Initial Environmental Examination

Project Number: 44321-013

November 2020

Cambodia: Climate Resilient Rice Commercialization Sector Development Program (Kien Kaes 1 village, Kouk Khmum commune, Thmar Koul District, province)

Prepared by Ministry of Economy and Finance (MEF) for the Royal Government of and the Asian Development Bank.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

KINGDOM OF CAMBODIA Nation Religion King

Ministry of Economy and Finance

Climate-Resilient Rice Commercialization Sector Development Program ADB Loans 3006/3007/8271 and Grants 0349/0350-CAM

Initial Environmental Examination for Establishment of Paddy Drying and Storage Facility at City Rice Mill in Kien Kaes 1 village, Kouk Khmum commune, ,

October 2020

CURRENCY EQUIVALENTS (October 2020)

Currency Unit – riel (KR) KR1.00 = $0.00025 $1.00 = KR4, 000

ABBREVIATIONS

ADB Asian Development Bank CLAC Commune Land Acquisition Committee DD & CS Detailed Design and Construction Supervision EHS Environmental, Health and Safety EIA Environmental Impact Assessment EMP Environmental Management Plan EQS Environmental Quality Standard IEE Initial Environmental Examination IEIA Initial Environmental Impact Assessment IRC Inter-ministerial Resettlement Committee MAFF Ministry of Agriculture, Forestry and Fisheries MEF Ministry of Economy and Finance MOE Ministry of Environment MOWRAM Ministry of Water Resources and Meteorology PDA Provincial Department of Agriculture PDOE Provincial Department of Environment PDOLVT Provincial Department of Labor and Vocational Training PDLMUPC Provincial Department of Land Management, Urban Planning and Construction PDS Paddy Drying and Storage Facility PGRC Provincial Grievance Redress Committee PIO Provincial Implementation Office PMO Program Management Office PRC Procurement Review Committee RDB Rural Development Bank RGC Royal Government of Cambodia RWG Resettlement Working Group SPS Safeguard Policy Statement TPD tons per day UXO Unexploded Ordnance

WEIGHTS AND MEASURES Km – kilometer Kg – kilogram Ha – hectare m2– square meter mm – millimeter

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... vi I. INTRODUCTION ...... 1 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 2 A. Government Environment Policy and Regulation ...... 2 1. Law on Environmental Protection and Natural Resource Management ...... 2 2. Environmental Impact Assessment Process Sub-Decree ...... 2 B. Evaluation Standards ...... 3 C. ADB Environment Requirement ...... 5 D. Environmental, Health, and Safety Guidelines ...... 7 III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN ...... 7 A. Subproject Provinces ...... 7 B. Subproject Scope...... 8 C. Subproject Context...... 10 IV. DESCRIPTION OF THE ENVIRONMENT ...... 11 A. Physical Resources ...... 11 1. Topography, Geology and Soils ...... 11 2. Climate ...... 11 3. Water Resources ...... 12 B. Biological / Ecological Resources ...... 13 C. Socio-economic Resources ...... 14 1. Items of Historical and Archaeological Significance ...... 14 2. Human and Economic Development ...... 14 1) Livelihoods ...... 14 2) Poverty Levels ...... 15 3) Health ...... 16 4) Unexploded Ordinance ...... 16 V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ...... 17 A. Method of Assessment ...... 17 B. Environmental Impacts Related to Location ...... 17 C. Environmental Impacts Related to Construction ...... 17 D. Environmental Impacts Related to Operation ...... 19 E. Global, Trans-boundary and Cumulative Impacts ...... 20 VI. ANALYSIS OF ALTERNATIVES ...... 20 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...... 21 A. Consultations and Information Disclosure during design ...... 21 B. Further Information Disclosure ...... 22 VIII. GRIEVANCE REDRESS MECHANISM ...... 22 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 24 A. Responsibilities for Environmental Management ...... 24 B. Environmental Monitoring ...... 25 1. Monitoring for Compliance with EMPs ...... 26 2. Testing for Noise and Dust Control ...... 26 C. Environmental Monitoring Reports ...... 26 D. Institutional Arrangement and Responsibilities ...... 26 X. CONCLUSION AND RECOMMENDATIONS ...... 27 XI. REFERENCES ...... 28 XII. ANNEXES ...... 29 Annex 1: Agreement of City Rice Mill with PDOE, Battambang ...... 29 Annex 2: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation .... 33 Annex 3: Land Title of City Rice Mill Issued by PDLMUPC ...... 34

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Annex 4: Existing Location of City Rice Mill ...... 44 Annex 5: Detail Design of PDS facility for City Rice Mill ...... 45 Annex 6: Calculation of Capacity Including Raw Materials for PDS facility at City Rice Mill .. 47 Annex 7: Total Annual and Average Monthly Rainfall from 2011-2018 in Battambang ...... 48 Annex 8: Rapid Environmental Assessment (REA) Checklist...... 49 Annex 9: Environmental Management Plan Summary) ...... 55 Annex 10: Environmental Monitoring Plan ...... 63 Annex 11: Minutes of public consultation meeting...... 74

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LIST OF TABLES

Table 1: Annex of Prakas No. 021 PRK.BST dated 03 February 2020 ...... 3 Table 2: Drinking Water Standards (2004) ...... 4 Table 3: Ambient Air Quality Standard ...... 5 Table 4: Maximum Permitted Noise Level at Workshop, Factory and Industry Area (dB) ...... 5 Table 5: Rice Crop Production by Season ...... 14 Table 6a: Poverty levels (2010-2017) by district in Battambang ...... 15 Table 6b: Poverty levels (2004-2012) by communes in Thma Koul ...... 16

LIST OF FIGURES Figure 1: Location of Project Provinces ...... 7 Figure 2: Location of City Rice Mill...... 9 Figure 3: Annual Rainfall from 2011-2018 at Battambang ...... 12 Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang ...... 12 Figure 5: Photo of consultations meeting with relevant stakeholder ...... 21 Figure 6: Grievance redress mechanism ...... 23

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EXECUTIVE SUMMARY

1. The establishment of paddy drying and storage (PDS) facilities are one of the key activities under the Climate-Resilient Rice Commercialization Sector Development Program (Rice-SDP) to help accommodate paddy supplies at peak periods after harvest to ensure better quality for processing and retained added value in Cambodia. The Ministry of Economy and Finance (MEF) is the Executing Agency (EA) of the Rice-SDP and has established a Program Management office (PMO). The PMO has established a PDS Selection Committee in cooperation with the Ministry of Agriculture, Forestry and Fisheries/National Implementation Office (MAFF/NIO) and the Provincial Implementation Offices (PIOs) at three target provinces, Battambang, Kampong Thom and Prey Veng, who will participate in the entire PDS procurement process. The funds for the construction of the PDS facilities will be made available through concessional loans to the Rice Millers and the Rural Development Bank (RDB) will be involved as a representative of the MEF to collect the loan from the Rice Millers in accordance with a loan agreement to be signed between RDB and Rice Millers.

2. The Rice Millers eligible to avail the concessional loans from Rice-SDP to establish the PDS Facilities are selected following a cumbersome process. Upon receipt of the expression of interest (EOI) from City Rice Import Export Co., Ltd. (simply referred as City Rice Mill), the PMO conducted a quick feasibility study, assessed its PDS business proposal, and employed a detailed design and construction supervision (DD & CS) firm to support the Rice Miller. The participation of the City Rice Mill from Battambang province was endorsed by the PDS Selection Committee and the Rice Miller was selected to avail the concessional loan for establishment of PDS Facility. Following the endorsement by the PDS Selection Committee, both the PMO and the DD & CS consultants worked with the City Rice Mill and completed the initial survey for detailed design, verification of the proposed location, site layout for construction, system and process design, machine layout drawings, detailed design and specifications of equipment, and budget estimates for the Facility. Following the detailed design of the Facility, a Public Consultation Meeting on environmental and social safeguards impact assessment for the proposed PDS Facility was conducted by a Rice-SDP technical team comprising of MEF/PMO officials and consultants, Provincial officials and consultants, and DD&CS consultants. The main focus of the assessment was to avoid risks and support the Rice Miller to strengthen his/her safeguard systems and develop the capacity to manage environmental and social risks.

3. The feasibility study and subsequently the detailed design present a proposal for establishment of a PDS Facility within the existing business compound of the City Rice Mill located in Kien Kaes 1 village, Kouk Khmum commune, Thma Koul district, Battambang province. The City Rice Mill owns about 10 hectares of a single piece of land including rice mill compound and adjoining farm land in the location, and the proposal proposes establishment of a PDS Facility on an area of 1,800m2 (around 0.18 ha) within the existing rice mill compound of the City Rice Mill. The proposed Facility will have a drying capacity of 480 tons per day (TPD) of wet paddy.

4. The proposed Facility is not environmentally critical and not within or adjacent to environmentally sensitive areas and classified as Category B for environmental impact (according to ADB project framework criteria). The proposed work will mainly involve installation of paddy drying equipment within an existing building of a size of 30 m x 60 m x 16.5 m (Width x Length x Height). The activities will not be critically harmful to the environment. The few adverse direct impacts during construction and installation of equipment are expected to be local, temporary and short- term and most likely to occur during working hour of the construction period. These will not be sufficient to threaten or weaken the surrounding natural resources. The Rice Miller has applied

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and received the Environmental Protection Agreement from Provincial Department of Environment (PDOE) as part of establishing the PDS Facility and improving the business operation performance to fulfill the Government’s requirements. The specific environmental management plan (EMP) addressing adequate mitigation measures to be implemented by the contractor especially during the construction of the PDS Facility is in place.

5. Overall, the proposed PDS Facility will significantly contribute to a qualitative improvement in the villagers living standards as they will get opportunity to expand their rice business as the Rice Miller will buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport the paddy very far, and also they can work as labor at the Facility to earn income. The Facility is considered both socially and technically feasible and is recommended for proceeding to the next (procurement) stage.

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I. INTRODUCTION

6. The Climate Resilient Rice Commercialization Sector Development Program (Rice- SDP) will finance policy support, infrastructure, information management and capacity development investments to enhance the production of quality rice, consistent with the Royal Government of Cambodia (RGC)’s Strategy on Agriculture and Water 2010-2013 and its Policy on the Promotion of Paddy Production and Rice Export (the Rice Policy). The Program will support infrastructure development through subprojects in the participating provinces of Battambang, Kampong Thom and Prey Veng. Infrastructure subprojects will include the construction or rehabilitation of irrigation systems, on-farm water conservation structures, paddy drying and storage (PDS) facilities, or other types of infrastructure that are likely to contribute to the program impact and outcome, based on selection criteria agreed with key stakeholders (Supplementary Appendix IV section II.B.3). Infrastructure improvements will be complemented by soft interventions such as targeted agricultural extension, land leveling, famer water user community (FWUC) support and other initiatives that add benefit to the investment in civil works under the subproject.

7. Furthermore, the Agricultural Sector Strategic Development Plan 2014-2018 was prepared basically in line with the RGC’s Policy Paper on “the promotion of paddy production and rice export” which was promulgated on August 17th, 2010 by the RGC and relevant documents for the agricultural sector development, with the aim of transforming Cambodia as a leading rice exporting country in the region. Presently, the agricultural sector has been supported through the improvement of irrigation, dissemination of new technology and other endeavors, especially agricultural research and development to adapt to climate change.

8. The proposed PDS facility for City Rice Mill includes social and environmental safeguards assessment and management plan. The purpose of the Facility is to increase paddy drying capacity by 480 tons per day (TPD), disseminate new technology, and reduce the flow of wet paddy to neighboring countries. The City Rice Mill owns about 10 hectares of a single piece of fully fenced land at the proposed location, Kien Kaes 1 Village, Kouk Khmum Commune, Thma Koul District in Battambang province. The Rice Miller has constructed rice mill and other buildings for business purposes on a 2.5 hectares of land (land title issued by Provincial Department of Land Management and Urban Planning-“PDLMUPC”, Battambang, on 06 July 2018). The proposed paddy drying equipment shall be installed within an existing building constructed on an area of 1,800m2 (around 0.18 hectare) within the Rice Mill compound.

9. This initial environmental examination (IEE) is based on the consultation with relevant stakeholders and prepared according to the guidance provided in the environmental assessment and review framework (EARF) and the ADB’s Safeguard Policy Statement of June 2009 and the RGC Law on Environmental Protection and Natural Resource Management (December 1996) with further guidance from the Sub-decree on Environmental Impact Assessment (1999) and the Prakas on EIA Classification for Development Projects (2020).

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II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. Government Environment Policy and Regulation

1. Law on Environmental Protection and Natural Resource Management

10. The Law on Environmental Protection and Natural Resources Management was enacted by the National Assembly and launched by the Preah Reach Kram/NS-RKM-1296/36 on December 24th, 1996. This law has the following objectives: (i) To protect and promote environment quality and public health through prevention, reduction and control of pollution; (ii) To assess the environmental impacts of all proposed projects prior to the issuance of a decision by the Government; (iii) To ensure the rational and sustainable conservation, development, management and use of the natural resources of the Kingdom of Cambodia; (iv) To encourage and provide possibilities for the public to participate in the protection of environment and the management of the natural resources; and (v) To suppress any acts that cause harm to the environment.

11. Under this law the developers or project owners need to prepare an Initial Environmental Impact Assessment (IEIA) or a full Environmental Impact Assessment (EIA) report for their proposed or existing development projects.

2. Environmental Impact Assessment Process Sub-Decree

12. The sub-decree No. 72 ANRK.BK on Environmental Impact Assessment Process dated August 11th, 1999 sets out EIA procedures. The main objectives of this sub-decree are: (i) To determine an Environmental Impact Assessment (EIA) for every private and public project or activity, and it must be reviewed by the MOE, prior to the submission for a decision from the Government. (ii) To determine the type and size of the proposed project(s) and activities, including existing and ongoing activities in both private and public sector prior to undertaking the process of EIA. (iii) To encourage public participation in the implementation of the EIA process and take into account their input and suggestions for re-consideration prior to the implementation of any project.

13. The sub-decree includes an annex which provides information on development projects requiring EIA or IEIA. The annex was further updated through the Prakas No. 021 PRK.BST dated 03 February 2020 on EIA Classification for Development Projects. An excerpt for relevant projects is provide in Table 1 below.

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Table 1: Annex of Prakas No. 021 PRK.BST (Dated 03 February 2020)

Environmental Impact Assessment Classification Sl. No. based on the scales of development projects (as in Prakas) Types of Projects Contract on EIA IEIA Environment Protection

1. Mining, Energy and Industrial Sectors

68 All types of soft drink and juice (All types) factories

69 Fruit jam factories (≥ 500 (< 500 tons/year) tons/year) Rice and grain (processing) millers (≥ 3.000 70 or factories tons/year)

Fish sauce, soy sauce, soy paste, (≥ 500.000 71 chili sauce, tomato sauce factories liters/year) 75 Cotton processing factories All sizes

79 Rice flour factories All sizes 2. Agricultural Sector

145 Dense forest business (≥ 500 ha) (< 500 ha)

Forest land (≥ 500 ha) (< 500 ha) 146

Agro-industrial farmland (≥ 500 ha) (< 500 ha) 147 Agro-industrial rehabilitation and 155 (≥ 500 ha) (< 500 ha) development

14. Since this PDS Facility comes under the “Rice and grain (processing) millers or factories”, as per Table 1 above, the City Rice Mill has applied and received the Environmental Protection Agreement from Provincial Department of Environment (PDOE) as part of establishing the PDS Facility and improving the business operation performance to fulfill the Government’s requirements (see Annex 1). The proposed Facility will be constructed well within the existing rice mill compound owned by the City Rice Mill and will be monitored by PDOE as mentioned in the Environmental Protection Agreement.

B. Evaluation Standards

1) Law on Water Resources Management

15. The Law on Water Resources Management was adopted by the National Assembly on 22 May, 2007. This law provides procedures for the management of water resources within Cambodia. The purpose of the law is to foster the effective management of the water resources of the Kingdom of Cambodia to attain socio-economic development and the welfare

Page | 3 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill of communities.

16. The Law shall determine: (i) The rights and obligations of water users; (ii) The fundamental principles of water resources management; (iii) The institutions in charge of its implementation and enforcement; and (iv) The participation of users and their associations in the sustainable development of water resources.

17. Under this law, MOWRAM may declare any basin, sub-basin or aquifer as Water Law Implementation Area when within that basin, sub-basin, ground water or aquifer there are likely to be conflicts among water users, problems of water pollution or watershed degradation.

2) Water pollution control sub-decree

18. The sub-decree No 27 ANRK.BK dated April 6th, 1999 is on Water Pollution Control. The purpose of this sub-decree is to regulate water pollution in order to prevent and reduce water pollution of public water bodies so that protection of human health and conservation of bio- diversity can be ensured. This sub-decree applies to all sources of pollution and all activities causing pollution of public water bodies. The sub-decree also provides the pollution types, effluent standards, and water quality standards in different areas. Water quality standards are stipulated in this sub- decree for public water (see Annex 2).

3) Drinking Water Quality Standards

19. For well water used for domestic purposes, including drinking, the Ministry of Industry Mines and Energy (MIME) Drinking Water Quality Standards of January 2004 is the evaluation standard. These are summarized in Table 2 below.

Table 2: Drinking Water Standards (2004)

No Parameter Unit Standard Value 1 pH mg/l 6.5 – 8.5 2 Turbidity NTU 5 3 Arsenic mg/l 0.05 4 Iron 0.03 5 Total Dissolved Solid mg/l 800 6 Chlorine mg/l 0.2-0.5 7 Copper mg/l 1 8 Sulphate mg/l 250 9 Nitrite mg/l 3 10 Nitrate mg/l 50 11 Lead mg/l 0.01 12 Mercury mg/l 0.001 13 Coliform CFU/100ml 0

4) Solid waste management sub-decree 20. The sub-decree No 36 ANRK.BK dated April 27th, 1999 is on Solid Waste Management. The purpose of this sub-decree is to regulate solid waste in order to ensure protection of human health and conservation of bio-diversity. This sub-decree applies to all activities related to disposal, storage, collection, transport, recycling, dumping of garbage and hazardous waste.

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5) Air pollution control sub-decree th 21. The sub-decree No 42 ANRK.BK dated July 10 , 2000 is on Air Pollution Control and Noise Disturbance. The purpose of this sub-decree is to protect quality of environment and public health from air pollutants and noise pollution. This sub-decree applies to all mobile and stationary sources of air and noise pollution. These are summarized in Table 3 and Table 4 below. Table 3: Ambient Air Quality Standard1

No Period 1h Period 8h Period 24h Period 1year

Average Average Average Average Parameters (mg/m3) (mg/m3) (mg/m3) (mg/m3)

1 Carbon monoxide (CO) 40 20 - - 2 Nitrogen dioxide (NO2) 0.3 - 0.1 - 3 Sulfur dioxide (SO2) 0.5 - 0.3 0.1 4 Ozone (O3) 0.2 - - - 5 Lead (Pb) - - 0.005 - 6 Total 0.1 - - 0.33 Suspended Source: Annex1 of Sub-Decree on Air Pollution Control and Noise Disturbance, 2000.

Table 4: Maximum Permitted Noise Level at Workshop, Factory and Industry Area (dB) 2 Noise Level (dB (A)) Maximum Period of Time Level 75 32 Ear protection equipment shall be provided to worker 80 16 who works at a location with 85 8 noise level over 80dB(A) 90 4 95 2 100 1 105 0.5 110 0.25 115 0.125 Source: Annex 7 of the Sub-decree on Air Pollution and Noise Disturbance (2000)

C. ADB Environment Requirement

22. Safeguard Policy Statement was overarching Statement on ADB’s Commitment and Policy Principles. ADB affirms that environmental and social sustainability is a cornerstone of economic growth and poverty reduction in Asia and the Pacific. ADB’s Strategy 2020 therefore emphasizes assisting DMCs to pursue environmentally sustainable and inclusive economic growth. In addition, ADB is committed to ensuring the social and environmental sustainability of the projects it supports. In this context, the goal of the Safeguard Policy Statement is to promote the sustainability of project outcomes by protecting environment and people from project potential adverse impacts. The objectives of ADB’s safeguards are to:

(i) Avoid adverse impacts of projects on the environment and affected people, where possible; (ii) Minimize, mitigate, and/or compensate for adverse project impacts on the

1 Note: This standard is applied to evaluate ambient air quality and to monitor air pollution status. 2 Note: This standard is applied to control noise level in location of workshop, industries and factories.

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environment and affected people when avoidance is not possible; and (iii) Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks.

23. ADB adheres to the objectives of the safeguards and their delivery. ADB assumes the responsibility for conducting due diligence and for reviewing, monitoring, and supervising projects throughout the ADB’s project cycle in conformity with the principles and requirements embodied in the Safeguard Policy Statement. By adhering to its social and environmental safeguards, ADB enhances the predictability, transparency, and accountability of its actions and decision making; helps borrowers/clients manage social and environmental impacts and risks; and promotes the long- term sustainability of investments. Transforming this commitment into results on the ground depends on shared, but differentiated, efforts by ADB and its borrowers/clients. ADB’s Safeguard Policy Statement sets out the policy objectives, scope and triggers, and principles for three key safeguard areas: (i) Environmental safeguards, (ii) Involuntary resettlement safeguards, and (iii) Indigenous Peoples safeguards.

24. On basis of subproject screening in the feasibility stage, using a rapid environmental checklist, this PDS Facility has been determined to be classified as Category B for environmental impact during the feasibility study. This category entails environmental impacts that can be mitigated. This consolidated IEE has been prepared under the provisions of the ADB’s Safeguard Policy Statement 2009 which requires a number of critical considerations, including: (i) project level grievance redress mechanism, including documentation in the environmental management plan (EMP); (ii) physical cultural resources damage prevention analysis; (iii) climate change mitigation and adaptation; (iv) occupational and community health and safety requirements, including emergency preparedness and response; (v) economic displacement that is not part of land acquisition; (vii) meaningful consultation and participation; and (viii) an EMP which comprises implementation schedule and (measurable) performance indicators.

25. Relevant ADB Environmental policies and guidelines used in the preparation of this IEE are: (i) Safeguard Policy Statement. ADB, 2009. (ii) Operation Manual Bank Policies (BP) on Safeguard Policy Statement. ADB, 2009. (iii) Environment Policy of the Asian Development Bank, November 2002. (iv) Environmental Assessment Guidelines, 2003 – Annex 3: Content and Format of Initial Environmental Examination (IEE). (v) Environmental Guidelines for Selected Agricultural and Natural Resources Development Projects (November 1991). (vi) Rapid Environmental Checklist. ADB, 2013.

26. The main purpose of the Rapid Environmental Checklist is to screen the potential environmental impacts of the proposed PDS Facility for City Rice Mill that may occur during project design, construction, and operation phase. The environmental study is undertaken through field investigations and screening of potential impacts both negative and positive and developing of mitigation measures for each negative impact are made. Based on the results of the environmental and social field investigations and recommendation from relevant stakeholders and local communities in the project area, the potential environmental impacts that are expected to occur due to the project activities during pre-construction, construction,

Page | 6 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill and operation phases are noted and their mitigation measures established. The results of Rapid Environmental Assessment are described in Annex 8.

D. Environmental, Health, and Safety Guidelines

27. ADB’s Safeguard Policy Statement applies pollution prevention and control technologies and practices consistent with international good practices as reflected in internationally recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines. The Guidelines provide the context of international best practice and contribute to establishing targets for environmental performance. The air and noise standards in the EHS guidelines will be used to complement the Government standards in this document where needed. Occupational and community health and safety, as laid out in the EHS Guidelines, will be a cross-cutting assessment for the Facility. Additionally, the risks faced by workers and the public due to COVID 19 pandemic will be included in the health and safety management plan following recommendation from ADB Cambodia Resident Mission (letter dated 21 May 2020).

III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN

A. Subproject Provinces

28. All the PDS facilities to be established under the Rice-SDP will be located in three target provinces of Kampong Thom, Battambang and Prey Veng. These 3 provinces were selected for project investment as these are the largest rice producers in Cambodia. In an effort to increase paddy for export, these provinces have prioritized (i) improving efficiency of land and water, (ii) increasing postharvest handling capacities, and (iii) enhancing resilience of the rice ecosystems. All three provinces are located along the GMS Southern Economic Corridor along which rice can be conveniently transported to Thailand, Viet Nam, and all provinces in Cambodia. By focusing on these provinces, there are good opportunities to enhance national food security by improving availability of milled rice for both export and potentially addressing domestic demand and supply imbalances. The three project provinces are shown in Figure 1 below. The proposed PDS facility for City Rice Mill is located in Battambang province. Figure 1: Location of Project Provinces

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29. Battambang is located in the Northwest of Cambodia and borders Banteay Meanchey to the north, Pursat to the south-east and south, Siem Reap to the northeast, Pailin to the west, and Tonle Sap to the east. The western boundary of the province forms a part of the international border with Thailand. The area of the province is 11,872 square kilometers (Source: NCDD, updated 30 May 2015). The northeast part bordering the Tonle Sap Lake has floodplain areas. Battambang is one of the provinces included in the Tonle Sap Biosphere Reserve. The province has mostly lowland paddy fields and the fertile rice fields have led to a mostly agricultural economy giving rise to the moniker “the Rice Bowl of Cambodia”. The estimated population is 1,173,414 persons of which 588,724 are female. The people of Battambang province live in 14 districts composed of 102 communes and 799 villages and the population density is 100/km2 (Source: Battambang Development Plan 2016- 2018).

B. Subproject Scope

30. The proposed PDS Facility for City Rice Mill will be constructed within the existing Rice Mill compound situated on the National Road No. 57B, Kien Kaes 1 village, Kouk Khmum commune, Thma Koul district in Battambang province. The existing Rice Mill started its operation since 1990 and running for the last 30 years. Thus, the Rice Miller has vast experience in rice milling industry. The existing Rice Mill is located on a single piece of 10 hectares of fully fenced land owned by the Rice Miller (land title issued by Provincial Department of Land Management and Urban Planning-“PDLMUPC”, Battambang, on 06 July 2018 is attached as Annex 3). The Rice Mill front boundary borders National Road 57B and across the road there are residential houses. In the back of the Rice Mill, adjacent to the backyard boundary are agriculture fields belonging to the Rice Mill and a pagoda about 130m away while on the right side, adjacent to the right-hand side boundary, are agriculture fields belonging to villagers, 6 residential houses and a village road. On the left side of Rice Mill, there is railway track about 100m away and Huot Gnuon Hong rice mill and 2 residential houses about 150m away. (see Figure 2 below and Annex 4). The current milling capacity of the Rice Mill is 720 TPD (i.e. 110,000 tons paddy per year or 71,500 milled rice per year). Existing drying type is Batch columnar recirculation type for a volume of 1,010 TPD. The Rice Miller has currently engaged 150 workers of which 70 are women.

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Figure 2: Location of City Rice Mill

31. The proposed paddy drying equipment shall be installed within an existing building constructed on an area of 1,800 m² (30m x 60m x 16.5m) inside the existing Rice Mill compound. The proposed Facility will have a drying capacity of 480 TPD of wet paddy. Some of the salient features of the Facility to be established are: • Drying system: The drying plant will be installed which will start from Paddy intake – Precleaning – Batch-Recirculating Drying – and Storing. All immature grains and dust will be sent to storage room. • Bulk handling system: During drying process, wet paddy will be conveyed by bucket elevators and dried paddy will be conveyed by overhead belt conveyor to storage room. • Biomass furnace: This indirect heat furnace will be a Cyclonic type which will use mainly husk as biomass fuel. The amount of husk used will be 25 TPD (≥ 1,500-2,000 tons per year) which will be collected from the rice mill. Currently the Rice Miller also uses husk as biomass fuel for their furnace/burner. • The amount of ash generated per day will be 1 TPD (≥ 60 ton per year) but no ash/smoke will be released to the environment as the Cyclonic type furnace has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income.

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• Storage system: Warehouse type with aeration system including some bag storage for different varieties of paddy. • Construction: Construction work will use a small amount of water only as readymade mixed concrete from supplier will mainly be used. Contractor will install onsite WCs for their workers separated by and between male and female. • Operation: No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance.

32. The detailed design of the PDS Facility for City Rice Mill in brief can be found in Annex 5 while the complete sets of drawings along with full description of the detailed design can be found in the bidding documents. The detailed calculation of the capacity of the Facility including use of raw materials, generation of husk and ash can be found in Annex 6.

C. Subproject Context

33. The lack of adequate number of wet paddy drying facilities within ready reach of farm enterprises is identified as a serious constraint for the in-country handling of the increasing volume of wet paddy, quality rice production, and retained added value inside the country. The lack of drying facilities is also forcing many Cambodian farmers to sell their wet paddy directly to buyers from neighboring countries where modern facilities are available. Most of the processing facilities in the country are rudimentary, featuring significant crop losses, non- uniform drying, higher proportions of cracked grains and higher risks of fungal growth. The development of drying and storage facilities accessible to cooperatives are given priority by the RGC for the implementation of the rice policy.

34. The proposed site for PDS Facility for City Rice Mill is located about 28 km from Battambang town and 3Km from the Thma Koul district headquarter. It is on national road 57B that connects with national road 5. The establishment of PDS facilities at City Rice Mill will expand the current capacity of drying wet paddy by 480 TPD thereby improve the quality and quantity of domestically milled rice, increase the capacity for paddy storage in Battambang, accommodate paddy supplies at peak periods after harvest, reduce the movement of unprocessed paddy across the border to Thailand and Viet Nam immediately after harvest, ensure better quality for processing and retained added value in Cambodia. The improvement in the Facilities will also help the Rice Miller achieve a fully satisfactory performance of the rice mill by ensuring its durability and economic efficiency. In the immediate setting, the surrounding villages will benefit greatly from establishment of the Facility as most of the villagers cultivate paddy and the Rice Miller can buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport far, and their sons/daughters could work as labor at the Facility to earn income. After the completion of the facilities, the Rice Miller may employ around 15 more workers including 60-70% women in the mill.

35. In addition to the establishment of PDS facilities, associated activities will form part of the investment to (i) strengthen the technical extension services directed at quality seed production to agriculture cooperatives (ACs), (ii) contract farming between the Rice Millers and ACs, (iii) business matching between RDB/Financial Institutions - Rice Millers - ACs, and (iv) technical, financial and managerial capacity building of Rice Millers as well as ACs including access to credit.

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IV. DESCRIPTION OF THE ENVIRONMENT A. Physical Resources

1. Topography, Geology and Soils 36. Cambodia is divided into three distinct topographic regions: the central plains, the flat coastal areas, and the mountain ranges with high plateaus. The proposed PDS Facility is situated on flat land, characteristic of much of the floodplain of the lower Mekong Basin. The land has been formed by sedimentation during the Pleistocene epoch (between 10,000 and 2.5 million years ago)3, causing a layer of deposits in the order of 100 m deep, over the largely sandstone parent rock beneath.4 Soils in much of the area are clays (unconsolidated, relatively fertile soils deposited during the formation of the lake that have developed under saturated conditions), and hydromorphic soils (saturated soils that have developed under conditions of poor drainage), both of which are suitable for rice production.

2. Climate 37. Cambodia has a moist tropical climate, classified as equatorial monsoonal5, consistent with its location 10-13 degrees latitude north of the equator. The climate features warm to hot temperatures throughout the year and an annual monsoon cycle of alternating wet and dry seasons. The main wet season, the Southwest monsoon, occurs between June and October, when reduced air pressures over Central Asia cause air to be drawn landward from the Indian Ocean. Project Management and Contractors need to be aware that there has been considerable change in the incidence of drought and late arrival of wet season rains across Cambodia. Approximately 80% of all rainfall occurs during this season. Conversely, during the cooler months between November and January, air flows over Cambodia originate from Central Asia and are drier, resulting in cooler and less rainy weather. It is projected that as a result of Climate Change, the amount of rain fall in the wet season will increase, the duration of the wet season will be shorter and periods of dry spell will occur within the wet season. The dry season is expected to be longer.

38. Flooding data has been recorded in every Sangkat/commune of Battambang during the rainy season from June to December. In 2013, serious floods affected the whole province (flooding occurred mostly in October to December). The highest level of flooding occurred in Kouk Khmum commune with water depth ranging from 1-2 meters

39. The Battambang weather station managed by the PDWRAM, Battambang is situated near the proposed PDS Facility for City Rice Mill. The detailed design for the proposed Facility considered the last 8 years rainfall data i.e. from the year 2011 to 2018. The annual rainfall during 2011 to 2018 at Battambang weather station varied from 885 mm to 1,657 mm with the average being 1,230 mm. (Annex 7 & Figure 3 below).

3Rice-SDP Supplementary Appendix IV - Initial Environmental Examination, Svay Antor Paddy Drying and Storage Subproject. 4 Seng, V., R.W. Bell, P.F. White, N. Schoknecht, S. Hin and W. Vance, (2007) Sandy Soils of Cambodia in Management of Tropical Sandy Soils for Sustainable Agriculture. FAO, Rome.

5 Peel, M. C., Finlayson, B. L., and McMahon, T. A, (2007), Updated world map of the Köppen-Geiger climate.

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Figure 3: Annual Rainfall from 2011-2018 at Battambang Annual rainfall year 2011-2018 2,000.0

1,500.0

1,000.0

Rainfall,mm 500.0

- 2011 2012 2013 2014 2015 2016 2017 2018 Year

Source: Provincial Department of Water Resources and Meteorology

40. The wet-season in Cambodia starts from May to October. Peak levels of rainfall are up to 96.8 mm in a day found in March 2017 and 191 mm in one day in July 2014 may be return storm period. The average monthly rainfall recorded during 2011 to 2018 at Battambang weather station varied from 8.5 mm in January to 226.4 mm in September. (see Annex 7.1 & Figure 4 below).

Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang

Average Monthly rainfall (Year 2011-2018) 250.0 200.0 150.0 100.0 50.0 0.0 Ma Ma Rainfall,mm Jan Feb Apr Jun Jul Aug Sep Oct Nov Dec r y Rainfall(mm) 8.5 8.7 40.4 60.0 109. 138. 157. 116. 226. 220. 71.2 11.9 Month

Source: Provincial Department of Water Resources and Meteorology

3. Water Resources

41. The proposed PDS Facility area, and much of Cambodia, is within the Lower Mekong Basin where flooding takes place regularly. People and farming systems are vulnerable to variability in flood levels and this vulnerability is heightened by the effects of climate change. The Inter-governmental Panel on Climate Change predicts increasing difficulties to lives and livelihoods caused by more frequent storm events and extreme weather conditions in the Mekong sub-region.6 The Lower Mekong Basin has suffered successions and combinations of droughts and floods over the last two decades as well as in the more distant past. Flooding that occurred in 2000 is believed to be the most severe in Cambodia in 70 years, while severe flooding also occurred in 1996, 2001, 2002, 2011, 2013

6 M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson, Eds (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, Cambridge University Press, Cambridge, UK.

Page | 12 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill and 2020. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area.

42. Groundwater occurs in aquifers in the Pleistocene deposits and is used in the proposed PDS Facility area for domestic purposes. Deeper, more substantial aquifers may occur in rock layers but extensive geophysical and drilling exploration is needed to assess the potential of groundwater for use. The City Rice Mill has 1 private water pond (20m x 60m x5m) and 3 private pumping well (one is about 60m depth and rest two about 40m depth) at the proposed location. The pond harvests rain water and the Rice Miller uses water from both the pond and pump wells for drinking and other purposes. The Rice Miller has tested the water and found the water quality as good. The proposed site is about 28km from , about 2 km from Prolay Pram (canal five) and about 3 km from Prolay Pir (canal two).

B. Biological / Ecological Resources

43. Based on Royal Decree (Preah Reach Kret) on the Establishment and Designation of Protected Areas of November 01, 1993, there are 23 Protected Areas, of which 3 natural protection areas are located in Battambang province: (i) 59,000 ha of Phnom Samkos Wildlife Sanctuary situated in Samlot and Koskralor district.

(ii) 20,000 ha of Samlot Multiple Use Area (forest protection area) situated in Samlot district. (iii) 20,000 ha of Prektorl flooded forest protection area situated in Aekphnom and 44. The proposed PDS Facility for City Rice Mill is located far away from these protected areas. It’s about 28 km from Sangkae River, about 43 km from river and about 15-18km from Prey Roneam (flooded forest). The flooded forest and forest surrounding Battambang province are reportedly have been destroyed for commercial and family scale rice farming affecting the habitats of fisheries and birds (source: Battambang Development Plan, 2016- 2018).

45. The aquatic ecosystems that occur in the Battambang include seasonally flooded fields and small streams and are important habitats to fish, aquatic reptiles and amphibians. At least 500 fish species recorded in the Cambodia’s Mekong River (the Lower Mekong basin encompasses at least 1,200 fish species). Within the above figure, 296 fish species are from Tonle Sap Lake. So, both Mekong River and Tonle Sap Lake have great diversity of fish species in Cambodia (Source: So Nam, 2010).

46. The RGC has implemented fisheries reforms to promote small-scale fishing. In Battambang province some 22 species are commonly caught from paddy fields and streams, and some 29 species are commonly caught in family scale fishing from lake and river. Based on first semiannual report of 2016 by Battambang Fisheries Administration Cantonment, family scale fishing and paddy fields catch quantities were 6,687.8 tons and 2,625.61 tons, respectively.

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C. Socio-economic Resources

1. Items of Historical and Archaeological Significance

47. Ancient structures, mainly temples and shrines but sometimes bridges and water storage or control structures are common over the Cambodian landscape, with the major cluster in the Angkor temple complex within Siem Reap. However, no ancient structures or no ancient temples or shrines are located around the proposed PDS Facility. The proposed location is about 1km from Kien Kaes 1 primary school and about 130m from Chhundur Sva Pagoda.

2. Human and Economic Development 1) Livelihoods

48. Rural livelihoods are predominantly based on agriculture. Battambang is long renown for quality rice, fruit and vegetable production. Farming is the main source of income for the majority of households in the subproject area, while other income is obtained from off-farm employment in construction, other industries, government employment, and trading. A minority of rural households derive income from fishing, though this activity is merely a supplementary activity for part of the year.

49. Rice production is the mainstay of the rural economy in most areas. The total paddy production in Battambang province in 2014 was about 836,925 tons out of which wet season production was 796,059 tons and that of the dry season was 40,866 tons. 30% rice crop production in Battambang province depended on natural irrigation and irrigation, and 70% depended on rain water. Rice crop production has changed from traditional farming to mechanized farming through the use of modern agricultural equipment, rice seed, chemical fertilizer and pesticide, even though the increase in seasonal rice crop production is limited due to absence of irrigation facility (Source: Battambang Development Plan 2016-2018).

Table 5: Rice Crop Production by Season in 2014 Rice Production National National Battambang Battambang Indicator (Wet Season) (Dry Season) (Wet Season) (Dry Season)

Area Cultivated- ha. 2,564,572 490,935 279,123 10,500 Area Harvested- ha. 2,537,976 490,860 279,123 10,500 Paddy Production –T 7,143,520 2,180,896 796,059 40,866 Yield-T/ha. 2,815 4,443 2,852 3,892 Source: MAFF 2014 and Battambang Development Plan 2016-2018

50. Aquatic ecosystems are vulnerable to the effects of agrochemical use, particularly pesticides. The pesticides in use in the area included products that are known to contain compounds that are classified as persistent, such as 2 4-Dichlorophenoxyacetic acid (2 4-D), or methyl parathion, the active ingredient in the product Folidol.7 While these compounds progressively break down on release, fish and other aquatic organisms can be harmed, particularly as a result of improper, uninformed or irresponsible use or methods of container disposal. The proposed PDS Facility does not deal with the pesticides and hence will have no

7 Ministry of the Environment / UNEP (2009), Cambodia Environment Outlook.

Page | 14 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill negative effect on aquatic ecosystem. However, the project through associated activities (as mentioned in para 35), will strengthen the technical extension services directed at farmers and ACs on the use of pesticides.

51. Many small and marginal farmers do not have regular cash incomes, either because of access constraints, lack of landholdings and shortage of employment opportunities. Many families are dependent on remittances by family members working away from home, most often in the construction, garment, industries and overseas migrant workers.

2) Poverty Levels

52. Although, Cambodia is a country rich in natural resources, it remains one of the world’s poor nations, in part the legacy of decades of war, internal conflict and corruption. An additional legacy of war is the huge amount of unexploded ordinance which contributes to ongoing maiming and injury of the nation’s rural poor. In 2008, alleviating poverty became RGC’s highest priority according to its Millennium Development Goals. Thereafter, sustained efforts by the RGC led to the decrease in poverty rate from 47.8% in 2007 to 13.5% in 2014. But the rural poverty incidence where 90% of the poor live fell from 24.6% in 2009 to 20% in 2012.

53. Based on the Battambang Development Plan, the poverty level in Thma Koul district of Battambang province has reduced from 21.02% in 2010 to 20.24% in 2017(see Table 6a below). In the Kouk Khmum Commune of Thma Koul District, where the proposed PDS Facility is located, the poverty rate has decreased from 33.2% in 2004 to 15.3% in 2012 (see Table 6b below, Ministry of Planning, 2012). The proposed PDS Facility will significantly contribute to a qualitative improvement in the villagers living standards as they will get opportunity to expand their rice business as the Rice Miller will buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport the paddy very far, and also they can work as labor at the Facility to earn income.

Table 6a: Poverty rates by districts of Battambang province (from 2010-2017)

No. Districts 2010 2011 2012 2013 2014 2015 2016 2017 1 Banan 28.61 26.63 23.37 24.07 24.22 23.46 21.85 22.71 2 Thma Koul 21.02 18.55 22.34 22.05 21.91 21.16 20.56 20.24 3 Krong Battambang 8.76 8.20 17.08 17.14 16.51 16.39 16.47 16.61 4 Bavel 31.74 31.69 31.43 25.21 28.11 26.43 23.23 23.16 5 Aek Phnum 23.58 22.91 22.60 22.86 21.63 21.61 21.38 22.48 6 Moun Ruessei 28.52 26.65 24.96 24.63 24.07 22.94 22.92 22.10 7 Rotonak Mondol 34.91 30.01 29.06 28.36 25.75 24.85 22.49 22.04 8 Sangkae 22.98 21.08 21.97 20.54 19.50 19.16 19.92 18.99 9 28.60 24.29 23.30 24.07 21.10 21.41 21.32 20.42 10 Sampov Lum 27.32 26.30 26.03 25.23 22.99 21.73 20.17 22.25 11 Phnom Proek 28.65 25.64 23.37 24.08 22.64 21.80 21.43 21.92 12 27.57 25.19 24.06 24.16 22.01 22.00 21.10 20.60 13 35.97 31.56 28.73 27.78 26.30 25.37 23.75 24.01 14 Rukhak Kiri 37.37 32.54 27.01 27.57 25.28 25.12 22.35 21.77 Source: Battambang Provincial Department of Planning (PDP-BTB),2018

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Table 6b: Poverty rates by communes-sangkats, Thma Koul (2004-2012)

District/Cummune 2004 2005 2006 2007 2008 2009 2010 2011 2012 202.Thma Koul 32.8 31.7 30.6 29.7 28.2 26.2 24.6 21.0 18.6 29.2 12.2 28.2 25.4 25.4 27.9 26.7 25.3 21.9 15.0 14.5 Kouk Khmum 33.2 30.5 28.4 27.0 26.4 24.5 24.6 17.5 15.3 Chrouy 30.8 28.7 27.7 26.8 25.7 24.0 21.9 21.4 18.3 Chrey 29.7 28.7 28.3 28.3 25.5 22.3 22.2 19.4 18.5 Bansay 34.0 32.5 31.5 29.4 27.8 26.0 24.4 23.0 18.6 Rung Chrey 35.3 34.3 33.3 29.1 26.4 25.2 24.6 22.7 20.7 39.0 39.5 37.9 32.7 29.6 39.4 26.2 26.3 21.3 Ou Ta Ki 34.5 35.6 33.3 31.1 30.5 25.6 27.1 26.1 23.1 40.3 41.3 39.7 41.3 41.8 37.0 36.5 33.4 28.5 Source: Ministry of Planning, 2012

3) Health

54. Public health in the subproject area is influenced by the standard of water supply, and of the standard of sanitary living conditions. The incidence of water related diseases is high. And a significant portion of the population does not have access to piped water supply and fewer have access to improved sanitation. Pesticides pose a severe health risk if they are applied incorrectly and without the use of protective clothing. Part of the problem has been a lack of instruction on how to handle and use pesticides. The law now requires that pesticides are packaged and sold with clear instructions in Khmer word and this is enforced by staff of the Provincial Department of Agriculture. Additionally, pandemics such as the COVID 19 put workers and the public in great risks and the advisory on health and safety has been issued by the Government.

55. Battambang province has 6 referral hospitals, 77 health centers, 365 private clinics, 13 laboratories and 213 pharmacies (Source: Battambang Development Plan 2016-2018). In the Thma Koul district where the proposed PDS Facility is located there is one district referral hospital and nine health centers including one in Kouk Khmum commune. The proposed location is about 3 km from Kouk Khmum commune health center, about 2.5 km from Ta Pung health center and about 2km from 2 health clinics.

4) Unexploded Ordinance

56. Unexploded ordnance (UXO) remaining from civil conflict is evident in Battambang, resulting from both aerial drops and from ground fighting. However, the proposed PDS Facility site and its surrounding area have been actively cultivated since the years of conflict, and respondents and relevant stakeholders participated in the consultation meeting confirmed that they did not come across with any UXO in proposed area. Based on Battambang UXO report 2015, Battambang mine clearance was made by CMAC which aims at bringing about the personal security and safety of the people, safety of land and community living in mine affected areas in Battambang province. Thma Koul district was also cleared by CMAC. If required, the safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in subproject area and such certification will be included in the semiannual environmental monitoring reports to be submitted to ADB.

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V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

A. Method of Assessment

57. Following the sub-decree No. 72 ANRK.BK on Environmental Impact Assessment and Prakas No. 021 PRK.BST on EIA classification for development projects (see para 12 & 13 above), potential impacts have been assessed through site visits, consultation meetings with stakeholders, and a review of secondary sources of information. To identify potential impacts related to location, construction and operation, stakeholders were consulted, suitable mitigation measures and an environmental management plan (EMP) developed.

B. Environmental Impacts Related to Location and Pre-construction

58. The proposed PDS Facility is located on national road 57B that connects with national road 5. The site has good road access for both the construction and operation phases. The proposed paddy drying equipment shall be installed within an existing building constructed on an area of 1,800 m² (30m x 60m x 16.5m) inside the existing Rice Mill compound which is already elevated from the ground level. A Land Acquisition and Resettlement Plan for the Facility is not relevant as the land is privately owned.

59. The area is on a floodplain, susceptible to floods. Flooding causes risks of release of waste from the grain handling process and from toilets within the facility. However the Rice Mill has constructed buildings and treatment ponds on raised platforms and included provisions for drainage of a specification sufficient for safe draining of flood water.

60. There are no buildings, temples or items of cultural significance that will be affected by the works. There are no salinity issues expected at the site as ground water will not be used, and soil erosion will be avoided through proper compaction.

61. Environmental Health and Safety (EHS) Manual including plan for COVID 19 pandemic under the Facility implementation is recommended to develop to avoid or reduce any anticipated impact on workers or community (see Annex 9 and 10). Discussion with stakeholders on the specific roles and responsibilities focused on environmental health and safety accountabilities of the working labor law. Authorities are made responsible to document any impact on the project participants (workers, staff and community people) during the Facility operation. The bidding document for contractor consideration and discussion focused on: (i) The plan for performing the tasks on behalf of the client; (ii) The action that has to be taken and/or procedures that has to be followed; (iii) Significant environmental health and safety aspects/hazards that shall be documented after risk assessments; and (iv) Accident that could have been due to the Facility shall be investigated in a timely manner.

C. Environmental Impacts Related to Construction

62. Construction activities will cause environmental impacts that are potentially significant, although in most cases they can be mitigated and, in all cases, effects are temporary. Mitigation measures are stipulated in an EMP which is to be included in bid documents, allowing bidding contractors to include the cost of mitigation in their pricing.

63. There is no storage building construction. So, the preparation of foundations and excavation/drilling for civil works will not be undertaken.

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64. Dust will be released from equipment installation. However, the activities will take place well within the private land owned by the Rice Miller and dust is not expected to cause nuisance or hazard to local people. And when installation takes place during dry conditions, the installation area and stockpiled material shall be sprayed with water to prevent the release of dust

65. Vehicle activity will take place away from peoples’ homes and nuisance and health effects of exhaust emissions will not be significant. For the same reasons, noise nuisance is not expected to be significant. Site manager shall ensure all vehicles are kept in a secure and appropriate location, based on contractor’s campsite (outside or inside the Rice Mill compound). The drivers or users of vehicles shall be trained operators and where appropriate shall have license for operating them. Noise from hammering (for temporary period only) initially during construction period will be monitored and managed through use of new motor or good maintenance.

66. Much of the labor and some of the skilled labor required for the work will be obtained locally, however contractors are likely to bring staff from other parts of Cambodia, who will be accommodated locally during construction, either in rented accommodation or in temporary housing. Interactions with local residents can potentially lead to the spread of communicable diseases, social disturbance and the release of raw sewage from temporary toilets. Potential effects will be mitigated by (i) maximizing employment form local residents, to the extent practicable, (ii) construction of suitable toilets such as pit latrines on sites identified by local communities, and arrangements for grey water treatment and discharge, such as soakage pits, to minimize the release of pollutants into waterways, (iii) arrangements for collection of solid waste, (iv) briefing of workers and awareness raising of the local population on potential risks of infection and communicable diseases, including advice on avoidance of such problems, and (v) allocation of responsibility to an on-site member of the contractor’s staff to ensure that these measures are observed continuously.

67. Site works may pose potential hazards to workers and villagers. Personal Protective Equipment (PPE) shall be issued to workers wherever appropriate including helmet, steel toe-capped boots and hand protection when working on excavations, and dust masks when working in dusty conditions. Provision shall be made for safe storage and use of hazardous materials such as fuels and lubricants. Each contractor shall prepare a site safety plan and obtain approval for it from the supervising agency prior to the start of works. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan.

68. Covid-19 health and safety plan: In view of the COVID 19 pandemic, Contractor shall come up with a COVID 19 health and safety risk management plan to ensure social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

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D. Environmental Impacts Related to Operation

69. The facility will be housed in a large industrial scale building constructed for the purpose and will contain storage and transfer bays and specially designed high capacity machinery for processing functions. Potential health and safety hazards to workers include accidental contact with moving parts, noise nuisance and respiratory problems from dusty conditions. These risks are mitigated by the inclusion of safety railings, and by training and instruction to workers. The mill owner will provide sufficient PPEs to all workers including hard hat (helmet), booth, mask and glove.

70. Power generation by means of a gasifier fed with rice husk will produce exhaust gas. The gasification process causes the organic material of which the husk is formed to be converted to a producer gas, which is a clean fuel, which is then burned to produce electrical power. Gasification results in more complete breakdown of the organic material, and minimal release of particulate pollutants. The feasibility of using gasification depends on the quality and volume of husk produced, and availability of skilled technical services for periodical maintenance of the gasifier plant. A small amount of dust is produced by the gasification process, which shall be collected during regular cleaning of the plant and used by the Rice Miller or provided to local farmers to make use of its nutrient content.

71. In the event that a gasifier does not prove feasible, a diesel generation plant shall be installed. Any diesel generation plant will conform to Electricity Authority of Cambodia standards, will be fitted with exhaust baffles, exhaust fumes shall be released at a height of not less than 15 m above the ground and at least 20 m away from any raised working platform, and shall be subject to regular routine maintenance.

72. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. The dust removal system is expected to bring ambient dust levels within the plant to acceptable levels. However, dust masks will be made available for workers and operators, and dust levels will be monitored. Should dust levels within the plant exceed the national standard (less than 0.33 mg/m3 of total suspended particles in ambient air) the use of dust masks by workers will be made mandatory.

73. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry. The settling ponds are on a raised platform, at least the above the height of 10-year flood levels.

74. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance.

75. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. An assessment of the adequacy of the water supply will be made to test the water quality and quantity. If water from the supply is not potable or available in adequate quantity, alternative sources of water shall be investigated, which may include the collection and storage of rain water (as a partial supply), or use of groundwater.

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Provision shall be made for treatment for use to render it safe for washing purposes, while potable water shall be obtained from a supply approved by the Ministry of Industry, Mines and Energy.

76. The site is prone to periods of intense rainfall during storm events and may be subject to occasional flooding. The Rice Miller has constructed buildings and treatment pond on raised platforms and included provisions for drainage of a specification sufficient for safe draining of flood water.

E. Global, Trans-boundary and Cumulative Impacts

77. The proposed PDS Facility will contribute to expanding the cumulative paddy drying and storage capacity in Cambodia thereby alleviating the current disadvantage to Cambodian farmers whereby they are forced to sell wet paddy to buyers from neighboring countries.

78. The successful installation of dust control and worker safety measures will provide examples of good practice in providing replicable examples of healthy working environments in an industrial setting around the country. Similar measures may be taken up by other industries.

79. The wider availability of safe and high standard grain drying facilities will mean fewer farmers have to resort to on-farm drying, which can be problematic when crops are exposed to contamination by vehicle fumes and similar, and drying is often uneven through the crop, creating most pockets where fungus can develop.

80. Reducing dependence on drying and storage facilities in neighboring countries will have an impact on trans-boundary trade. However, no trans-boundary environmental impacts are envisaged.

VI. ANALYSIS OF ALTERNATIVES

81. The alternative means of ensuring access by farmers to PDS facilities are (i) allowing the existing situation, where facilities in neighboring countries are used, (ii) promotion of on farm drying, and (iii) provision of fewer, larger scale facilities. The existing situation would allow current constraints on profitability to remain, where price is controlled by buyers from neighboring countries, and less thorough on-farm and ad hoc drying continues. The promotion of on-farm drying offers little scope to improve current practices, as many farmers have insufficient land to use for drying surfaces and are nonagricultural flat areas such as road verges, where the crop is subject to contamination by vehicle fumes and pathogens on the ground, as well as uneven drying and the potential for fungal infestation to develop.

82. The “no project” alternative would mean either, the substitution of the subproject with an alternative eligible subproject, or continued reliance on foreign facilities or on-farm facilities. Private companies may take advantage of the opportunity to provide paddy drying, but this may develop over a protracted period in the absence of the subproject which, as a pilot will replicable example of a well designed and constructed facility.

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VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultations and Information Disclosure during design

83. Consultations were conducted from early subproject preparation stage relating to preliminary engineering designs prepared by the consultants and other items concerning to the subproject implementation through visits to the subproject site, commune and PIO during May- June 2020. The subproject was discussed with the Governor’s office, and with the director and staff of the provincial department of agriculture (PDA) in the province.

84. A public consultation meeting was conducted on 29 September 2020 at the subproject site to undertake subproject screening and design tasks through discussions with relevant stakeholders including Rice Miller, villagers including those who have land boundaries with the proposed subproject site, village chief, commune chief, district governor, PIO director and staff, PDOE director, provincial gender focal point, etc. and with the participation of PMO officials & consultants, and DD& CS consultant for PDS Facilities. A total of 24 participants including 7 women participated in the consultation meeting. (See Annex 11).

85. In the consultation meeting, subproject plans were outlined and stakeholders were asked if they had any concerns or other points to raise. The discussion with stakeholders particularly villagers surrounding the rice mill was conducted focusing on potential environmental impact of the proposed Facility. Rapid Environmental Assessment Checklist (REA), EMP, and Grievance Redress Mechanism (GRM) were discussed and agreed upon during consultation process. The results of the public consultation meetings concluded that villagers and authorities at all levels have welcomed the proposed PDS Facility. All of them understand that the proposed Facility will give more benefit to the people in Kouk Khmum commune. Furthermore, the participants whole heartedly welcomed and supported the subproject as the proposed PDS Facility will provide opportunity to them to expand their rice business as the Rice Miller will buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport the paddy very far, and also they can work as labor at the Facility to earn income. The public consultation was organized in an atmosphere free of intimidation or coercion ensuring gender inclusiveness and enabled the incorporation of all relevant views into the project design and arrangements for implementation. Figure 5: Public Consultation meeting with relevant stakeholders and visit to proposed PDS Facility location (dated 29 September 2020)

Discussion/Meeting Photos

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Site visit and Group Photos

B. Further Information Disclosure

86. A summary of this IEE will be presented to commune officials and the public, and to the PIO/PDA/ PDOE in Battambang. Copies will be left for review and during construction and operation, communities in and around the subproject area will be kept informed of construction activities that are likely to cause noise and dust nuisance, or disruption to irrigation flows or roads and pathways. Project profile and progress report will be posted in project website.

VIII. GRIEVANCE REDRESS MECHANISM 87. People living close to a development site may experience some adverse impact during the subproject implementation period. People who may be affected by the subproject or concerned about its environmental impacts are entitled to lodge complaints regarding any aspect of the preparation and implementation of the subproject.

88. The objective of the grievance redress mechanism is to resolve complaints as quickly as possible and at the local level through a process of conciliation; and, if that is not possible, to provide clear and transparent procedures for appeal.

89. A well-defined grievance redress and resolution mechanism is established to resolve grievances and complaints in a timely and satisfactory manner. The PMO has informed and discussed about it with the villagers during the public consultation meeting. All affected persons

Page | 22 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill will be made fully aware of their rights, and the detailed grievance redress procedures will be publicized through an effective public information campaign. The grievance redress process applies to potential environmental issues and includes four steps of which three are followed before complaints may be elevated to a court of law as a last resort, as follows (see Figure 6 below):

Figure 6: Grievance Redress Mechanism

Next Higher Court

Provincial court

Provincial Governor Office (PIO), PDAFF and/or YES Grievanc Provincial Grievance Redress Committee (PGRC) with participation from PMO Program Manager/ Program Director. (if no result elevate to ……) Resolution of Complaint

YES Meeting of the complainant with District Governor, Grievanc Provincial Implementation Office (PIO) Representative, PDAFF officials, Commune Chief, and Representative of the Contractor (if no result elevate to Province level)

Meeting of the complainant-APs with Village Chief, YES Commune Chief and Site Manager of the Contractor (if Grievanc no result elevate to District level)

Complainant-APs and stakeholder inform Village Chief, Commune Chief, Site Manager of the Contractor (before elevate to the District level)

(i) 1st step: Complaints and grievances will be provided verbally or in writing to the village chief or commune chief and/or contractor’s representative. The receiving agent will provide immediate written confirmation of receiving the complaint. If after 15 days the complainant does not hear from the village chief or commune chief and/or contractor’s representative or if he/she is not satisfied with the decision taken in the first stage, the complaint may be brought to the District Office.

(ii) 2nd step: The District Office in cooperation with the Provincial Implementation Office

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(PIO) representative, PDAFF officials, commune chief and contractor’s representative has 15 days within which to resolve the complaint to the satisfaction of all concerned. If the complaint cannot be solved at this stage, the District Office will bring the case to the Provincial Governor Office (PIO) and/or Provincial Grievance Redress Committee (PGRC) and has to inform the complainant.

(iii) 3rd step: The PIO/PGRC in cooperation with the PMO Program Manager/Program Director and contractor meets with the aggrieved party and tries to resolve the situation within 30 days of receiving the complaint and to the satisfaction of all concerned. The PIO/PGRC will make a written decision and submit copies to the executing and implementing agency (MEF/PMO).

(iv) 4th step: If the aggrieved person does not hear from the PIO/PGRC or is not satisfied, s/he can bring the case to Provincial Court. The Court will make a written decision and submit copies to the executing agency and implementing agency. If any party is still unsatisfied with the Provincial Court judgment, he/she can bring the case to a higher- level court.

90. It is recognized that, in many cases, people with a grievance may not have the writing skills or be able to express their grievances verbally, however, complainants are encouraged to seek assistance from other family members, villagers, village heads or community chiefs to have their grievances recorded in writing and to have access to project documentation to ensure that where disputes do occur all the details have been recorded accurately enabling all parties to be treated fairly.

91. The Program Management Office (PMO) under the Program will shoulder all administrative costs incurred in the resolution of grievances and complaints within the project-level grievance redress mechanism. If the complainant seeks grievance redress through local or country-level judicial and administrative mechanisms, the requirements and procedures applicable to the relevant jurisdiction shall apply.

92. All complaints and resolutions will be properly documented in a logbook by the concerned project officials including representative of the contractor and DD & CS firm and be available for the public and review for monitoring purposes. The logbook will be kept in a place accessible to all relevant stakeholders to record complaints and action taken properly during the subproject implementation.

93. Environmental monitoring reports will include the following aspects pertaining to progress on grievances: (i) number of cases registered with the PIO/PGRC, level of jurisdiction (first, second, and third tiers), number of hearings held, decisions made, and the status of pending cases; and (ii) lists of cases in process and already decided upon may be prepared with details such as name, identification with unique serial number, date of notice, date of application, date of hearing, decisions, remarks, actions taken to resolve issues, and status of grievance (i.e. open, closed, and pending).

IX. ENVIRONMENTAL MANAGEMENT PLAN

A. Responsibilities for Environmental Management

94. The environmental management plan (EMP) covers all phases of the subproject implementation from preparation through commissioning and operation, and it aims to ensure the monitoring of environmental impacts and activation of environmental mitigation

Page | 24 Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill measures. Relevant parts of the EMP will be incorporated into the construction, operation, and management of subproject. Environmental protection measures will (i) avoid, and (ii) where avoidance is not possible, mitigate environmental impacts, and (iii) achieve compliance with national environmental regulations and ADB safeguard Policy statement 2009.

95. The mitigation measures required for the design and preconstruction, construction and operation phases of the improved infrastructure are described in Annex 9, where the allocation of responsibility for costs of mitigation are detailed. The PMO has overall responsibility for implementing the EMPs and during the design and construction phases, will be supported by the Provincial Implementation Office (PIO) located at Governor’s office in the province. The PMO will be fully supported by the Detailed Design and Construction Supervision (DD&CS) consultant on safeguard implementation, monitoring and reporting activities. The cross sectorial implementation consultants based at PMO will provide necessary backstopping in review and finalization of reports and recommendation of mitigation measures based on EMP.

96. The EMP should form part of the contract documentation so that the contractor in each case incorporates the cost of mitigation into the bid price, including provision of staff and equipment necessary to carry out all mitigation tasks in full. Preparation of the environment section in the Terms of Reference for bidders for construction contracts and environmental contract clauses for contractors, namely the special conditions (referencing the EMP and monitoring plan) will be prepared and included. The contractor shall review the EMP and shall within 30 calendar days from the date of the Letter of Acceptance submit for approval of the Project Manager the Construction Environmental Management Plan (CEMP) to include any additional or varied environmental management or mitigation measures that the Contractor wishes to apply or considers are desirable. Subject to the approval and amendments required by the Project Manager, the CEMP will be incorporated into the Contract documents, and will be finalized ahead of any contract works commencing.

97. During PDS facility operation, responsibility for mitigation rests primarily with the Rice Miller supported by relevant provincial departments.

98. The budget for implementation of EMP is included in the cost estimates. For details, please refer to summary of environmental management plan as attached in Annex 9.

B. Environmental Monitoring

99. Environmental issues associated with the subproject that potentially warrant monitoring are: (i) compliance with EMPs during construction and operation to ensure that the required monitoring takes place, (ii) noise and dust nuisance during construction, and (iii) noise, dust and safety issues during operation. See the detail environmental monitoring plan in Annex 10.

100. Construction impacts will be limited, partly because construction site is distant from homes, and also because effects will be short lived and, if EMPs are properly implemented, significantly mitigated. No monitoring other than for compliance with EMPs is recommended.

101. It is therefore recommended that monitoring is confined to monitoring for compliance with EMPs and basic testing for noise and dust levels.

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1. Monitoring for Compliance with EMPs

102. To ensure that potential environmental problems are detected and addressed appropriately, environmental monitoring will take place during construction and operation of each subproject. During construction, the key tasks are monitoring the compliance with environmental mitigation measures in the EMP for the subproject, which shall be done by the construction supervision team. During operation, responsibility for monitoring shall rest with the provincial departments.

2. Testing for Noise and Dust Levels

103. The ambient air within grain drying and handling plant will be tested to measure total suspended particles. The required standard is less than 0.33 mg/m3 of total suspended particles, given in Annex 1 of the Sub-decree on Air Pollution and Noise Disturbance (2000). (see Table 3). Tests will be carried out once per year during operation, at each plant.

104. Noise levels will be determined with an integrating noise meter. The maximum noise level in a workshop, factory and industry as specified in Annex 7 of the Sub-decree on Air Pollution and Noise Disturbance (2000) is 85 dB(A). This should be taken as the continuous noise equivalent level of 85 dB(A) Leq, and determined by using an integrating noise meter. Readings and analysis will be undertaken once per year during operation, at each plant. 8

C. Environmental Monitoring Reports

105. To ensure proper and timely implementation of the EMP and adherence to the agreed environmental covenants, the PMO will submit semi-annual environmental monitoring report to the ADB. The semi-annual report will be prepared based on primary and secondary sources of information collected through monitoring and inspections (see the detail in Annex 11: Environmental Monitoring Plan) and the report will be disclosed on the ADB website.

D. Institutional Arrangement and Responsibilities

106. At the feasibility stage of the PDS Facilities following a revised implementation approach the primary management framework overseeing the implementation of the EMP was defined by: 1) the MEF who is the executing agency and has established a PMO to oversee implementation of the subprojects in Battambang, Kampong Thom and Prey Veng provinces; and 2) the PIO located at Governor’s office in these provinces will support and assist the PMO in implementation of these subprojects. The PMO has established a PDS Selection Committee in cooperation with the Ministry of Agriculture, Forestry and Fisheries/National Implementation Office (MAFF/NIO) and the three Provincial Implementation Offices (PIOs) who will participate in the PDS procurement process.

107. The PMO will shoulder all administrative costs incurred in the resolution of grievances and complaints within the project-level grievance redress mechanism and is responsible for implementing the EMPs. During the design and construction phases, the PMO will be supported by the PIOs. The winning contractor shall prepare the CEMP and upon endorsement by the Program Manager will be fully responsible for its implementation. The

8 The results of testing for noise and dust levels during operation will be reflected in the semiannual environmental monitoring reports to be submitted to ADB.

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PMO will be supported by the DD&CS consultants on safeguard implementation, monitoring and reporting activities. The environmental specialist and other cross sectorial implementation consultants of the program will provide necessary backstopping in review and finalization of reports and recommendation of mitigation measures based on EMP. During PDS facility operation, responsibility for mitigation w i l l rest primarily with the Rice Miller supported by relevant provincial departments (PDOE/PDOLVT).

X. CONCLUSION AND RECOMMENDATIONS

108. This IEE process has found that the subproject will not cause significant negative environmental impacts. Potential negative impacts relate mainly to the installation phase and can be managed and brought to acceptable levels through the implementation of the EMP. The Rice Miller has applied and received the Environmental Protection Agreement from PDOE as part of establishing the PDS Facility and improving the business operation performance as attached in Annex 1.

109. The subproject is therefore being classified as Category B according to the environmental assessment and ADB’s classification system. This refers to subprojects that are judged to have some adverse environmental impacts, but can be mitigated by specific EMP. The subproject specific EMP as attached in Annex 9 and environmental monitoring plan as attached in Annex 10 will be implemented to mitigate negative impacts during or after subproject implementation.

110. During consultation meeting and field observation all relevant stakeholders confirmed that the proposed PDS Facility site and its surrounding area have been actively cultivated since the years of conflict, and they did not come across with any UXO in the proposed area. If required, the safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in subproject area and such certification will be included in the semiannual environmental monitoring reports to be submitted to ADB. 111. It is recommended that the EMP is included in the bidding and contract document for works contracts.

112. PMO will monitor and supervise the subproject under the technical support by the Detail Design (DD) and CS consultants to ensure contractors are properly implementing all environmental mitigation measures during construction stage as set out in the IEE, EMP, and CEMP and other environmental safeguards. The PMO will also deploy the cross sectorial implementation consultants based at PMO to provide necessary backstopping in monitoring and supervision of the subproject.

113. In view of the COVID 19 pandemic, Contractor shall come up with a COVID 19 health and safety risk management plan to avoid or reduce any anticipated impact on workers or community as reflected in the EMP (Annex 9) and EMoP (Annex 10). Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

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XI. REFERENCES

▪ Royal Government of Cambodia Sub-Decree No 72 ANRK. BK. (Dated 11 August 1999). ▪ Prakas No. 021 PRK.BST dated 03 February 2020 on EIA Classification for Development Projects. ▪ Water Quality Standard in Public Water Areas for Bio-Diversity Conservation. Annex 4 of Sub-decree on Water Pollution Control, 1999. ▪ Average annual and monthly Rainfall 2011-2018. Provincial Department of Water Resources and Meteorology. ▪ Ambient Air Quality Standard. Annex1 and Annex 7 of Sub-Decree on Air Pollution Control and Noise Disturbance, 2000. ▪ Name of villages, communes and districts of provinces. Minister Interior. 2015. ▪ Water Testing Parameters and Maximum Value. Directorate General of Environmental Protection Laboratory, MOE. ▪ IFReDI.2010. Fisheries Resources in Cambodia-Current Status, Key Issues and Direction. Dr. So Nam. ▪ First Semiannual Report, 2016. Battambang Fisheries Administration Cantonment. ▪ Battambang Development Plan, 2016-2018. ▪ Solid waste management sub-decree No 36 ANRK.BK. D a t e d 2 7 April 1999. ▪ Law on Environmental Protection and Natural Resources Management. The Preah Reach Kram/NS-RKM-1296/36. Dated 24 December 1996. ▪ The sub-decree No 27 ANRK.BK on Water Pollution Control. Dated 6 April 1999. ▪ Ministry of Planning, Poverty Reduction by Capital, Provinces, Municipalities, Districts, Khans, and Communes, Sangkats, Based on Commune Database (CDB) 2004-2012.

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XII. ANNEXES

Annex 1: Agreement of City Rice Mill with PDOE, Battambang

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Kingdom of Cambodia Un-official Translation Nation Religion King

Environmental Protection Agreement

I am Lay Chhun Hang, age 29 years old, Cambodia Nationality, ID Card: 171060639 dated 15 March 2016; Expire date: 14 March 2026, Permanent Address: No. 06, Group 1, Thma Koul Tboung Village, Ta Pung Commune, Thma Koul District, Battambang Province, Representative of City Rice Import Export Co., Ltd.

To: Director of Battambang Provincial Department of Environment

To contribute to environmental protection in the process of social development, I do the following environmental commitments to Battambang Provincial Department of Environment for City Rice Mill business operation located in Kien Kaes 1 village, Kouk Khmum commune, Thma Koul district, Battambang Province, as below:

Provision 1. Ensure management and reduction of dust and debris (paddy rice, corn, rice husks and ashes…..) from the production line by installing appropriate technology and equipment to filter dust and reduce the health effects on neighboring residents.

Provision 2. Ensure proper storage of ash and rice husks with regular watering for protection against dust and debris to avoid harming the lives and crops of the neighbors.

Provision 3. Ensure minimization of noise, vibration, dust, and odor release due to rice mill operation and avoid health hazards to workers and people living nearby due to the release.

Provision 4. Ensure proper management of wastes (ash, rice husks, and sacks) without dumping in public places or areas near water sources affecting society and neighbors.

Provision 5. Ensure proper management of oil wastes and spare parts from repairs, do not dispose off in public places or areas near the sources of water thereby causing leakage or damage to water sources and soil quality. Provision 6. Ensure management of the wastes from guests, workers and kitchen wastes by properly employing trash bins and set up storage tanks for other solid wastes within the rice mill compound.

Provision 7. Ensure traffic management at the entrance and exit gates to avoid traffic jam and possible traffic accidents. Transportation need to follow weight of the load rule to avoid damage to public roads.

Provision 8. Reserve and ensure proper management of temporary parking area, parking lots, and waiting areas to avoid chaos, disorder, or harming to neighbors.

Provision 9.

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Allow Environmental Officer from Battambang Provincial Department of Environment who has valid mission letter to inspect the rice mill site every 30 days to advise on pollution control in the environment.

Provision 10. In case the department or the Ministry of Environment requires me to modify any environmental techniques to comply with the new guidelines and standards, I would completely agree to the guidelines.

Provision11. Volunteer to contribute 500,000 Riels per year as environmental fee to Battambang Provincial Department of Environment.

Provision12. This agreement is valid for one year from the date of this agreement. 30 days prior to the expiry of this agreement, I will submit a request for renewing the agreement to Battambang Provincial Department of Environment for the new term.

Provision13. In the case that I failed to comply with any provision or contrary to this agreement, I shall be fully responsible under the relevant Cambodian Laws, especially Environmental Protection and Natural Resources Law.

Seen and Verified To Director of PDOE

BTB Date:13.10.2020 BTB Date: 13.10.2020 Vice Chief of Environmental Protection Thumb Print of City Rice Office Owner

Chhay Mary Lay Chhun Haing

No. 437/Bor.Sthor.khor.Bor Seen and Approved BTB Date: 13.10.2020 Director of PDOE

Kort Boran

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Annex 2: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation

No Parameter Unit Standard Value A. River 1 pH mg 6.5 – 8.5 2 BOD5 mg 1 – 3 Suspended Solid mg/l 2510 – 100 4 Dissolved Oxygen mg 2.0 - 7.5 5 Coli-form MPN/100ml < B. Lakes and Reservoirs 1 pH mg 6.5 – 8.5 2 COD mg 1 3 Suspended Solid mg 1– – 4 Dissolved Oxygen mg 2.0 - 7.5 5 Coliform MPN/100ml < 6 Total Nitrogen mg 0.1 – 0.6 7 Total Phosphorus mg 0.005 – 0.05 C. Coastal water 1 pH mg 7.0 – 8.3 2 COD mg 2 3 Dissolved Oxygen mg 2– – 4 Coliform MPN/100ml < 5 Oil content mg 0 6 Total Nitrogen mg 0.2 – 1.0 7 Total Phosphorus mg 0.02 – 0.09 Note: l = liter; mg = milligram; ml = milliliter Source: Annex 4 of Sub-decree on Water Pollution Control, 1999

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Annex 3: Land Title of City Rice Mill Issued by PDLMUPC

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Annex 4: Existing Location of City Rice Mill

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Annex 5: Detail Design of PDS facility for City Rice Mill

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Annex 6: Calculation of Capacity Including Raw Materials for PDS facility for City Rice Mill

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Annex 7: Total Annual Rainfall from 2011-2018 in Battambang Province

Year 2011 2012 2013 2014 2015 2016 2017 2018 Average 1,656.9 1,337.8 1,374.0 885.3 1,095.1 960.1 1,350.7 1,181.2 1230.14 Rainfall(mm) Source: Provincial Department of Water Resources and Meteorology, Battambang province.

Annex 7.1: Average Monthly Rainfall from 2011-2018 in Battambang Province

Year/ Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month

2011 - 50.8 35.1 152.7 151.5 107.0 186.8 253.2 289.1 392.2 34.3 4.2

2012 16.2 46.8 57.8 56.3 166.2 73.7 133.6 93.2 356.7 249.4 87.9 -

2013 - - 21.6 35.6 90.1 277.4 152.4 86.4 311.5 275.9 94.3 28.8

2014 - 0.4 2.4 84.1 46.9 69.6 191.0 146.8 88.9 208.7 39.8 6.7

2015 0.3 9.4 6.9 31.0 66.0 147.9 174.9 72.9 281.5 214.2 90.1 -

2016 15.9 1.0 1.2 17.4 115.0 100.4 157.1 95.5 197.0 179.4 65.6 14.6

2017 18.8 0.1 96.8 107.6 118.9 190.9 133.9 184.8 145.0 246.7 100.7 6.5

2018 8.5 3.2 96.0 88.0 165.1 109.3 156.0 137.3 204.3 167.1 19.7 26.7 Average Rainfall (mm) 8.5 8.7 40.4 60.0 109.7 138.5 157.0 116.7 226.4 220.2 71.2 11.9 Source: Provincial Department of Water Resources and Meteorology, Battambang province.

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Annex 8: Rapid Environmental Assessment Checklist Screening Questions Yes No Remarks A. Project Siting Is the Project area adjacent to or within any of the following environmentally sensitive areas? ▪ Cultural heritage site x No cultural heritage sites are adjacent to or within the subproject area. ▪ Protected Area x There are no environmentally sensitive areas within the subproject area. ▪ Wetland x

▪ Mangrove x

▪ Estuarine x

▪ Buffer zone of protected x area

▪ Special area for x protecting biodiversity

▪ Bay x

B. Potential Environmental Impacts Will the Project cause…

Ecological disturbances x The proposed PDS Facility is to be built on privately owned land arising from the and it is not in or nearby any sensitive habitats. Respondents did establishment of a plant or not express any concerns about any loss of ecological values by facility complex in or near construction and operation of the Facility. sensitive habitats?

▪ Eventual degradation of x The Facility includes sewage treatment ponds constructed on a water bodies due to raised platform. Water from the dust removal plant will be discharge of wastes and combined with condensate from the dryer and will be treated in other effluents from plant settling ponds, to enable organic matter to be extracted, and used or facility complex? by the Rice Miller or provided to farmers as a slurry for re-use as a soil conditioner. The settling pond is on a raised platform above the height of 8-year flood levels. There are no major civil works. So, there will be no excavation and silt produced.

▪ Serious contamination of x Not expected as the small scale construction work will use a small soil and groundwater? amount of water only as readymade mixed concrete from supplier will mainly be used. There are also no salinity issues expected at any sites as ground water will not be used. Provision shall be made for safe storage and use of hazardous materials such as fuels and lubricants. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan.

▪ Aggravation of solid waste x Solid wastes from the Facility will be treated in the treatment problems in the area? ponds and organic matter will be extracted, and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.

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Screening Questions Yes No Remarks ▪ Public health risks from x The proposed Facility will be far from local residents and discharge of wastes and nuisance and health effects of exhaust emissions and noise poor air quality; noise and will not be significant. The proposed paddy drying equipment foul odor from plant shall be installed within an existing building constructed on an emissions? area of 0.18ha inside the existing Rice Mill compound of 10 ha of single piece of land owned by the Rice Miller. Responded did not express any concern on the discharge of wastes, noise and foul odor from the current Rice Mill. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. ▪ Short-term construction x Construction work will use a small amount of water only and no impacts (e.g. soil erosion, ground water will be used for construction. Contractor will install deterioration of water and onsite WC for their workers. Noise and vibration from hammering air quality, noise and (for temporary period and short duration only) during construction vibration from period will be monitored and managed through use of new motor construction equipment? or good maintenance. When installation/small works takes place during dry conditions, surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. Good construction practices to mitigate noise and dust will be specified in the EMP and specifications. In addition, most construction activities will be far from local residents and nuisance and health effects of exhaust emissions will not be significant. For the same reasons, noise nuisance is not expected to be significant. ▪ Dislocation or involuntary x Not Applicable as the proposed Facility will be constructed on a resettlement of people? small plot of land (about 1,800 m²) inside the existing Rice Mill compound which is constructed on a 10 ha of single parcel of fully fenced land owned by the Rice Miller (Land title issued by PDLMUPC, Battambang, on 06 July 2018 is attached as Annex 3 to the IEE).

▪ Disproportionate impacts x The Facility will not impact poor, women and children, or other on the poor, women and vulnerable groups negatively. Currently, the Rice Mill employs children, Indigenous 150 villagers including about 70 women and after the completion Peoples or other of the Facility, the Rice Mill may employ about 15 more villagers vulnerable groups? of which 60-70% will be women. The Rice Miller has good

reputation of treating men and women equally and paying same rate for the same task. Contractors will be made aware and proper monitoring and supervision will be done to make sure no child labor is employed during the construction/installation. However, if people are not happy, they can complain through the GRM process established under the project.

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Screening Questions Yes No Remarks ▪ Environmental x Rice cultivation is the predominant land use in the proposed degradation (e.g. erosion, PDS Facility area. The lack of drying facilities is forcing many soil and water farmers to sell their wet paddy directly to buyers from neighboring contamination, loss of soil countries where modern facilities are available. The surrounding fertility, disruption of villages will benefit greatly from establishment of the Facility as wildlife habitat) from the Rice Miller can accommodate more wet paddy from them than intensification of earlier times. The Facility will neither alter agricultural land use agricultural land use to nor modify natural species diversity. supply raw materials for plant operation; and modification of natural species diversity as a result of the transformation to monoculture practices?

▪ Water pollution from x No waste water from this type of drying process is generated as discharge of liquid moisture from wet paddy will evaporate. The Facility includes effluents? sewage treatment ponds constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry. ▪ Air pollution from all plant x When installation/small works takes place during dry conditions, operations? surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. ▪ Gaseous and odor x Power generation by means of a gasifier fed with rice husk will emissions to the produce exhaust gas. The gas is a clean fuel which will be used atmosphere from to produce electrical power. No ash/smoke will be released to the processing operations? environment as the Cyclonic type furnace will be utilized which has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income. ▪ Accidental release of x Provision shall be made for careful loading and unloading, safe potentially hazardous storage and use of hazardous materials such as fuels and solvents, acidic and lubricants. Each contractor shall prepare a site safety plan and alkaline materials? obtain approval for it from the supervising agency prior to the start of works. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan. The drivers or users of excavators and vehicles shall be trained operators and where appropriate shall have license for operating them. ▪ Uncontrolled in-migration x Not Applicable as the proposed Facility is located next to the with opening of roads to National Road 57B and will be constructed on a small plot of land forest area and inside the existing Rice Mill compound which is constructed on a overloading of social 10 ha of single parcel of private land owned by the Rice Miller. infrastructure?

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Screening Questions Yes No Remarks ▪ Occupational health x Protective clothing shall be issued to workers wherever hazards due to fugitive appropriate when doing civil works, and dust masks when dust, materials handling, working in dusty conditions. Noise proof materials for housing will noise, or other process be used to reduce noise from ash room, dust room and operations? machinery. Noise from blower and its drivers will be monitored and managed through good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Risks due to material handlings will be mitigated by the inclusion of safety railings, and by training and instruction to workers. ▪ Disruption of transit x The proposed Facility is located next to the National Road 57B. patterns, creation of noise The Facility will be constructed on a small plot of land inside the and congestion, and existing Rice Mill compound which is constructed on a 10ha of pedestrian hazards single parcel of private land owned by the Rice Miller. However, aggravated by heavy safety precautions such as flagman to regulate traffic will be trucks? provided as specified in the EMP.

▪ Disease transmission x The Contractor will install onsite WC for their workers. To ensure from inadequate waste sanitary conditions in and around the facility, an on-site system of disposal? treatment of sewerage from workers’ toilets will be provided. Additionally, for COVID-19 pandemic, social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, additional hand wash facilities (e.g. pop ups), provision of a welfare attendant for smooth operation, etc. will be ensured. In particular, facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes will be ensured. The Rice Miller will carry out regular fumigation around the compound to destroy temporary breeding places for diseases such as those transmitted by mosquitoes and rodents. ▪ Risks and vulnerabilities x No chemical, biological and radiological hazards are expected related to occupational during construction and operation. For physical safety, PPE and health and safety due to pit latrines will be provided to all workers. Contractor will physical, chemical, and provide orientation to all workers about using PPE, first aids kit, biological hazards during etc. To prevent pollution of soil and water surface/ groundwater: project construction and (i) storage facilities for fuels, oil, cement, and chemicals will be operation? within secured areas on impermeable surfaces, provided with bunds and cleanup installations. (ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that affects the soil and water sources. (iii) fuel storage and refilling areas will be located at least 50 m from the construction sites and will be protected by temporary drainage bunds to contain spills. (iv) During construction, care will be taken while loading and unloading of fuel stored at the campsite. During operation, the Rice miller will continue to provide PPE, first Aids kit, etc. and training courses to workers on safety standard; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE.

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Screening Questions Yes No Remarks ▪ Large population increase x The number of non-local workers will be small in number. If during project necessary, construction contractors will be required to provide a construction and worker’s camp with independent basic facilities. The Rice Miller operation that cause has currently employed 150 workers including 70 women and increased burden on upon completion of PDS Facility, the Rice Miller is expected to social infrastructure and engage 15 more villagers. Currently, the Rice Miller has services (such as water accommodation facilities totaling 34 bedrooms (21 rooms for supply and sanitation workers and 13 rooms for staff) and 16 toilets cum bathrooms (12 systems)? are outside and 4 are inside the building for staff and guest). The Rice Miller carries out monthly fumigation around the compound, provides sanitation orientation to the workers, have assured water supply to all people working in the rice mill, and provides filter water for drinking and cooking purposes. During the public consultation meeting, the Rice Miller mentioned that they have ensured good quality water to workers and staff through 3 pumping wells and 1 pond and they always conduct water testing to ensure its quality. ▪ Social conflicts if workers x Priority in labor employment will be given to local residents from other regions or and non-local workers will be small in number. countries are hired?

▪ Community health and x Construction area will be clearly demarcated and access safety risks due to the controlled. Safety warnings and diversion signboards will be transport, storage, and employed. First aids kit, additional hand washing facilities (e.g. use and/or disposal of pop ups) to the usual welfare, particularly facilities such as hand materials likely to create sanitizer -minimum 60% alcohol based, adequate supplies of physical, chemical and soap and fresh water and suitable and sufficient rubbish bin for biological hazards during hand towels with proper and regular removal and disposal of construction, operation waste will be provided to the workers, project staff and and decommissioning? stakeholders.

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A Checklist for Preliminary Climate Risk Screening

Screening Questions Score Remarks

Location Is siting and/or routing of the project (or its 0 The paddy drying equipment will be and components) likely to be affected by climate installed inside an existing building Design of conditions including extreme weather related constructed within the existing Rice Mill project events such as floods, droughts, storms, compound which is elevated from the landslides? ground level. The proposed location has never been flooded after the big flood in 2011 when water was about 1m above the ground level. The Rice Miller has raised the land about 1.3m above the ground level in 2012 which is considered good enough for construction of PDS facilities. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area. The Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water if this occurs. The drainage system is sufficient to prevent the formation of ponds and muddy patches within the facility compound. The settling pond is on a raised platform above the height of 8- year flood levels. Would the project design (e.g. the clearance for 0 Not applicable. bridges) need to consider any hydro- meteorological parameters (e.g., sea-level, peak river flow, reliable water level, peak wind speed etc.)? Materials Would weather, current and likely future climate 0 Not applicable. and conditions (e.g. prevailing humidity level, Maintena temperature contrast between hot summer days nce and cold winter days, exposure to wind and humidity hydro-meteorological parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)? Would weather, current and likely future climate 0 Not applicable. conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s)? Performa Would weather/climate conditions and related 1 Climate extreme events may affect the nce of extreme events likely affect the performance (e.g. supply of paddy to the Facility thereby project annual power production) of project output(s) (e.g. affecting the performance of the Facility. outputs hydro-power generation facilities) throughout their design life time?

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Annex 9: Environmental Management Plan Summary

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Design and Preconstruction

Risk of flooding The paddy drying equipment will be installed inside an existing building constructed within Include in DD/CS Firm (IRE) MEF/PMO the existing Rice Mill compound which is elevated from the ground level. The proposed construction location has never been flooded after the big flood in 2011 when water was about 1m budget above the ground level. The Rice Miller has raised the land about 1.3m above the ground level in 2012 which is considered good enough for construction of PDS facilities. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area. The existing Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water if this occurs. The existing drainage system is sufficient to prevent the formation of ponds and muddy patches within the facility compound. The settling pond is on a raised platform above the height of 8- year flood levels. Lack of mechanism to Establish and function a grievance redress mechanism (GRM), as described in the IEE PMO budget PMO /PIO MEF/PMO address environmental (Section 8). complaints Make public the existence of the GRM through public awareness campaigns and PMO budget DD/CS firm (IRE)/ MEF/PMO display poster of GRM at the subproject site. PIO/PMO

Ensure that names and contact numbers of representatives (Contractor site Manager, PMO budget Contractor/DDCS MEF/PMO Village -Commune Chief, PIO and MEF/PMO representative) are placed on the notice firm (IRE)/ boards outside the construction site and at local government offices (e.g., provincial PIO/PMO and commune levels).

Build capacity of the contractor and PIO on implementation and monitoring of EMP PMO budget PMO MEF/PMO

Prepare a logbook and put at a place accessible to all relevant stakeholders to record Include in Contractor/DDCS MEF/PMO complaints and action taken properly during the subproject implementation. construction firm (IRE)/ Budget PIO/PMO

Effects on homes A Land Acquisition and Resettlement Plan for the Facility is not relevant as the land is Rice Miller Rice Miller MEF/PMO/PIO and Property. privately owned. The Facility will be built well within the privately-owned land and there will be no need for any compensation.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Environmental, Health Measures to ensure occupational health and safety will include: Include in Contractor DDCS firm (IRE)/ and Safety (EHS) - Contractor shall be required by the PMO to ensure that their workers and other construction MEF/PMO staff engaged in the proposed constructions are in a safe environment. budget - Contractor shall ensure that (i) all reasonable steps are taken to protect any person on the site from health and safety risks; (ii) the construction site is a safe and healthy workplace; (iii) machineries and equipment are safe; (iv) adequate training or instruction for occupational health and safety is provided; (v) adequate supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety. - Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE) - Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites. - Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings) Community health and safety will be safeguarded by: - Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated to its original condition after construction. - Implementing safety measures around the construction sites to protect the public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites. - Maximizing employment of local residents to the extent practicable.

COVID-19 Pandemic - Contractor shall ensure that social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. are provided or followed. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out and provided. Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Construction The selected contractor shall review the EMP and submit to the Project Manager the Include in Contractor DD/CS firm (IRE)/ Environmental CEMP to include any additional or varied environmental management or mitigation construction MEF/PMO Management Plan measures such as (i) safety of workers and local population at construction site and budget (CEMP) campsite; (ii) pprovision of adequate PPE and orientation on safety to workers, (iii) safe storage and use of hazardous materials such as fuels and lubricants, (iv) maximizing employment from local residents, (v) construction of suitable toilets such as pit latrines, and arrangements for grey water treatment and discharge, such as soakage pits, (vi) arrangements for collection of solid waste, (vii) provision of adequate clean water for drinking and electricity for the worker staying overnight in the safe campsite, (viii) provision of primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health including safety from COVID 19, (ix) awareness raising of workers and local population on potential risks of infection and communicable diseases, and (x) allocation of responsibility to an on-site member of the contractor’s staff to ensure that these measures are observed continuously.

Construction Phase

Effects associated with The proposed works includes small civil works and no excavation of soil or borrow pit Include in Contractor DD/CS firm (IRE)/ the use of excavated is foreseen. But if such case arises, the contractor will construction MEF/PMO soil and/or laterite for (i) Re-use excavated material to the extent practicable budge PDS Facilities construction. (ii) Obtain materials from licensed quarries (iii) Enter in to appropriate agreements with landowners for borrow sites, and landscaping works to use borrow sites, in accordance with the agreements made with landowners (iv) Not be allowed to dispose the excavated soil into water body or other free land without local authority permit Release of silt from the The proposed works includes small civil works and no excavation of soil is foreseen. But Include in Contractor DD/CS firm (IRE)/ site excavated due to if such case arises, the contractor will conduct (i) Adequate supervision of the works, construction MEF/PMO the subproject (ii) Discretionary use of silt traps where warranted, (iii) Careful placing of excavated budget implementation material, and (iv) Clean the silt after daily work. Water / Pollution from (i) Wastewater from the camp sites discharged by building latrine with good septic Include in Contractor DD/CS firm (IRE)/ construction waste tank, construction MEF/PMO water. (ii) Transporting waste residue to dispose at approved dumpsites by authority to avoid budget contamination of the people household, agricultural land and waterways surrounding the location, and (iii) Provide regular truck maintenance to improve the condition and store the oil properly

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Risk of contamination of The Contractor will install onsite WC for their workers. To ensure sanitary conditions in Include in Contractor DD/CS firm (IRE)/ nearby waterways and around the facility, an on-site system of treatment of sewerage from workers’ toilets construction MEF/PMO will be provided. The existing Facility includes provision for drainage of a specification budget sufficient to handle storm-water flows, and safe draining of storm water if this occurs.

Health risks to worker When small civil works/installation takes place during dry conditions, surfaces and Include in Contractor DD/CS firm (IRE)/ from dust pollution stockpiled material shall be sprayed with water to prevent the release of dust. The construction MEF/PMO proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence budget no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions. Risks of unsanitary The paddy drying equipment will be installed inside an existing building constructed within Include in Contractor DD/CS firm (IRE)/ working and grain the existing Rice Mill compound which is elevated from the ground level. The proposed construction MEF/PMO storage conditions location has never been flooded after the big flood in 2011 when water was about 1m budget during flood events above the ground level. The Rice Miller has raised the land about 1.3m above the ground level in 2012 which is considered good enough for construction of PDS facilities. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area. The settling pond is on a raised platform above the height of 8-year flood levels. The Contractor will install onsite WC for their workers and stakeholders. To ensure sanitary conditions in and around the Facility, an on-site system of treatment of sewerage from Hazardous materials Toworkers’ prevent toilets pollution will beof soilprovided. and water surface/groundwater: Include in Contractor DD/CS firm (IRE)/ during subproject (i) Storage facilities for fuels, oil, cement, and chemicals will be within secured construction MEF/PMO implementation areas on impermeable surfaces, provided with bunds and cleanup installations. budget (ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that is going to affect soil and water sources. (iii) Fuel storage and refilling areas will be located at least 50m from construction sites and will be protected by temporary drainage bunds to contain spills. (iv) Be careful in loading and unloading fuel during the construction activities.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

(i) Equipment will be maintained to a high standard to ensure efficient running and fuel-Include in Contractor DD/CS firm (IRE)/ Air quality burning. construction MEF/PMO (ii) High- horsepower equipment will be provided with tail gas purifiers. budget (iii) All vehicle emissions will be in compliance of with relevant Cambodian emission standards.

Dust control (i) Good practices on dust control during and after the operation such as material Include in Contractor DD/CS firm (IRE)/ stockpiles, concrete mixing equipment will be equipped with dust shrouds construction MEF/PMO (ii) Water spraying for suppression soil dust or any other particulates and budget maintenance of driving surfaces will be standard site management practices (iii) Vehicles carrying soil, sand or other fine materials to and from the construction sites will be covered.

Noise and Vibration/ Construction during night time within 280m of residences shall be strictly prohibited. Include in Contractor DD/CS firm (IRE)/ Noise impacts on During daytime construction, contractor will ensure that: construction MEF/PMO sensitive receivers (i) Sites for concrete- mixing plants and similar activities will be located at least 1 km budget

away from residences and schools; and (ii) Temporary anti-noise barriers will be installed to shield any schools or residences within 100m of the construction site. Borrow pit /quarry for The proposed works includes small civil works and no excavation of soil is foreseen. But Include in Contractor DD/CS firm (IRE)/ getting soil for if such case arises, the Contractor have to include orientation to all workers on borrow pit construction MEF/PMO subproject construction budget protection to avoid the danger (i.e. prevent cattle and people – specifically children falling into the borrow pit during and after construction activities). Contractor will ensure to: • Install fence around the pit and put up warning signboard during the construction activities, and • Back fill with soil after construction activities are completed.

Use of land for storage (i) Contractor will provide compensation to landowners by early in a month. Include in Contractor DD/CS firm (IRE)/ and campsite (ii) In cases where landowners temporarily provide their land to the contractor to build construction MEF/PMO camp site, it will be based on a contract agreement (details will be stated in contract budget agreement) (iii) After completing works, contractor will carry out restoration of land to former condition or better, according to agreements formed with landowners. Effects of vehicle Although the construction will take place inside privately owned land but the contractor Include in Contractor DD/CS firm (IRE)/ access related to daily has to carry out: (i) careful supervision of vehicle movements to ensure minimal damage construction MEF/PMO operational to farmland and vegetation, etc. if any and (ii) minimal disturbances to human beings, budget management children going to school and animal.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Effects of the temporary (i) Assigning the responsibility of the contractor’s staff, workers and local people’s Include in Contractor DDCS firm (IRE)/ worker populations welfare to a senior member of the contractor’s staff construction MEF/PMO staying in a camp site (ii) Maximizing employment of local residents to the extent practicable. budget

(iii) Construction of suitable toilets such as pit latrines on sites. (iv) Providing electricity to all workers staying overnight. (v) Providing primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such as soakage pits, to minimize release of pollutants into waterways. (vii) Orientation to the workers on dangers of communicable diseases and COVID -19 pandemic such as social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hand for Covid-19 health and safety plan (in Khmer Version) at campsite. Safety hazards to Contractor work plan have to include allocation of responsibility for site safety to the Include in Contractor DD/CS firm (IRE)/ workers and local contractor’s site supervisors to ensure all reasonable safety measures, have been taken construction MEF/PMO people during up. budget construction (i) Prepare and provide enough safety protection clothing and equipment, flagman, sign boards, etc. and place hazard warnings. (ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and contractor’s site supervisors staff. Occurrence of water Contractor work plan during construction have to include raising awareness to the Include in Contractor DD/CS firm (IRE)/ related diseases workers on hazards posed by poor sanitation and use of untreated water for drinking construction MEF/PMO and bathing. budget Operation phase

Maintenance of Contractor work plan have to include technical training/orientation to all stakeholders Include in Contractor DD/CS firm (IRE)/ equipment and avoiding (operators, workers, managers etc.) involved on work routine and periodic maintenance, construction MEF/PMO damage to the assets quality of equipment, and raw material to be used based on contract document. budget

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Water pollution from No waste water from this type of drying process is generated as moisture from wet Rice Miller Rice Miller PDOE, MEF/ discharge of liquid paddy will evaporate. To ensure sanitary conditions in and around the facility, an on-site PMO/PIO effluents system of treatment of waste water The existing from workers’ toilets will be provided. Facility includes sewage treatment ponds constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry. Dust control The proposed Facility will use Cyclonic type furnace which has no exhaust stack and Rice Miller Rice Miller PDOE, MEF/ hence no ash/smoke will be released to the environment. Dust produced by the drying PMO/PIO process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions. Noise and Vibration/ Noise proof materials for housing will be used to reduce noise from ash room, dust Rice Miller Rice Miller PDOE, MEF/ Noise impacts on room and machinery. Noise from blower and its drivers will be monitored and managed PMO/PIO sensitive receivers through good maintenance. Noise within the facility will be reduced by the inclusion of

noise baffles on machinery and ear protection is provided where necessary. Risks and vulnerabilities Rice miller will continue to provide PPE, first aids kit, additional hand washing facilities Rice Miller Rice Miller PDOLVT/PDOE/M related to occupational (e.g. pop ups) to the usual welfare, particularly facilities such as hand sanitizer -minimum EF/PMO/ PIO health and safety during 60% alcohol based, adequate supplies of soap and fresh water and suitable and sufficient operation rubbish bin for hand towels with proper and regular removal and disposal of waste, etc. and training courses to workers on safety standard; include safety railings to mitigate risks due to material handlings and provide training and instruction to workers; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE.

Residue of husk Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Rice Miller Rice Miller PDOE/MEF/ (Ash)/Waste i. Ash will be collected at the ash room and use as fertilizer by the Rice Miller PMO/PIO himself or may sell to farmers to generate extra income. ii. Husk will be used as biomass fuel by the Rice Miller for their furnace/burner. iii. Ash will not be allowed to dispose into water bodies.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Potential Mitigation measure (s) Cost Responsibility Supervising Environmental Impact Allocation for Agency Implementation

Garbage/Waste i. Provide specific basket or bucket for kitchen garbage disposal (suitable and Rice Miller Rice Miller PDOE/MEF/ generation by workers sufficient rubbish bin for hand towels with proper and regular removal and PMO/PIO disposal of waste). ii. Make arrangements for collection of solid waste. iii. Make arrangements for grey water treatment and discharge, such as soakage pits. iv. Assign specific role and responsibility and clear schedule for maintenance and collection of all waste.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Annex 10: Environmental Monitoring Plan Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Design and Preconstruction Phase

Risk of flooding The paddy drying equipment will be installed inside an existing Site of proposed PDS Detailed design Quarterly -follow Resident Engineer Include in building constructed within the existing Rice Mill compound which is Facility for City Rice Mill and construction up record and construction elevated from the ground level. The proposed location has never been located in Kien Kaes 1 supervision. report Budget flooded after the big flood in 2011 when water was about 1m above village, Kouk Khmum the ground level. The Rice Miller has raised the land about 1.3m above commune, Thma Koul the ground level in 2012 which is considered good enough for district, Battambang construction of PDS facilities. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area. The existing Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water if this occurs. The existing drainage system is sufficient to prevent the formation of ponds and muddy patches within the facility compound. The settling pond is on a raised platform above the height of 8-year flood levels. Lack of Establish and function a grievance redress mechanism (GRM), as described Site of proposed PDS Public information Quarterly follow Environment PMO budget mechanism to in the IEE (Section 8). Facility for City Rice Mill booklet. up record and Specialist, Resident address located in Kien Kaes 1 report Engineer and Site Make public the existence of the GRM through public awareness campaigns environmental village, Kouk Khmum Manager of the and display poster of GRM at the subproject site. Complaints commune, Thma Koul contractor Ensure that names and contact numbers of representatives (Contractor site district, Battambang List of contact Manager, Village -Commune Chief, PIO and MEF/PMO representative) are person and placed on the notice boards outside the construction site and at local participant list government offices (e.g., provincial and commune levels). Build capacity of the contractor and PIO on implementation and monitoring Training of EMP document and Training program Prepare a logbook and put at a place accessible to all relevant stakeholders Logbook Include in to record complaints and action taken properly during the subproject construction implementation. Budget Effects on A Land Acquisition and Resettlement Plan for the Facility is not relevant as Site of proposed PDS Land title and Quarterly – Site Manager of the Include in homes and the land is privately owned. The Facility will be built well within the privately -Facility for City Rice Mill observation follow up record contractor and construction Property. owned land and there will be no need for any compensation. located in Kien Kaes 1 and report Resident Engineer. Budget village, Kouk Khmum commune, Thma Koul district Battambang

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

EHS Measures to ensure occupational health and safety will include: Site of proposed PDS List of skilled labor Monthly and Site Manager of the Include in - Contractor shall be required by the PMO to ensure that their workers and Facility for City Rice Mill and worker, list of quarterly – contractor and construction other staff engaged in the proposed constructions are in a safe environment. located in Kien Kaes 1 equipment for follow up report Resident Engineer. Budget village, Kouk Khmum contract - Contractor shall ensure that (i) all reasonable steps are taken to protect any commune, Thma Koul implementation, person on the site from health and safety risks; (ii) the construction site is a safe district, Battambang water basin or and healthy workplace; (iii) machineries and equipment are safe; (iv) adequate bucket,first aid kit training or instruction for occupational health and safety is provided; (v) adequate supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety. - Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE)

- Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites.

- Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings) Community health and safety will be safeguarded by:

- Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated

to its original condition after construction.

- Implementing safety measures around the construction sites to protect the

public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites. - Maximizing employment of local residents to the extent practicable. COVID-19 Pandemic Contractor shall ensure that social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet,

provision of additional hand wash facilities (e.g. pop ups), provision of

mask, provision of a welfare attendant for smooth operation, etc. are provided or followed. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap

and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Construction The selected contractor shall review the EMP and submit to the Project Site of proposed PDS Construction Daily and Site Manager of the Include in Environmental Manager the CEMP to include any additional or varied environmental Facility for City Rice Mill or schedule and bill Monthly records contractor and construction Management management or mitigation measures such as (i) safety of workers and local within 5km of site earth of quantity Resident Engineer Budget Plan (CEMP) population at construction site and campsite; (ii) provision of adequate PPE work. and orientation on safety to workers, (iii) safe storage and use of hazardous materials such as fuels and lubricants, (iv) maximizing employment from local residents, (v) construction of suitable toilets such as pit latrines, and arrangements for grey water treatment and discharge, such as soakage pits, (vi) arrangements for collection of solid waste, (vii) provision of adequate clean water for drinking and electricity for the worker staying overnight in the safe campsite, (viii) provision of primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health including safety from COVID 19, (ix) awareness raising of workers and local population on potential risks of infection and communicable diseases, and (x) allocation of responsibility to an on-site member of the contractor’s staff to ensure that these measures are observed continuously.

Construction Phase

Effects associated The proposed works includes small civil works and no excavation of - Site of proposed PDS Construction Daily and Site Manager of the Bill of quantity with the use of soil or borrow pit is foreseen. But if such case arises, the contractor Facility for City Rice Mill or schedule and bill Monthly records contractor and in the contract excavated soil will within 5km of site earth of quantity Resident Engineer award and/or laterite for (i) Re-use excavated material to the extent practicable, work. PDS Facilities (ii) Obtain materials from licensed quarries, -List of construction construction. (iii) Enter in to appropriate agreements with landowners for borrow sites, and material landscaping works to use borrow sites, in accordance with the agreements made with landowners, (iv) Not be allowed to dispose the excavated soil into water body or other free land without local authority permit.

Release of silt from The proposed works includes small civil works and no excavation of Site of proposed PDS Observation, Daily and Site Manager of Bill of quantity the site excavated soil or borrow pit is foreseen. But if such case arises, the contractor Facility for City Rice Mill the will crosschecking Monthly records in the contract due to the located in Kien Kaes1 with Rice Miller based on the contractor and award subproject (i) Adequate supervision of the works, village, Kouk Khmum and stakeholders specific Resident Engineer implementation (ii) Discretionary use of silt traps where warranted, commune, Thma Koul construction district, Battambang (iii) Careful placing of excavated material, and schedule (iv) Clean the silt after daily work. Page | 65

Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Water / Pollution (i) Wastewater from the camp sites discharged by building latrine with Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity from good septic tank. Facility for City Rice Mill cross checking based on the contractor, in the contract construction (ii) Transporting waste residue to dispose at approved dump sites by located in Kien Kaes 1 with Rice Miller specific work Resident Engineer, award wastewater authority to avoid contamination of the people household, agricultural village, Kouk Khmum and stakeholders Rice Miller and land and waterways commune, Thma Koul Village Chief district, Battambang (iii) Provide regular truck maintenance to improve the condition and store the oil properly Risk of The Contractor will install onsite WC for their workers. To ensure sanitary Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity contamination of conditions in and around the facility, an on-site system of treatment of Facility for City Rice Mill cross checking based on the contractor, in the contract nearby waterways sewerage from workers’ toilets will be provided. The existing Facility located in Kien Kaes 1 with Rice Miller specific work Resident Engineer, award includes provision for drainage of a specification sufficient to handle storm- village, Kouk Khmum and stakeholders Rice Miller and water flows, and safe draining of storm water if this occurs. commune, Thma Koul Village Chief district, Battambang Health risks to When small civil works/installation takes place during dry conditions, Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity worker from dust surfaces and stockpiled material shall be sprayed with water to prevent the Facility for City Rice Mill cross checking based on the contractor, in the contract pollution release of dust. The proposed Facility will use Cyclonic type furnace which located in Kien Kaes 1 with Rice Miller specific work Resident Engineer, award has no exhaust stack and hence no ash/smoke will be released to the village, Kouk Khmum and stakeholders Rice Miller and environment. Dust produced by the drying process will be collected by commune, Thma Koul Village Chief passing dust laden air from the dryer into a chamber where water is district, Battambang introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions. Risks of unsanitary The paddy drying equipment will be installed inside an existing Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity working and grain building constructed within the existing Rice Mill compound which is Facility for City Rice Mill cross checking based on the contractor, Resident in the contract storage conditions elevated from the ground level. The proposed location has never located in Kien Kaes 1 with Rice Miller specific work Engineer, Rice award during flood events been flooded after the big flood in 2011 when water was about 1m village, Kouk Khmum and stakeholders Miller and Village above the ground level. The Rice Miller has raised the land about commune, Thma Koul Chief 1.3m above the ground level in 2012 which is considered good district, Battambang enough for construction of PDS facilities. The recent heavy flooding (2020) had no effect on the proposed PDS Facility area. The settling pond is on a raised platform above the height of 8-year flood levels. The Contractor will install onsite WC for their workers and stakeholders. To ensure sanitary conditions in and around the Facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Hazardous To prevent pollution of soil and water surface/groundwater: Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity materials during (i) Storage facilities for fuels, oil, cement, and chemicals will be within Facility for City Rice Mill cross checking based on the contractor, in the contract subproject secured areas on impermeable surfaces, provided with bunds and located in Kien Kaes 1 with Rice Miller specific work Resident Engineer, award implementation cleanup installations. village, Kouk Khmum and stakeholders Rice Miller and commune, Thma Koul Village Chief (ii) The contractor will not use the spilled materials related to the vehicle, district, Battambang machinery, and equipment that is going to affect to soil and water sources. . (iii) Fuel storage and refilling areas will be located at least 50m from construction sites that will be protected by temporary drainage bunds to contain spills. (iv) Be careful in loading and unloading fuel during the construction activities. (i) Equipment will be maintained to a high standard to ensure efficient Site of proposed PDS Observation, Monthly records Site Manager of the Bill of quantity Air quality running and fuel-burning. Facility for City Rice Mill or cross checking based on the contractor, in the contract (ii) High- horsepower equipment will be provided with tail gas purifiers. surrounding location of with Rice Miller specific work Resident Engineer, award the subproject, located in and stakeholders Rice Miller and (iii) All vehicle emissions will be in compliance of with relevant Cambodian Kien Kaes 1 village, Kouk Village Chief emission standards. Khmum commune, Thma Koul district, Battambang

Dust control (i) Good practices on dust control during and after the operation such as Site of proposed PDS Observation, Daily and Site Manager of the Bill of quantity material stockpiles, concrete mixing equipment will be equipped with dust Facility for City Rice Mill or record, cross Monthly records contractor, in the contract shrouds. surrounding location of checking with Rice based on the Resident award the subproject, located in specific work (ii) Water spraying, at least 2 times per day, for suppression soil dust or any Miller and Engineer, Rice other particulates and maintenance of driving surfaces will be standard site Kien Kaes 1 village, Kouk stakeholders Miller and Village Khmum commune, Thma management practices. Chief Koul district, Battambang (iii) Vehicles carrying soil, sand or other fine materials to and from the construction sites will be covered.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Noise and Construction during night time within 280m of residences shall be strictly Site of proposed PDS Observation, Daily and Site Manager of the Bill of quantity Vibration/ prohibited. During daytime construction, contractor will ensure that: Facility for City Rice Mill or record, cross Monthly records contractor, in the contract Noise impacts on (i) Sites for concrete- mixing plants and similar activities will be located at surrounding location of checking with Rice based on the Resident award sensitive receivers least 1 km away from residences and schools; and the subproject, in Kien Miller and specific work Engineer, Rice Kaes 1 village, Kouk (ii) Temporary anti-noise barriers will be installed to shield any schools or stakeholders Miller and Village Khmum commune, Thma Chief residences within 100m of the construction site. Koul district, Battambang

Borrow pit /quarry The proposed works includes small civil works and no excavation of Location of soil Observation, Monthly and Site Manager of the Bill of quantity for getting soil for soil is foreseen. But if such case arises, Contractor have to include collections. record, cross quarter records contractor, in the contract subproject orientation to all workers on borrow pit protection to avoid the danger (i.e. checking with Rice Resident award construction prevent cattle and people – specifically children falling into the borrow pit Miller/ Land owner Engineer, Rice during and after construction activities). Contractor will ensure to: and stakeholders Miller/ Land owner (i) Install fence around the pit and put up warning signboard during the and Village Chief construction activities, and (ii) Back fill with soil after construction activities are completed.

Use of land for (i) Contractor will provide compensation to landowners by early in a Site of proposed PDS Contract Monthly Site Manager of the Bill of quantity storage and month. Facility for City Rice Mill or agreement payment report Contractor in the contract campsite (ii) In cases where landowners temporarily provide their land to the surrounding location of between award contractor to build camp site, it will be based on a contract agreement the subproject, located in contractor and (details will be stated in contract agreement) Kien Kaes 1 village, Kouk landowner Khmum commune, Thma (iii) After completing works, contractor will carry out restoration of land to Koul district, Battambang former condition or better, according to agreements formed with landowners. .

Effects of vehicle Although the construction will take place inside privately owned land but the Site of proposed PDS Check to verify Monthly and Site Manager of the Bill of quantity access related to contractor has to carry out: (i) careful supervision of vehicle movements to Facility for City Rice Mill or The contractor Quarterly report contractor and in the contract daily operational ensure minimal damage to farmland and vegetation, etc. if any and (ii) surrounding location of rule book and Resident Engineer, award management minimal disturbances to human beings, children going to school and animal. the subproject, located in license of driving Rice Miller and Kien Kaes 1 village, Kouk Village Chief Khmum commune, Thma Koul district, Battambang

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Effects of the (i) Assigning the responsibility of the contractor’s staff, workers and local Existing workers Observation on Quarterly and Site Manager of the Bill of quantity temporary worker people’s welfare to a senior member of the contractor’s staff campsite and the worker site operation based on the contractor and in the contract populations (ii) Maximizing employment of local residents to the extent practicable. from the villages. including list and operation status Resident Engineer, award CV of the worker Rice Miller and staying in a camp (iii) Construction of suitable toilets such as pit latrines on sites site Village Chief (iv) Providing electricity to all workers staying overnight. . (v) Providing primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such as soakage pits, to minimize release of pollutants into waterways. (vii) Orientation to the workers on dangers of communicable diseases and COVID -19 pandemic such as social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out and provided. Contractor will post the MoH’s guidance on washing hand for Covid-19 health and safety plan (in Khmer Version) at campsite.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Safety Contractor work plan have to include allocation of responsibility for site Existing workers Labor Law in Quarterly and Site Manager of the Bill of quantity Hazards to safety to the contractor’s site supervisors to ensure all reasonable safety campsite and the worker 1999 of Royal based on the contractor and in the contract workers and local measures, have been taken up. from the villages. Government operation status Resident Engineer award people during (i) Prepare and provide enough safety protection clothing and Cambodia Rice Miller and construction equipment, flagman, sign boards, etc. and place hazard warnings. Village Chief (ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and contractor’s site supervisors staff.

Occurrence of Contractor work plan during construction have to include raising awareness Site of proposed PDS Specific water Based on the Contractor, Include in water related to the workers on hazards posed by poor sanitation and use of untreated Facility for City Rice Mill or company or shop diseases Commune construction diseases water for drinking and bathing. surrounding location of address and list of occurred Chief, health Budget the subproject, located in patients. centers, village Kien Kaes 1 village, Kouk Collection of chief, Rice Miller, Khmum commune, Thma sample and PIO and other Koul district, Battambang laboratory stakeholders . analysis.

Operation phase

Maintenance of Contractor work plan have to include technical training/orientation to all Site of proposed PDS Operation and Quarterly report Site Manager of the Include in equipment and stakeholders (operators, workers, managers etc.) involved on work Facility for City Rice Mill maintenance contractor, construction avoiding damage routine and periodic maintenance, quality of equipment, and raw located located in Kien schedule Resident Engineer, Budget to the assets material to be used based on contract document. Kaes 1 village, Kouk Rice Miller, and Khmum commune, Thma other stakeholder Koul district, Battambang

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Water pollution No waste water from this type of drying process is generated as moisture Site of proposed PDS Operation and Quarterly report Rice Miller, PDOE/ Rice Miller from discharge of from wet paddy will evaporate. To ensure sanitary conditions in and Facility for City Rice Mill or maintenance MEF/PMO/PIO liquid effluents around the facility, an on-site system of treatment of waste water surrounding location of schedule from workers’ toilets will be provided. The existing Facility includes the subproject, in Kien sewage treatment ponds constructed on a raised platform. Water from the Kaes 1village, Khmum dust removal plant will be combined with condensate from the dryer and will commune, Thma Koul be treated in settling ponds, to enable organic matter to be extracted, and district, Battambang used by the Rice Miller or provided to farmers as a slurry. Dust control The proposed Facility will use Cyclonic type furnace which has no exhaust Site of proposed PDS Operation and Quarterly report Rice Miller, PDOE/ Rice Miller stack and hence no ash/smoke will be released to the environment. Dust Facility for City Rice Mill or maintenance MEF/PMO/PIO produced by the drying process will be collected by passing dust laden air surrounding location of schedule from the dryer into a chamber where water is introduced by a series of the subproject, in Kien sprayers. The water spray causes the dust to collect and form a slurry which Kaes 1 village, Kouk is non-toxic and can be provided to famers for re-use as a soil conditioner. Khmum commune, Thma Protective clothing such as dust masks shall be issued to workers when Koul district, Battambang working in dusty conditions.

Noise and Noise proof materials for housing will be used to reduce noise from ash Site of proposed PDS \Operation and Quarterly report Rice Miller, PDOE/ Rice Miller Vibration/ room, dust room and machinery. Noise from blower and its drivers will be Facility for City Rice Mill or maintenance MEF/PMO/PIO Noise impacts monitored and managed through good maintenance. Noise within the surrounding location of schedule on sensitive facility will be reduced by the inclusion of noise baffles on machinery and ear the subproject, in Kien receivers protection is provided where necessary. Kaes 1 village, Kouk Khmum commune, Thma Koul district, Battambang

Risks and Rice miller will continue to provide PPE, first aids kit, additional hand Site of proposed PDS Operation and Quarterly report Rice Miller, Rice Miller vulnerabilities washing facilities (e.g. pop ups) to the usual welfare, particularly Facility for City Rice Mill maintenance PDOLVT/PDOE/ related to facilities such as hand sanitizer -minimum 60% alcohol based, located in Kien Kaes 1 schedule MEF/PMO/PIO occupational adequate supplies of soap and fresh water and suitable and village, Kouk Khmum health and safety sufficient rubbish bin for hand towels with proper and regular commune, Thma Koul during operation removal and disposal of waste, etc. and training courses to workers district, Battambang on safety standard; include safety railings to mitigate risks due to material handlings and provide training and instruction to workers; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate Residue of husk Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Site of proposed PDS Operation and Quarterly report Rice Miller, PDOE/ Rice Miller (Ash)/Waste (i) Ash will be collected at the ash room and use as fertilizer by the Rice Miller Facility for City Rice Mill maintenance MEF/PMO/PIO himself or may sell to farmers to generate extra income. located in Kien Kaes 1 schedule village, Kouk Khmum (ii) Husk will be used as biomass fuel by the Rice Miller for their commune, Thma Koul furnace/burner. district, Battambang (iii) Ash will not be allowed to dispose into water bodies.

Garbage/Waste (i) Provide specific basket or bucket for kitchen garbage disposal (suitable Site of proposed PDS Operation and Quarterly report Rice Miller, PDOE/ Rice Miller generation by and sufficient rubbish bin for hand towels with proper and regular removal Facility for City Rice Mill maintenance MEF/PMO/PIO workers and disposal of waste) located in Kien Kaes 1 schedule (ii) Make arrangements for collection of solid waste. village, Kouk Khmum commune, Thma Koul (iii) Make arrangements for grey water treatment and discharge, such as district, Battambang soakage pits. (iv) Assign specific role and responsibility and clear schedule for maintenance and collection of all waste.

Training program:

A training program is set out in below table which address the safeguard reporting and implementation requirements during construction. The engagement of national Environmental Specialist/project implementation specialists will be ensured to build capacity of the PIO staff and to ensure monitoring and reporting are managed effectively during implementation. Training for EMP Implementation. The proposed training required for project implementation is set out in Table below

Capacity Building and Training Requirements

Subject/Content Participants Trainer Frequency

EMP adjustment and implementation – PMO, PIO, Contractors national Environmental Once prior to construction Development and adjustment of the EMP, Specialist/project implementation specialists

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Subject/Content Participants Trainer Frequency roles and responsibilities, monitoring, supervision and reporting

Grievance Redress Mechanism – roles and PMO, PIO, Contractors, District, national Environmental Once prior to construction responsibilities Commune councils Specialist/project implementation specialists

Environmental Protection Pollution control PMO, PIO, Contractors national Environmental Once during the project construction on construction sites (air, noise, wastewater, Specialist/project implementation solid waste……….) specialists

Environmental Monitoring – monitoring PMO, PIO, Contractors national Environmental Once prior to construction methods, data collection and processing, Specialist/project implementation reporting systems specialists

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

Annex 11: Minutes of the public consultation meeting

MINISTRY OF ECONOMY AND FINANCE

Program Management Office (PMO) Climate Resilient Rice Commercialization Sector Development Program (Rice-SDP)

Minutes of Public Consultation Meeting on Social Safeguard Impact Assessment for Establishment of Paddy Drying and Storage (PDS) Facility within City Rice Mill

Tuesday (08:00-11:30AM), 29 September 2020 City Rice Mill, Kien Kaes 1 Village, Kouk Khmum Commune, Thma Koul District, Battambang Province

Chair: H.E Chhim Sabonn, Provincial Program Director, PIO/Battambang

Participants: Villagers (people living around the rice mill), Village Chief, Commune Chief, PIO/BTB Program Director and Officers, BTB/PDOE Officer, MEF/PMO Officers and Consultants, IRE (DD&CS Consultant for establishment of PDS Facility) and Rice Miller.9 A total of 24 Participants including 07 females participated in the Public Consultation Meeting (see participants list as attached under section V of the DDR). Agenda 1.0 Objective of the Public Consultation Meeting 2.0 Opening Remark by Provincial Program Director, PIO/BTB 3.0 Presentation of Detail Design of proposed City Rice Mill PDS Facility 4.0 Open Discussion on Social Safeguard for the proposed City Rice Mill PDS Facility 5.0 Closing of the Meeting

Presentations, discussions, decisions, assignments and conclusion

1.0 Objective of the Meeting The purpose was to disseminate information on the proposed establishment of PDS Facility for the participants to understand, raise issues/challenges that might arise due to the Facility, and contribute to the discussions/solutions for mitigating any possible negative effects due to the Facility. The meeting had the following objectives:

• Inform the participants on the establishment of PDS Facility • Present the detail design of the PDS Facility for City Rice Mill • Discuss on the social safeguards requirements for the PDS Facility and conflict resolution, if any.

2.0 Opening Remark by Provincial Program Director, PIO/BTB

H.E Chhim Sabonn, Provincial Program Director, PIO/BTB, welcomed the Rice-SDP team (officials and consultants) and thanked the villagers living close to the City Rice Mill, Village Chief, Commune Chief, provincial officials, and Mr. Lay Se (Rice Mill owner) and his colleagues for participating in the public consultation meeting. He informed the participants about the Rice-SDP project and its objectives that is to boost paddy rice production, improve quality of milled rice, increase export to the international market as well as to help solve problems of farmers due to lack of post-harvest facilities. He said that Battambang Province is able to dry 4,000 to 5,000 tons of paddy rice per day but that could not able to meet the demand of the province. He informed that Rice-SDP is providing long term loans to the private rice millers to invest in PDS Facilities and the meeting is related to that activity. He further informed the participants

9 BTB= Battambang Province, DD&CS= detailed design and construction supervision firm, MEF= Ministry of Economy and Finance, PDOE= Provincial Department of Environment, PDS= Paddy Drying and Storage, PIO= Provincial Implementation Office, PMO= Program Management Office. Page | 74

Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill that Rice-SDP has already provided loan to Phou Poy Rice Mill in Battambang province and plans to provide loan to one more rice miller. The City Rice Mill has applied for the loan. Thus, the meeting is very important to study the impact of social and environmental safeguards requirements to mitigate issues that might affect the people and avoid/resolve conflicts if any because development must go hand in hand with the welfare of the people. He then requested the Rice-SDP team to give presentation on the design of the Facility and asked participants to provide their comments and raise concerns on the effects of the Facility on their living and businesses if any. He requested all the participants to fully participate in the discussions to make the Facility a successful one.

3.0 Presentation of Detail Design of proposed City Rice Mill PDS Facility Please see Annex III.

4.0 Open Discussion on Social Safeguard for proposed City Rice Mill PDS Facility After the presentation on detail design, the Rice-SDP team presented the location/building constructed by the City Rice Mill and proposed for the installation of paddy drying equipment. The team then raised the following points and/or queries for discussion with the participants:

4.1 Land Title: Does the land title submitted by Mr. Lay Se as the proposed location of the PDS Facility belong to him? Does the proposed land have any conflict with neighbors? Is the accreditation issued by Authorities genuine?

In response to the queries, the participants replied as below:

(1)- Mr. Lay Se, owner of City Rice Mill, informed the meeting that he owns about 10 hectares of land at the proposed site and he has constructed buildings on 2.5 hectares of land for his rice milling business purposes. The proposed paddy drying equipment will be installed within the new building constructed for the purpose and size of the building is 30m x 60m x 16.50m.

(2)- Mr. Siv Sak, Kien Kaes 1 Village Chief, said that the proposed land legitimately and rightfully belongs to Mr. Lay Se, owner of City Rice Mill. He had bought the land from the villagers at the market price and did not have any dispute with his neighbors and/or villagers regarding his land boundary. Mr. Siv Sak added that Mr. Lay Se and his family members are kind people and they normally donate fund and materials to Kouk Khmum commune for road repairing and other humanitarian purposes and he never heard/received any complaint regarding any conflict from people living around the Rice Mill or their business partners.

(See Annex II: City Rice Mill Land Title).

4.2 Establishment of PDS Facility: To explore the benefits and/or concerns that the participants might have for establishing a PDS Facility in their locality that might affect their living and/or daily life, especially for the people who live nearby the Facility, the Rice-SDP team raised the following queries:

• Do you have any concern on working hours for construction works at the site especially at night time? • Do you have any concern on safety due to construction and/or do you need any protection or signs to avoid any possible accidents/danger?

In response to the queries, the participants replied as below: 1. Mr. Meas Meun, a villager who resides adjacent to City Rice Mill, said that working hours should not be a concern as Cambodian Labor Law will be followed and the construction site is within the compound of City Rice Mill. He further mentioned that currently the dust and sound have little effect on his home and he has no issue with the Rice Mill.

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill 2. Mr. Siv Sak, Kien Kaes 1 Village Chief said that workers are clever and know the working hours. They would charge extra for any overtime work and they would not work for free of charge. So, he is not concerned about working hour during construction and business operation. As for safety sign and safe materials, he said that even though the construction will be within the compound building of the Rice Mill, protection for workers and visitors who visits the construction site should be taken care of.

3. Mr. Chhuon Sophath, a villager from the nearby village, said that noise or sound should not be a concern to neighbors because the paddy drying equipment/machines would be installed inside the current business building. What’s more, the contractor will use electricity and Inverter Welding Machine to build the warehouse and to connect the metal frame.

4. Mr. Lay Se, owner of City Rice Mill, said that he will take necessary precautions related to the safety sign and use of safe materials for workers and visitors during construction/Installation period and include them in the contract with the contractor. He added that he did not want to take any chance with his Rice Mill Business.

Continuing the discussions, the Rice-SDP team proposed the participants to discuss the benefits of establishing a new PDS Facility in the locality and how to resolve conflicts if any in the future. To kick start the discussion, the team proposed following queries:

o Do you prefer to have a PDS Facility on the site of City Rice Mill? o Do you think PDS Facility will benefit Mr. Meak Meun, Kien Kaes 1 Village said farmers or villagers in general? “I support the Paddy Drying Facility within o If you have any conflict with City City Rice Mill because if the City Rice Mill Rice Mill, whom do you report to for has new PDS Facility then he will increase resolution? buying more quantity of paddy rice to operate his Facility and villagers will get o Do you have any idea on solving any more profit from their production. Also it of the concerns? will create employment opportunity for

local labors and reduce migration of Both authorities and people expressed their happiness and were enthusiastic about the upcoming people to outside the village’’. PDS Facility inside the land owned by City Rice Mill. They mentioned that the PDS Facility would benefit most of the villagers as they cultivate rice and the rice miller could buy more paddy from them than earlier times, farmers would be able to save on transportation cost as they did not have to transport far, and also their sons/daughters could work as labor at the Facility to earn income. The participants added that they are not concerned about the perceived negative points on establishment of PDS Facility within City Rice Mill as they will get opportunities to expand their rice business. The participants said that if they have any concerns in the future, they would directly talk to Mr. Lay Se, Owner of City Rice Mill or Mr. Lay Chhun Hang, General Manager of City Rice Mill or report to Village/Commune Chief or District

Governor for solutions. The PMO informed the participants that there is a well-defined grievance redress and resolution mechanism (GRM) established in the project to resolve grievances and complaints in a timely and satisfactory manner. The GRM was then discussed in detail in the meeting. The PMO informed the participants that it will further disseminate the GRM through an effective public information campaign prior to and during the construction period.

Participating in the discussion Mr. Lay Se said that he has upgraded his business from family scale to commercial scale and he is taking care of peoples’ welfare and environment. He also confirmed that he would be happy to discuss with people and authority to solve any problem arising due to the PDS Facility and his business operation. Joining the discussion, Mr. Lay Chhun Hang, General Manager of City Rice Mill said that the Rice Mill currently employs 150 poor/vulnerable villagers including 70 women. They are from different areas of Battambang such as Thma Koul District and Battambang Town but a big majority is from Thma Koul district. He mentioned that after completion of the proposed PDS facilities, the Rice Mill will engage around 15 more villagers of which he expects women to be around 60-70% of the work force.

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5.0 Closing of the Meeting Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

H.E Chhim Sabonn, Provincial Program Director, PIO/BTB, congratulated all the participants for sharing ideas related to Social and Environmental Safeguards for the establishment of PDS Facility within City Rice Mill. He suggested that if participants have any issue with City Rice Mill, they should report to the village or commune chief or directly talk with the owner or his management staffs for resolutions. He agreed with the village chief and the owner of the rice mill that for safety during construction and business operation, there need to be safety signs and also barricade to allow only people who are related to work. At the end, he thanked all the participants, local authorities, Rice-SDP team, provincial team and Mr. Lay Se and his colleagues for participating in the public consultation meeting and for a fruitful outcome.

List of Participants

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Rice-SDP - Initial Environmental Examination- PDS Facility for City Rice Mill

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