E1114 V. 6 Attachment 5 Environmental Report/IAIL3

E1114 V. 6

Public Disclosure Authorized

Attachment 5 Environmental Report/IAIL3

ENVIRONMENT REPORT Public Disclosure Authorized

(ANHUI PROVINCE) Public Disclosure Authorized Public Disclosure Authorized China Research Academy of Environmental Sciences January 2005 TABLE OF CONTENTS

1. INTRODUCTION ...... 4

1.1. Purpose and Contents of Report...... 4 1.2. Background...... 4

2. OVERALL ASSESSMENT OF ENVIRONMENTAL IMPACTS OF IAIL2 PROJECT ...... 5

2.1. Environmental Issues of IAIL2 Project ...... 5 2.2. Assessment of Actual Environmental Impacts of IAIL2 Project ...... 6 2.3. Summary Conclusions of IAIL2 Environmental Impacts Assessment ...... 9 2.4. Recommendations for Improvement of IAIL3 Environmental Management.9

3. COMPARISON OF ENVIRONMENTAL CONDITIONS AND ENVIRONMENTAL IMPACTS BETWEEN IAIL3 AND IAIL2...... 10

3.1. Comparison of Project Counties (Cities)...... 10 3.2. Comparison of Environmental Conditions...... 14 3.3. Comparison of Project Contents ...... 15 3.4. Main Conclusions...... 17

4. CLARIFICATION ON PREPARATION OF IAIL3 ENVIRONMENTAL MANAGEMENT PLAN...... 18 1. Introduction

1.1. Purpose and Contents of Report

This Environment Report (the Report) for Anhui Province is prepared for the appraisal of the proposed World Bank loan-financed Irrigated Agriculture Intensification Project III (IAIL3, the Project).

The World Bank preparation mission of November 2004 proposed that the environment category of the Project remains to be type B due to the similarities between the Project and IAIL2 in terms of project areas and basic contents. In order to simplify procedures the Bank no longer requires to review a full environmental assessment report for the Project, but requires to 1) assess the actual environmental impacts of the IAIL2 Project; 2) compare the environmental conditions of IAIL3 and IAIL2; and 3) prepare environmental management plan by Project provinces.

In compliance with the above requirements the main contents of the Report include:

1) Overview of the actual environmental impact assessment of the IAIL2 Project Anhui Component; 2) Comparison of environmental conditions and contents between IAIL3 and IAIL2 in Anhui; 3) Clarification on the preparation of Environmental Management Plan for IAIL3 in Anhui; 4) Anhui Project Area Environmental Management Plan (attached to the Report).

1.2. Background

Since 1998 the IAIL2 Project had been implemented in 21 cities (districts) of Anhui’s four municipalities, including Hefei, Chaohu, Liu’an and Anqing. Project implementation was completed as scheduled in end 2002.

Project implementation has improved local agricultural productive conditions, promoted agricultural restructuring, increased farmers’ income and improved the level of agricultural technologies, thus achieving remarkable economic, social and ecological benefits. To this end, the State Office for Comprehensive Agricultural Development (SOCAD) has decided to continue to implement the IAIL3 Project in the above five provinces.

4 Entrusted by SOCAD the China Research Academy of Environmental Sciences has undertaken to conduct environmental impact assessment (EIA) for the Project and prepared the Report according to the requirements of the Bank preparation mission.

2. Overall Assessment of Environmental Impacts of IAIL2 Project In June 2004 SOCAD prepared the “Environmental Management Report for the Irrigated Agriculture Intensification Project II” to be as one of the IAIL2 ICR supporting documents (Reference Document 1). The report summarizes and evaluates the environmental management work, status of implementation of relevant environmental covenants in the Loan Agreement and the actual environmental impacts following project implementation. The Report only outlines the actual environmental impacts of IAIL2.

2.1. Environmental Issues of IAIL2 Project

The main objectives of the project were to increase agricultural production and farmers’ income through improvement and rehabilitation of the existing irrigation facilities in the project areas. Main project components include canal lining, constructing on-farm works, rehabilitating existing and building new pumping stations and tube wells, land leveling, improving field passageways and building field drainage network and windbreak shelter belts. The project does not involve the construction of new reservoirs and new main and branch canals. In March 1997 the Bank preparation mission rated the project as Category B in terms of its environmental impacts.

Based on the EIA report of IAIL2 the Project Appraisal Document (PAD) specified that there were no significant environmental issues under the project and, the important environmental issues included likely impacts of irrigation run-off on Chaohu Lake eutrophication, and other environmental issues included control over the application of pesticides and chemical fertilizers, dam safety of reservoirs for irrigation water supply and environmental impacts of construction activities etc., as shown in Table 2-1.

Table 2-1: Bank PAD-specified Environmental Issues for IAIL2

Environmental Significant Important Other Environmental Issues Issues Environmental Environmental Issues Issues Likely Chaohu Lake Control over application of pesticides eutrophication due to and chemical fertilizers; Main Contents None irrigation run-off Dam safety of irrigation water supply reservoirs Impacts of construction activities;

5 2.2. Assessment of Actual Environmental Impacts of IAIL2 Project

2.2.1. Significant Environmental Issues

Evidences of project implementation in Anhui Province have verified the conclusion in the Bank’s PAD of “the Project doesn’t involve any significant environmental issues”. The project did not see any of them during its implementation and will unlikely see any either in the future.

2.2.2. Important Environmental Issues

The important environmental issue involved in IAIL2 is the impacts of irrigation run-off on Chaohu Lake eutrophication. According to studies of Anhui project area, the major pollutant sources caused the problem are industrial wastewater and urban domestic sewage from the project areas, which account for about 80~90% while the pollution of non-point polluting sources takes up around 10-20%. The total catchment area of the lake is 1.3 million ha, the project area of Anhui was only 130,000 ha while the space of areas whose irrigation run-off could directly flow to the lake was only 55,000 ha, 4.2% of the lake’s total catchment area. According to estimations of Anhui Province, if excluding the impacts of the measures such as land leveling, conservation of soil fertility and moisture as well as balanced fertilization and calculated based on the rate of chemical fertilizers losses without the project, growth of the lake’s nitrogen and phosphate load due to project implementation was only 0.58% and 0.66% respectively of the lake’s total nitrogen and phosphate load.

In fact, since project implementation, due to the above measures loss of chemical fertilizers had been greatly reduced, especially that of nitrogen and phosphate was reduced by 36% and 38% respectively. In another word, the annual increment nitrogen and phosphate load in the lake by run-off from the project areas accounted for only 0.37% and 0.41% respectively of itstotal nitrogen and phosphate load. Therefore, they had tiny impacts on the lake’s eutrophication. Table 2-2 provides the analysis on the project’s impacts on Chaohu Lake eutrophication.

Monitoring results of Anhui Provincial Environmental Monitoring Center show from 1998 through 2000 Chaohu Lake was in a status of eutrophication, but its degree was decreasing year by year. Between 2001 and 2002, eutrophication had dropped to the medium level. Although the improvement was largely due to upgraded treatment of industrial wastewater and municipal sewage, the implementation of this project has at least not produced negative impacts on the control of Chaohu Lake eutrophication.

6 Table 2-2: Impacts of Nitrogen and Phosphate Losses from Project Areas on Chaohu Lake Eutrophication

Impact of industrial wastewater and urban sewage 90 % Impact of pollutants from agricultural non-point sources < 10 % Total catchment area 1.3 million ha Project areas with irrigation run-off direct entering into the lake 55,000 ha Project areas with irrigation run-off direct entering into the lake out of total 4.2 % catchment area Increase of the nitrogen load by the project out of total nitrogen load of the lake 0.37 % Increase of the phosphorus load by the project out of total phosphorus load of 0.41 % the lake

2.2.3. Other Environmental Issues

I) Control of Fertilizer and Pesticide Application

During project implementation, IPM technologies were widely adopted in the project areas. The integration of disease-resistant varieties promotion with application of pesticides with high efficiency, low toxicity and low residue and bio-pesticides replacing original highly toxic pesticides had effectively improved farmland eco-environment in the project areas. Table 2-3 compares the use of pesticides and chemical fertilizers during and before the project.

Table 2-3: Changes in Application of Pesticides and Their Residues in Soil and Water in Project Areas (%)

Reduction of Reduction of Increase of Reduction of Reduction of Pesticides Per Highly Toxic Bio- Pesticides Pesticides Unit Area Pesticides pesticides Residue in soil Residue in Water 54.9 85.2 146 18 21

In response to the deficit of phosphate and potassium, particularly potassium, the project provinces carried out a number of measures during the implementation of the project to balance soil fertility, i.e. control of nitrogen (reducing nitrogen application in some project areas), stabilizing phosphate (increasing phosphate application in some areas) and supplementing potassium. Changes in soil fertility in project areas between 1998 and 2002 are summarized in Table 2-4.

Table 2-4: Changes of Soil Fertility in Project Areas between 1998 and 2002

7 Without Project With Project N P2O5 K2O N P2O5 K2O 1 0.38 0.35 1 0.51 0.46

In addition, advanced fertilizing techniques were disseminated in project areas, such as deep application, mixed application, etc., thus increasing the efficiency of fertilizers, lowering loss of chemical fertilizers and reducing the negative impacts of irrigation run- off on receiving water bodies. Based on the environmental monitoring results during five years’ project implementation, Table 2-5 summarizes basic environmental monitoring conclusions.

Table 2-5: Basic Conclusions of Environmental Monitoring

Items Evaluation Conclusion 1. Environment Quality 1) Surface irrigation In general, the quality was good and improved year by year. water quality Water met irrigation requirements. 2) Irrigation run-off The quality met the requirement of irrigation with quality comprehensive pollution index decreasing year by year, no significant negative impacts on receiving water bodies. 3) Groundwater Quality was good and stable. Secondary mineralization found quality only in a few spots. 4) Soil pollution Soil quality was good with single and comprehensive pollution indices decreasing. 5) Farm produce Good quality farm produce, which met relevant national quality contamination standards. 2. Soil Fertility Soil fertility increased with more rational composition of nitrogen, phosphate and potassium

The above results indicate that due to effective implementation of various environmental protection measures, overall environment quality was rather good and improved year by year. Project implementation has not imposed any significant negative impacts on the environment. Therefore, the project is environmentally sustainable.

II) Dam Safety

Among the reservoirs involved under the project, Mahe Reservoir was unsafe and needed to be strengthened. So far, the work has been completed, as shown in Table 2-6.

During project implementation there had been no dam safety problems or environmental problems related to dam safety.

Table 2-6: Statistics of Dam Strengthening in the Project Area

8 Total Name Approved Inception Completion Investment (100 mil. yuan) Foziling September May 2002 May 2005 1.62 Reservoir 2002 Longhekou May 2001 February 2002 October 2004 0.4727 Reservoir

III) Impacts of Construction Activities

Most of the works under this project were excavation and construction of laterals, structures and pumping stations. These works were small and relatively simple and scattered. Most of the activities were undertaken in already developed farmland areas and the construction period was short (generally within half a year). Therefore, environmental problems related to project construction were minor and the impacts were tiny.

In addition, during project implementation, for construction of relatively important projects the contractors were required in the contracts to comply with relevant national and local laws, regulations and standards on environmental protection, sanitation and epidemics control and the Engineers were entrusted to supervise the contractors. Therefore, construction of all civil works caused neither major environmental problems nor significant public health problems or public complaints.

2.3. Summary Conclusions of IAIL2 Environmental Impacts Assessment

Table 2-7 summarizes the actual assessment on the environmental impacts of IAIL2.

2.4. Recommendations for Improvement of IAIL3 Environmental Management

Based on the lessons learned from IAIL2 in terms of environmental management practices improvements should be made in the following aspects:

1) IAIL2 EMP was not so specific and IAIL3 EMP should be more targeted and applicable; 2) IAIL2 didn’t focus on water saving and water saving objectives should be clearly set for IAIL3; 3) According to the environmental practices of IAIL2 methodologies and contents of environmental monitoring for IAIL3 should be adjusted as appropriate.

9 Table 2-7: Summary Conclusions of Environmental Assessment

Items Status of Completion/Assessment Conclusion Significant Environmental No significant environmental issues occurred. Issues Important Environmental Issues Lake eutrophication Minor impacts were found and could be ignored Environmental Monitoring 1) Environment quality Monitoring for consecutive five years shows good environment quality in the project areas. 2) Soil fertility Monitoring results show improved soil fertility and composition of N, P and K. Other Environmental Issues 1) Environment management Relevant laws and rules were observed during during construction construction. No important environmental problems emerged. 2) Control of pesticides and IPM and balanced fertilizing reduced pesticide residue chemical fertilizers and loss of chemical fertilizers. 3) Dam safety Relevant dam rehabilitation works have been completed and no dam safety problems occurred.

3. Comparison of Environmental Conditions and Environmental Impacts Between IAIL3 and IAIL2

3.1. Comparison of Project Counties (Cities)

3.1.1 Comparison by Administrative Division

Table 3-1 lists the project cities and counties of IAIL2 and IAIL3 and Figure 3-1 gives the location of IAIL2 and IAIL3 project cities and counties.

11 Figure 3-1 Locations of IAIL3 and IAIL2 Subprojects in Anhui Province

Suzhou

Fuyan Bengb Huaina

Chuzh

Henan Province Hefei

Chaohu Wuh Lake

Hebei Province

Jiangxi Provinc

IAIL2 IAIL3

The table indicates that with the exception of Hefei the other project areas are all different from those of IAIL2. Therefore, most of the IAIL3 areas are new.

Table 3-1: Comparison of IAIL2 and IAIL Project Areas in Anhui (by Administrative Division)

IAIL2 Project Areas IAIL3 Project Areas Municipality County (City, District) Municipality County (City, District) Feidong, Changfeng, Hefei Feidong, Changfeng, Feixi Hefei outskirts Lujiang, Hexian, Hanshan, Wuwei, Chaohu Chaohu Juchao Huoqiu, Shouxian, Shucheng, Liu’an Lu’an Jin’an, Yu’an Huaining,Zongyang, Tongcheng, Anqing Qianshan, Taihu, Susong, Anqing Wangjiang, Anqing Outskirts Huaiyuan, Wuhe, Bengbu Bengbu Guzhen Huainan Huainan Fengtai, Panji Dingyuan, Jinjiao, Fengyang, Mingguang, Chuzhou Chuzhou Nanjiao, Tianchang, Langya, Lai’an Note: Bold ones refer to new project cities and counties.

3.1.2 Comparison by Irrigation Districts

Since IAIL3 is located in different areas from IAIL2, its irrigation water sources are also different. Water comes from surface rivers and reservoirs near the project areas. Table 3-2 lists the irrigation districts under IAIL3.

Table 3-2: Division of Project Areas of Anhui by Irrigation District County (City, Municipality Irrigation District District) Feidong Reservoir irrigation district (Pi-shi-hang ID) Hefei Changfeng Reservoir irrigation district (Pi-shi-hang ID) Outskirts River irrigation district (Nafei River) Huaiyuan Well irrigated district River irrigation district (Huaihong New River, Bengbu Wuhe Beifei River, Tianjing Lake) Guzhen Well irrigation district

13 River irrigation district (Yongxing River, Fengtai Huainan Xifei River) Panji River irrigation district (Huai River, Ni River) Dingyuan Chi River Basin Irrigation District Quanjiao River irrigation district (Chu River) Reservoir irrigation district (Guangou Fengyang Reservoir, Fengyangshan Reservoir, Randeng Reservoir) Mingguang Fengshuiling Reservoir River irrigation district (Qingliu River, Sha Nanjiao Chuzhou River) Reservoir irrigation district (Fushan Tianchang Reservoir, Chuanqiao Reservoir, Datong Reservoir) Reservoir irrigation district (Sha River Langya Reservoir) River irrigation district (Lai River, Baita Lai’an River, Chu River) Note: Bold ones refer to IAIL3 well irrigated area.

3.2. Comparison of Environmental Conditions

Table 3-3 compares the agricultural natural conditions in IAIL2 and IAIL3 project areas.

Table 3-3: Comparison of Natural Conditions of IAIL2 and IAIL3 Project Areas Natural IAIL2 IAIL3 Environment Subtropical humid monsoon climate; within medium Subtropical humid monsoon climate, and low latitude areas, great weather changes with multi-year average precipitation 900- frequent activities of cold and warm currents. Great Climate 1,450mm; great annual precipitation changes of precipitation distribution in different years variations and very unbalanced and within a specific year. Precipitation declines from distribution. Annual average the south to the north. Multi-year average precipitation temperature 15-170 C 900-1,450mm. Annual average temperature 15.5-16.90 C. Middle to southern hilly areas between Hilly areas between Yangtze and Huai Rivers and Huai Topography Yangtze and Huai Rivers with River plain. complicated topography. Variety of soil parent materials; rice Soil Mostly rice soil, then brown soil. soil, brown soil & brown moisture soil. Irrigation Water Surface reservoirs and rivers with Surface reservoirs and rivers with guaranteed water Sources guaranteed water sources. sources. Regional Long-term agricultural development Long-term agricultural development region Development region It is seen from Table 3-3 that the environmental conditions in IAIL3 areas are quite similar with that in IAIL2 areas although most of the IAIL3 areas are different to IAIL2 areas. Therefore, the environmental issues involved in IAIL3 are similar to that in IAIL2.

In addition, it can be seen from Figure 3-1 that the IAIL3 areas are between the areas of IAIL1(21 counties of Huaibei, Fuyang, and Suzhou Cities) and IAIL2: IAIL2 was located mainly at south of Yangtze River, IAIL1 was located mainly at north of Huai River, and IAIL3 is located between the Huai River and the Yangtze River. The environmental conditions in IAIL3 are similar partly to that in IAIL1 and partly to that in IAIL2 without new environmental issues involved.

Anyway, in IAIL2, the Chaohu lake was assessed for possible eutrophication impacts due to farmland run-off and drainage from project area. The IAIL3 is basically out of Chaohu Lake basin with no adverse impacts on the lake’s eutrophication. Most of IAIL3 areas are in Huai River basin and therefore the farmland run-off and drainage from IAIL3 areas might have adverse impacts on the water quality of the tributaries of the Huai River basin, for which measures have been included in the EMP/Anhui.

3.3. Comparison of Project Contents

Table 3-4 compares the main contents of IAIL2 and IAIL3.

Table 3-4: Comparison of IAIL2 and IAIL3 Project Contents

Project IAIL2 Contents IAIL3 Contents Works Canal and ditch excavation & dredging, Canal excavation, bridges, culverts and structures, drainage & irrigation pumping other structures, constructing new and stations, agricultural-use power cable, rural Water renovating existing pumping stations, roads, O&M equipment, 100 small water Infrastructure agricultural-use power cable, rural storage works (ponds and water tanks below Construction roads, O&M equipment, 220 water 100,000 m3) to be built, 111 tube wells to be storage dams repaired & maintained and renovated, 1,478 new tube wells to be drilled Canal lining, underground pipeline, Anti-seepage canals, low-pressure pipes, Engineering sprinkler and drip irrigation and mobile sprinkler and micro-(drip) irrigation and Water Saving surface hoses mobile surface hoses Land leveling, deep ploughing/soil Land leveling, deep ploughing/soil Agronomical loosening, return of straw to field, loosening, return of straw to field, balanced Water Saving balanced fertilization, training fertilization, training and dissemination Management WUA, SIDD WUA, SIDD Water Saving Improved-variety breeding and processing, Improved-variety breeding and IMP, county agricultural extension centers, processing, IMP, township agricultural township stations for comprehensive extension centers, township stations for agricultural services, agricultural machinery, comprehensive agricultural services, agricultural training and agricultural Agriculture agricultural machinery and service dissemination and extension, green stations, agricultural training and produce dissemination and extension, agricultural dissemination and specialized farmer associations, pilot extension, barn and sunning ground cooperative operations among farmers renovation, fertilizer batching plants and dragonheads

15 Construction of farmland windbreak Construction of farmland windbreak shelter Forestry shelter belts, nurseries, forestry pest belts, nurseries, forestry pest control control Training, study tour, technical assistance, Institutional Training, study tour, technical scientific research and dissemination, office Development assistance, scientific research, MIS, 4 equipment and MIS system, farmers’ and Support SIDDs and 23 WUAs. associations (including WUA) Note: Bold parts refer to new additional contents.

The comparison reveals that while improving, strengthening and rehabilitating the original irrigated agricultural regions, the main contents of the two projects are basically the same, including canal lining, constructing on-farm works, rehabilitating existing and building new pumping stations and tube wells, land leveling, improving field passageways and building field drainage network and windbreak shelter belts. Table 3-4 also shows two main differences in the contents of IAIL2 and IAIL3:

1) Well Irrigation District

There were no irrigation districts under IAIL2 while IAIL3 will have well irrigated areas of Huaiyuan and Guzhen counties. Project contents include repair and drilling of 1,589 tube wells. The two counties are rich in groundwater resources and groundwater overdraft will not be an issue.

2) Agriculture

In terms of agriculture, the Project include three new additional contents: 1) “green”(Non-polluted) farm produce; 2) specialized farmer associations; and 3) pilot farmer-dragon head cooperative operations. In terms of component selection, those with livestock breeding, high water consumption, heavy pollutions and use of wild resources are ruled out. Table 3-5 provides the proposed key pilot bases for “green” farm produce and sites for pilot farmer-dragonhead cooperative operations of Anhui. Table 3-6 lists the proposed specialized farmers associations to be established in the project areas. Table 3-5: Green Farm Produce Production Bases and Products of Anhui

Category Municipality County Name Products Hefei Feidong Green vegetables Carrot, tomato Green Farm Mingguang Green Produce Chuzhou Mingguang Green bean Bean Big Green Soybean Big green Bengbu Huaiyuan Pilot Farmer- Association soybean dragonhead Xinji Town Cooperative Vegetable Production Huainan Fengtai Vegetables Operations and Marketing Company

Table 3-6: Specialized Farmers’ Associations in Anhui Project Area Municipality County Associations/produce Feidong Xiaodao vegetable Hefei Changfeng Zhuxiang rice oil Bahe Dayu grape Fengtai Xinji vegetable Huainan Panji Pinyu mushroom Huaiyuan Xincheng bean Bengbu Guzhen Xinmaqiao fruits

Wuhe Huinan rice Fengyang Damiao rice Jinjiao Chenqian cole Nanjiao Shahe corn Chuzhou Tianchang Datong cotton Dingyuan Yanqiao rice Mingguang Lushan melon seeds Laian Shunshan rice Langya Grass

As shown in Tables 3-5 and 3-6 the IAIL3 Project aims at supporting the planting, processing and marketing of green farm produce, farmer-dragonhead cooperative operational organizations and specialized farmers’ associations. There are no activities involving livestock breeding, high water consumption, heavy pollutions and use of wild resources and therefore, there will be no relevant environmental issues.

3.4. Main Conclusions

Based on the comparison of IAIL2 and IAIL3 projects the following conclusions can be drawn:

1) With the exception of Hefei the other project areas under IAIL3 are new; 2) Natural conditions of IAIL2 and IAIL3 areas are same or similar. All belong to long- term agricultural development areas. Therefore, environmental issues involved under IAIL3 are similar to IAIL2; 3) Under IAIL2 irrigation run-off affected lake is Chaohu Lake while under IAIL3 the affected water bodies are tributaries of Huai River;

17 4) No well irrigated areas under IAIL2 while there are two well irrigated areas of Huaiyuan and Guzhen under IAIL3, in which water resources are rich without groundwater overdraft problems. 5) The new contents of “green” farm produce, farmer-dragonhead cooperative operational organizations and specialized farmer associations are to plant, process and market their respective local dominant agricultural products and there will be no components involving livestock breeding, high water and wild bio-resources consumption and heavy pollutions. Therefore, new contents will not lead to negative environmental impacts.

4. Clarification on Preparation of IAIL3 Environmental Management Plan 1) According to World Bank requirements the province has prepared a complete and separate IAIL3 Environmental Management Plan to be the attachment of the Report; 2) Since the five provinces under the IAIL3 Project vary greatly in natural conditions and differ in focuses on environmental issues, according to the requirements of the Bank preparation mission separate EMPs by province will be prepared to make the plans more targeted at environmental issues and facilitate their implementation by each of the provinces; 3) In view of the successful implementation of IAIL2 and that the natural conditions of the project areas and contents of IAIL3 are basically the same as IAIL2, IAIL3 EMP is prepared based on the experience and lessons learned from IAIL2, which will further improve the EMP for the Project. 4) Compared with IAIL2 EMP, IAIL3 Anhui EMP has got the following features: z Emphasizing water resources protection and impacts of irrigation run-off on lake eutrophication as important environmental issues in the project areas of Anhui; z Confirming above everything else environmental issues involved in the Project, based on which the objectives and contents of environmental management are decided, making the EMP more targeted and applicable; z Emphasizing analysis, evaluation and application of environmental monitoring results; z Clarifying environmental management agencies, their respective responsibilities and costs and sources of funding for EMP implementation; z Making necessary adjustments to the items, parameters, venue and frequency of environmental monitoring; z In light of the current model for construction management of physical projects in China, the environmental protection measures to be implemented by the Contractor are summarized and incorporated into the contract in the form of “Rules for Construction Environmental Protection, with its implementation being supervised by the site Engineer entrusted by the Project Management Office (PMO). Environmental protection measures for construction activities will not be detailed in the EMP;

18 z There is no soil salinization in the project areas of Anhui and the issue is no longer addressed in the EMP.

Attachment 1: IAIL3 Anhui Environmental Management Plan