the Naryn campus. Based on a review of the alternatives, recommendations have been made to source supply water from beach wells instead of groundwater wells. With regard to wastewater management, the preferred alternative is to construct a new treatment plant. Coal-fired boilers were eliminated as a design alternative due to their adverse air quality impacts. Similarly, combustion emissions from boilers fired by fuel oil are a disadvantage of this alternative. Distributed electric boilers are currently considered to be the preferred alternative to meet the heating requirements of the Project.

9. The establishment of the University is expected to occur in three phases. In the first phase, capacity will be built for a total of 1305 students, i.e. 435 students per campus comprised of 375 undergraduate students and 60 graduate students. In the second phase, the capacity will be increased to a total of 2340 students, i.e. 780 students per campus comprised of 600 undergraduate students, 120 graduate students, and 60 Executive Development students. After expansion in the third phase, the total university capacity will be 3600 students, i.e. 1200 per campus, comprised of 960 undergraduate students, 180 graduate students, and 60 Executive Development students.

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Description of the Site

10. The site of UCA’s Naryn campus is on the outskirts of Naryn town. Located approximately 350 km southwest of Bishkek at an elevation of 2,200 metres above sea level, the site is characterized by cold winters and cool summers. The total area of the campus is approximately 335 hectares with current land use being dominated by agriculture.

Assessment of Potential Environmental Impacts

11. Impacts on the physical and biological environment are expected to be localized in nature and for the most part transient and reversible. Potential impacts include noise, erosion and dust generation during excavation and earthworks as well as combustion emissions from mobile and stationary sources. Several measures will be taken to reduce these potential impacts including dust suppression techniques, use of appropriate emissions controls and regular maintenance of equipment. Potential impacts to surface waters will be mitigated by a new wastewater treatment plant and solid wastes will be managed under an integrated strategy that minimizes disposal requirements. Environmental performance will be a key factor in the selection of building designs and energy systems. Trees will be planted throughout the campus and measures will be put in place to protect wildlife.

Impacts on the Socioeconomic Environment

12. Economic impacts during construction and operation of the campus will be positive and significant. UCA’s mission, according to its Charter, is to promote the socio-economic development of the Central Asian region. During the construction phase, there will be significant opportunities for local construction organizations. Positive economic impacts on the region as a result of the university’s operations include employment and contracting opportunities for the local population, as well as positive induced impacts. Across all three campuses, UCA is expected to employ almost 1,200 individuals by the first year of operations, including faculty, academic staff, senior management and ancillary staff for housing, food services, housekeeping, travel and transportation, laundry services, shops, security, and general facility maintenance. More than 90% of UCA’s staff will be from the Central Asian region.

Public Consultations & Disclosure and Grievance Redress Mechanism

13. Proactive consultation with local communities has been a key principle in all of UCA’s planning. Commencing in 2002, consultations with members of the public were held for all three UCA locations and feedback on the proposed concept was incorporated into the campus plans. Feedback was received on a number of issues including gender-specific needs, public transportation, and the management of meandering flocks in areas surrounding the campuses. A Grievance Redress Mechanism (GRM) will be established through which affected stakeholders can communicate their concerns and receive a response in a timely fashion. Monthly reports on grievances received and their resolution will be provided to UCA’s Executive Committee.

Environmental Management and Evaluation Framework

14. The Environmental Management Plan and the Environmental Monitoring Plan summarize potential environmental impacts as well as the mitigation and monitoring techniques that will be implemented during the construction and operational phases of the University.

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15. During the construction phase, impacts will be mitigated through management of construction practices. An environmental inspector will be present to ensure that mitigative measures are in place to minimize noise, dust and erosion. During normal operations, monitoring will be done for stationary combustion sources if appropriate; detailed design and modeling of potential sources will be used in this regard. Treated liquid effluent will be monitored prior to discharge to receiving waters. The frequency of monitoring will be weekly during commissioning and monthly thereafter for the first three year period. Subject to performance, the monitoring period may become quarterly, unless otherwise required by local regulations. Liquid effluent parameters to be monitored include biochemical oxygen demand, suspended solids, total nitrogen, total phosphorus and total coliform.

Conclusions and Recommendations

16. The development and operation of the University of Central Asia’s Naryn campus is not expected to have significant adverse environmental impacts on the physical or biological environments. On the contrary, this project is specifically designed to result in significant positive socioeconomic impacts. The results of the IEE support ADB’s Category B classification of the Project.

17. A number of detailed environmental studies will be undertaken during the detailed design phase of the project including a waste management study for the campus, detailed analysis for the selection of the final design of the wastewater treatment system, and detailed design of the solid waste management strategy. As part of UCA’s Environmental Management Plan, preventative measures will be implemented to mitigate the risk of adverse environmental impacts. The University’s Executive Committee will receive environmental and sustainability reports indicating progress being made, issues that may arise, as well as any grievances received.

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Table of Contents

Executive Summary ...... ES-1 A. Introduction and Overview ...... A-1 A.1 Project Overview ...... A-1 A.2 Initial Environmental Examination – Purpose and Scope ...... A-2 A.3 Policy, Legal and Administrative Framework ...... A-3 A.3.1 Kyrgyz Republic Environmental Policies and Approvals ...... A-3 A.3.2 Environmental Standards ...... A-3 A.3.3 ADB Safeguards Policy Statement ...... A-3 A.4 Organization of Report ...... A-4 B. Description of the Project ...... B-1 B.1 Need for the Project ...... B-1 B.1.1 Higher Education Needs in the Kyrgyz Republic ...... B-1 B.1.2 UCA’s Value Proposition ...... B-1 B.2 Project Site ...... B-2 B.3 Project Environmental Design Principles ...... B-4 B.4 Project Infrastructure ...... B-4 B.5 Project Services: Needs ...... B-6 B.5.1 Water Supply: Needs ...... B-6 B.5.2 Wastewater Management: Needs ...... B-7 B.5.3 Electricity: Needs ...... B-8 B.5.4 Heating: Needs ...... B-8 B.5.5 Solid Waste Management: Needs ...... B-8 B.6 Project Services: Evaluation and Selection of Preferred Alternatives ...... B-9 B.6.1 Water Supply: Alternatives ...... B-9 B.6.1.1 Surface water from fresh water springs discharging into the Naryn River ..... B-9 B.6.1.2 Groundwater from the Naryn River ...... B-10 B.6.2 Wastewater Management: Alternatives ...... B-10 B.6.3 Electricity: Alternatives ...... B-11 B.6.4 Heating Plant: Alternatives ...... B-11 B.6.4.1 Coal-Fired Boilers ...... B-11 B.6.4.2 Electric Boilers ...... B-11 B.6.4.3 Fuel Oil Boilers ...... B-11 B.6.5 Solid Waste Management: Alternatives ...... B-12 B.6.5.1 Source Separation ...... B-12 B.6.5.2 Opportunities to Reduce, Reuse and Recycle ...... B-12 B.6.5.3 Recovery, Treatment and Disposal ...... B-12 B.6.6 Snow Removal Alternatives ...... B-13 B.7 Project Phasing ...... B-13 C. Description of the Existing Environment ...... C-1 C.1 Local Climate ...... C-1 C.2 Air Quality ...... C-2

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C.3 Water Resources ...... C-2 C.4 Biological Environment ...... C-4 C.4.1 Terrestrial Vegetation ...... C-4 C.4.2 Terrestrial Wildlife ...... C-5 C.4.3 Protected Areas and Red Book Species ...... C-6 C.5 Geology and Soils ...... C-7 C.5.1 Geology [15]...... C-7 C.5.2 Soils [15] ...... C-9 C.6 Physical and Cultural Resources ...... C-9 C.7 Socio-Economics ...... C-9 C.7.1 Employment and Income ...... C-9 C.7.2 Industry ...... C-10 C.7.3 Agriculture ...... C-10 C.7.4 Health ...... C-10 C.7.5 Education ...... C-11 C.7.6 Infrastructure ...... C-11 D. Anticipated Environmental Impacts and Mitigation Measures ...... D-1 D.1 Introduction ...... D-1 D.2 Assessment Methodology ...... D-1 D.3 Identification of Project-Environment Interactions and Likely Environmental Impacts ...... D-1 D.3.1 Project Phases and Activities ...... D-2 D.3.1.1 Construction Phase ...... D-2 D.3.1.2 Operational Phase ...... D-3 D.3.2 Project-Environment Interactions ...... D-3 D.4 Atmospheric Environment ...... D-7 D.4.1 Air Quality ...... D-7 D.4.1.1 Environmental Standards ...... D-7 D.4.1.2 Summary of Interactions ...... D-9 D.4.1.3 Assessment of Potential Impacts and Mitigation ...... D-10 D.4.2 Noise and Vibration ...... D-12 D.4.2.1 Environmental Standards ...... D-12 D.4.2.2 Summary of Interactions ...... D-12 D.4.2.3 Assessment of Potential Impacts and Mitigation ...... D-13 D.5 Water Resources ...... D-14 D.5.1 Hydrology ...... D-14 D.5.1.1 Summary of Interactions ...... D-14 D.5.1.2 Assessment of Potential Impacts and Mitigation ...... D-14 D.5.2 Water Quality ...... D-14 D.5.2.1 Environmental Standards ...... D-14 D.5.2.2 Summary of Interactions ...... D-16 D.5.2.3 Assessment of Potential Impacts and Mitigation ...... D-16 D.6 Biology ...... D-18 D.6.1 Aquatic Biology ...... D-18 D.6.1.1 Summary of Interactions ...... D-18 D.6.1.2 Assessment of Potential Impacts and Mitigation ...... D-19

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D.6.2 Terrestrial Biology ...... D-19 D.6.2.1 Summary of Interactions ...... D-19 D.6.2.2 Assessment of Potential Impacts and Mitigation ...... D-20 D.7 Geology and Hydrogeology...... D-21 D.7.1 Geology and Seismicity ...... D-21 D.7.1.1 Summary of Interactions ...... D-21 D.7.1.2 Assessment of Potential Impacts and Mitigation ...... D-21 D.7.2 Hydrogeology ...... D-21 D.7.2.1 Summary of Interactions ...... D-21 D.7.2.2 Assessment of Potential Impacts and Mitigation ...... D-21 D.8 Physical and Cultural Resources ...... D-22 D.8.1 Physical and Cultural Resources ...... D-22 D.8.1.1 Summary of Interactions ...... D-22 D.8.1.2 Assessment of Potential Impacts and Mitigation ...... D-22 D.9 Socio-Economics ...... D-22 D.9.1 Population and Economic Base ...... D-22 D.9.1.1 Summary of Interactions ...... D-23 D.9.1.2 Assessment of Potential Impacts and Mitigation ...... D-23 D.9.2 Community Infrastructure and Resources ...... D-23 D.9.2.1 Summary of Interactions ...... D-24 D.9.2.2 Assessment of Potential Impacts and Mitigation ...... D-24 D.9.3 Current Land Use ...... D-25 D.9.3.1 Summary of Interactions ...... D-26 D.9.3.2 Assessment of Potential Impacts and Mitigation ...... D-26 D.10 Cumulative Effects ...... D-27 D.10.1 Methodology ...... D-27 D.10.2 Evaluation of Potential Cumulative Effects ...... D-29 D.11 Effects Assessment Summary ...... D-30 E. Public Consultations & Disclosure and Grievance Redress Mechanism ...... E-1 E.1 Consultations ...... E-1 E.2 Comments and Concerns ...... E-1 E.2.1 Gender Consideration ...... E-2 E.2.2 Public Transportation Facilities ...... E-2 E.2.3 Meandering Flocks ...... E-2 E.3 Planned Disclosure and Consultation during Implementation ...... E-2 E.4 Grievance Redress Mechanism ...... E-2 E.4.1 Communication Channels ...... E-2 E.4.2 Preventing Grievances ...... E-3 E.4.3 Grievance Documentation and Reporting Procedures ...... E-3 E.4.4 Grievance Redress Management ...... E-3 F. Environmental Management and Evaluation Framework ...... F-1 F.1 Environmental Management ...... F-2 F.1.1 Mitigation Measures ...... F-2 F.2 Monitoring ...... F-7

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F.2.1 Monitoring Measures ...... F-7 F.2.2 Monitoring and Reporting Procedures ...... F-8 F.2.3 Independent Review ...... F-8 F.3 Implementation Arrangements ...... F-8 F.3.1 Organizational Structure ...... F-8 F.3.2 Cost Assessment for Environmental Management Plan ...... F-9 G. Conclusions and Recommendations ...... G-1 H. References ...... H-1 I. Limitations ...... I-1

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List of Tables

Table B.5.1-1 Naryn Water Demand and Storage Capacity [13] ...... B-7 Table B.5.1-2 Naryn Water Demand and Storage Capacity [13] ...... B-7 Table B.5.5-1 Waste Composition [13] ...... B-8

Table C.1-1 Average Monthly Temperatures and Precipitation in Naryn ...... C-1 Table C.3-1 Outflow for Naryn River at Naryn town (m3/s) ...... C-3 Table C.3-2 Water Quality Data for Naryn River [8] ...... C-3 Table D.3-1 Project-Environment Interactions and Potential Adverse Impacts ...... C-5

Table D.4.1.1-1 WHO Ambient Air Quality Guidelines [7] ...... D-8 Table D.4.2.1-1 Noise Limits for Various Working Environments[7] ...... D-12 Table D.4.2.1-2 Noise Level Guidelines – One Hour LAeq (dBA) ...... D-12 Table D.5.2.1-1 Effluent Discharge Concentrations for Wastewater Treatment Plant ...... D-15 Table D.5.2.1-2 Required Water Quality for Irrigation Water [10] ...... D-15 Table D.10.1-1 Summary of Residual Project Impacts that Could Contribute to Cumulative Effects ...... D-29

Table F.1.1-1 Summary of Management Plan Mitigation ...... F-3 Table F.2.1-1 Monitoring Measures for UCA Naryn Campus – Operations Phase ...... F-7 Table F.3.2-1 Summary of Costs of Environmental Management Plan ...... F-10

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List of Figures

Figure A.1-1 Locations of UCA Campuses ...... A-1

Figure B.2-1 Campus Location Relative to Naryn Town ...... B-2 Figure B.2-2 Representative Current Site Conditions...... B-2 Figure B.2-3 Architectural Rendering of the Naryn Campus ...... B-3 Figure B.4-1 Infrastructure Layout for the Naryn Campus ...... B-5

Figure C.1-1 Average Monthly Wind Speeds in Naryn [13] ...... C-2 Figure C.7.5-1 Number of Students (thousands) [3] ...... C-11

Figure D.10.1-1 Scope of Potential Cumulative Effects ...... D-28

Figure E.4.4-1 Management Structure for Grievance Redress Process ...... E-4

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A. Introduction and Overview

A.1 Project Overview

18. The University of Central Asia (UCA) was established by an International Treaty and Charter signed by His Highness the Aga Khan and the Presidents of Kazakhstan, the Kyrgyz Republic and Tajikistan. UCA’s mission is to promote the socio-economic development of Central Asia’s mountain societies, while also helping the diverse peoples of the region to draw upon their rich cultural traditions and heritages as assets. UCA consists of three campuses located in Naryn (Kyrgyz Republic), Khorog (Tajikistan), and Tekeli (Kazakhstan), the locations of which are shown in Figure A.1-1.

Figure A.1-1 Locations of UCA Campuses

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19. The University will offer a range of internationally recognized undergraduate and graduate programmes including undergraduate and graduate programs in fields such as environmental science and natural resource management, natural sciences, and the arts. At full capacity, UCA will host 2880 undergraduate students and 540 graduate students, as currently envisioned, across its three campuses. Each of the university campuses will include undergraduate, graduate, and faculty housing; recreational facilities; and academic buildings.

20. The focus of the current report is UCA’s campus in Naryn, Kyrgyz Republic. Located approximately 350 km from Bishkek and 200 km from the Chinese border, the town of Naryn has an estimated population of 45,000. The site intended for construction of UCA’s Naryn campus is located along the northern and southern banks of the Naryn River, 12 km west of the town.

21. Conceptual designs for the Naryn campus have been completed and detailed design / engineering exercises are being initiated. The current Project schedule envisions that Phase 1 of the University will be operational by 2016, at which time the first cohort of students will be accepted into undergraduate and graduate programs. Substantial civil works are anticipated to occur in 2012.

22. A full description of the Project is presented in Section B.

A.2 Initial Environmental Examination – Purpose and Scope

23. This report comprises an Initial Environmental Examination (IEE) for the Naryn campus. The Asian Development Bank’s (ADB’s) 2009 Safeguard Policy Statement requires that an IEE be prepared for all projects designated as “Category B”, which is the classification assigned to each of the UCA campuses, including Naryn. The Category B designation is based on the expectation that any adverse impacts associated with the construction and operation of the campus would be site-specific, reversible and, in most cases, amenable to effective mitigation.

24. The Naryn IEE is a consolidation of the results of already completed design studies, environmental assessments and consultations. Specifically, it builds upon an initial Environmental Impact Assessment (EIA) completed in 2009 to meet national requirements (UCA Naryn Campus Detailed Design: Environmental Protection, Zlatograd, 2009), a study on energy options (Tata Consulting Engineers Limited, 2010), the Infrastructure Systems Concept Design Report for the campuses (UCA, 2006) and a geo-hazard assessment report (Arup, 2004). In addition to these source documents, the IEE also presents additional information to ensure compliance with ADB’s Safeguard Policy Statement.

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A.3 Policy, Legal and Administrative Framework

A.3.1 Kyrgyz Republic Environmental Policies and Approvals

25. The IEE, as well as the Project design, has considered all relevant Kyrgyz environmental management requirements. All construction and operational activities of UCA’s Naryn site will be in compliance with national requirements. Relevant national environmental legislation includes the Law on Environmental Protection (1999), the Law on Ecological Expertise (State Environmental Review, 1999), the Law on Air Protection (1999) and its associated Law on Amending Law on Air Protection (2005), and Instruction on Environmental Impact Assessment Performance Procedures in the Kyrgyz Republic (1997).

26. Specific standards of interest for the Project include:

• SNiP 2.04.03-85 Sewage – External Networks and Facilities • SanPiN 2.1.7.573-96 – Hygiene Requirements for the Use of Wastewater and their Residues for Irrigation and Fertilization Purposes • GOST 17.5.3.06-85 – Requirements for the Determination of Norms of Stripping of Topsoil in the Course of Performance of Earthworks • GOST 17.2.02-78 – Primary criteria for quality of ambient air in the course of establishing maximum permissible limits • GOST 17.2.3.02-78 – Environmental Protection. Atmosphere • GOST 17.5.1.02-78 – Classification of Dislocated Lands for Recultivation

A.3.2 Environmental Standards

27. The environmental management standards selected for the Project are based on the requirements of domestic legislation as well as best practices and international standards such as the World Bank’s Environment, Health and Safety (EHS) standards and regulations and policies in place in the European Union (EU) and in the United States (US). World Health Organization (WHO) ambient air quality guidelines, World Bank EHS guidelines, and the EU Directive for urban wastewater treatment (91/271/EEC) have also been consulted for setting acceptable standards for air emissions and liquid effluents. Noise limits are also established in accordance with GOST requirements and World Bank Occupational Health and Safety (OHS) standards. In developing policies for the university laboratory practices, international standards such as the US 40 CFR 262 standards relevant to academic laboratories were consulted.

28. Where international standards are more stringent than those of the country, the requirements of the international standards have been adopted by the Project. The specific standards adopted to prevent significant adverse impacts to the environment are presented in Section D.

A.3.3 ADB Safeguards Policy Statement

29. The Asian Development Bank’s Safeguards Policy Statement (2009) describes safeguard requirements that borrowers/clients are expected to meet when addressing social and environmental impacts and risks. The environmental safeguards requirements are designed to ensure the environmental

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soundness and sustainability of projects, and to ensure that environmental considerations are integrated into the project decision-making process. For Category B projects, an initial environmental examination is to be completed. Reports should include the policy, legal and administrative framework within which the environmental assessment is carried out; a description of the project; a description of environmental baseline data that considers physical, biological, and socioeconomic conditions in the project area; anticipated environmental impacts and mitigation measures; an analysis of project alternatives; a description of the process undertaken to engage stakeholders; the grievance redress framework for the project; and the environmental management plan.

A.4 Organization of Report

30. The report consists of the following sections:

31. A. Introduction and Overview – The present introductory section explaining the purpose of the Project, the stage to which the Project has progressed, the Project category, the scope of the IEE study and an overview of the applicable environmental management regime.

32. B. Description of the Project – This section describes the need for the Project and provides a detailed description of its various components, phases of implementation, and the linkages between on- site and off-site facilities. Due to their important role in determining potential environmental impacts, the section presents an overview of alternatives for several key components that were considered during the development of conceptual designs.

33. C. Description of the Existing Environment – This section describes the existing conditions of the site, with an emphasis on the various environmental components that have some potential of interacting with the Project.

34. D. Anticipated Environmental Impacts and Mitigation Measures - This section describes the impacts of the Project on the atmospheric environment, water resources, the biological environment, geology and hydrogeology, physical and cultural resources, and socio-economics. Consideration is also given to measures that will result in a reduction of potential environmental impacts.

35. E. Public Consultations and Disclosure and Grievance Redress Mechanism – This section describes the processes undertaken to engage stakeholders and summarizes comments and concerns received from stakeholders. The framework for receiving grievances and resolving complaints is explained.

36. F. Environmental Management and Evaluation Framework – This section summarizes the mitigation and management measures to be taken during the Project to mitigate adverse environmental impacts. Monitoring measures and implementation arrangements are elaborated.

37. G. Conclusion and Recommendations – This section provides conclusions and recommendations based on the outcomes of the IEE study.

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B. Description of the Project

B.1 Need for the Project

B.1.1 Higher Education Needs in the Kyrgyz Republic

38. In the Kyrgyz Republic, higher education has always been considered a priority for the government. Efforts to promote and improve higher education have been based on the vision of maintaining past successes as well as facilitating reforms that allow higher education institutions to integrate into the global educational environment. Although a long-term educational strategy to 2025 was laid out by the national Educational Doctrine, the economic crisis following independence has adversely affected higher education programs [2].

39. Naryn, the site of one of the UCA campuses, has one post-secondary institution, Naryn State University. However, existing standards at higher education institutions have not enabled students to respond quickly to changes in the labour market. There has also been a need for greater research at universities, as advocated by the national Education Development Strategy 2009-2011. Currently, only 12% of teaching staff at national universities are involved with research and development [6]. Priority sectors that have been identified include sciences and technology as well as industries related to the environmental sciences such as forestry science and hydroelectric power [6].

B.1.2 UCA’s Value Proposition

40. UCA aims to fill this gap as a high-quality, merit-driven university with academic programming designed to create competent and competitive graduates that can become productive members of their society. In particular, the University’s mission is to promote the socio-economic development of Central Asia’s mountain societies while helping the peoples of the region to preserve and draw upon their cultural traditions and heritages as assets for the future. UCA already has an active research program including the Mountain Societies Research Centre, an interdisciplinary research centre that aims to support and enhance the resilience and quality of life of mountain societies through research on sustainable development and management of their physical, social, economic and cultural assets. In terms of the undergraduate program, the three areas of focus will be Science and Technology (Biology, Chemistry, Physics, Engineering Sciences, and Mathematics and Computing), Humanities (History, Languages, Literature and Philosophy), and Social Sciences (Anthropology, Economics, Political Science, and Sociology).

41. Further, as UCA expands its existing series of agreements with leading educational institutions internationally, students and academics at UCA will benefit from the experience and knowledge of leading academics and researchers from around the world. A Graduate School of Development is also intended to address the unique resources and needs of the region by creating highly-skilled professionals and fostering research in the fields of Natural Resource Management and Environment; Business and Economic Development; Education Policy; Human Resource Development; Public Administration and Public Policy; Rural and Regional Development; and Tourism and Leisure Studies.

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B.2 Project Site

42. The campus in Naryn is located along the southern banks of the Naryn River, approximately 12 km west of the town of Naryn, as shown in Figure B.2-1. The elevation at the site varies from 1,990 m at the easternmost part adjacent to the Naryn River to 2,370 m in the south-westernmost part of the site. The total area of the campus is approximately 335 hectares with the land primarily used for agricultural purposes similar to the meadows depicted in Figure B.2-2.

43. The Naryn site is situated on the river terraces of the Eastern Plateau, which is at an elevation of about 15-20 meters above the river banks. The terrain of the campus site is relatively flat with a gentle slope of about 2-3%. There are steeper slopes and vertical faces along the northern boundary of the site. The southwestern boundary coincides with the state highway from Naryn to Dostuk. An architectural rendering of the Naryn campus is shown in Figure B.2-3.

Figure B.2-1 Campus Location Relative to Naryn Town

Figure B.2-2 Representative Current Site Conditions

.

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Figure B.2-3 Architectural Rendering of the Naryn Campus

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B.3 Project Environmental Design Principles

44. The following environmental design principles have been integrated throughout the conceptual design process for the University:

• Campus facilities should embrace and maintain a connection with nature; • Campus facilities should be designed as models of environmental sustainability; • Sustainable elements should serve as a teaching tool linked with the University’s core mission; and • Infrastructure elements should be planned and designed using rigorous sustainability standards.

B.4 Project Infrastructure

45. Once fully developed, infrastructure on the Naryn campus will include:

• Academic and administration facilities; • Cultural and recreational facilities; • On-site residences for students, faculty and staff; and • Physical plant for the provision of on-site services and utilities (see Section B.5).

The conceptual layout of site infrastructure is illustrated in Figure B.4-1.

46. Although final designs have yet to be prepared, it is currently anticipated that construction materials will be selected based on economical and durability considerations, function and shape. Reinforced concrete is chosen to be the main construction material for the structures due to the local availability of the corresponding components and workmanship, cost competitiveness, good durability and its ability to take various architectural forms. In some specific applications, structural steel and timbers may also be used.

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Figure B.4-1 Infrastructure Layout for the Naryn Campus

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B.5 Project Services: Needs

47. The effective operation of the Naryn campus will require a wide array of services including: water supply, wastewater management, electricity, heat and solid waste management. Due to their role in contributing to potential environmental impacts, the following sections provide a summary of the anticipated Project needs for the various services. The alternatives that were considered to meet these needs are discussed separately in Section B.6.

B.5.1 Water Supply: Needs

48. Potable and technical water will be used during the Construction Phase of the University campuses. Potable water will be used to meet the sanitary and drinking needs of construction personnel. This water will be taken from existing groundwater wells and will be treated on-site prior to use. Drinking water will comply with local and international standards for potable water quality.

49. Estimates for potable water consumption are based on an assumed consumption rate of 10 L/d per person. Technical water will be used for dust suppression operations during earthworks activities and water intake will be from the water channel that passes through the southern border of the University site. Dust suppression is assumed to be carried out for a period of 135 days during removal of the surface layer and for 180 days for excavation, crushing and backfilling activities. Water consumption during the Construction Phase amounts to:

• 2.8 m3/d (378 m3 for period) for removal of surface layer; and • 2.1 m3/d (378 m3 for period) for excavation, crushing and backfilling.

50. Water consumption during the Operational Phase for the campus is estimated based on typical water consumption rates together with a 50% overdesign factor [13]. Potable water and fire-fighting requirements will be stored in the same tank. Table B.5.1-1 and Table B.5.1-2 show the water consumption for the Naryn campus during the Operation Phase, together with the assumptions upon which the estimates are based. Per capita water consumption is assumed to be 250L/d in accordance with SNIP 2.04.02.84 [13]. Total water demand will be approximately 320 m3/d.

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Table B.5.1-1 Naryn Water Demand and Storage Capacity [13]

Water Consumption Water Population No. of Units L/container/day m3/day Undergraduate Students Full-time students 800 250 200.00 Prospective students 160 250 40.00 Total Undergraduate Students 960 250 240.00 Graduate Students Full-time students 120 250 30.00 Prospective students 0 250 0 Total Students 120 250 30.00 Post-Graduate Students 46 250 11.50 Total Students 1,126 250 281.5 Faculty Undergraduate 53 250 13.25 Graduate 8 250 2.00 Total Faculty 61 250 15.25 Staff 93 250 23.25 Total water consumption – for 1,280 250 320 domestic needs For fire safety needs 3 hours 16L/sec/container, 345 2 hydrants For irrigation needs 86,250 5 L/m2/day 430

Table B.5.1-2 Naryn Water Demand and Storage Capacity [13]

Needs for water storage Daily Reservoir for the water Reservoir for reservoirs requirements supply system irrigation water A container for 2 days of storage Water consumption 320 640 (m3/day) For fire safety (m3/day) 345 - Total estimated volume 985 430 (m3) Sections 2 1 Area (m x m) 12.5 x 10 12.5 x 10 Depth (m) 4.00 4.00 Total volume (m3) 1,000 500

B.5.2 Wastewater Management: Needs

51. No industrial wastewaters will be generated during the Construction Phase. Sanitary waste will be collected in single-seated portable (mobile) toilets equipped with a collection bowl. Prior to on-site wastewater treatment facilities becoming operational, sewage wastewaters from portable toilets will be transported for management by Naryn’s existing wastewater system.

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52. During the Operation Phase, the estimated volume of wastewater generated by the Naryn Campus is 300 m3/d. This is based on total potable water consumption minus a 10% loss factor to account for water losses in the system or other usages of water. Alternative wastewater treatment methods are discussed in Section B.6.2.

B.5.3 Electricity: Needs

53. The maximum electricity demand for the Naryn Campus in Phase I is approximately 2.2 MW. The maximum demand for the full program is estimated at 7.7 MW. Electrical loads will be reviewed during detailed design.[14]

B.5.4 Heating: Needs

54. The estimates for the thermal load required are calculated based on running continuously at full load for 6 months (October-March). The total maximum demand load (i.e. winter heating and hot water load) is estimated at 5.7 MW for Phase I. The minimum demand load (i.e. summer hot water load only) is estimated at 1.7 MW. For the full program, the maximum demand load is estimated at 14.5 MW and the minimum demand load during summer is estimated at 2.7 MW.[14]

B.5.5 Solid Waste Management: Needs

55. Based on a national estimated per capita solid waste generation rate of 1.88 kg/day taken for the urban areas, the total solid waste generation rate of the campus will be approximately 2.3 tonnes/day.

56. Solid waste management requirements will be determined, in large part, by the composition of the waste stream produced by the University. While the composition of waste produced by the University may vary, typical solid domestic waste composition in Central Asian countries shows that waste is comprised of 25% paper, 2.8% glass and 2% plastics (Table B.5.5-1).

Table B.5.5-1 Waste Composition [13]

Component % Paper 24.7 Others 16.1 Plastic 2 Glass 2.8 Scrap 2.8 Bones 3.7 Textile 7.8 Trees 2.2 Food Waste 37.9 Total 100

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B.6 Project Services: Evaluation and Selection of Preferred Alternatives

57. There are a number of alternatives for the supply of the services described in Section B.5. For example, due to the proximity of the campus to Naryn, some of the services could be provided through existing supply systems (e.g., electricity from the local grid). However, the same Project needs could also be met through dedicated on-site infrastructure.

58. The various service alternatives that are available to the Project were evaluated during the conceptual design process, taking into consideration a range of important factors including: a) the availability of surplus off-site capacity; b) the reliability/performance of off-site capacity; and c) capital and operating costs. In addition to these factors, the evaluation of alternatives also considered overall environmental performance. Given the importance of this topic to the IEE, the following sections present a summary of this analysis.

B.6.1 Water Supply: Alternatives

59. The town of Naryn is supplied with water from wells drilled on the banks of the Naryn River. The wells are drilled at depths ranging between 90 m and 100 m, and well pumps are installed at depths of 50 m to 60 m. The water is pumped to a 750 m3 storage reservoir located at 50 m above the town by means of a 250 mm pipeline.[13]

60. Local authorities have indicated that they will be able to provide the UCA campus with water; however, additional wells and reservoirs may be needed. If financing is available to upgrade the water supply system, then the water authority is willing to carry out the construction works and provide water to the campus.

61. In addition to obtaining water from the local supply system, UCA has evaluated the following two alternatives for the supply of water to the Naryn campus:

• Surface water from fresh water springs discharging into the Naryn River; and • Groundwater from the Naryn River.

B.6.1.1 Surface water from fresh water springs discharging into the Naryn River

62. Springs have been identified near the campus boundary and are currently used by the local inhabitants for water supply. In this alternative, an impoundment would be built at the source and water would be pumped to the campus using a 6.5 kW (4.6 L/s @ 50 m head) pumping station. A 150 mm pumping main with a total length of approximately 800 m would be required to transfer water to a treatment plant located on the campus. This alternative would also provide water to meet the irrigation needs of the campus.[13]

63. The use of this source is anticipated to require a high level of treatment due to elevated concentrations of suspended solids and pathogens. Additional investigations would be required to verify the water quality and flow rate from the springs.

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B.6.1.2 Groundwater from the Naryn River

64. This alternative requires the construction of wells on the banks of the Naryn River at the campus boundary. Deep well pumps of 12 kW capacity (4.6 L/s @ 100 m) would be required, as well as a 1.5 km water main with a diameter of 150 mm.[13]

65. The key advantage of this alternative is that the quality of the water will be relatively high since it would be pumped from the subsurface where natural filtration occurs through the soil strata.1 In order to be self sustaining, the conceptual design envisions that the water supply will need to feed a 3,000 m3 water reservoir at an elevation of approximately 2000 m.[13] This alternative can also meet the irrigation demands of the campus, although the effective cost of using this water for irrigation purposes is much higher. Irrigation water would therefore be supplied from the Naryn River directly.

66. Based on conceptual planning conducted to date, the preferred alternative is to drill groundwater wells in order to supply water to the Naryn campus. The exact location of the wells will be determined based on hydrogeological investigations to occur during the detailed design stage.

B.6.2 Wastewater Management: Alternatives

67. The existing wastewater collection system in the town of Naryn is in a deteriorated condition and is approximately 12 km from the campus boundary. The wastewater collected from the town is conveyed to a wastewater treatment plant at the entrance of the town near the Naryn River. The existing wastewater treatment plant has a limited capacity because some of its treatment units are currently not operational. Local authorities have expressed their interest in constructing a new wastewater treatment plant downstream of the campus site. Taking into consideration campus flows, the facility would have a minimum capacity of 5,000 m3/d. The authorities would operate and maintain the wastewater treatment plant once constructed if financing for the plant is secured from UCA.[13]

68. Based on a review of the options, it was decided that a wastewater treatment plant would be built on the Naryn campus to meet UCA’s wastewater treatment needs and treated effluent would be discharged to the Naryn River. Additional studies will be conducted during the detailed design and engineering stage to determine the preferred treatment technologies. These studies will also consider the assimilative capacity of the Naryn River. However, based on current planning, it is anticipated that biological wastewater treatment plant will be required (i.e., primary and secondary treatment). The effluent standards that would be applied to the Project are presented in Section D.5.2.

1 This is contingent on appropriate measures being put in place to minimize the risk of well water being contaminated with surface waters (e.g., grouting of well casings).

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B.6.3 Electricity: Alternatives

69. The power supply for the Naryn campus will originate from the local power authority. Power is largely produced from hydro resources and is reliable. Diesel generators will be used as required as backup to the local power network. Preliminary work has been undertaken to investigate options for implementation of renewable energy sources on the campus site and these investigations will be elaborated upon during the detailed design.

B.6.4 Heating Plant: Alternatives

70. As part of the investigation of heating plant alternatives, the option of tapping into local heating plants was investigated. No such plant exists in Naryn, and an independent on-site heat generation plant will therefore be required. The alternatives considered were:

• Coal-fired boilers; • Electric boilers; and • Light fuel oil or heavy fuel oil boilers with electric pre-heating.

B.6.4.1 Coal-Fired Boilers

71. The alternative of coal-fired boilers was eliminated due to the negative environmental impact associated with using coal as a fuel source.

B.6.4.2 Electric Boilers

72. The local generation, transmission and distribution system has sufficient capacity to meet the heating demands of the Project. UCA is currently discussing approaches to connect to the local grid via the transformer station immediately adjacent to the west of the site. The majority of grid power is sourced from hydro resources.

B.6.4.3 Fuel Oil Boilers

73. Although technically viable, emissions to the atmospheric environment from fuel oil boilers are the primary disadvantage of this alternative.

74. Based on conceptual plans, the preferred alternative for heating the Naryn campus involves the use of electric boilers. The final selection of the heating plant design will be carried out during detailed engineering.

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B.6.5 Solid Waste Management: Alternatives

75. The current solid waste management collection system within the town of Naryn is not operating effectively and needs to be more clearly defined through coordination with local authorities. Waste operations are limited to collection and dumping, with limited or no control of these operations from a technical and environmental standpoint.

76. Notwithstanding the challenges associated with the existing system in Naryn, UCA intends to develop an integrated solid waste management plan (ISWMP) for the Naryn campus. The ISWMP will consider best practices as well as national/international environmental standards. In order to reduce the amount of waste disposed and its associated impacts, UCA’s ISWMP will consider opportunities for source reduction and source separation, opportunities to reduce, reuse, and recycle waste, and options for residual waste disposal. The following descriptions present the major components of the ISWMP.

B.6.5.1 Source Separation

77. UCA will provide the appropriate infrastructure on campus for source separation and will provide educational programs to promote the effective use of this infrastructure. The program is anticipated to include bins that will be distributed in the proximity of several buildings to collect different types of wastes (e.g. glass, plastics, food, paper, other).

B.6.5.2 Opportunities to Reduce, Reuse and Recycle

78. Along with source separation, a focus will be placed on waste generation activities in an attempt to minimize waste generation rates. Such measures could involve a change in the type and quantity of raw materials used on campus. Options for reuse initiatives include utilization of containers and products and repairing items where possible instead of rendering as waste. Reuse may also entail transfer to another process where an item can be reused in a different function. Based on typical waste composition within the region (25% paper, 2.8% glass and 2% plastics - see Table B.5.5-1), there is a potential that large quantities of waste generated by the University could be recycled. However, this would require the presence of appropriate external infrastructure and systems to receive and recycle the wastes.

B.6.5.3 Recovery, Treatment and Disposal

79. Recovery of residual waste may entail composting of the organic fraction and then disposing the residual wastes. Two alternatives exist for the management of the final residual products:

• Collection and storage on-campus, treatment and disposal off-campus; and • Collection, treatment and disposal on-campus.

80. Based on preliminary planning, it is believed that the first alternative is more suitable due to technical, financial, and administrative reasons. However, as part of the detailed design phase, a focused study will be conducted to evaluate waste management strategies and recovery opportunities. This study, the recommendations of which will be integrated into the ISWMP, will consider the following subjects:

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• Site specific conditions and constraints of the campus in terms of location, land availability, land use plans, and nearby community waste management systems in place or envisaged; • The environmental legislative and regulatory framework in the area; • Existing markets for recycled materials and opportunities for energy recovery from waste; and • Future solid waste management plans in the surrounding area.

B.6.6 Snow Removal Alternatives

81. Due to the climate in the vicinity of Naryn, snow removal will be required to maintain access to and mobility within the campus. Snow removal can be carried out using a combination of snow ploughing, de-icing agents and/or heat pipe technology.

82. De-icing agents typically use calcium chloride or sodium chloride as the snow melting agent, and can result in salt damage such as rusting and other corrosion and deterioration of concrete. De-icing agents can also have adverse effects on vegetation growth. A number of non-chloride de-icing chemicals have been developed that are more suitable for salt sensitive areas. Heat pipe technology can also be used to prevent snow and ice accumulation. Heating pipes are embedded in the pavement through which a heated propylene glycol solution circulates.

83. Based on a preliminary analysis, UCA determined that the reliability of an in-ground heating system is likely to be a concern and that costs would be prohibitively high. A combination of snow ploughing and use of de-icing agents is therefore the preferred alternative. As described in Section D.5.2, the potential environmental impacts associated with de-icing agents can be effectively mitigated.

B.7 Project Phasing

84. The establishment of the University is expected to occur in three phases. In the first phase, capacity will be built for a total of 1305 students, i.e. 435 students per campus comprised of 375 undergraduate students and 60 graduate students. In the second phase, the capacity will be increased to a total of 2340 students, i.e. 780 students per campus comprised of 600 undergraduate students, 120 graduate students, and 60 Executive Development students. After expansion in the third phase, the total university capacity will be 3600 students, i.e. 1200 per campus, comprised of 960 undergraduate students, 180 graduate students, and 60 Executive Development students.

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C. Description of the Existing Environment

85. The following description of the existing environment is based on a review of prior reports to identify information that is pertinent to the general vicinity of the Naryn campus. This environmental “baseline” (i.e., the environment as it is now) serves as the basis for determining potential impacts that might be caused by the Project, as evaluated in Section D.

C.1 Local Climate

86. The following climate characteristics were derived from observations at the Naryn Meteorological Station (altitude 2,039 m). The region surrounding Naryn is characterized by large fluctuations in daily and annual temperatures, with cold winters and cool summers. Winter lasts for approximately five months and the average temperature in January is -17°C (extreme lows reach -38°C). The summers are dry with the average temperature in July at 18oC. The average annual precipitation ranges from 250 mm to 300 mm.

87. The average monthly temperature and precipitation are shown in Table C.1-1. Average wind speeds are shown in Figure C.1-1.

Table C.1-1 Average Monthly Temperatures and Precipitation in Naryn

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Temp. 2007 -10.5 -2.2 2.2 11.6 13.9 16.6 17.0 18.0 14.3 4.9 0.7 -11.3 6.3 2008 -18.6 -14.5 2.0 8.1 15.6 17.4 18.4 19.0 14.0 6.4 -2.6 -6.3 4.9 2009 -16.3 -10.5 -0.1 7.9 10.9 14.0 16.6 16.6 12.9 7.5 -0.9 -11.1 4.0 2010 -11.0 -9.4 -2.4 7.8 11.8 14.7 17.4 18.3 12.9 7.2 1.7 -10.3 4.9 Average -15.2 -12.3 -2.5 7.7 11.6 14.7 17.7 17.7 13.4 6.3 -2.7 -11.5 3.7

Precipitation (mm)

2007 3.6 2.4 20.5 15.0 48.4 40.2 67.6 10.9 0.5 3.0 5.7 5.4 223.2

2008 10.2 9.9 30.7 7.6 30.2 29.1 50.6 12.8 6.1 22.1 19.0 22.1 250.4

Average 8.2 12.6 19.9 32.2 55.5 60.3 35.6 22.0 13.5 15.8 12.4 10.4 298.4

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Figure C.1-1 Average Monthly Wind Speeds in Naryn [13]

C.2 Air Quality

88. There is no baseline air quality data for the site or Naryn. However, it is important to note that this IEE predicts that the Project will not result in significant air quality impacts (see Section D.4.1). On this basis, the lack of baseline data does not represent a substantive gap. UCA is currently considering a screening study to provide perspective on the potential releases to the local air shed.

C.3 Water Resources

89. The area of the UCA construction site has an important water artery in the form of the Naryn River that originates from the merger of the Chon-Naryn River and the Kichi-Naryn River. Its primary feeders are the At-Bashy, Alabuga, and Kekemeren Rivers. In terms of its nature and degree of wetness, the locality falls under Type 1 (SNiP KR 32-01:2004).

90. The Naryn River is the longest river in the Kyrgyz Republic with a total length of 535 km. The river has been known since ancient times and has been called Syr-Darya in the past. The river’s waters flow to the Aral Sea, just as the Amu-Darya Rivers does. Waters of the Naryn River are used for irrigation and the river also represents a significant energy resource as it is home to the Toktogul Hydro Power Plant, the Tash-Kumyr Hydro Power Plant, the Uchkurgan Hydro Power Plant, and the Kurpsay Hydro Power Plant, each with its respective reservoirs. Table C.3-1 shows the outflow for the Naryn River at Naryn town and Table C.3-2 shows water quality data for Naryn upstream and downstream of Naryn town.

91. The Naryn inter-mountain basin is a part of the Tien Shan fold-block hydrogeological area. Subsurface waters exist in the form of springs on mountain slopes, bottoms of gorges and plain floods.

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Table C.3-1 Outflow for Naryn River at Naryn town (m3/s)

Month 2008 Average Jan 32.6 26 Feb 31.8 24.9 Mar 26.4 26.3 Apr 42.9 47.2 May 145 120 Jun 182 208 Jul 183 243 Aug 208 205 Sept 91 90.2 Oct 55.1 48.3 Nov 36.2 34.6 Dec 28.8 29 Year avg 88.6 92.3 Highest Recorded 317 858 Date 5 Aug 19 Jun 1966 Lowest Recorded 18.5 5.9 Date 12 Mar 22 Jan 1938

Table C.3-2 Water Quality Data for Naryn River [8]

Upstream of Downstream of Parameter Units Naryn Town Naryn Town pH pH 8.25 8.20 Oxygen concentration mg/L 7.05 6.98 - HCO3 concentration mg/L 82.7 72.1 2- SO4 concentration mg/L 56.9 63.4 Cl- concentration mg/L 8.2 9.5 Ca2+ concentration mg/L 39.0 39.0 Mg2+ concentration mg/L 6.8 11.3 Total ions mg/L 194 195 Total water hardness mg/L 2.50 2.87

BOD5 mg/L 0.64 0.64 Oil products mg/L 0.00 0.00 Phenols, volatile mg/L 0.000 0.000 Nitrogen in ammonia mg/L 0.00 0.02 Nitrogen in nitrites mg/L 0.009 0.009 Nitrogen in nitrates mg/L 0.99 0.48 Total nitrogen mg/L 1.00 0.51 Phosphorus, mineral mg/L 0.022 0.018 Total iron mg/L 0.03 0.03 Siliceous mg/L 1.6 2.0 Fluorides mg/L 0.23 0.24

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C.4 Biological Environment

C.4.1 Terrestrial Vegetation

92. Subalpine meadows, steppes and spruce forest conifer woods gradually substitute the belt of meadow steppes and leaf forests and cover the area of high mountains. They appear at the altitude of 2,500 m – 2,700 m in the Ferghana Gorge, at the altitude of 2,700 – 3,100 m in the Naryn valley, and at even higher altitudes in the Alay valley. Meadow and steppe grass vegetation can also be found. In the summer, the belt is characterized by crop and motley fields. Between the altitudes of 1,600 m and 3,100 m, spruce forests comprised mainly of Tien Shan spruce as well as Semyonov firs can be found. The Tien Shan spruce, or the Schrenk spruce, only appears in the eastern part of the Kyrgyz Tien Shan. Local spruce also frequently include Tien Shan and Turkestan mountain ash, Tien Shan and Turkestan birch, and poplars. Underwood growth includes small-leaved honeysuckle, Albert briar, Turkestan pea shrubs, Alatau willow, and Turkestan juniper.

93. In addition to altitude, the nature of vegetative growth is also affected by the exposure of the mountain slope. At the same altitudes, slopes of the mountain range can be covered by conifer forests. At the uppermost belt, forests only appear at slopes facing east and south-east, while the opposite slopes are covered with alpine meadows and stone fields. From the altitude of 2,500 m – 2,600 m, conditions for the growth of spruce are favorable and forests descend into valleys, covering their edges. At high altitudes where it is cold, spruce trees can survive at well-heated southeastern and eastern slopes protected from cold winds. In the medium belt (below 2,500 m), living conditions for spruce become favourable as there is plenty of precipitation, sufficient heat, and fewer extreme winter temperatures.

94. Spruce forests give way to juniper shrubs. Juniper or as locally called “archa,” grow at 3,200 m of absolute altitude, and specimens more than 2,000 years old can be found. Juniper (“archa”) is a plant uniquely inherent to mountains of Central Asia where it is widespread bit does not form thick and dense forests. It grows sporadically and its groves never cover vast territories. In Tien Shan, large brushwoods of creeping elfin wood (Siberian and Turkestan juniper) are available. Juniper is a xerophilous plant and usually grows in mountains and steppes, in semi-savannas of low mountain horizons where precipitation is low and evaporation is significant. However, junipers also appear, although less frequently, in valleys and gorges of the alpine belt.

95. Subalpine meadows cover vast areas in Tien Shan. The highest belt – alpine meadows – is characterized by a harsh climate which causes the development of vegetation in which short grass is predominant. Ling, kobresia (of the Ling family) and certain crops are primary plants of alpine meadows. One can single out many bright-flowered plants on their green background: various cruciferous plants, light-grey edelweiss, yellow bloodroot, rose and purple aster.

96. The mountainous part of Tien Shan to the south-east from Issyk-Kul is covered mainly by kobresia alpine meadows. Shrubs here include juniper only, especially the creeping type. It even grows on harsh stony soils. Alpine vegetation reaches the upper snows and glaciers in the form of small meadows. Thanks to high aridity of Inner Tien Shan, this belt sometimes sports sheep fescue and feather-grass meadows.

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97. In Inner Tien Shan, forests can fall outside of the specter of altitudinal zonal distribution and hot steppes give way, at an altitude of 2,100-2,300 m, to grassy meadows and long cold steppes. One can frequently find cold semi-deserts at these altitudes. On steep windward slopes one can see cobbles covered with crustaceous lichen and moss. Among them one can see individual polster and grass tussock. Clefts of periglacial moraines are haven to saxifrage, edelweiss and primrose. The terrain is littered with once-ice-covered, wind-polished coble covered with multi-color lichen, large, grebe stone-like and dune- shaped and U-shaped Sibbaldia (of the rose-glower types); circles of ling are prevalent. Here, the vegetation is mainly used for haymaking and pasturing. Small ruminants graze all year round on vermouth and grass and vermouth associations. This belt is also home to arable land for irrigated, and less frequently, non-irrigated (bogharic) technical crops and vegetable gardens.

C.4.2 Terrestrial Wildlife

98. Wildlife in the mountains of Central Asia is more diverse than the wildlife of flat terrain. Since geographic landscapes in the mountains are in the form of vertical belts, animals follow them and are an integral part of the local ecological systems. The higher the mountain altitudes, the fewer species encountered. Forests serve as natural boundaries for animals since they separate inhabitants of bare, treeless areas from animals of the forest. Where the forest belt ends, one can see high-mountain animals descend into lower belts and similarly, inhabitants of low mountain areas can also be seen climbing the slopes.

99. The low hills are inhabited by the same animals as the plains: Persian gazelle, porcupine, fox, and wolf are as prevalent here; badgers can also be found approaching the belt of the woods. Wild boars, obligatory inhabitants of riparian woodlands, climb very high along the mountain valleys all the way to alpine meadows. Wild boars are problematic to farming activities; during the second half of summer when in Central Asia’s grain and garden crops start ripening, tillage and gardens must be protected from wild boars. Throughout the night, farmers must protect their small, irrigated plots of land from wild boars and during the day, crops must be protected from birds. Badgers can also be a threat to crops.

100. Forests are the richest media for wildlife. Within the forested regions are brown bears, wolves and boars. The belt of forests of the Central Tien Shan is inhabited by the Siberian roe, which has become somewhat of a rarity today. Thick and tall forests are home to lynx and its prey, which includes roe, piglets, hare, and small game. The emine and Turkestan weasel is a small but agile predator that feeds on mountain vole, small rats, hare or mice. The forests of Semirechye, the Ferghana mountains and the Western Tien Shan are also home to the beech marten. Normal Siberian boreal coniferous forest species such as squirrels and chipmunks are not commonly found even though the Sciurus vulgaris exalbidusin was acclimatized in the mountain and forest belts of the Northern and Inner Tien Shan during the 1950s – 1970s.

101. Coniferous woods are inhabited by birds including typical representatives of northern boreal coniferous forests such as blackcock, three-toed woodpecker, crossbill, and nutcracker. These inhabitants of boreal coniferous forests live close to southern Asian birds such as the Himalayan titmouse, mountain quail and rock thrush that inhabit West Asia, Tibet, and Chinese Turkestan. Flocks of mountain quail quickly run on gorges’ slopes where large cliff debris serve as havens to numerous insects upon which

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they prey. Turkestan mountain quail are only inherent to the mountains of Central Asia, although other types of this species inhabit the coasts of the Mediterranean and Africa. Sparrow hawk, hobby falcon, and Tien Shan nutcracker can also be found.

102. The upper horizon of coniferous forests is represented by brushwoods of arbuscle juniper or archa. Trees and shrubs grow sparingly and the region is bright, dry, and smells like tar. There forest-like diversity of animals is lacking including sources of food such as insets, worms, and mollusks. However, the juniper brushes are home to the juniper grosbeak, a motley bird that consumes berries of juniper. The bird is closely associated with junipers not only of Central Asia but also of Afghanistan and western provinces of China.

103. The deciduous forests are home to many species of birds. Songbirds include blackbirds, nightingales, doves, chickadees, penduline tits, orioles, flycatchers, and swifts. Pheasants tend to prefer coastal riverside brushes.

104. In the alpine belt, mountain meadows and steppes serve as great pastures for many herbivorous animals. Summers here are short and cold, and animals are frequently still “dressed” in their winter fur. Almost all rodents, once the cold of winter arrives, go into hibernation, while birds migrate. The wild Central Asian goat – kiyik – with twisted horns lives in herds in inaccessible high mountains. Wild sheep – argali – inhabit the alpine belt, and numerous types and subtypes of this family can be found.

105. Among the predators, the most dangerous species are headed by the large snow leopard, or ounce, a strong and extremely agile animal preying on jaal-goats and argali but not straining at rodents and birds. Today, argali and snow leopards are in the Endangered Species List of the Kyrgyz Republic.

106. The tops of Tien Shan are home to wolves (including the red alpine wolf), foxes, and weasels. Typical inhabitants of the alpine belt include marmots of which there are several species. The mountainous steppes are home to an epibiotic Tien Shan gopher that inhabits a vast territory all the way to Pamirs; mountain hare, and mountain voles. The Alay valley has plentiful voles and marmots.

107. The circle of mountainous birds includes alpine chough, alpine wallcreeper, rosy finch, alpine horned lark, ibis-bill, and house martin. Local predators among birds include the bearded vulture that mainly hunts for small mammals, mountain golden eagle, and snow Himalayan griffon. The gallinaceous are represented by blackbelly snowcock wandering the alpine meadows and mountain quail. Mountain quails live in flocks frequently seen together with herds of wild jaal-goats and argali. Mountain quails are inhabitants of Asia’s mountains and are represented by several types in a vast space from Asia Minor to Altai.

108. Unlike the steppes, the fauna of high mountains is not rich with reptiles. Only vipers, common lizards and another type of lizards climb that high into mountains.

C.4.3 Protected Areas and Red Book Species

109. The protected areas in the region include Naryn State Reserve and Salkyntor State Park. The Naryn State Reserve was founded in 1983 and protects an ecosystem comprised of coniferous forests and alpine meadows. The Salkyntor State Park is also in the Naryn oblast and was established in 2001.

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Salkyntor State Park encompasses almost 10,450 hectares and is dedicated to the reestablishment of the endangered Tien Shan Maral deer; the park is also used for recreational purposes by the local population. The Naryn State Reserve is also actively involved with captive breeding and release of this species.

110. The Red Book of rare and threatened species in the Kyrgyz Republic, as of 2009, encompasses 26 mammals, 57 birds, 10 reptiles and amphibians, 7 fish, 18 insects, and 87 plants and fungi, for a total of 204 species. The Naryn State Reserve has populations of Snow Leopard, Eurasian Lynx, Brown Bear, Markhor, and several birds of prey. The Salkyntor park in Naryn has 4 types of mammals, 6 types, 10 types of insects and 2 types of plants registered in the Red Book. Red Book species that are in the region include the vulnerable plant species of Semenov’s Onion (Allium semenovii Regel), Kaufmann’s Tulip (Tulipa kaufmanniana Regel), and Quadrifolious Tulip (Tulipa tetraphylla Regel). Red Book animal species in the region include the near threatened Black Stork (Ciconia nigra), which prefers wetlands in forest, subalpine and alpine belts and the Argali (Ovis ammon), which inhabits all mountainous ridges of .[5]

C.5 Geology and Soils

C.5.1 Geology [15]

111. The geological structure of the Naryn site is complex and the majority of the territory consists of gravel and silt soils. Faults were found and zones of fault-caused dislocations were established that can be categorized generally as east-west. Pursuant to seismic zoning of the territory of the Kyrgyz Republic, the area investigated falls under an 8-point seismic category (map of seismic microzoning KR SNiP 20-02:2004). There is a low potential for liquefaction. At many locations along the river there is evidence of streambank failures due to erosive forces.

112. Paleozoic and Cenozoic rocks form the physiographic framework of the area where the UCA Naryn campus is to be located. Paleozoic formations are represented by sedimentary rocks of Devonian and carboniferous systems and shape the northern branches of the Naryn-Too Range. Devonian sediments are represented by sandstone, gravel stone, conglomerates, shale bands and, less frequently, limestone.

113. Formations of the carboniferous system are represented by sandstone, gravel stone, limestone conglomerates, carbon shale, and conglomerates. The Cenozoic formations include sediments of the Palaeogene, Neogene and Quaternary systems. Palaeogene and Neogene rocks of Oligocene and Miocene are exposed on the right bank of the Naryn River and are represented by marmorate clay, silt, and, less frequently, malmstone bands.

114. The Quaternary system is represented by sediments of the contemporary and late Quaternary age. These are alluvial and alluvial-proluvial formations constituting the bed, flood plain and terraces above the flood plain of the Naryn River. Lithological sediments are represented by loam and, less frequently, sand clay, pebble, boulder rock and rubble. The immediate site investigated is formed by quaternary formations tens of meters deep including the surface loam. The site is dominated by light and dark

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chestnut soil that is loamy with traces of fines. The soil and vegetative layer does not exceed 20 cm in depth.

115. The site can be split into the following five zones for the purposes of developing detailed designs.

116. Western Upper Highlands (about 105 hectares) – The upper highlands occupying the better part of the land plot is located approximately 80 m above the Naryn River valley floor. The scarce vegetation growing on the highlands is used for agricultural/pasturing purposes. A monument is located in the center of the highlands. According to estimates, constraints of a geological nature are low including the potential destruction as a result of rockfall, shifting/seismic effects, floods or other destructive geological activity.

117. Northern Highlands (about 48 hectares) – The land across the university campus located north of the Naryn River descends steeply from the river cliff to highlands. These highlands descend at a gradient of approximately 6-8% and it appears that the lands were used for pasturing. Geological constraints in the area of the northern highlands, according to estimates, are rather high as a result of the presence of several assumed and confirmed faults. Constraints also exist due to the proximity to the river, in particular erosion and the possibility of flooding.

118. Western Highlands (about 80 hectares) – The majority of the western highlands is located on two elevated terraces, approximately 15 m – 20 m above the river. The land of the western highlands was traditionally used for agricultural purposes. The highlands boast plants of mature trees connected to existing structures; a large meadow of mature trees along the western and southern borders and a poplar alley along the public highway. The geological constraints of the western highlands lying to the north of the Naryn-Dostuk road are predicted to be high, while constraints for the territory located to the south of the road in the direction of the foot of the mountains is estimated to be low.

119. Central Highlands (about 52 hectares) – The territory on both sides of the public road within the boundaries of the central highlands is occupied by agricultural lands. The alley of mature trees along the road leads directly to rocks to the west. In the northern part of the highlands, where the river makes a steep turn, there is a nursery where young trees grow including open meadows with blackberry bushes and thick rows of young broad-leaved trees. Terracotta sandstone (rotten rock) cliffs in the north and badly crushed grey limestone rocks in the south constitute the overall picture of the central highlands. Starting from the road, the land descends to the river at a gradient of approximately 5%, and suddenly ends with a steep descent to the river bed (about 3 m). Just as in the western highlands, shadows affect the central plateau, especially in December and January.

120. Eastern Highlands (about 50 hectares) – The land located closest to the town of Naryn is basically a plain with a mild gradient (1-3%), except for the road and the riverbanks with steep cliffs. In the northeastern part of the highlands one can see cemeteries still in use. The land is open and has been traditionally used for agricultural purposes. Geological constraints in the area are predicted to be high due to signs of faults.

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C.5.2 Soils [15]

121. North Kyrgyzstan, with its high elevation and changes in hydrothermal conditions, is characterized by gray soil and chestnut soil (brownearth) with mountainous medium-humus black soil. Mountainous brown forest soil forms on slopes under spruce trees and mountainous brown earth forms under nut, berry and other trees. Mountain meadow as well as mountain peat soils are predominant in the upper boundary of the forest.

122. Agrologists single out takyr-like soils of high-mountain deserts and high-mountain meadow and steppe soils of vermouth and sheep’s fescue steppes and feather-grass and vermouth steppes in the high- mountain szyrts of the Inner Tien Shan. Black soils (black humus earth) are zonal soils of the subzone of feather-grass and grassland steppes with shrubs on slopes. These black soils are characterized by the intensive black color of the humus horizon, grainy structure and fluffy texture. The content of organic substances according to assay findings ranges from 4.4% to 7.2%. With regard to the content of humus, there are medium-humus (6-9%) and low-humus (less than 6%) black soils. The content of phosphorus and nitrogen in soils varies greatly. Lands covered by black soils are used as bogharic (dry) tillage and pastures. Land used in arable farming is obstructed by the conditions of the terrain that preclude mechanized tillage.

C.6 Physical and Cultural Resources

123. Naryn lies along a main caravan route of the Silk Road and a number of cultural artefacts such as rock drawings and burial sites exist in areas surrounding the town. For example, the Tasha Rabat caravanserai still exists from the 15th century. In the oblast, there is one musical drama theatre, three state museums and two school museums. There are also a number of historical monuments including the ruins of the fortress of Shyrdak-Bek, the Mausoleum of Tailak-Batyr, and the site of the Stone Age people.

124. The region is home to the Naryn State University which hosts more than 4,000 students. The town also has a gymnasium, lyceums including a Kyrgyz-Turkish lyceum, libraries, a local history museum, movie theatres, a musical drama theatre, the national Manas Rukhu theatre, a convention hall and parks.

C.7 Socio-Economics

125. The town of Naryn has a population of 45,000 while the Naryn province (oblast) has 272,000 (2008) [3]. Almost all of the residents (99%) are Kyrgyz with the primary language of communication being Kyrgyz.

C.7.1 Employment and Income

126. According to official statistics, in 2009, the average wage in Naryn was 4,741 som/month ($110/month). The town of Naryn’s real unemployment rate is estimated at 70 percent of the able-bodied population. The Naryn oblast accounts for 4% of the country’s GDP and contributes 1% to government revenues. The oblast is heavily dependent on external subsidies, including from intra-governmental

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transfers (almost 90% of the oblast budget), social payments (20% higher than the national average because of supplementary payments for living at high altitudes), and remittances from people who have emigrated to Bishkek, Kazakhstan and Russia.

C.7.2 Industry

127. The local economy is focused on a number of industries including agro-processing, construction, transportation, and communication companies. The oblast is rich in inputs used in producing construction materials such as gypsum, clay, crushed stone, lime and marble. There are large deposits of high grade iron ore, niobium (a valuable element used in electronics, aircraft construction), coal, semi-precious stones, and rock salt. The region has an iron ore mine, Jetim-Too, and gold ore deposits in Solton-Sary, and Kum-Bel. An operational gypsum plant is located in the village.

C.7.3 Agriculture

128. Agriculture accounted for 74% of Naryn’s gross regional production in 2004 [3]. While the cold climate and mountainous terrain limit crop cultivation, 57% of the oblast’s territory is suitable for pasture and rangeland. In 2003, the oblast had 121,200 head of cattle (almost 60,000 cows), 526,400 sheep, 165,000 goats, and 96,300 horses. The decline in herd size, seen immediately after the collapse of the Soviet Union, has reversed and is steadily increasing. There is currently a lack of agroprocessing enterprises such as slaughterhouses, meat processing plants, dairies, and creameries. It should be noted that agriculture accounts for a third of the Kyrgyz Republic’s GDP (2003) and it produces a livelihood for 53% of the employed population. However, the country is a net importer of agricultural products. The trade deficit in agricultural products is $18.7 million or 14.4% of the total $136 million.

C.7.4 Health

129. Over the 10 year period beginning in 1996, Phase 1 of the Health Sector Reform in Kyrgyzstan resulted in a transformation of the health care system from a curative approach to one focusing on family medicine. A mandatory health insurance scheme was also introduced. In Naryn, the first line of contact for patients is the Feldsher Nursing Midwifery Posts (FAP), of which there are 80 in the Naryn Oblast. Each FAP is intended to provide catchment for a population for 500 to 2,000. The facilities offer simple curative care, ante natal and post natal care, basic health prevention activities, immunization and health care. [9]

130. From the FAP, patients can be referred to a Family Group Practice (FGP). Approximately 45 FGPs exist, with the typical FGP being staffed by three to four family physicians. A typical FGP will have a lifestyle clinic, consulting rooms, treatment/procedure room, eye testing, basic laboratory with sample analysis, rehydration room, and a small pharmacy. In the Naryn Oblast, there are 6 Family Medical Centres (FMCs) which provide the outpatient function for hospitals. A typical FMC will be staffed by specialist physicians and provide outpatient services in fields such as obstetrics and gynecology, traumatology, urology, cardiology, oncology, and physiotherapy. A laboratory that provides biochemistry, serology, photometry, hematology, and imaging services such as general X-ray, fluoroscopy and ultrasound is also typically provided. [9]

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131. Secondary facilities include hospitals, of which there are five (four territorial/district/rayon and one provincial) in the Naryn Oblast. The Naryn Oblast has one provincial hospital of approximately 450 beds, located on two separate sites in Naryn Town. Within Naryn Town, there are five FGPs serving central, north, south, east and west Naryn and one centrally located FMC. The Provincial Hospital is centrally located in the town’s administrative area, although certain services such as ophthalmic services are provided in a separate hospital building located north of the River. [9]

C.7.5 Education

132. The literacy rate in Naryn is relatively high at 98.5% as a result of the Soviet legacy of mandatory secondary education. Over the five year period from 2004 to 2008, however, the number of students declined by 8,300 or 12%. One reason suggested for the high rate of dropouts is the socioeconomic challenge faced by families. In contrast to the fairly high secondary education coverage, coverage by pre- school education facilities was amongst the lowest in the country, ahead only of Osh oblast.

133. The numbers of students attending various levels of education institutions are shown in Figure C.7.5-1.

Figure C.7.5-1 Number of Students (thousands) [3] 80 70 60 50 40 30 20 10 0 2004/2005 2005/2006 2006/2007 2007/2008 2008/2009

Secondary Secondary professional Tertiary

2004/2005 2005/2006 2006/2007 2007/2008 2008/2009 Secondary (1-11 grades) 67.7 65.6 63.4 61.9 59.4 Secondary professional 1.0 1.1 1.0 1.0 1.2 Tertiary 4.2 4.2 3.8 3.7 3.5 Source: NSC, 2009b, p. 334; NSC, 2008a, p. 325; NSC, 2007a, p. 332; NSC, 2006a, p. 326; NSC, 2005a, p. 321

C.7.6 Infrastructure

134. Naryn’s lack of infrastructure has contributed to its economic challenges. Trade and travel are dependent on road infrastructure. The Bishkek-Torugart Road is the major transportation artery, connecting the Naryn oblast and the City of Naryn to the rest of the country. The AKDN is currently investigating opportunities to develop infrastructure in Naryn including transportation infrastructure and specifically it has been investigating the rehabilitation of the Naryn airport in partnership with the Kyrgyz government.

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D. Anticipated Environmental Impacts and Mitigation Measures

D.1 Introduction

135. This chapter identifies and examines the potential adverse impacts that the University may have on the environment, both during construction and operation. The assessment focuses on potential environmental impacts that were deemed plausible and potentially measurable. Mitigation measures and residual impacts (i.e., adverse impacts after mitigation) if any, are also identified. The significance of any residual impacts is also discussed.

136. As noted previously, UCA’s primary mission is to promote the socio-economic development of Central Asia’s mountain societies, while also helping the diverse peoples of the region to draw upon their rich cultural traditions and heritages as assets. In this regard, the Project is anticipated to be inherently positive. It is against this backdrop of positive impacts that potential adverse impacts of implementing the Project have been evaluated.

D.2 Assessment Methodology

137. The methodology used to evaluate potentially adverse impacts of the Project on the environment included:

• Description of baseline environmental conditions (as presented in Section C); • Identification and assessment of Project-environment interactions that have a potential for adverse environmental impacts; • Consideration of mitigation measures for potentially adverse impacts; • Identification of residual impacts and assessing their significance.

D.3 Identification of Project-Environment Interactions and Likely Environmental Impacts

138. Project-environment interactions and likely environmental impacts were screened through the creation of a “Project-environment Interaction Matrix” which is presented in Table D.3-1. The matrix summarizes the plausible interactions between the Project and the following environmental components:

• Atmospheric Environment; • Surface Water Resources; • Biology (Aquatic and Terrestrial); • Geology and Hydrogeology; • Physical and Cultural Resources; and • Socio-economics.

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139. Taking into consideration the proposed Project activities and the description of the existing environment (Section C), interactions that were considered to have some potential of resulting in adverse impacts were identified in Table D.3-1. Blank cells in the table indicate that no plausible impacts were identified. Each of the identified Project-environment interactions is further evaluated in Sections D.4 through D.9. A discussion of potential cumulative effects associated with the Project is presented in Section D.10.

D.3.1 Project Phases and Activities

140. The Project is composed of a large number of individual activities, some of which have the potential to interact with multiple environmental components. On this basis, it could be argued that each of the activities should be evaluated independently to determine whether adverse environmental impacts might occur. However, many of the activities are sufficiently similar that they can be grouped and analyzed as a single type of activity. For example, the construction of all campus buildings has been treated as a single activity due the common nature of the potential impacts that could be caused. By grouping the Project activities into common categories, potential adverse impacts were efficiently identified and assessed.

141. The left column of Table D.3-1 lists the groups of activities that were considered in the identification of Project-environment interactions. The activities have been assigned to both of the major phases of the Project (Construction and Operations) and are described below.

D.3.1.1 Construction Phase

142. The groups of activities during the Construction Phase will include:

• Site Clearing and Earthworks: All earthmoving activities on surface related to preparation of the site. This includes sub-activities such as building excavations, operation of a crushing plant, construction of land-forms (e.g., berms, surface drainage) and site grading. The activity involves use of heavy equipment to move granular materials that will be exposed in the process. • Construction of Surface Infrastructure: This includes all campus buildings and related services to support the University (e.g., water supply pipeline, electricity distribution system). Construction is anticipated to use conventional and local building techniques. • Road Construction and Paving: In terms of potential interactions with and impacts to the environment, this activity is identical to Site Clearing and Earthworks. • Transportation: All movement of materials and personnel to, from and within the site. • Fuel Management and Maintenance: Any on-site management of bulk fuels (e.g., to power earth moving equipment).

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D.3.1.2 Operational Phase

143. For the purpose of the IEE, the major groupings of activities during the Operational Phase include:

• Academic Programs and Residency: Use of the campus infrastructure by students and faculty. • Back-up Electricity Generation: Periodic on-site generation of electricity using diesel-fired generation sets. • Heating: On-site generation of heat to service campus buildings. • Water Treatment and Usage: Extraction of water from groundwater wells, treatment and distribution to campus facilities. • Wastewater Treatment and Usage: On-site treatment of domestic and institutional wastewater generated on campus (no industrial wastewaters produced). Discharge of treated effluent to the Naryn River. • Waste Generation and Management: Waste production (primarily solid domestic and institutional wastes). Management in both on-site and off-site facilities. • Transportation: All movement of materials and personnel to, from and within the site. • Fuel Management and Maintenance: Any on-site management of bulk fuels (e.g., to power stationary combustion equipment).

D.3.2 Project-Environment Interactions

144. To facilitate the analysis of Project-environment interactions, 12 “types” of impacts with a theoretical potential to affect the environment were identified. Based on professional judgment, many of the Project-environment interactions and impacts are anticipated to be insignificant. Nonetheless, such interactions and impacts have been incorporated into the IEE to ensure the evaluation is rigorous. As noted on Table D.3-1, the types of impacts are as follows:

1. Increased turbidity in water: All Project activities that involve unconsolidated granular materials coming in contact with water have the potential to result in increased concentrations of suspended solids (i.e., turbidity). In addition to increasing concentrations of suspended solids in water, major surface disturbances and modifications to the current hydrological regime may result in increased rates of erosion and associated sedimentation. 2. Potential releases: Despite comprehensive efforts to control accidental releases (spills) to the environment, complete containment of such releases is seldom possible. For example, operation of heavy equipment will inevitably result in the release of small quantities of petroleum hydrocarbons (lubricants and fuel). Use of de-icing agents on roads represents another pathway for such releases. 3. Site drainage: Changes to the surface hydrology that may influence downstream volumetric flows/levels in receiving waters.

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4. Dust (suspended solids in air): Sources of particulate matter include the movement of large volumes of granular material, crushing and transportation activities. 5. Combustion emissions: Some of the Project activities will involve the use of heavy equipment that will consume petroleum hydrocarbons. The exhaust produced from this equipment will be dispersed in the atmospheric environment surrounding the site. The same applies to stationary combustion equipment such as back-up diesel generators that will be used during the operational phase of the Project. 6. Noise/vibration: Operation of heavy equipment and other site activities will generate noise emissions and vibration. 7. Effluent: The wastewater treatment plant will produce an effluent for discharge to the receiving environment. 8. Odour: Some activities have the potential to produce odours that could affect aesthetic air quality. 9. Vapour: Passive volatilization of vapours from fuel storage tanks. Certain construction activities may also release vapours (e.g., welding, paints). 10. Surface disturbances: The presence of heavy equipment and people during the implementation of the Project represents a potential disturbance to terrestrial species that might otherwise be on site. 11. Animal mortality: Although efforts will be made to minimize impacts to terrestrial animals, there is a potential that some mortality will occur on roads and as a result of pest control. 12. Local supply: The Project will require a variety of inputs from the area and communities surrounding the site. Examples of such inputs include: human resources, materials and utilities. The use of these inputs has the potential to affect their availability to other users.

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Table D.3-1 Project-Environment Interactions and Potential Adverse Impacts

Atmospheric Biological Geology & Physical & Cultural Water Resources Socio-economics Environment Environment Hydrogeology Resources

MAJOR PROJECT

WORKS AND ACTIVITIES Use Visual Quality Biology quantity) Geology/ (quality & Hydrology Seismicity Terrestrial Air Quality Resources Description Community Population & Landscape & Current Land Hydrogeology Surface Water Archaeological Infrastructure & Aquatic Biology Economic Base Noise Vibration/

CONSTRUCTION

dust & surface noise/ site Site Clearing and Earthworks combustion turbidity turbidity disturbances and vibration drainage emissions dust dust, combustion noise/ local supply Construction of Surface Infrastructure dust emissions & vibration (materials) vapours local supply dust & surface surface Road Construction noise/ site (human local supply combustion turbidity turbidity disturbances disturbances and Paving vibration drainage resources) (materials) emissions and,dust dust & local supply Transportation of Materials, Equipment noise/ potential dust, animal combustion (transportation and Personnel vibration releases mortality (traffic) emissions infrastructure)

potential potential Fuel Management and Maintenance vapours releases releases

OPERATIONS surface Academic Programs and Residency disturbances

Back-up combustion noise/

Electricity Generation emissions vibration local supply local supply surface (human Use of Grid Electricity (elec. gen/dist. disturbances resources) capacity)

Heating

local supply Water Treatment and Usage (groundwater)

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Atmospheric Biological Geology & Physical & Cultural Water Resources Socio-economics Environment Environment Hydrogeology Resources

MAJOR PROJECT

WORKS AND ACTIVITIES Use Visual Quality Biology quantity) Geology/ (quality & Hydrology Seismicity Terrestrial Air Quality Resources Description Community Population & Landscape & Current Land Hydrogeology Surface Water Archaeological Infrastructure & Aquatic Biology Economic Base Noise Vibration/

Wastewater Treatment and odour effluent effluent Discharge local supply animal mortality Waste Generation and Management odour (waste disposal (pest control) capacity) dust & local supply noise/ potential potential animal mortality Transportation combustion (transportation vibration releases releases (traffic) emissions infrastructure) potential potential Fuel Management and Maintenance vapours releases releases

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D.4 Atmospheric Environment

145. This section describes the predicted impacts of the Project on the Atmospheric Environment which comprises two sub-components: Air Quality and Noise.

D.4.1 Air Quality

D.4.1.1 Environmental Standards

146. Air emissions standards consider the need to protect the environment from adverse environmental impacts as well as the need to prevent poor air quality that could result in irritation, discomfort or illness to workers.

147. For projects that have a reasonable potential to cause significant air quality impacts, quantitative assessments are conducted. These assessments take into consideration baseline air quality data together with dispersion modeling of project-specific emissions to determine potential ground level contamination.

148. The qualitative evaluation presented in this IEE predicts that the Construction and Operation of the Naryn campus will not result in significant air quality impacts (refer to Section D.4.1.3). Nevertheless, UCA is considering conducting a screening level assessment to confirm this. Such a study would consider the final design and any potential air quality impacts will be determined based on a comparison of predicted air quality concentrations with the World Health Organization’s (WHO) Ambient Air Quality Guidelines (as presented in Table D.4-1) or local regulations.

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Table D.4.1.1-1 WHO Ambient Air Quality Guidelines [7]

a Parameter Units Average Period Guidelines

24-hour 125 (Interim 1)

Sulphur dioxide 50 (Interim 2) μg/m3 (SO2) 20 (Guideline) 10 minute 500 (Guideline)

Nitrogen dioxide 1 year 40 (Guideline) μg/m3 (NO2) 1 hour 200 (Guideline)

1 year 70 (Interim 1) 50 (Interim 2) 30 (Interim 3) 20 (Guideline) Particulate matter μg/m3 (PM10) 24-hour 150 (Interim 1) 100 (Interim 2) 75 (Interim 3) 50 (Guideline)

35 (Interim 1) 25 (Interim 2) 1-year 15 (Interim 3)

10 (Guideline) Particulate matter μg/m3 (PM2.5) 75 (Interim 1)

50 (Interim 2) 24-hour 37.5 (Interim 3) 25 (Guideline)

160 (Interim 1) 3 Ozone (O3) μg/m 8-hour daily max 100 (Guideline)

a - WHO interim targets are provided in recognition of the need for a staged approach to achieving the recommended Guideline standards.

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D.4.1.2 Summary of Interactions

149. As indicated in Table D.3-1, the majority of Project activities have some potential to interact with air quality. The interactions are associated predominantly with the movement of granular materials (i.e., earthworks) and use of combustion equipment (bulldozers, haul trucks, etc.). Other activities also have some potential to result in vapour and odour impacts. The types of impacts and associated activities related to air quality are as follows:

Dust

• Site clearing and earthworks (Construction Phase);

• Construction of surface infrastructure (Construction Phase);

• Road construction and paving (Construction Phase); and

• Transportation (Construction and Operation Phases).

Combustion emissions

• Site clearing and earthworks (Construction Phase);

• Construction of surface infrastructure (Construction Phase);

• Road construction and paving (Construction Phase);

• Transportation (Construction and Operation Phases); and

• Back-up electricity generation (Operation Phase). Vapours

• Construction of surface infrastructure (Construction Phase); and

• Fuel management and maintenance (Construction and Operation Phases).

Odour

• Wastewater treatment and discharge (Operation Phase); and

• Waste generation and management (Operation Phase).

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D.4.1.3 Assessment of Potential Impacts and Mitigation

150. As indicated previously, UCA is in the process of initiating detailed designs for the Project. Once the designs are sufficiently advanced, consideration will be given to performing quantitative assessments of potential air quality impacts. This is likely to include refinements to preliminary emissions estimates and, potentially, dispersion modelling to evaluate incremental air quality impacts to receptors.

151. While insufficient design details are available to perform quantitative assessments at this time, the following qualitative discussions of potential impacts are justified. When considering these potential impacts, it is important to emphasize the scale and relatively benign nature of the activities associated with the Project. Specifically, as an academic institution, potentially adverse interactions between UCA and the Air Quality environment are expected to be minor relative to industrial developments (e.g., mining or manufacturing).

Dust 152. The majority of dust (suspended particulate matter) produced by the Project would be attributable to the movement of granular materials (i.e., earthworks) and construction activities. Such activities will occur only during the Construction Phase of the Project and effective mechanisms can be put in place to mitigate impacts. Furthermore, dust generation is anticipated to occur at a slower rate during frozen periods.

153. A number of measures will be put in place to effectively mitigate dust emissions from the Project site. Some or all of the following measures will be integrated into the Project designs and contract documents (specifications) to ensure dust is reduced to the greatest degree possible:

• Surface Applications – To reduce dust emissions, haul roads and areas where earthworks are to be carried out will receive water applications. The application of chemical dust suppressants (e.g., calcium chloride) will also be considered in situations where water provides insufficient dust control. Based on experience at other sites, these measures are anticipated to achieve an 80% reduction of particulate matter emissions. • Work Controls – In the event that surface applications are not sufficient to control emissions (e.g., during a prolonged summer drought) alternate measures will be put in place. This could include staging activities during periods when the impacts of emissions and/or dispersion can be minimized. The need for additional work controls such as truck covers and temporary surface stabilization will be determined on a case-by-case basis.

154. As described further in Section F, these and other mitigation measures will be incorporated into the Environmental Monitoring and Management Plan for the Project.

155. Taking into consideration the scale and nature of potential dust sources, as well as the proposed mitigation measures, the residual impacts associated with dust are not anticipated to be significant.

Combustion Emissions 156. The Construction Phase of the Project will involve the operation of light and heavy equipment and release of associated combustion emissions. In addition to mobile sources, the Operational Phase will

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result in emissions from a series of stationary combustion sources, including those required for back-up electricity generation.

157. Mitigation measures that will be put in place to minimize the impacts of combustion emissions on air quality include:

• Equipment specifications – Emissions performance will be considered during the selection process for stationary combustion equipment (e.g., back-up generation sets). Selected contractors will also be required to use mobile construction equipment equipped with appropriate emissions controls. • Equipment and vehicle maintenance – Regular scheduled inspections and maintenance to ensure optimal performance. • Operational controls – Where possible, reductions in the number of construction vehicles and/or periods of operation (limiting idling periods, number of vehicles operating simultaneously, etc.).

158. Based on the scale of activities at the University (both during Construction and Operation), as well as the proposed mitigation measures, incremental combustion emissions are predicted to be minor relative to those produced from other sources in and around Naryn. Within this context, the residual impacts associated with combustion emissions from the Project are not expected to be significant. This assumption will be revisited once additional design details become available (types and sizes of vehicle fleets, specifications of stationary combustion sources, etc.).

Vapours 159. Fuel for stationary and mobile combustion sources will be stored in bulk on-site during the Construction and Operation Phases. There is a potential that volatile fuel fractions will be released to the atmosphere during the storage and dispensing of these fuels (breathing and working losses). Similarly, some construction activities may result in the release of vapours during the Construction Phase (e.g., volatile paints and welding).

160. Mitigation measures that will be put in place to control the discharge of vapours from the Project include:

• Material specifications – To the extent feasible and available, low volatility products will be used preferentially. The use of water-based paints is an example. • Bulk fuel storage specifications – Best practices to minimize product volatilization and release.

Taking into consideration the nature of the Project activities and proposed mitigation, there are no significant residual impacts associated with vapour emissions.

Odour 161. Unless managed properly, wastewater treatment and solid waste management can result in localized odour concerns. However, these concerns can be adequately addressed through the selection of appropriate technologies and location of facilities. Such considerations will be integral to the detailed design process for the wastewater and solid waste management facilities/programmes.

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162. As a consequence, no significant residual odour impacts are anticipated. Nonetheless, in the event odour concerns are reported, case-specific corrective actions will be applied.

D.4.2 Noise and Vibration

D.4.2.1 Environmental Standards

163. Various noise standards have been established to protect workers from adverse impacts associated with high noise levels, as well as to minimize disturbances to local residents. For example, the World Bank EHS Guidelines noise limits are shown in Table D.4.2.1-1. In accordance with Occupational Health and Safety (OHS) standards, no worker on the UCA campus will be exposed to a noise level greater than 85 dB(A) for more than 8 hours per day without hearing protection. The importance of hearing protection will also be emphasized as part of worker OHS training.

Table D.4.2.1-1 Noise Limits for Various Working Environments[7]

Location / activity Equivalent Level (LAeq 8h) Maximum (LAmax,fast) Heavy industry (no demand for oral 85 dB(A) 110 dB(A) communication) Light industry (decreasing demand 50-65 dB(A) 100 dB(A) for oral communication) Open offices, control rooms, services 40-50 dB(A) - counters or similar

Individual offices no disturbing noise) 45-50 dB(A) -

Classrooms, lecture halls 35-40 dB(A) -

Hospitals 30-35 dB(A) 40 dB(A)

164. In order to limit noise impacts to the community, noise levels will not exceed the levels shown in Table D.4.2.1-2 or result in an increase in background levels of more than 3 dB at the nearest receptor location off-site.

Table D.4.2.1-2 Noise Level Guidelines – One Hour LAeq (dBA)

Receptor Daytime 07 :00 – 22 :00 Night time 22 :00 – 07 :00 Residential; institutional; 55 45 educational

Industrial; commercial 70 70

D.4.2.2 Summary of Interactions

165. Similar to air quality, a number of Project activities have some potential to cause noise emissions and vibration. The dominant sources of such impacts are associated with heavy equipment operation,

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construction activities, transportation and stationary combustion equipment. Specifically, the main activities that are likely to result in noise emissions and vibration are as follows:

Noise and Vibrations

• Site clearing and earthworks (Construction Phase);

• Construction of surface infrastructure (Construction Phase);

• Road construction and paving (Construction Phase);

• Transportation (Construction and Operation Phases); and

• Back-up electricity generation (Operation Phase).

D.4.2.3 Assessment of Potential Impacts and Mitigation

166. The incremental noise and vibrations produced during the Construction Phase of the Project will be sporadic and temporary. Similarly, the distance of the site to potentially sensitive receptors will serve to attenuate noises that are produced. The potential for such impacts will reduce even further during the Operational Phase.

167. Although noise impacts are expected to be minor, the following mitigation measures will be put in place.

• Equipment specifications - All heavy equipment will be equipped with standard industrial noise suppression devices and will be maintained in good working order. Stationary combustion equipment will be designed and located to minimize noise impacts. For example, the back-up electricity generators will be equipped with appropriate noise suppression devices and will be strategically located to reduce potential impacts to sensitive receptors.

• Maintenance - All equipment that is a source of noise and vibration will be maintained as required.

• Operational controls - To the extent feasible, efforts will be made to schedule activities so as to minimize any potential noise impacts (e.g., work at night will be minimized) and to limit the extent to which traffic passes through community areas.

168. Based on the Project activities and proposed mitigation, no significant residual noise and vibration impacts are anticipated. Nonetheless, similar to odour, case-specific corrective actions will be applied if any noise and vibration concerns are reported.

169. Noise levels will be periodically monitored, particularly during activities with a potential to disturb local residents.

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D.5 Water Resources

170. This section describes the predicted impacts of the Project on Water Resources, which comprises two sub-components: Hydrology and Surface Water Quality.

D.5.1 Hydrology D.5.1.1 Summary of Interactions

171. As indicated in Table D.3-1, changes to site drainage are the only type of impact that might affect hydrology. Such impacts are associated with the following activities that have the potential to alter the drainage patterns and volume of surface water runoff from the site.

Site Drainage

• Site clearing and earthworks (Construction Phase); and

• Road construction and paving (Construction Phase).

D.5.1.2 Assessment of Potential Impacts and Mitigation

Site Drainage 172. Although localized topographical modifications will be required to accommodate particular elements of the campus (e.g., cut and fill to create sports fields), the general topographic structure of the site will be retained. As a consequence, any changes to the surface water drainage patterns of the site will be relatively minor.

173. Once fully constructed, portions of the site will be less pervious than their pre-development condition due to the presence of buildings, roads, parking areas and other impervious surfaces. While this may result in localized increases of surface flow volumes and rates during precipitation events, any impacts to downstream receiving waters (i.e., the Naryn River) would be inconsequential. This is due to the extremely small footprint of new impervious surfaces relative to the catchment area of the river. On this basis, there are no anticipated site drainage impacts and mitigation is not required.

D.5.2 Water Quality

D.5.2.1 Environmental Standards

Treated Effluent Discharges

174. Although other activities have the potential to contribute to water quality impacts, the discharge of treated wastewater represents the greatest potential source of impacts to the Naryn River. It will, therefore, be necessary to select appropriate effluent discharge criteria for the wastewater treatment plant to ensure that surface water resources are protected.

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175. In order to determine the treatment specifications for the wastewater treatment plant, best practices and effluent concentrations used in a number of jurisdictions were reviewed. Table D.5.2.1-1 shows the typical influent wastewater characteristics together with the permissible effluent concentrations, as defined in the World Bank Environment, Health & Safety Guidelines and the EU Directive for urban waste water treatment (91/271/EEC). The EU Directive applies to wastewater from residential settlements and services as well as industrial wastewater and defines requirements that wastewater treatment plants must satisfy prior to discharge. Specifications are defined for discharges to fresh-water and estuaries from agglomerations (i.e., communities) with populations that are less than 2,000 (equivalent). UCA’s wastewater treatment plants will treat wastewater to the more stringent of the two standards. The UCA Objectives for treated liquid effluent are shown in the last column of Table D.5.2.1-1 and represent the achievable levels for best available technologies. To the degree possible, UCA will strive to achieve these Objectives, but at a minimum will meet the more stringent of the reference standards.

Table D.5.2.1-1 Effluent Discharge Concentrations for Wastewater Treatment Plant

Influent[ 91/271/EEC Minimum UCA Parameter Units WB EHS[7] 13] [4] Reduction[4] Objectives

BOD5 mg/L 190 25 70% – 90% 30 10 COD mg/L 430 125 75% 125 - TSS mg/L 210 35 90% 50 10 Total N mg/L 40 15 70% – 80% 10 10 Total P mg/L 7 2 80% 2 2 Oil and Grease mg/L 90 - - 10 10 Fecal Coliforms /100mL 104–106 - - - Total Coliforms /100mL - - - 400 pH - 6 to 9 6 to 9 6 to 9

176. In the case of water discharged into an irrigation channel, the water quality being discharged must conform to SanPiN 2.1.7.573-96 Hygiene Requirements for the Use of Wastewaters and their Residues for Irrigation and Fertilization Purposes. These requirements are shown in Table D.5.2.1-2.

Table D.5.2.1-2 Required Water Quality for Irrigation Water [10]

Required Quality Required Quality Parameter Units Parameter Units for Irrigation for Irrigation COD mg/L 350 Cl mg/L 70

TSS mg/L 160 SO4 mg/L 80 Total N mg/L 40 Ca mg/L 55

NH4 mg/L 15 Mg mg/L 25

P2O5 mg/L 8 Na mg/L 90

Solid Residue mg/L 600 K2O mg/L 20

HCO3- mg/L 350 pH pH 7.2

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177. In the absence of appropriate environmental management practices, the laboratories that will be located on the campus also have some potential to impact water quality. Environmental standards and best practices for academic laboratories exist in some jurisdictions. For example, in the United States, Title 40 Protection of the Environment Part 262 Standards Applicable to Generators of Hazardous Waste contains Subpart K – Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities. This subpart provides a framework for the management of wastes generated in university laboratories. The standard contains specific labelling and management requirements for laboratory wastes. These include:

• Labelling requirements for unwanted materials or chemical wastes; • Training requirements; • Removal of containers of unwanted material from laboratories; • Determination of hazardous wastes; • Laboratory clean-outs; and • Laboratory management plans.

178. Such EHS best practices and standards will be consulted for the development of UCA’s EHS practices for laboratory activities and laboratory wastes.

D.5.2.2 Summary of Interactions

179. Table D.3-1 identified three types of impacts to water quality that could arise through the implementation of the Project. Those impacts and the various activities that could cause them are as follows:

Turbidity in Surface Water

• Site clearing and earthworks (Construction Phase); and

• Road construction and paving (Construction Phase).

Discharge of Treated Wastewater Effluent to Surface Water

• Wastewater treatment and discharge (Operation Phase).

Additional Releases to Surface Water

• Transportation (Construction and Operation Phases); and

• Fuel management and maintenance (Construction and Operation Phases).

D.5.2.3 Assessment of Potential Impacts and Mitigation

Turbidity in Surface Water

180. Similar to most projects that involve extensive earthworks, many of the activities associated with current Project will require the deliberate disturbance of granular materials. A key concern with such activities is the potential for increased erosion and turbidity which, under extreme conditions, can have an

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adverse impact on water quality. Mitigation measures will, therefore, be required to minimize potential adverse impacts. These measures will include standard operational practices to control erosion and sedimentation. Typical practices include:

• Controls - When carrying out earthwork or vegetation clearing activities in the vicinity of a drainage course or a body of water, silt fences, floating silt curtains and/or containment berms will be used, as appropriate, to prevent the release of sediment into water. • Scheduling - Areas subject to potential erosion will remain open for the minimum period necessary to implement the required work. In addition, work will be avoided during wet and rainy periods in areas where erosion poses a problem. • Material management - Properly containing and stabilizing material stockpiles to prevent sediment from entering any water body. • Re-vegetation - Where possible, planting disturbed areas, preferably with native trees, shrubs or grasses, and covering such areas with mulch to prevent erosion and to help seeds germinate. If there is insufficient time remaining in the growing season, the site should be stabilized (e.g., cover exposed areas with erosion control blankets to keep the soil in place and prevent erosion) and vegetated the following spring.

181. The construction contractor for the site will be required to submit a plan outlining the specific sediment management controls that will be put in place.

182. Taking into consideration the above mitigation measures and the high-energy receiving environment of the Naryn River which will encourage rapid plume dissipation, potential impacts of turbidity are not predicted to be significant.

Discharge of Treated Wastewater Effluent to Surface Water 183. Domestic and institutional wastewater produced on campus will be treated on-site prior to discharge to the Naryn River. The specific technologies used by the wastewater treatment plant will be determined during the detailed engineering stage of the Project. However, as discussed in Section 5.2.1, UCA has established stringent objectives for effluent discharge criteria. By conforming with these specifications, the Project is not anticipated to result in significant adverse impacts to surface water quality. The performance of the wastewater treatment system will be verified through a discharge monitoring program.

Additional Releases to Surface Water

184. The environmental management and evaluation framework for the University (see Section F) includes a variety of measures to prevent inadvertent releases to the environment, including surface water. While complete avoidance of such releases is seldom possible, the environmental management plan will effectively detect and mitigate any associated impacts. For example, operation of heavy equipment and bulk fuel facilities may result in the release of small quantities of petroleum hydrocarbons (lubricants and fuel) to the terrestrial environment. Such releases could, theoretically, migrate to surface waters. However, the spill detection, reporting and mitigation elements of the environmental management plan will greatly reduce the potential and severity of impacts to surface water.

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185. In addition to inadvertent releases (i.e., spills), the Project will include the deliberate use of materials that have some potential to affect surface water quality. Specifically, de-icing agents may be required during the winter months to ensure the safety and functionality of campus roads. Potential environmental impacts will be considered during the selection of de-icing agents and their use will be minimized. Supplies of de-icing agents, as well as snow stockpiles ploughed from roads, will be managed in a fashion that minimizes the potential for direct releases to the surface water environment.

186. Although additional materials that could affect water quality will be present on the site, such materials will be subjected to a variety of controls that limit the possibility of releases to the surface water environment. For instance, laboratory reagents and wastes will be managed according to the strict protocols described in Section D.5.2 and, as a result, there will be no opportunities for potentially toxic materials to be discharged to surface waters.

187. To summarize, some potentially deleterious materials required for the construction and operation of the University may be released to the environment. However, the environmental management plan has been designed to detect and effectively mitigate such releases to the point where significant impacts to water quality are not expected. Impacts to the Naryn River, if any, would be negligible.

D.6 Biology

188. This section describes the predicted impacts of the Project on Biology, which comprises two sub- components: Aquatic Biology and Terrestrial Biology.

D.6.1 Aquatic Biology

D.6.1.1 Summary of Interactions

189. As indicated in Table D.3-1, there are a number of Project-environment interactions that, in theory, could result in adverse impacts to aquatic species and habitat. The types of impacts and associated activities are as follows:

Turbidity in Surface Water

• Site clearing and earthworks (Construction Phase); and

• Road construction and paving (Construction Phase).

Discharge of Treated Wastewater Effluent to Surface Water

• Wastewater treatment and discharge (Operation Phase).

Additional Releases to Surface Water

• Transportation (Construction and Operation Phases); and

• Fuel management and maintenance (Construction and Operation Phases).

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D.6.1.2 Assessment of Potential Impacts and Mitigation

190. With the exception of impacts to surface water quality, there are no other mechanisms by which the Project will interact with aquatic biology. As indicated in Section D.5.2, none of the potential impacts to water quality are anticipated to be significant. Specifically, no concerns have been identified related to: turbidity, discharge of treated wastewater effluent and additional releases to surface waters.

191. In the absence of significant impacts to water quality, no impacts to aquatic biology are predicted and additional mitigation is not required. This will be verified on an opportunistic basis during the implementation of the Environmental Monitoring Program for the Project. In the unlikely event that potential impacts to the aquatic environment are observed, case-specific corrective actions will be developed.

D.6.2 Terrestrial Biology

D.6.2.1 Summary of Interactions

192. As indicated in Table D.3-1, there are a number of Project-environment interactions that have a potential to result in impacts to Terrestrial Biology. The types of impacts and associated activities are as follows:

Surface Disturbances • Site clearing and earthworks (Construction Phase); and • Road construction and paving (Construction Phase).

Dust • Site clearing and earthworks (Construction Phase); • Construction of surface infrastructure (Construction Phase); • Road construction and paving (Construction Phase); and • Transportation (Construction Phase).

Animal Mortality • Transportation (Construction and Operation Phases); and • Waste generation and management (Operation Phases).

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D.6.2.2 Assessment of Potential Impacts and Mitigation

Surface Disturbances 2

193. Section C.4 describes the baseline terrestrial habitat and species that are present in the general vicinity of the site. Although physical changes to portions of the site will permanently affect terrestrial habitat (within a limited footprint) this habitat is not considered to be unique. Taking into consideration the general abundance of similar habitat elsewhere within the local area, the limited reductions that might occur are considered to be very minor.

194. With regard to species, the presence of heavy equipment and people during the implementation of the Project represents a potential disturbance to individual animals that might otherwise use the site. Depending on the circumstance and the species involved, such disturbances could result in displacement of animals to other off-site habitats. While this may have an adverse affect on individual animals, no impacts to local species are anticipated. Some of the displaced animals may return to the site during quieter periods (e.g., post construction), thereby exposing them to other risks such as vehicle deaths. Such impacts are discussed separately below.

195. Taking the above factors into consideration, surface disturbances associated with the Project will not result in significant adverse impacts to terrestrial biology.

Dust

196. Respiration of airborne particulate matter and deposition on plants are the primary mechanisms by which dust can have an impact on terrestrial biology. As described in Section D.4.1, a variety of mitigation measures will be implemented to limit the impact of dust on air quality. While the measures are intended primarily to limit the respiration of particulate matter by humans, they will also minimize dust impacts to animals (respiration) and plants (deposition).

197. With the proposed mitigation measures in place, the Project will not result in significant dust impacts to terrestrial biology.

Animal Mortality

198. Despite the active presence of humans during the Construction and Operation Phases, some wild and domesticated animals will continue to use the site. Under most circumstances, the Project will pose limited risks to animals. The only notable exception is vehicle transportation on campus roads which could result in animal fatalities. This potential will be mitigated through the posting and enforcement of reduced vehicle speeds within the campus (50 km/h). In the unlikely event that animal mortality becomes a regular concern, consideration will also be given to other controls (e.g., fencing portions of the site).

199. In addition to traffic impacts, animal mortality may be required as a means of pest control. For example, the presence of municipal waste on site could serve as an attractant for certain species. This can

2 Note – Although surface disturbances include noise, such impacts have already been evaluated in Section D.4.2. That analysis also applies to terrestrial biology (i.e., noise disturbances).

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be effectively mitigated through the design process and use of appropriate housekeeping practices such as those associated with the solid waste management program. There will also be a prohibition on the feeding/luring and hunting of animals.

200. Taking into consideration the nature of activities on the site and the various mitigation measures that will be in place, the Project is not expected to result in significant animal mortality concerns.

D.7 Geology and Hydrogeology

201. This section describes the predicted impacts of the Project on Geology and Hydrogeology.

D.7.1 Geology and Seismicity

D.7.1.1 Summary of Interactions

202. As shown in Table D.3-1, there are no Project-environment interactions that have the potential to result in adverse impacts to geology and seismicity.

D.7.1.2 Assessment of Potential Impacts and Mitigation

203. In the absence of Project-environment interactions, the Project will not have any adverse impacts on geology and seismicity. No mitigation is required.

D.7.2 Hydrogeology

D.7.2.1 Summary of Interactions

204. The Project-environment interaction matrix identified only one potentially adverse interaction involving hydrogeology:

Local Supply

• Water treatment and usage (Operation Phase).

D.7.2.2 Assessment of Potential Impacts and Mitigation

Local Supply (Groundwater)

205. The Project’s water requirements will be met by groundwater wells. Further hydrogeological studies will be undertaken during detailed design. This will include taking into consideration the use of technologies and approaches that reduce water requirements to the extent feasible. Similarly, the final selection of well locations will consider other demands that are being placed on the local reservoirs. If the abundance of local groundwater resources is determined to be a concern, alternative water sources will be considered. As a result, the Project will not result in significant impacts to local groundwater supplies.

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D.8 Physical and Cultural Resources

206. This section describes the predicted impacts of the Project on Physical and Cultural Resources.

D.8.1 Physical and Cultural Resources

D.8.1.1 Summary of Interactions

207. As shown in Table D.3-1, there are no Project-environment interactions related to physical and cultural resources. This is attributable to the fact that there are no physical and cultural resources (e.g., archaeological sites) within the footprint of the campus.

D.8.1.2 Assessment of Potential Impacts and Mitigation

208. In the absence of Project-environment interactions, the Project will not have any adverse impacts on physical and cultural resources. However, while there are no known physical and cultural resources on the site, there remains a possibility that such resources will identified in the future. As a precautionary measure, the following mitigation will be put in place during the Construction Phase to limit any potential impacts:

• Ensuring that all archaeological finds are reported to relevant authorities; • Instructing all employees to not knowingly remove, disturb or displace any archaeological specimen or site; and • All activities in the vicinity of a potential archaeological find will be put on hold until such time that appropriate direction is provided by authorities.

D.9 Socio-Economics

209. This section describes the predicted impacts of the Project on Socio-economics, which comprises three sub-components: Population and Economic Base; Community Infrastructure and Resources; and Current Land Use.

D.9.1 Population and Economic Base

210. Prior to discussing potential adverse impacts of the Project on the Population and Economic Base, a brief overview of the Project’s positive impacts is warranted.

211. Economic impacts on the region as a result of the University’s operations will be positive and include employment opportunities for the local population. Across all three campuses, UCA is expected to employ almost 1,200 individuals by the first year of operations, including faculty, academic staff and senior management staff. More than 90% of UCA’s staff will be from the Central Asian region. Opportunities to have maximum induced positive impacts are also being explored including sourcing of goods and materials for construction as well as goods and services for the University’s operations.

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212. Positive economic impacts include an increase of opportunities for local construction organizations and consequently greater revenues. The forecasted total investment for the development of the Naryn campus will be in excess of $250 million over the coming years. In 2009, a total of 168 people, including 156 Kyrgyz nationals, were directly employed in construction related works in Naryn. At least 50 additional Kyrgyz nationals were provided indirect employment.

213. In addition to direct employment and contracting opportunities for goods and services, the primary mandate of the University is to stimulate the socio-economic capacity of the region. Through the delivery of higher education programmes that are designed to meet the unique needs of Central Asian economies, the capacity of human resources will increase, thereby resulting in long-term positive impacts.

214. The positive economic impacts associated with the Construction and Operation Phases of the UCA campuses will be tracked by an Economic Fallout group.

D.9.1.1 Summary of Interactions

215. As shown in Table D.3-1, all Project activities have the potential to interact with the local Population and Economic Base. The potential impacts are associated with the local supply of human resources.

D.9.1.2 Assessment of Potential Impacts and Mitigation

Local Supply (Human Resources)

216. The Project will clearly result in a significant net positive impact on the Population and Economic Base. Without diminishing the value of this contribution, there is a theoretical potential that some adverse impacts would be associated with increased competition for human resources. For example, in the case of other projects, increased demand for human resources can result in adverse impacts to other businesses and institutions that will no longer have access to the limited pool of human resources. This is particularly true in situations where highly specialized skills are in demand in market places with high employment rates.

217. This theoretical risk does not apply to the University. First, based on the low employment rate in the vicinity of Naryn (70 % of able-bodied residents are employed), there is ample residual capacity in the regional human resource pool. As a consequence, even if all positions are filled with local candidates, additional human resources will be available to staff other initiatives. On this basis, the Project is not predicted to have an adverse impact on the local supply of human resources. To the contrary, the University will result in significant improvements to the overall socio-economic capacity of the region.

D.9.2 Community Infrastructure and Resources

218. Community Infrastructure and Resources are goods and services that local residents rely on to support their livelihoods and lifestyles. Project activities that introduce competition for goods and services that are in short supply have the potential to result in adverse impacts on local residents. Such

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impacts can materialize in the short-term (e.g., use of electricity) or long-term (e.g., depletion of non- renewable resources).

219. In many respects, the Project has been designed to minimize the demands on external goods and services, where appropriate. For example, wastewater generated on the campus will be treated in dedicated on-site facilities, thereby limiting stresses on Community Infrastructure and Resources. These “built-in” forms of mitigation will assist in minimizing adverse impacts to community infrastructure and resources. At the same time, the University itself will make important positive contributions to Community Infrastructure and Resources through the provision of new facilities and services that will be available for use by local residents.

D.9.2.1 Summary of Interactions

220. As shown in Table D.3-1, a number of Project activities are likely to interact with the local supply of Community Infrastructure and Resources. These interactions have been sub-divided into the following categories to recognize the different types of impacts that might occur.

Local Supply (Materials) • Construction of surface infrastructure (Construction Phase); • Road construction and paving (Construction Phase).

Local Supply (Electricity)

• Use of grid electricity (Operation Phase).

Local Supply (Waste Disposal Capacity)

• Waste Generation and Management (Operation Phase).

Local Supply – Transportation Infrastructure

• Transportation (Construction and Operation Phases).

D.9.2.2 Assessment of Potential Impacts and Mitigation

Local Supply (Materials)

221. Many of the materials that will be used in the construction of University infrastructure will be sourced from Naryn and the surrounding region. This is likely to include aggregate, cement, timber and steel that are required inputs for buildings, roads and other infrastructure. Procurement strategies that result in positive economic fallout for the local communities are being considered. As a result, the Project is not anticipated to result in significant impacts to the local supplies of materials. This will be verified as the Project advances through the detailed engineering phase.

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Local Supply (Electricity)

222. As described further in Section B.5.3, the peak electricity demand of the Project is approximately 3 MW, subject to detailed design review and value engineering [13]. It is currently estimated that at full capacity, UCA will require 9 MW of heat at peak load. The local generation, transmission and distribution system has sufficient capacity to meet this demand and UCA is currently discussing approaches to connect to the local grid via the transformer station immediately adjacent to the west of the site. The majority of grid power is sourced from hydro resources. On this basis, the Project is not expected to have a significant impact on the local supply of electricity.

223. Notwithstanding the expected reliability of the local power grid, there may be periods when the electricity supply has unforeseen interruptions (due to equipment failure, for example). During such periods, campus electricity demands will be met through stand-by diesel generators located on-site.

Local Supply (Waste Disposal Capacity)

224. The proposed waste management program for the University includes a number of source control, waste reduction and recycling initiatives that will assist in minimizing the amount of waste generated on campus (see Section D.6.5). These “built in” forms of mitigation will result in substantive reductions to the amount of waste requiring disposal in off-site facilities (e.g., landfills). Taking into consideration these reductions, as well as the small University population relative to the population of Naryn, the incremental off-site waste disposal requirements of the University are assumed to be relatively minor. On this basis, the Project is not predicted to result in a significant impact to local waste disposal capacity. This conclusion will be revisited during the detailed engineering phase.

Local Supply (Transportation Infrastructure)

225. To facilitate access to and within the campus, the Project will include a network of site roads and upgrades to the existing arterial roads that service the site. The new road network has been designed to accommodate existing traffic requirements, as well as any incremental demand associated with future University operations. Once implemented, the new road network is predicted to result in an overall improvement in the effectiveness of the local transportation system.

226. With regard to the Construction Phase, some activities may result in local traffic disruptions as materials and construction workers are mobilized to the site. These disruptions are predicted to be minor and of limited duration. Within the context of the overall improvements that will be achieved by the Project, significant adverse impacts to the effectiveness of the existing transportation system are not expected.

D.9.3 Current Land Use

227. The Naryn campus will be constructed on lands that are currently used for other purposes (primarily agriculture). The presence of the University will result in changes to these land uses and, therefore, an evaluation of potential adverse impacts associated with these changes is warranted.

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D.9.3.1 Summary of Interactions

228. As shown in Table D.3-1, all Project activities will result in “Surface Disturbances” that have the potential to affect Current Land Use, particularly during the long-term (permanent) operation of the University.

D.9.3.2 Assessment of Potential Impacts and Mitigation

Surface Disturbances

229. On July 2, 2004, UCA was granted a total of 251.58 hectares (ha) of land through Government Decree #493. The majority of land transferred to UCA was owned by the State, with the exception of 7.5542 ha belonging to a variety of private owners (0.3092 ha belonging to seven households, 0.045 ha belonging to a private fuel station, and 5.2 ha belonging to a private farm). In total, seven households were resettled resulting in 26 affected persons. While household occupants had to relocate, the resettlement did not result in the loss of income generating activities. Affected households generally depended on multiple sources of income, such as rearing of livestock and labour wages, and these sources of income were not affected by the land transfer. The private farm that was located on the site was also displaced, but at the time of the land transfer to UCA, the land was not used by the owner. The owner of the farm was compensated adequately to purchase a new home in the center of Naryn.

230. Land procurement was based on a willing seller-willing buyer basis. The price for land and other assets was equivalent to or higher than fair market value price. The purchases were considered private transactions and were carried out and documented in accordance with national laws and regulations. All the affected households were able to buy new houses with access to clean drinking water and to invest in businesses and they continued to work at the same places of employment as before the relocation. UCA also compensated land tenants of agricultural land for the loss of income opportunity. The owner of a small fuel station improved and enlarged his business and now owns two fuel stations in the town of Naryn. Job opportunities were also provided not only to the affected households, but also to citizens living close to the UCA campus.

231. As evidenced above, UCA has taken a proactive approach to mitigating the impacts of the Project to existing land users. Within this context, the Naryn campus is not expected to have significant adverse impacts on current land users.

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D.10 Cumulative Effects

D.10.1 Methodology

232. As noted in Sections D.4 through D.9, the Construction and Operation of UCA’s Naryn campus is not expected to result in any significant adverse impacts to the environment. The absence of significant impacts is largely due to the inherently low-impact nature of the Project (i.e., an academic institution). The environmental performance of the Project will be further strengthened through the implementation of a broad suite of mitigation measures.

233. While these mitigation measures will serve to minimize the magnitude, physical extent and/or duration of Project, some impacts cannot be eliminated entirely. As a consequence, the Project is likely to result in some minor “residual” impacts. Although these impacts are not significant by themselves, there is a potential that they could contribute to cumulative effects, when combined with the impacts of other projects.

234. Cumulative effects are defined as those Project impacts that are likely to result from a project in combination with the impacts of other past, existing and reasonably foreseeable projects. Such effects will only occur if the residual impacts associated with UCA’s Naryn campus and those of another development meet all of the following conditions:

1. The effects are similar in nature; 2. They overlap spatially; and 3. They overlap temporally.

235. The relationship between these requirements is illustrated in Figure D.10.1-1.

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Figure D.10.1-1 Scope of Potential Cumulative Effects

Scope of Cumulative Effects Assessment

236. The first step in evaluating potential cumulative effects is to identify the residual impacts from the Project, which are summarized in Table D.10.1-1. As indicated in the table, none of the Project impacts are anticipated to be significant. However, the Project is likely to result in minor (i.e., non- significant) residual impacts after appropriate mitigation measures have been implemented. Such impacts are the focus of the cumulative effects assessment and include impacts to the following environmental components:

• Air Quality;

• Noise / Vibration;

• Surface Water Quality;

• Aquatic Biology; and

• Terrestrial Biology.

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237. Potential cumulative effects to each of these environmental components are discussed in the following section.

Table D.10.1-1 Summary of Residual Project Impacts that Could Contribute to Cumulative Effects

Considered for Significant Residual Environmental Interactions with Potential Impacts Impacts after Component the Project? Cumulative Predicted? Mitigation? Effects?

Air Quality Yes No Yes Yes

Noise/Vibration Yes No Yes Yes

Hydrology Yes No No No

Surface Water Quality Yes No Yes Yes

Aquatic Biology Yes No Yes Yes

Terrestrial Biology Yes No Yes Yes

Geology/Seismicity No No No No

Hydrogeology Yes No No No

Archaeological Resources No No No No

Landscape and Vis. Desc. No No No No

Pop. and Economic Base Yes No No No

Comm. Infras. and Yes No No No R Current Land Use Yes No No No

D.10.2 Evaluation of Potential Cumulative Effects Air Quality

238. The site of the Naryn campus is in a relatively undeveloped area with activities that are generally limited to semi-rural residential properties and local transportation activities. Some of these activities are likely to result in atmospheric emissions that are similar to those that will be produced at the Naryn campus. These emissions, which include dust, combustion exhaust and vapours, are expected to continue throughout the Construction and Operation Phases of the Naryn campus.

239. Based on the fact that the Naryn campus and other activities will result in similar emissions, at the same time and in the same general vicinity, there is a theoretical potential that cumulative effects will

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occur. However, taking into consideration the minor contributions that the Project and other activities will individually have on the degradation of air quality, a significant cumulative effect is not anticipated.

Noise / Vibration

240. The discussion presented above for air quality also applies to noise and vibration. Specifically, any cumulative noise and vibration effects are not anticipated to be significant.

Surface Water Quality

241. Discharge of treated wastewater effluent is the primary source of potential impacts that the Naryn campus could have on surface water quality. Conformance with the water quality standards presented in Section D.5.2 will assist in minimizing any potential adverse impacts to the water quality of the Naryn River. There is, however, a potential that the residual minor impacts from the Project will combine with similar impacts of other activities that discharge to the river. Such activities include sanitary discharges (treated and untreated) and stormwater runoff.

242. The performance of the Naryn campus wastewater treatment facility will be monitored to ensure effluent water quality standards are met. Similarly, sampling will also be conducted in the Naryn River to confirm that significant cumulative effects are not occurring.

Aquatic Biology

243. Interactions between the Project and aquatic biology are solely via surface water quality. The discussion presented above for surface water quality therefore applies to aquatic biology as well.

Terrestrial Biology

244. As discussed in evaluation of Project-specific effects presented in Section D.6.2, the Project is not expected to result in significant impacts to terrestrial biology on or in the vicinity of the site. This conclusion was based on the incremental impacts that the Project might have when superimposed over current conditions. With the exception of the new Naryn campus, such conditions are not anticipated to change substantively in the foreseeable future. For example, UCA is unaware of any plans for major developments on the lands immediately adjacent to the Naryn campus. In the absence of such developments, it is unlikely that significant impacts to terrestrial biology will occur.

D.11 Effects Assessment Summary

245. As described in Sections D.4 to D.9 and summarized in Table D.10-1, the findings of the effects assessment are as follows:

1. The construction and operation of the Naryn campus will interact with various components of the environment. Each Project-environment interaction represents a theoretical potential for adverse impacts.

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2. A variety of mitigation measures will be implemented to effectively minimize and/or eliminate potential adverse impacts that the Project might cause. 3. Although there will be some residual impacts after mitigation, none of the Project impacts are anticipated to be significant. 4. When combined with the impacts of other developments, none of the residual impacts are anticipated to result in significant cumulative effects to the environment.

246. Based on the above, it has been concluded that the University of Central Asia’s Naryn campus will not have significant adverse impacts on the environment. The results of the IEE support ADB’s Category B classification of the Project.

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E. Public Consultations & Disclosure and Grievance Redress Mechanism

E.1 Consultations

247. Extensive consultations have been held in the region since the Project’s conceptualization, with the earliest formal consultations occurring in 2002. In March 2005, focus groups were held to discuss the facilities program. The process involved discussions with a total of 816 individuals: 401 in Kazakhstan, 187 in the Kyrgyz Republic and 228 in Tajikistan. Most of the respondents were from the towns and regions where the university campuses would be located, while 130 respondents resided in either Almaty, Bishkek, or Dushanbe. The study was carried out by the Schools of Professional and Continuing Education in Khorog, Naryn and Tekeli. Respondents were grateful for being consulted and occasionally expressed surprise that someone would make an effort to solicit their views.

248. Interviews were conducted with current undergraduate and graduate students (107 in total) and grades 10 or 11 high school students (145). The views of a large number (233) of educators were also solicited including university administrators and faculty, directors of specific services such as sports facilities, experienced secondary school teachers and senior staff in local and regional government educational departments. The study was also informed by the observations of numerous public authorities, i.e. elected and appointed town and regional government officials, police, fire chiefs, directors of sports facilities, medical personnel and public health officials, heads of museums, etc. (132). A total of 159 members of the communities where the campuses are located were consulted including private business owners, farmers, artisans, journalists, youth organizations, and religious leaders. The views of Aga Khan Development Network (AKDN) and UCA employees were also considered (31) and prominent intellectuals and visual and performing artists in Bishkek and Dushanbe (9) were also consulted. Women comprised 56% of the total respondents, in-line with their gender representation in higher education. Consultation processes have been documented and recorded and the following sections describe some of the elements.

E.2 Comments and Concerns

249. The proposed facilities program for UCA differs radically from the typical Soviet higher education experience. In general, there was excitement about the potential contribution of UCA to the intellectual and cultural life of Central Asia and to regional economic development. While the results of the consultation progress are documented in the 2004 Socio-Cultural Study report prepared by Sasaki Associates, the key comments relevant to ADB’s Safeguard Policy Statement are discussed below. The final facilities program was refined in response to the Socio-Cultural Study.

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E.2.1 Gender Consideration

250. The majority of the respondents thought that the proposed recreational and athletic facilities were excellent. During the consultation, women respondents felt strongly that fitness room hours should be separate for men and women. Most respondents also agreed that gender segregation was desirable to some degree in the residences with the module being the basic unit of separation (separate use of common rooms and pantries). These comments will be considered in the operational plans for the UCA recreational facilities.

E.2.2 Public Transportation Facilities

251. One focus group leader reported that “the number of parking spaces drew laughter”. Bike stands were thought to be more useful, and in particular, bike sheds to better protect against widespread theft. Student respondents and townspeople assumed there would be adequate public transportation connection to the facilities. These comments have also been taken into consideration.

E.2.3 Meandering Flocks

252. A number of respondents wondered how the University parklands would be protected from meandering flocks of goats and sheep. Khorog botanical garden employees provided an original suggestion: instead of mounting steel barred fences, they suggested creating impassable obstacles from thorny bushes.

E.3 Planned Disclosure and Consultation during Implementation

253. UCA’s mandate entails contributing to the economic and social development of the region by creating jobs, increasing the demand for local goods and services, and providing the skills and knowledge to enable students to take advantage of new economic opportunities. Consultations are conducted on an ongoing basis, particularly on issues that may affect local populations.

E.4 Grievance Redress Mechanism

E.4.1 Communication Channels

254. UCA will provide a number of formal and informal communication channels through which comments can be received. These include:

• UCA Website – UCA’s home page provides a Contact us link through which members of the public can submit an e-mail to the University of Central Asia. Any grievances through UCA’s website will be forwarded by the UCA Central Administration to the appropriate department. • On-site Contacts – A notice board will be posted at each site with the telephone, facsimile, mail and e-mail contact details through which comments can be received. These notice boards will be placed in a visible area known to the public. Notices will be displaced in Russian, English and the local language of each region.

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E.4.2 Preventing Grievances

255. Open dialogue and communication with stakeholders will be maintained throughout the construction period and continue through the University’s operations. Provision of information about Project activities on a regular basis can play a role in preventing misunderstandings or inconsistent information. Throughout the Project’s construction period, an annual Sustainability Report will be developed that specifically reports on the progress of the social and environmental safeguards being implemented.

E.4.3 Grievance Documentation and Reporting Procedures

256. Once received, grievances will be registered within a centralized database and classified according to the site location and the type of issue raise. The parameters that will be logged include:

• the assigned reference number for the complaint; • the name of the affected person (if provided); • the site to which the grievance applies; • the affected person’s contact details; • the date upon which the grievance was received; • the channel through which the grievance was received; • the individual at UCA assigned to addressing the complaint; • the action taken to address the issue; • the date upon which the issue was resolved; and • the date upon which the affected person was notified regarding resolution of the issue.

257. An Environmental Ombudsman will be established and will report on a monthly basis to UCA’s Executive Committee regarding grievances received and the status of those grievances. An initial response to the affected party to acknowledge receipt of the comment will be provided within a one week period, and UCA will seek to address grievances within a 30 day period from the date of receipt. If additional time is required to address the issue, the affected party will be notified accordingly.

E.4.4 Grievance Redress Management

258. Figure E.4.4-1 shows the management structure for the grievance redress process. All of the facilitators of grievances will be responsible for logging the complaint. The completed logs will be sent to the Grievance Coordinator who will maintain a central database and inform the appropriate senior managers for construction and planning purposes. Resolution will be done through delegation of responsibilities by senior management. Updates on the Grievance Redress Mechanism (GRM) will be provided on a monthly basis to the UCA Executive Committee.

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Figure E.4.4-1 Management Structure for Grievance Redress Process

UCA Administrator

Site Representative Tekeli UCA Environmental Ombudsman Executive Site Committee Representative Naryn

Site Representative Khorog

COMPLAINTS BY INDIVIDUALS GROUPS OR INDIVIDUALS BY COMPLAINTS Receipt of Complaint Resolution Enforcement

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F. Environmental Management and Evaluation Framework

259. A comprehensive Environmental Management and Evaluation Framework (EMEF) will be established to ensure the environmental performance of the Project. The EMEF will include the following two major components:

1. Environmental Management Plan – To mitigate potential environmental impacts associated with the construction and operation of the Naryn campus; and 2. Environmental Monitoring Plan - To verify that the environmental performance of the Project is as predicted. In the event that environmental monitoring identifies adverse impacts that were not predicted, additional forms of environmental management (i.e., mitigation) will be put in place.

260. As the Project advances through the detailed design and engineering phase, a formal, stand-alone document describing the EMEF will be prepared. The EMEF will integrate all objectives, policies practices and procedures into a single document that will guide environmental management on the campus. The overall objective of the EMEF will be to provide effective guidance for the development and implementation of actions that assist the UCA to deliver on its environmental commitments.

261. Prior to developing such a document, a number of detailed design studies are required. These studies are currently being initiated by the UCA and include:

• Water Supply System – source, treatment and distribution; • Wastewater Treatment - treatment facility and characterization of the receiving environment; • Solid Waste Management – diversion and disposal strategy; • Energy Systems – electricity / heat sources and supply (including alternative sources); and • Hazardous Wastes - development of waste management plans for laboratory practices.

262. The formal EMEF will be prepared in parallel with the above studies. The EMEF will clearly define the implementation details for the mitigation measures. This will include: assigning responsible parties (e.g., UCA, contractors and independent consultants), Standard Operating Procedures (SOPs), performance targets, documentation requirements, etc.

263. The major components of the EMEF are described in the following sections.

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F.1 Environmental Management

F.1.1 Mitigation Measures

264. As described throughout Section D, a variety of mitigation measures have been identified to address potential adverse impacts associated with the Project. These measures, which are summarized in Table F.1.1-1, will form the backbone of environmental management on the site. Collectively, the measures will prevent all potentially significant environmental impacts.

265. The implementation of the mitigation measures will be the responsibility of the Environmental Management Office (refer to Section F.3 Implementation Arrangements). All of the engineering design safeguards shown in Table F.1.1-1 including equipment specifications, wastewater treatment system components, fencing, storage containers, etc. will be in places or specified by the end of the detailed design phase such that the appropriate systems are implemented during the construction of UCA’s facilities. Operational controls, scheduling, and maintenance will be a mandatory requirement of construction contractors and all construction works will be required to be carried out in accordance with the Environmental Management Plan. Ensuring the execution of the EMP requirements will be the responsibility of the Environmental Management Office.

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Table F.1.1-1 Summary of Management Plan Mitigation

Environmental Potential Description of Mitigation Component Impact Type

• Surface Applications – To reduce dust emissions, haul roads and areas where earthworks are to be carried out will receive water applications. The application of chemical dust suppressants (e.g., calcium chloride) will also be considered in situations where water provides insufficient dust control. If required, the application of such materials will be consistent with standard environmental management practices. Dust • Work Controls – In the event that surface applications are not sufficient to control dust emissions, alternate measures will be put in place. This could include staging activities during periods when the impacts of emissions and/or dispersion can be minimized. The need for additional work controls such as truck covers and temporary surface stabilization will be determined on a case-by-case basis.

• Equipment specifications – Emissions performance will be considered during the selection process for stationary combustion equipment (e.g., back-up generation sets). Selected contractors will also be required to use mobile construction equipment equipped with appropriate emissions controls. Air Quality Combustion • Equipment and vehicle maintenance – Regular scheduled inspections and maintenance will be performed to Emissions ensure optimal performance.

• Operational controls – Where possible, reductions in the number of construction vehicles and/or periods of operation (limiting idling periods, number of vehicles operating simultaneously, etc.).

• Material specifications – To the extent feasible and available, low volatility products will be used preferentially. Vapours The use of water-based paints is an example. • Bulk fuel storage specifications – Best practices to minimize product volatilization and release will be applied.

• Design – Potential odour concerns will be adequately addressed through the selection of appropriate Odour technologies and location of facilities. Such considerations will be integral to the detailed design process for the wastewater and solid waste management facilities/programmes.

• Equipment specifications - All mobile heavy equipment will be equipped with industrial noise suppression devices and will be maintained in good working order. Stationary combustion equipment will be designed and Noise / Vibration Noise / vibration located to minimize noise impacts. For example, the back-up electricity generators will be equipped with appropriate noise suppression devices and will be strategically located to reduce potential impacts to sensitive receptors.

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Environmental Potential Description of Mitigation Component Impact Type • Maintenance - Inspection of the equipment that is a source of noise and vibration and equipment maintenance and adjustment as required.

• Operational controls - To the extent feasible, efforts will be made to schedule activities so as to minimize any potential noise impacts (e.g., work at night will be minimized) and to limit the extent to which Project traffic passes through community areas.

Hydrology Site Drainage • Design – The Project will be designed to minimize changes to site drainage.

• Operational Controls - When carrying out earthwork or vegetation clearing activities in the vicinity of a drainage course or a body of water, silt fences, floating silt curtains and/or containment berms will be used, as appropriate, to prevent the release of sediment into water.

• Scheduling - Areas subject to potential erosion will remain open for the minimum period necessary to implement the required work. In addition, work will be avoided during wet and rainy periods in areas where erosion poses a Turbidity in Surface problem. Water • Material management - Properly containing and stabilizing material stockpiles to prevent sediment from entering any water body.

• Re-vegetation - Where possible, planting disturbed areas, preferably with native trees, shrubs or grasses, and covering such areas with mulch to prevent erosion and to help seeds germinate. If there is insufficient time remaining in the growing season, the site should be stabilized (e.g., cover exposed areas with erosion control Water Quality blankets to keep the soil in place and prevent erosion) and vegetated the following spring. Discharge of • Design and Operational Controls – The wastewater treatment plant will be designed and operated to achieve the treated wastewater effluent discharge criteria established for the Project (see Tables D.5.2.1-1 and D.5.2.1-2). effluent

• Design – All facilities will be designed in accordance with standard best management practices to reduce the probability and severity of releases to the environment. Examples include: - Fuel in bulk quantities will be stored in double-walled containers. Additional releases - Fuel dispensing areas will be lined and a sump will be dug to collect any spills that may occur. to surface water - De-icing agents will be stored and used in a fashion that minimizes potential releases to surface waters.

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Environmental Potential Description of Mitigation Component Impact Type • Operational Controls – A series of initiatives and operational procedures will be put in place to prevent and respond to potential releases to the environment. These procedures include:

- Emergency response plans will be in place to deal with fuel spills and other types of unauthorized discharges. Separate plans will be prepared for the Construction and Operation Phases. - Spill kits will be available at fuel storage and dispensing facilities. - Spill response training will be provided to personnel. - Daily inspection of vehicles and fuel storage facilities will be carried out.

With the exception of impacts to surface water quality, there are no other mechanisms by which the Project will Aquatic Biology Via Water Quality interact with aquatic biology. As a consequence, the mitigation measures for water quality also apply to aquatic biology. No additional mitigation is required.

Surface disturbances associated with the Project are predicted to be minor (displacement to other off-site habitats). Surface Other forms of mitigation will serve to minimize the impacts associated with such disturbances (e.g., mitigation that Disturbances addresses air and water quality). Further mitigation is not required.

The dust mitigation measures that will reduce Project impacts to air quality also apply to terrestrial biology. Further Dust mitigation is not required.

• Design – Campus designs will discourage animals from using the sites. For example, depending on the Terrestrial Biology effectiveness of other controls, consideration will be given to fencing portions of the site. Potential animal attractants will also be managed as appropriate (e.g., collection and consolidation of organic wastes).

• Operational Controls – Animal mortality will be mitigated through the following procedures: Animal Mortality - Posting and enforcement of reduced vehicle speeds within the campus. - Appropriate housekeeping practices such as those associated with the solid waste management program. - Prohibition on the feeding/luring and hunting of animals.

Geology and None identified No potential impacts have been identified therefore no mitigation is required. Seismicity

Local supply No potential impacts are anticipated. This will be verified during the detailed design phase and mitigation measures Hydrogeology (groundwater) will be selected as appropriate.

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Environmental Potential Description of Mitigation Component Impact Type

• Operational Controls - Physical and cultural resources have not been identified on the site (e.g., archaeological sites). As a precautionary measure, the following mitigation will be put in place to limit any potential impacts:

Physical and - Ensuring that all archaeological finds are reported to authorities with jurisdiction; Cultural None identified - Instructing all employees to not knowingly remove, disturb or displace any archaeological specimen or Resources site; and - All activities in the vicinity of a potential archaeological find will be put on hold until such time that appropriate direction is provided by authorities.

Population and Local Supply The Project will not have any adverse impacts on the local supply of human resources. To the contrary, it will Economic Base (Human Resources) expand and enhance the capacity of the local human resource pool. On this basis, no mitigation is required.

• Procurement Strategy - Procurement strategies that result in positive economic fallout for the local communities Local Supply are being considered. Through this process, potential impacts to the local supply of materials will be avoided. (Materials) This will be verified as the Project advances through the detailed engineering phase.

Local Supply The Project is not expected to have any adverse impacts on the local supply of electricity. On this basis, no (Electricity) mitigation is required. Community Infrastructure and • Design - The proposed waste management program for the University includes a number of source control, Resources Local Supply waste reduction and recycling initiatives that will assist in minimizing the amount of waste generated on campus (Waste Disposal (see Section D.6.5). These “built in” forms of mitigation will result in substantive reductions to the amount of Capacity waste requiring disposal in off-site facilities (e.g., landfills). This conclusion will be revisited during the detailed engineering phase.

Local Supply Although minor impacts will occur during the Construction Phase, the Project will result in an overall improvement to (Transportation local transportation infrastructure. On this basis, no mitigation is required. Infrastructure)

Surface Compensation – Previous land-users on the site have been formally compensated (refer to Section D.9.3.2 for Current Land Use Disturbances details). No additional mitigation is required.

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F.2 Monitoring

F.2.1 Monitoring Measures

266. A series of design assessments and modeling initiatives will be used to establish the framework for on-site monitoring of emissions. During the construction phase, emissions are expected to mainly involve dust, noise, and erosion. Given the nature of the work, the degree to which these emissions occur is not expected to be significant. During the construction phase, monitoring will consist of on-site visual inspections to ensure that mitigation practices are being implemented and unforeseen events are managed and controlled.

267. During operations, emissions from the Project will be extremely limited. Releases include continuous release of treated wastewater and potentially periodic short-term air emissions associated with operation of back-up diesel generators. Mobile emissions will be consistent with use of the site by students, faculty, and other stakeholders. Based on the nature of activities to be implemented during operations, monitoring of periodic use of the generators and mobile sources is not deemed to be necessary. Monitoring of the wastewater treatment will be carried out on a regular basis. The parameters and the rationale are shown in Table F.2.1-1.

Table F.2.1-1 Monitoring Measures for UCA Naryn Campus – Operations Phase

Monitored Project Rationale Parameter Phase • To ensure adequate pH range for functioning of wastewater treatment plant Effluent pH Operation • To ensure that effluent does not adversely affect pH of receiving waters • To ensure no adverse thermal impacts on receiving waters Effluent Operation • To ensure that wastewater treatment plant is operating in temperature optimized temperature range. • To measure organic load of treated wastewater to receiving waters Effluent BOD Operation • To measure effectiveness/efficiency of wastewater treatment plant

Effluent • To ensure adequate pathogen kill in wastewater treatment plant Operation Coliform • To ensure adequate protection of downstream water users

• To measure and mitigate potential eutrophication impact of Effluent wastewater on receiving waters Operation Nitrogen • To measure effectiveness/efficiency of wastewater treatment plant • To measure and mitigate potential eutrophication impact of Effluent wastewater on receiving waters Operation Phosphorus • To measure effectiveness and efficiency of wastewater treatment plant • To measure the level of impact of suspended solids on receiving Effluent waters Suspended Operation • To measure effectiveness and efficiency of wastewater Solids treatment plant

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268. As part of the detailed design and engineering phase, detailed monitoring SOPs applicable to all three UCA campuses will be developed. The SOPs will include details on the parameters being monitored and the rationale for the monitoring measures, the acceptable test methods and equipment requirements, the required frequency of monitoring activities, and the required reporting procedures.

F.2.2 Monitoring and Reporting Procedures

269. The frequency and format of monitoring will be determined during the detailed design phase. It is currently anticipated that all monitoring data will be incorporated into annual “State of the Environment” (SOE) reports. The SOE reports will aggregate all monitoring data to assist with the identification of emerging trends and potential environmental concerns. This feedback will be used to modify existing mitigation measures and/or identify additional measures that may be required.

270. In addition to annual reporting, UCA’s Executive Committee will be given monthly reports that will include information on any recently identified environmental concerns. Such reports will be accompanied by action plans to address any deficiencies that have been identified.

F.2.3 Independent Review

271. All annual environmental reports will undergo a formal review by an independent third-party during the first 3 years. Thereafter, an independent audit will be carried out on the site operations. Based on the findings of the independent audit, the need for ongoing review of annual reports and the timing of future independent audits will be reassessed to see if the frequency of external reviews and audits are appropriate.

F.3 Implementation Arrangements

F.3.1 Organizational Structure

272. During the pre-construction period, an Environmental Management Office (EMO) will be established. The EMO will be comprised of individuals with expertise in engineering design, ecology, sociology, and economic analysis. The EMO will report to the Project Manager who will be responsible for implementing the required responses as well as monitoring and mitigation activities. The EMO will include representatives from UCA as well as an International Environmental Contractor. Responsibilities of the EMO will include:

• Developing the comprehensive EMEF and all associated SOPs; • Continuing to evaluate potential environmental impacts of decisions made during the detailed design phase; • Providing environmental expertise with respect to project-related impacts and proposing mitigation measures and the corresponding implementing schedule for these measures; • Defining the resources required to ensure effective implementation of environmental measures; • Completing economic analyses for environmental mitigation measures and monitoring requirements; and

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• Ensuring that the detailed environmental studies shown in the implementation plan are executed.

273. During UCA’s operational phase, the EMO will transition into the operational Environmental Health and Safety Office (EHSO). The EHSO will be responsible for:

• Updating of existing SOPs and development of new SOPs as required for new materials or research programs; • Ensuring regular maintenance and inspection of all equipment; • Development of training programs as required and maintenance of training records; • Development of labelling procedures for chemicals, biological agents, and equipment; • Ensuring adequate EHS training of all faculty, researchers, and lab personnel; • Providing support for maintenance of all chemical inventories on-site; • Investigating and ensuring proper documentation of accidental releases or spills; and • Keeping up to date with EHS regulatory and legal requirements and with international EHS best practices.

274. The detailed mandate and responsibilities of the EHS, its composition, as well as its reporting procedures will be developed as part of UCA’s planning activities. The EHSO is expected to be report on a regular basis to UCA’s Senior Management.

F.3.2 Cost Assessment for Environmental Management Plan

275. The achievement of environmental performance will be ensured through proper operation and maintenance of final design components and utilities. The associated costs will be integrated within the capital and operating budgets of the campus.

276. An environmental organization, the Environmental Management Office (EMO) will be developed as outlined in Section F.3.1 above. The costs associated with the organization’s efforts arise primarily with respect to the human resource costs and are within the UCA budget.

277. The incremental costs associated with environmental monitoring are expected to be related primarily to the development of a quantitative air quality modeling assessment of point and fugitive sources (stacks, mobile equipment, dust) and to routine and regular sampling of water treatment effluent discharges. Subject to the results of the air quality modeling assessment, air quality monitoring is expected to be based on observations to confirm that dust generation is being effectively managed. If dusting is noted, on-site mitigation measures will be enacted. The cost of the air quality modeling is estimated to be on the order of $60,000.

278. Monitoring of the liquid effluent from the wastewater treatment plant will be weekly during commissioning of the plant (approximately 2 months), monthly for the first three years of operations, and quarterly thereafter, assuming that the plant has been performing as expected with no or limited upsets. The budgeted annual cost for the analyses would range from $16,000 in the first year of operation, $12,000 in year two and three, and $4,000 thereafter. The budgeted allowance will be subject to completion of the final detailed design and regulatory sampling requirements. In addition, the manner in

September 2011 Page F-9 University of Central Asia Initial Environmental Examination Naryn Campus which samples are analyzed (e.g. commercial or UCA laboratory) will affect the actual unit cost per sample, and correspondingly the annual monitoring costs.

279. An allowance is carried for the independent review of annual reports in the amount of $5,000 per year for a three-year period. An independent audit in year 4 would be budgeted at approximately $20,000.

280. The costs of the Environmental Management Plan are summarized in Table F.3.2-1.

Table F.3.2-1 Summary of Costs of Environmental Management Plan

Category Description Timing Budget Responsible for developing EMEF and SOPs and Environmental ensuring that all environmental impacts are evaluated Established during Included in HR Management during the decision making process. EMO will also be Pre-construction Construction Office responsible for overseeing implementation of required Phase Requirements safeguards.

Environmental Air quality monitoring and air quality assessments as Pre-construction and $60,000 Modeling required. Construction Phase

Plant Commissioning $16,000 Y1 Liquid Effluent Liquid effluent monitoring during commissioning and Phase and $12,000 Y2/Y3 Monitoring operation of wastewater treatment plant. Operation Phase $4,000 / year

Review of Independent review of annual reports of environmental Early Operation $5,000 per year Annual Reports safeguards and environmental performance. Phase

Independent Independent audit of environmental practices and Year 4 $20,000 Audit compliance with environmental policies.

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G. Conclusions and Recommendations

281. The University of Central Asia’s Naryn campus is not expected to result in significant adverse environmental impacts. The results of the IEE support ADB’s Category B classification of the project. Effective mitigation measures will be taken to reduce impacts on air quality, water quality, and the physical environment. UCA is committed to implementing best practices and to meeting international standards for environment, health and safety. Significant benefits are expected as a result of the University’s construction and operation including new revenue opportunities for local businesses and significant employment opportunities.

282. Key environmental studies that will be undertaken during the detailed design phase of the project include:

• Water Supply System – source, treatment and distribution; • Wastewater Treatment - treatment facility and characterization of the receiving environment; • Solid Waste Management – diversion and disposal strategy; • Energy Systems – electricity / heat sources and supply (including alternative sources); and • Hazardous Wastes - development of waste management plans for laboratory practices.

283. As part of UCA’s Environmental Management Plan, preventative measures will be implemented to mitigate the risk of adverse environmental impacts. For example, measures will include dust suppression techniques, use of appropriate emissions controls and regular maintenance of equipment. Potential impacts to surface waters will be mitigated by a new wastewater treatment plant and solid wastes will be managed under an integrated strategy that minimizes disposal requirements. Environmental performance will be a key factor in the selection of building designs and energy systems. Trees will be planted throughout the campus and measures will be put in place to protect wildlife.

284. During construction, environmental performance will be monitored daily through visual inspections of the site and work activities. Environmental impacts associated with construction activities are anticipated to be minimal and this can be confirmed through modeling. Noise monitoring will be carried out to ensure that noise impacts are not significant. Noise will be controlled through equipment maintenance and scheduling of activities. During operations, liquid effluent will be monitored at the discharge of the plant. The University’s Executive Committee will receive environmental and sustainability reports on progress being made, issues that may arise, as well as any grievances received.

September 2011 Page G-1 University of Central Asia Initial Environmental Examination Naryn Campus

H. References

[1] Asian Development Bank. Safeguard Policy Statement. June 2009.

[2] Brunner, J. J. and Tillett, A. Higher Education in Central Asia: The Challenges of Modernization. Case Studies from Kazakhstan, Tajikistan, The Kyrgyz Republic and Uzbekistan.

[3] Chynbaeva, J. Socio-economic profile of Naryn oblast for 2004-2008. University of Central Asia. April 2010.

[4] Council of the European Communities. Council Directive of 21 May 1991 concerning urban waste water treatment. 91/271/EEC. Official Journal of the European Communities, No L 135/40.

[5] Development Policy Institute. [Website]. Salkyntor State Park. Retrieved September 30, 2011 from http://www.naryninvest.kg/en/why-naryn-oblast/tourism/Salkyntor.

[6] European Commission TEMPUS. Higher Education in Kyrgyzstan. October 2010.

[7] International Finance Corporation / World Bank Group. Environmental, Health and Safety General Guidelines. April 30, 2007.

[8] Ministry of Transport and Communications. Initial Environmental Examination Report for CAREC Transport Corridor I (Bishkek-Torugart Road) Project. Prepared for the Asian Development Bank. Project Number 39674. July 2008.

[9] Planning for Health Ltd. Proposals for Medical Facilities: Western Naryn, Naryn Oblast, Republic of Kyrgyzstan. January 9, 2009.

[10] SanPiN 2.1.7.573-96 Hygiene Requirements for the Use of Wastewaters and their Residues for Irrigation and Fertilization Purposes.

[11] Sasaki Associates, Socio-cultural Study, 2004.

[12] State agency on environment protection and forestry under the Government of Kyrgyz Republic. Kyrgyz Republic Red Data Book. Second Edition. Bishkek. 2006.

[13] University of Central Asia. Infrastructure Systems Concept Design Report. 1-RPT-PM-01 REVC C. 2006.

[14] Waterman. [Technical Note]. University of Central Asia: Khorog Mechanical & Electrical Infrastructure Systems. Rev 0. April 19, 2011.

[15] Zlatograd. Construction Project “UCA Naryn Campus” Detailed Design: Environmental Protection. Bishkek 2009.

September 2011 Page H-1 University of Central Asia Initial Environmental Examination Naryn Campus

I. Limitations

285. This Initial Environmental Evaluation (IEE) report was prepared by SENES Consultants Limited (SENES) on behalf of the University of Central Asia (UCA). The report reflects SENES’ best judgement, taking into consideration the information available to SENES within the time constraints and terms of reference for the assignment.

286. The IEE is based primarily on a desk-top review of documents provided by UCA and a visual inspection of the subject property by SENES. Confirmation sampling, monitoring and/or intrusive on-site testing were beyond the instructions and scope of this review. SENES accepts no liability or responsibility for conditions arising from information or facts which were not fully disclosed, or conditions which can only be confirmed through sampling, monitoring or intrusive testing. Should additional information become available with respect to the findings provided in this report, SENES would be pleased to have this information brought to our attention so that we may reassess the conclusions presented.

287. This report was prepared by SENES for the sole and exclusive use of UCA and lending agencies, and in particular, the Asian Development Bank. Any use of, or reliance or decision based on this report by any third party is the sole and exclusive responsibility of such third party. SENES accepts no responsibility for damages, if any, suffered by any third party as a result of the use of or reliance or decision based on this report.

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