Initial Environmental Examination
July 2011
VIE: Comprehensive Socioeconomic Urban Development Project – Viet Tri, Hung Yen, and Dong Dang (Dong Dang)
Prepared by Provincial People’s Committee of Lang Son for the Asian Development Bank
CURRENCY EQUIVALENTS (as of 01 June 2010)
Currency Unit – dong (D) D1.00 = $0.000049 $1.00 = D20,298
ABBREVIATIONS
ADB – Asian Development Bank BOD – biological oxygen demand CBMC – community-based monitoring committee COD – chemical oxygen demand CPC – city people’s committee DoNRE – Department of Natural Resources and Environment DOT – Department of Transportation EIA – environmental impact assessment EMD – Environmental Management Division EMP – environmental management plan EPC – environmental protection commitment GoV – Government of Viet Nam GMS – Greater Mekong Subregion IEE – initial environmental examination LEP – Law on Environmental Protection km – Kilometer km2 – square kilometer m – Meter MOLISA – Ministry of Labour, Invalids, and Social Affairs MoNRE – Ministry of Natural Resources and Environment NSEC – North-South Economic Corridor PMU – project management unit PPC – provincial people’s committee PPTA – project preparatory technical assistance ROW – right-of-way SEDP – socioeconomic development plan TA – technical assistance TSS – total suspended solids WU – Women’s Union
NOTE In this report, "$" refers to US dollars unless otherwise stated.
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.
TABLE OF CONTENTS
I. TABLE OF CONTENTS 3 II. EXECUTIVE SUMMARY 5 III. INTRODUCTION 7 A. Background to Project and IEE 7 B. Assessment Context 8 IV. POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK 9 V. DESCRIPTION OF THE PROJECT 10 A. General Description of Project Components (DD1 and DD2) 12 1. Pre-construction Phase 12 2. Construction Phase 12 1. Post-Construction Operation Phase 13 VI. DESCRIPTION OF AFFECTED ENVIRONMENT 13 A. Topography and Geography 13 B. Socio-economy 15 1. Border Exchange with China 16 C. Physical Resources 17 1. Climate 17 2. Soil Resources 17 3. Land Use 17 4. Mineral Resources 17 5. Water Resources 18 6. Water and Sediment Quality 18 7. Ground Water Quality 20 8. Air Quality and Noise 20 D. Ecological Resources 21 1. Fauna 21 2. Flora 21 3. Protected Areas and Wildlife 22 E. Conditions at Huu Nghi Gate, Dong Dang Market 23 VII. PUBLIC CONSULTATION 25 A. Stakeholder involvement during project implementation 26 VIII. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 27 A. Project Benefits 27 B. Project Impacts and Mitigations 28 1. Pre-construction Phase 28 2. Construction Phase 28 3. Operation Phase 31 4. Induced Impacts 31 5. Cumulative Impacts 32 6. Strategic Assessment 32 IX. INFORMATION DISCLOSURE AND PUBLIC GRIEVANCE MECHANISMS 32 A. Project Information 32 B. Grievance Process 33 C. Access Hotline 33
X. ENVIRONMENTAL MANAGEMENT PLAN 34 A. Institutional Arrangements and Responsibilities 34 B. Mitigation Plan 35 C. Monitoring Plan 46 1. Reporting 46 2. Estimated Cost of Mitigation and Monitoring Plans 46 D. Institutional Capacity Review and Needs 46 XI. CONCLUSIONS AND RECOMMENDATION 50 XII. REFERENCES AND INFORMATION SOURCES 51 XIII. APPENDIX A: PARTICIPANTS OF STAKEHOLDER CONSULTATION 52
Table 1. Summary specifications of project components DD1 and DD2 ...... 10 Table 2. Summary of major generic activities of DD1 and DD2...... 13 Table 3. Total trade and passenger traffic across Huu Nghi border gate, 2005-2010 ...... 16 Table 4. Sediment quality in Ky Cung river ...... 19 Table 5. Water quality data in the Ky Cung river ...... 19 Table 6. Ground water quality in Lang Son City ...... 20 Table 7. Air quality in Lang Son ...... 20 Table 8. Stakeholder comments on project in Dong Dang...... 25 Table 9. Applicable Laws, Directives and Environmental Standards...... 30 Table 10. Environmental Impact Mitigation Plan ...... 36 Table 11. Environmental Monitoring Plan ...... 48
Figure 1. Four branches of the North South Economic Corridor of the GMS ...... 8 Figure 2. Huu Nghi border gate upgrade schematic (DD1)...... 11 Figure 3. Rehabilitation of market drainage infrastructure schematic (DD2)...... 11 Figure 4. Huu Nghi border gate to China...... 14 Figure 5. Elevations along road to Huu Nghi gate along western side Ky Cung river...... 15 Figure 6. Existing masterplan for Huu Nghi border gate...... 24 Figure 7. Air and surface water quality monitoring sampling sites...... 47
I. EXECUTIVE SUMMARY
1. Dong Dang of Lang Son province is one of three cities of the Comprehensive Socio- Economic Urban Development Project (CSUD) along with Hung Yen of Hung Yen province, and Viet Tri of Phu Tho province to be developed to ultimately join Ha Noi as northern Viet Nam's economic center. The outcome of the Dong Dang project is improved urban infrastructure, and improved municipal and international border services with the impact of contributing to the CSUD, and the overall transformation of the North-South Economic Corridor (NSEC) of the Greater Mekong Sub-region (GMS) from a transport corridor to full-fledged economic corridor.
2. The initial environmental evaluation (IEE) of the Dong Dang subproject was prepared as part of project preparatory technical assistance (PPTA) 7516-VIE. The IEE presented herein has been re-formatted and updated pursuant to the requirements of ADB’s SPS (2009). This category B project is at the feasibility design phase and defined by the following components:
DD1: Upgrade of Huu Nghi Border Gate Facilities DD2: Rehabilitation of Dong Dang Market Drainage Infrastructure
3. The evaluation of the pre-construction, construction, and operational phases of the two Dong Dang components which included input from a community stakeholder meeting indicates that the direct environmental impacts of the project are mostly short-term civil construction- related that can be mitigated. The stakeholder meeting in Dong Dang indicated the need for effective management of noise, dust, traffic disruptions, and safety during the construction phase. A HOTLINE telephone number to a responsive project management unit (PMU)/city people’s committee (CPC) office posted at all construction sites is proposed to facilitate continued community engagement through the construction phase.
4. Available data and information from the Department of Natural Resources and Environment (DoNRE) indicate the absence of critical wildlife habitat, rare or endangered species, and ecological protected areas in the general area surrounding the Huu Nghi border, with no sensitive ecological or cultural receptors in the Dong Dang market area. This focuses the short-term direct impacts of the project on the local community and workers that will be affected primarily by construction activities. The civil construction impacts of elevated dust, noise, traffic disruptions, erosion and sedimentation, and public and worker safety can be mitigated and managed effectively with provincial, national, and international construction management directives and guidelines.
5. However, the presence or absence of sensitive ecological receptors right at the Huu Nghi border site should be confirmed with supplemental survey data. Similarly, the aquatic resources and uses of the Ky Cung river at the border gate site and adjacent to the Dong Dang market should be confirmed. These data and information should be collected as part of the update of the EMP during the detail design stage of the project.
6. Potential induced environmental impacts of the project are increased natural resource consumption and environmental degradation which could stem from the subproject impact of socioeconomic development in and around Dong Dang. These induced environmental impacts would potentially accumulate regionally with similar effects of the other two subprojects of the CSUD, along with other ongoing separate economic development projects of the region. Strategic-level environmental concerns of CSUD are normally addressed at the regional
planning stage such as with the Government of Viet Nam’s (GoV) socioeconomic development plans (SEDP).
7. The IEE concludes that the project description at the feasibility design stage combined with available information on the affected environment is sufficient to understand the scope of potential environmental impacts of the project. Provided that major changes in the design of one or more of the project components do not occur at the detailed design phase, and the supplemental ecological and resource use information for the border gate and Ky Cung river are obtained for review, further detailed environmental impact assessment (EIA) is not required.
8. An environmental management plan (EMP) has been prepared for the project. The EMP provides an impacts mitigation plan, an environmental monitoring plan, and specifies the institutional responsibilities and capacity development needs for the implementing unit of the project. The IEE recommends that the EMP be reviewed when the final detailed project designs are completed to ensure that the EMP fully addresses the project’s adverse environmental impacts.
II. INTRODUCTION
A. Background to Project and IEE
9. The IEE presented herein is based on the IEE that was prepared as part of the technical assistance (TA) Report for PPTA 75161. The IEE from the TA Report is re-formatted here for the ADB with additional information on the project added where required.
10. The Huu Nghi border gate and Dong Dang city in northern Lang Son province are two adjacent sites that form the Dong Dang subproject, which together with Viet Tri of Phu Tho province and Hung Yen city of Hung Yen form the three subprojects of the Comprehensive Socio-Economic Development Project (CSUD). The CSUD will develop the three cities to complement Hanoi as northern Viet Nam's economic centers to contribute to the transformation of the North-South Economic Corridor (NSEC) from a transport corridor to full-fledged economic corridor2.
11. The four branches of the NSEC (Figure 1) which connect southeastern People's Republic of China (PRC) with the Greater Mekong Sub-region (GMS) are undergoing rapid economic development. The northeastern branch which links Ha Noi and Hai Phong, Vietnam to Nanning and Kunming, China is the focus of the CSUD. The blue dots in Figure 1 indicate the locations of the three CSUD subproject cities of southern Hung Yen, western Viet Tri, and northeastern Dong Dang.
12. The CSUD aims to improve urban infrastructure and municipal services in the project cities through investments in urban infrastructure construction and remediation, and capacity development and strengthening of local government in urban management. Weak urban infrastructure and services along with insufficient capability to plan for the growth is a significant constraint to the socioeconomic development in the area. Basic urban infrastructure and services are insufficient for existing demands, notwithstanding the additional demand expected to be induced by increased movements of goods and people in the economic corridor.
13. The Huu Nghi border gate and Dong Dang market drainage area are located at the northern apex of the triangle formed by the three project cities with Hanoi at the center (Figure 1). The improvement of the existing border gate is vital to the growing trade with China. The government envisions the development of the Huu Nghi border gate to match the superior infrastructure in place on the China side, and to attract more investments into the region with particular interest in the logistics hub of Lang Son city located south of Dong Dang.
14. Dong Dang provides a base for housing and servicing the workers and transient population at the border gate. In order to accomplish the development objective, the physical infrastructure of the border gate needs to be improved—specifically by constructing a road extension to link up with a newly constructed road on the China side, improve cargo handling facilities and the customs and immigration administration buildings, and upgrade the sewage treatment. In Dong Dang, the flooding problem in the market area is to be addressed by improving the drainage system and raising the river embankment adjacent to the market area.
1 Groupe Huit - Primex – SCC, 2011. Draft Final Report on the Socioeconomic Development Project: Viet Tri, Hung Yen, Dong Dang, submitted to ADB, TA 7516-VIE, Appendix XVc. 2 ADB 2010. Concept Paper for the Comprehensive Socioeconomic Development Project, Project No. 41462, 4 pgs, + 5 Appendices
Source ADB
Figure 1. Four branches of the North South Economic Corridor of the GMS
B. Assessment Context
15. The overall CSUD project was assigned Environmental Category B which requires an initial environmental evaluation (IEE) pursuant to the ADB’s safeguard policy3, and environmental assessment guidelines4. A category B refers to projects which cause minor environmental and social impacts that can be prevented or mitigated.
3 ADB, 2009. Safeguard Policy Statement, ADB Policy Paper. 4ADB, 2003, Environmental Assessment Guidelines.
16. The detailed designs for the upgrades to the Huu Nghi border gate and rehabilitation of drainage infrastructure in market area of Dong Dang have not been prepared. The IEE including EMP was conducted based on the information on construction and operational phase activities of both components that was available at the FS stage of the project combined with general knowledge of the potential environmental impacts of these types of developments. The IEE was prepared using available data and information on sensitive cultural and ecological receptors that exist at the different project sites. The EMP will be updated where necessary to serve the detailed designs of these project components when they are completed.
III. POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK
17. The ADB Safeguard Policy Statement (ADB SPS 2009) clarifies the rationale, scope and content of an EA as supported by technical guidelines (e.g., Environmental Assessment Guidelines 2003). Projects are initially screened to determine the level of assessment that is required according to the following three environmental categories: Category A for projects that normally cause significant or major environmental impacts that are irreversible, diverse or unprecedented such as hydroelectric dams (an environmental impact assessment is required); Category B projects which have potential adverse impacts that are less adverse than those of category A, and such impacts are site-specific, largely reversible and mitigation measures can be designed more readily than for category A projects (an initial environmental examination is required); and Category C projects that are likely to have minimal or no negative environmental impacts (environmental assessment is not required but environmental implications need to be reviewed).
18. The overall ADB environmental categorization of the CSUD is "B" as approved by the ADB Chief Compliance Officer on 19 February 2010. For the components of the Dong Dang sub-project the negative environmental impacts are site-specific, will occur primarily during construction phase, are temporary, and can be mitigated. However, for involuntary resettlement the CSUD was classified as Category A.
19. The Viet Nam Law on Environmental Protection (LEP 2005) prescribes the requirements for environmental assessment (EA) for development and domestic project interventions that affect the natural and social environments. Government Decree 80/2006/ND-CP in conjunction with Decree 21/2008/ND-CP and the recently promulgated Decree 29/2011/ND-CP - April 18, 2011 elaborate the EIA requirements specified by the LEP (2005).
20. The updated screening criteria of Decree 29 distinguish projects that require an EIA from projects requiring the simpler Environmental Protection Commitment (EPC). The difference between the two processes reflects the level of assessment, and ultimate review and appraisal that is required. Circular 05/TT-BTNMT supports Decrees 80, 21, and 29 with technical guidance for preparing and reporting both levels of assessments.
21. The Lang Son Provincial People’s Committee (PPC) is the executing agency (EA) and implementing agency (IA) of the Dong Dang subproject. The provincial Project Management Unit (PMU) will manage construction of the buildings of Huu Nghi border gate with the Border Gate Economic Zone PMU managing the infrastructure works (including short road) of the border gate. Customs will manage operation of the entire border gate complex when completed.
The Provincial Water Supply and Drainage Company will build and operate the upgraded drainage infrastructure in the Dong Dang market area5.
22. The Department of Natural Resources and Environment (DoNRE) of Lang Son is responsible for management and protection of the environment in the province. The Ministry of Natural Resources and Environment (MoNRE) is the national environmental agency which provides policy and guideline support to the provincial DoNREs, and who also is responsible for administering GoV EA safeguards to development projects of national or interprovincial significance.
23. The environmental management of the Dong Dang subproject falls under the responsibility of the Lang Son DoNRE. At the time of the ADB Loan Fact Finding Mission (May 9-21) the DoNRE indicated that the entire upgrade of the Huu Nghi border gate facility will require a single GoV EIA, and that the rehabilitation of the drainage infrastructure at the market would require a GoV EPC. The GoV environmental safeguards will be prepared by the IA.
24. With assistance from the Project Implementation Consultants (see below) the PMU will update the ADB EMP to serve the requirements of the detailed designs, and with support from the CPC will be responsible to ensure that the environmental safeguards implemented for the project meet the requirements of the EMP.
IV. DESCRIPTION OF THE PROJECT
25. The subproject is at the feasibility stage. From the TA report the subproject consists of the following three components (Figures 2 and 3), which are summarized in Table 1. Component DD1: Upgrading Huu Nghi Border Gate Facilities Component DD2: Rehabilitation of Drainage Infrastructure in Dong Dang Market
Table 1. Summary specifications of project components DD1 and DD2 Subcomponents Features and Dimensions Rationale Huu Nghi border Roads, parking areas, and one Improvement of the border gate gate facilities building for immigration, facilities is expected to enhance trade (DD1) emigration and customs between China and Vietnam, and to administration. All civil works attract investments in the region are located inside a 124 centered on logistics and related hectare area covered by an services. Facilities improvement will existing master plan. also enhance efficiency in administering the border gate. Dong Dang 1 km primary, and 2.8 km of Proposed investments will reduce market area secondary and tertiary, frequency and severity of local drainage system drainage network. flooding around the market area and improvement protect residents the Ky Cung river. (DD2) 850 meters of riverbank retaining wall for flood protection to be upgraded. DD = Dong Dang, km = kilometer. Adapted from footnote 1
5 ADB, 2011. Memorandum of Understanding of Loan Fact Finding Mission for CSUD, 20 May 2011.
Figure 2. Huu Nghi border gate upgrade schematic (DD1).
Figure 3. Rehabilitation of market drainage infrastructure schematic (DD2).
A. General Description of Project Components (DD1 and DD2)
26. The detailed design phase of the project has not occurred which means the sequence of detailed civil and infrastructure work activities for the two components have not been defined. Provided below are general project activities from the TA report, which are supplemented with generic activities of similar projects, and the needs for environmental safeguard requirements.
1. Pre-construction Phase
27. The major activities prior to the initiation of DD1 and DD2 are: 1) completion of detailed designs for the border gate and drainage rehabilitation in market; 2) update and initiation of environmental management plan (EMP); and 3) land and asset acquisition and resettlement. Preparatory activities for the infrastructure upgrades in market area will occur to make residents and merchants aware of the construction works that will occur and associated disturbances.
28. After the detailed designs of the components are completed the initial use surveys of affected lands, and land and asset acquisition requirements will be reviewed and updated. This review is needed in order to update where necessary the resettlement and/or compensation that will be required, and to clarify right-of-way (ROW) of new feeder road through border gate. Similarly, the mitigation and monitoring plans of the EMP need to be updated to meet the detailed designs of the project.
2. Construction Phase
29. The upgrades to Huu Nghi border gate including new buildings and feeder road will employ standard civil construction techniques and practices. Similarly, the rehabilitation of the drainage infrastructure including placement the 850m flood control retaining embankment along the Ky Cung river that runs through Dong Dang will involve standard civil works activities as generalized below.
1. finalization of RoW for new road to border gate; 2. development of construction camp(s); 3. transport of heavy equipment and materials; 4. land clearing including UXO survey and removal; 5. establishment of borrow pit(s) for embankment fill and road; 6. shoreline clearing for embankment; 7. placement of embankment; 8. excavation for building foundations; 9. construction of buildings and footpaths; 10. excavation for pipelines and utility conduits; 11. installation of service and utility conduits (e.g. water supply and electricity); 12. installation of new storm and wastewater collection system; 13. backfilling and grading; 14. (re)surfacing with asphalt or concrete; 15. placement of utilities, light standards, signage, rails, and road paint; and 16. restoration (landscaping, grass, shrubs, trees, brick, paint).
Table 2. Summary of major generic activities of DD1 and DD2.
Development Phase Summary of Expected Major Activities Pre-construction 1. completion of detailed designs 2. update and initiation of EMP 3. land and physical asset acquisition 4. resettlement Construction 5. finalization of RoW for new road to border gate; 6. development of construction camp(s); 7. transport of heavy equipment and materials; 8. land clearing including UXO survey and removal; 9. establishment of borrow pit(s) for embankment fill and road; 10. shoreline clearing for embankment; 11. placement of embankment; 12.excavation for building foundations; 13. construction of buildings and footpaths; 14. excavation for pipelines and utility conduits; 15. installation of service and utility conduits (e.g. water supply and electricity); 16. installation of new storm and wastewater collection system; 17. backfilling and grading; 18. (re)surfacing with asphalt or concrete; 19. placement of utilities, light standards, signage, rails, and road paint; and 20. restoration (landscaping, grass, shrubs, trees, brick, paint). Post-construction 21) international business and public use of Huu Nghi Border. Operation 22) use of Dong Dang market
1. Post-Construction Operation Phase
30. The new feeder road for transport trucks combined with increased efficiency of new border facilities will initially reduce traffic congestion at the Huu Nghi border crossing. In the future the volume of traffic crossing the border will increase in support of planned economic and social development in the area.
31. Rehabilitation of drainage and flood control of the Ky Cung river will improve conditions for current business in the market. The improved drainage infrastructure and flood control embankment will need to be maintained.
V. DESCRIPTION OF AFFECTED ENVIRONMENT6
A. Topography and Geography
32. Lang Son province shares borders with Cao Bang province on the south, Bac Giang province on the north, Guangxi (China) on the east, Quang Ninh province on the north-east and Bac Kan, and Thai Nguyen provinces on the west.
33. The Huu Nghi border gate with China (Figure 4) is one of four border crossings in Lang Son province. Among the four it is the most important gate for cross-border movement of goods and bulk cargo. Figure 4 shows the location of the gate in relation to Dong Dang (greyscale).
6 Some data and information from Thanh Trinh Thi (2011). Report on Dong Dang prepared for TA 7516
Figure 4. Huu Nghi border gate to China.
34. Lang Son province is a frontier province in the northeast of Vietnam. About 80% of the province is hilly and mountainous with elevation ranging from 20 to 1,540 meters. Huu Nghi border gate is situated on hilly terrain (Figure 5). The access road and facilities of the border gate are located between the slope of a narrow valley on the west side of the area, and the Ky Cung River on the east. The Ky Cung river flows downstream from China to Dong Dang. Parallel to the east side of the river is a railway that also crosses the China border.
Figure 5. Elevations along road to Huu Nghi gate along western side Ky Cung river.
B. Socio-economy
35. The economy of Lang Son province is currently based on 80% agriculture and forestry. There are substantial mineral deposits of bauxite, coal and phosphate as well as reserves of gold, silver and lead which are currently being explored for exploitation.
36. The GDP is expected to reach 14-15% annually with an increase of 20-12% in construction sector, and 3.5-4% in agriculture. The service sector expects 13-14.5% growth with more development in infrastructure, commercial centers, goods transit warehouses, and trade- service and hotel clusters.
37. The agriculture, forestry, and fishery sectors plan to reach an average growth rate of 3.5–4%. These sectors will be developed with intensive farming and modern technology to raise productivity. Anticipated output is further development of short-term industrial processing of tobacco, soy bean, sugarcane, ginger and fruit trees. Total fruit tree area of over 31,000 hectares occurred in 2010.
38. Industrial growth is expected to reach 19-20% annually with a focus on agriculture and forestry products, foodstuff, and refined products for export. Development of small and medium sized industrial zones is encouraged.
39. Data and information on human use of the Ky Cung river as it flows by the Huu Nghi border gate and Dong Dang are not available. The Lang Son DoNRE was not able to provide an inventory of uses patterns of the river.
1. Border Exchange with China
40. Compared with the other border provinces with China, Lang Son is considered to have the most potential as a transit area for goods exchanged between the two countries. Indeed, trading in retail commodities and bulk goods across the four Lang Son border gates is active and growing, and this is believed to account for the higher average income per capita in the province compared with the national average.
41. Dong Dang is just south of the Huu Nghi border gate which is the near fast growing economic export zone and logistics center of China’s Guanzi Zhuangzu province. An international railway station services Dong Dang with plans to upgrade the railway link. The population of Dong Dang in 2009 was 7,240.
42. Currently there is only one gate at the Huu Nghi border to process the flow of both people and freight/cargo crossing the border. The gate acts as a bottle neck to the flow of good to and from the gate. The proposed plan is to provide separate approaches and gates for people and for freight trucks. Of the four border gates in Lang Son, the Huu Nghi border gate serves as the only international gateway — meaning it is intended to be the crossing point of goods originating from Cambodia or Laos. Whereas the three gates at Tam Thanh, Coc Nam and Bao Lam cater to trade between China and Vietnam.
43. The Huu Nghi border gate is the biggest and most active of the four border crossings. Total trade (i.e., exports plus imports) in 2010 reached US $943.4 million, a three-fold increase from the level of $279.7 million in 2006 (Table 3). Imports surpassed exports by a ratio of 3.8. In terms of passenger traffic, the total number of crossings last year was 710,606 persons, about 4.5 times the volume recorded in 2005.
Table 3. Total trade and passenger traffic across Huu Nghi border gate, 2005-2010
Average Trade Value ($’000) Average Year Passenger Change (%) Export Import Total Trade Increase (%) 2005 449,609 n.a. n.a. n.a. - 2006 255,701 -43 50,698 229,045 279,743 - 2007 554,413 117 42,911 439,510 482,420 72 2008 684,338 23 58,082 655,592 713,675 48 2009 743,490 9 99,637 686,245 785,882 10 2010 710,606 -4 198,383 745,001 943,384 20 na – data not available Source: Huu Nghi border gate (Customs office)Huu Nghi border gate (Customs office)
44. About 70–100 cargo trucks pass through the Huu Nghi border daily from both sides. Recorded daily passenger traffic is 2,000–2,500 persons. Toll fees are collected from every truck that crosses the border gate. Passengers also pay for immigration services, and the Government earns tax revenue from imports and exports that cross the border.
C. Physical Resources
1. Climate
45. Lang Son’s climate is typical of northern Vietnam with distinct seasons. Temperature is also affected by the complex mountainous terrain. Seasonal temperature is summarized as follows:
Annual average temperature: 17–22 oC. Annual average rainfall: 1200–1600 mm. Annual average relative humidity: 80–85%. Average amount of cloud cover: 7.5%/10% Average annual sunny hours: 1600 hrs.
46. Wind direction and speed of Lang Son are affected by the circulation of atmosphere and the terrain. A north wind prevails in winter with south and south-easterly winds in summer. The wind speed is not strong in general averaging 0.8 to 2 m/s.
2. Soil Resources
47. There are three main soil types located in the low mountain and hill regions (under 700m). Humus dominates in the high mountain areas (700m–1500m) with alluvial soils in the flood plain of the river.
3. Land Use
48. The total area of Lang Son is approximately 830,521 ha which is apportioned by the following uses:
- Agricultural land: 68,959 ha - Forestry land: 277,394 ha - Specialized land: 12,040 ha - Rural land: 4,114 ha - Urban land: 684 ha - Unused land, rivers, streams and rocky mountains:467,366 ha
4. Mineral Resources
a. Ferrous metal mineral
49. Iron ore is the dominant ferrous metal in the area which has been exploited by the French and Japanese since 1937. The Gia Chanh iron mine is located in Gia Sao commune of Chi Lang district.
b. Nonferrous metals
50. This group contains aluminum, copper, lead, zinc and poly metallic ore. The aluminum reserve is the largest followed by copper, lead, zinc and poly metallic ore. There are 37 aluminum mines. Aluminum ore deposits are distributed mainly in Bac Son mountain chain and along 1A Highway from Lang Son to Dong Dang. Aluminum ore in Lang Son consists of two kinds such as bauxite and a lit.
51. Eight bauxite mines and bauxite ore deposits are located in area near Lang Son city. Ma Meo, Tam Lung, Loong village, Khon Phich, Thanh Moi, Na Doong and Na Chuong. Ma Meo mine has an estimate reserve of 20 million tons.
52. Copper exists in conjunction with ore deposits. The province’s total reserves of lead and zinc are about 100.000 tons. Poly metallic ore that is found in Tinh Sung mine in Gia Cat commune of Cao Loc district has the reserves of about 500 tons.
c. Precious metals
53. Gold has been discovered at over 35 mines which Huu Lung, Bac Son, Binh Gia, Van Mich and That Khe. In this area, hundreds of hectares of washed placer scatter inside valleys, rivers, and streams.
5. Water Resources
54. There are six main rivers in the province. The Ba Thin river flows from the highland in Quang Tay-China to the Ky Cung river in Khuat Xa commune of Loc Binh district. The river is 54km and runs through the basin of approximately 320 km2
55. The Bac Giang river is 114 km with a basin area of 2,670 km2. The Hoa river is 47km in a basin of 385 km2. The Trung river is 65 km with a basin of 1,270 km2
56. The Bac Khe river is 54 km with a basin area of 801 km2. It is the second largest river of Lang Son originating from Na Pa Phuoc Mountain Chain (Chi Lang district). It runs in the depression of Mai Sao-Chi Lang and the locality of Bac Giang province. The river is 157km in a basin of 6,640km2
57. Information and data on the aquatic resources of the Ky Cung river near the Huu Nghi border gate and in Dong Dang are not available. The Lang Son DoNRE were not able to provide an inventory of aquatic resources for the river.
6. Water and Sediment Quality
58. The Ky Cung River flows past the Huu Nghi border gate from China and downstream toward Dong Dang. The river is about 50 km and drains an area covering about 6,700 km2. Water quality data for four sites along the Ky Cung river as reported by the Lang Son DONRE for 2009 are shown in Table 5. Sampling sites are defined by N1 at Ngam Bridge in Lang Son city; N2 at Ma Pha Bridge in Lang Son city; N3 at Ba Cung village at Huu Nghi; and N4 at Pa Phieng bridge at Huu Nghi).
59. In addition, the PPTA team took a sample of the river water at Dong Dang near the town market on 13 January 2011 (site N5). Parameters exceeding the quality standard for B1-class surface water are suspended solids, BOD, COD, ammonia and nitrates, and phosphates. Coliform level at Dong Dang also exceeds the standard. Soil erosion from human activity along the river bank, and the discharge of untreated domestic waste to the river would be the likely causes of those water quality parameters exceeding the standards.
60. A sample of the bottom sediment from the Ky Cung River at Dong Dang was analyzed for heavy metals (Table 4). None exceeded QCVN standards as shown in table.
Table 4. Sediment quality in Ky Cung river
QCVN 03:2008/ Netherlands Parameter Unit Value BTNMT Standard Pb mg/kg 11.7 70 85 Cu mg/kg 15.5 50 36 Cd mg/kg 0.11 2 0.8 Zn mg/kg 11.2 200 140 Ni mg/kg 1.95 35
Table 5. Water quality data in the Ky Cung river
N5 (Dong QCVN Parameter Unit N1 N2 N3 N4 Dang 08/2008-B1 pH 6.87 7.11 6.86 6.92 7.1 5.5-9 SS mg/l 202 156 43 38 34 50 DO mg/l 4.5 3.5 4.2 4.1 4.2 ≥ 4 BOD5 mg/l 31 32 19.1 22.1 37.9 15 COD mg/l 73 57 39.3 40.3 52 .7 30 N - NH4 mg/l 1.7 1.32 0.32 0.42 7.25 0.5 N - NO2 mg/l 0.03 0.03 0.12 0.02 0.05 0.14 N - NO3 mg/l 18.5 15.5 9.5 4.7 8.7 10 PO4 mg/l 0.35 0.46 0.17 0.11 1.7 0.3 Fe mg/l 0.186 - 0.04 - 1.24 1.5 As mg/l 0.007 0.001 0.001 0.001 0.008 0.05 Cu mg/l 0.062 0.11 0.14 < 0.01 0.01 0.5 Zn mg/l 1.64 1.02 0.75 0.57 1.52 1.5 Cr mg/l < 0.001 < 0.001 < 0.001 < 0.001 Not detected 0.04 Pb mg/l 0.007 0.002 0.002 0.002 < 0.001 0.05 CN- mg/l < 0.001 0.001 0.001 0.001 < 0.001 0.02 Ni mg/l < 0.001 < 0.001 < 0.001 < 0.001 - 0.1 Hg mg/l < 0.001 < 0.001 < 0.001 < 0.001 - 0.001 Oil and grease mg/l 0.12 0.07 0.04 0.05 - 0.1 Phenol mg/l 0.001 0.001 < 0.001 < 0.001 - 0.01 Coliform MPN/100ml 7200 1.1 x 103 410 4100 11,550 7,500 l = liter, mg = milligram, ml = milliliter. Source: Lang Son DoNRE, 2009, and PPTA team (station N5)
Table 6. Ground water quality in Lang Son City
Parameter Unit Ground water QCVN 09/ 2009 pH 5.5 - 6.1 5.5 – 8.5 TSS mg/l 5-7 1500 - NO3 mg/l 0.07 – 2.16 15 + NH4 mg/l 0.02 – 0.2 0.1 Total iron mg/l 0.01 - 0.06 5 Manganese m g/l 15 – 29 0.5 COD mg/l 0.24 - 0.89 4 E. Coli MPN/100ml 0 – 110 0 Total Coliform MPN/100ml 0 – 280 3 l = liter, mg = milligram, ml = milliliter. Source: The environmental status Lang Son, 2005 – 2010, Lang Son DoNRE
7. Ground Water Quality
61. Ground water in the Lang Son city has pH between 5.3 - 6.1, slightly lower than the neutral value (Table 6). All other physico-chemicals parameters of groundwater meet the Vietnamese Standards for groundwater quality (QCVN 09/ 2009).
8. Air Quality and Noise
62. Table 7 indicates that the levels of dust and common pollutants (SO2, NO2, CO) are within the Vietnam Standard for Ambient Air Quality (QCVN 05/2009).
Table 7. Air quality in Lang Son
Wind Concentration of pollutants (mg/m3) To Humidity velocity o Location ( C) (%) (m/s) Dust SO2 NO2 CO N1 23.90 88 0.6 0.12 0.075 0.044 1.39 N2 23.99 87 0.8 0.17 0.118 0.065 1.88 N3 27.80 67 0.6 0.03 0.095 0.078 1.94 N4 23.80 84 0.7 0.18 0.095 0.074 1.84 Vietnam Standard 0.30 0.500 0.400 40.00 c = centigrade, m = meter, m3 = cubic meter, mg = milligram, s = second. N1 – Crossroads Phai Ve – Le dai Hanh, Lang Son city; N2 – Dong Kinh market, Lang Son city N3 – The centre of Cao Loc, Dong Dang; N4 – The Huu Nghi, Dong Dang gate Source: Lang Son DoNRE, 2009 - Report on status environmental of Lang Son province
a. Noise Levels
63. Noise levels measured by the Lang Son DoNRE indicate that noise levels in the Lang Son area range from 63–78 dB(A) higher than the allowable limit TCVN 5949/1995 of 75 dB(A). In Dong Dang noise levels range from 62–79 dB(A) which are higher than the allowable limit TCVN 5949/1995 of 75 dB(A). It is believed that truck traffic across the border, and local industry are the main causes of the elevated noise in Dong Dang.
D. Ecological Resources
64. The northern forested mountainous area supports a rich diversity of flora and fauna. The karst limestone formations (also known as carbonate karst) occupy 5% of the natural forest area of Vietnam Long Son and Cao Bang, and have an important place in the floral and faunal wealth of the forests. Northeast Viet Nam has 36% of the country’s 1.15 million ha of rocky mountains out of which Lang Son and Cao Bang provinces account for a substantial part of limestone formations.
65. Some of the districts such as Hữu Lũng District have sugar cane plantations and grow oranges and pineapples, others grow tea and plums. Animal husbandry is developed in Lang Son Province. The province is also noted for its That Khe duck speciality.
1. Fauna
66. Animal life in Lang Son is quite diversified and plentiful. The dominant class of animals is comprised of 8 orders with 56 species (e.g., tiger, silky-haired panther, leopard, Tibetan bear, civet, fox, chamois, spotted deer, deer, badger, rhesus monkey, black gibbon, squirrel). The dominant class of birds is represented by 18 orders, 46 families with 200 species (e.g., phoenix, peafowl, pheasant, grackle, great hornbill, woodpecker, parrot, hawk, stork, night heron).
67. Amphibia and reptiles are found in 3 orders, 17 families with 50 species. Popular species are gecko, python, snake, frog, toad, and turtle. Ten of families of fish are present. Some valuable and rare species are bango and carp. According to forest statistics of Vietnam these limestone formations have 69 mammal species; five of them are endemic and 26 are rare species.
2. Flora
68. The plant assemblages found in Lang Son belong to five types: 1) tropical evergreen humid rain forest; 2) tropical evergreen humid rain forest; 3) tropical humid semi-deciduous forest; 4) tropical humid deciduous forest; and 5) subtropical evergreen humid rain forest in low mountains.
69. Valuable natural forest trees exist such as such as iron wood, bassia, and sandalwood. Artificial forest trees include such as eucalyptus, pine tree. Industrial crops are tobacco and anise.
70. The most important tree grown in Vietnam (and also in China) is the star anise (illicium verum), an evergreen tree which has aromatic janceolate leaves, and an important spice. Lang Son Province supported the greatest area of this tree approaching 9000 ha, mostly in its Van Quan. Other provinces also have this species of trees but the coverage is limited. Initially the tree belonged to the state farm enterprises under collective farming. However, since the 1990s, it has been deregulated and given the trees to village families to manage.
71. Fruit trees consist of Japanese seedless persimion, custard apple, yellow tangerine, plum, and pear. Main crops include rice, which accounted for 40,000 hectares out of a total of 55,000 hectares grown in 1986, and sweet potato, maize and manioc. It is also known for its commodities of tea and yellow tobacco. These crops are generally grown in the valleys of the Bac Son Mountains, Binh Gia Mountains and the Van Quan Mountains and along the rivers plains of the Ky Cung River and the Thuong River.
3. Protected Areas and Wildlife
72. The Huu Nghi border gate and market in Dong Dang are not located in ecological protected areas. However, as mentioned Lang Son province as a whole is rich in biodiversity contained in its forests, part of which are notable for being found on karst limestone formations (also known as carbonate karst). These karst forests provide home to 69 mammal species, 5 of which are classified as endemic and 26 are classified as rare.
73. In general, the mountainous areas of Vietnam’s northern provinces next to the Chinese border are home to numerous species of large and increasingly rare mammals—notable among which are the Asian tiger, silky-haired panther, leopard, Tibetan bear, civet, fox, chamois, and spotted dear. Also found in these forests are 200 identified species of birds and 50 species of amphibian reptiles.
74. The most significant threat to conserving wildlife in Vietnam appears to be illegal trade— which include live animals, meat products for human consumption, processed/dry medicinal products, and decorative stuffed animals). In terms of value, meat products account for most of the trade, consisting of snakes, palm civets, monitor lizards, porcupines, leopards, pangolins, monkeys, forest pigs, hardshell turtles, soft-shell turtles, civets, boas and birds.
75. A study by Hanoi Agricultural University7 estimated that up to 4,000 tons of live animals, meat, skins, ground bones and other illegal wildlife products are trafficked into and out of Vietnam--generating more than $67 million in annual revenues. These mostly come from Vietnam's national parks and from neighboring Laos and Cambodia--to be consumed in Vietnam or destined for China, South Korea, Taiwan and Japan. A large volume is smuggled across the Vietnam-China border, which is estimated at 2,500 to 3,500 kg every day. Demand is driven by need for specific animal parts used in traditional Asian medicine, for human consumption, and as symbols of wealth.
76. The Ha Noi study also mapped the network of illegal trade in wildlife in Vietnam.8 Hanoi serves as the main collection and transit point for wildlife products originating elsewhere in Vietnam or from Laos and Cambodia. The main network is along Road A1 which connects central and south Vietnam to Ha Noi, and then from Ha Noi to China through the border gates at Mong Cai (in the coastal province of Quang Ninh) or through Lang Son (which has four road border crossings with China, and one railway crossing). This route is believed to account for about 90% of illegal wildlife trade with China. Other known wildlife trade routes are from the northeast--such as Ha Giang along Route 2, Lao Cai along route 70, and the border crossing from Laos through Dien Bien Phu and Son La via Route 6—all bound for Ha Noi. Ha Noi is a big consumer of wildlife meat products, aside from being a center of trade for wildlife products bound for China.
77. The government is aware of the threats to the country’s biodiversity and its importance of conservation for sustainable development, and has issued a series of regulations on the management and protection of valuable wildlife resources. Since it became a Party to CITES9,
7 Nguyen Van Song , Wildlife Trading in Vietnam: Situation, Causes, and Solutions, Journal of Environment and Development, June 2008, 17: 145-165. 8 Nguyen Van Song, Wildlife Trading in Vietnam: Why It Flourishes, Economy and Environment Program for Southeast Asia, 2003. 9 Report on the Review of Vietnam’s Wildlife Trade Policy, CRES/FPD/UNEP/CITES/IUED, Hanoi, Vietnam, 2008. CITES refers to the Convention on International Trade in Endangered Species of Flora and Fauna.
in 1994 Vietnam has issued many regulations on the harvesting and trading of wildlife in line with the objectives of the CITES. There is now existing policy and legal framework for regulating wildlife trade which have had positive impacts on biodiversity, particularly by preventing excessive exploitation of endangered wildlife.
E. Conditions at Huu Nghi Gate, and Dong Dang Market
78. At the northwest end of the Nuu Nghi gate near the Chinese border, the hillside has already been cut and the adjacent area--approximately 2.5 hectares--has been leveled to provide space for parking and unloading/loading for trucks that exchange cargo going into or arriving from China. The ground surface at this trans-shipment area has not been paved yet, and the hillside which was cut to provide the space is exposed. At the northern end of the gate close to the border, slope stabilization works to reinforce the exposed cuts on the hillside are underway on both the Vietnamese and Chinese sides of the border.
79. The present road connecting the Vietnam and China sides of the border passes through an existing tunnel located on the China side. According to the existing master plan (Figure 6) for the border gate development, a new access route to accommodate increased cargo traffic across the border will be provided on the eastern side--as indicated in the image above by the double-headed yellow arrow. The road segment for this new cross-border route is being constructed on the China side, so the road segment on the Vietnam side is intended to link up with the road alignment on the China side (indicated by the broken yellow line in the image below). The Vietnam side of the new cross-border road will cut through a low hill on the west side of the Ky Cung River.
80. At Dong Dang there is a need to improve the drainage system in the market area and to remove obstructions and accumulated trash in the Ky Cung River as well as to strengthen the embankment along an 850 m stretch of the river. The main concern is to address local flooding problems which usually happen during June and July. According to residents along the river bank, floods occur two to three times every year, but the water recedes in about one hour. Severe local flooding reportedly occurred in 2008.
81. The city’s central area near the market is already served by a network of concrete-lined and covered drainage system. However, the secondary and tertiary drainage ditches need to be enlarged. Construction of the latter will temporarily affect some stall-owners in the market, particularly those along the side streets and alleys. There are about 300 stall renters and a number of itinerant vendors who sell their wares along the alleyways.
1. Sensitive receptors
82. There are no ecological or cultural sensitive receptors in the urban market area of Dong Dang. Similarly, no cultural sensitive receptors exist at the Huu Nghi border crossing site. However, information or data confirming the presence/absence of ecological sensitive receptors at the border site do not exist. Ecological data and information on fauna and flora, rare and endangered species, and critical habitat at the Huu Nghi border gate are unavailable according to the Lang Son DoNRE. Similarly, information on aquatic resources and uses of the Ky Cung river at the border gate area, and adjacent to the Dong Dang market are not documented. It is recommended that as part of the EMP update during the detailed design stage that brief surveys are conducted to ascertain the presence or absence of these valued ecosystem components at the immediate project sites.
Figure 6. Existing masterplan for Huu Nghi border gate.
VI. PUBLIC CONSULTATION
83. Consultations were held with stakeholders in Huu Nghi and Dong Dang to disclose information on the proposed upgrading of Huu Nghi border gate and drainage infrastructure in Dong Dang. The consultations were conducted to obtain stakeholder concerns of potential environmental impacts, and socio-economic impacts such as resettlement and livelihood disruptions. A stakeholder consultation was held on 13 January 2011.
84. The consultations generated feedback on concerns about socio-economic impacts, resettlement and compensation concerns for households affected by the road construction at the border gate, and environment impacts.
85. The consultation was held at the Dong Dang People’s Committee Office attended by 24 participants representing the People’s Committee of Cao Loc district (which covers Huu Nghi), the Dong Dang People’s Committee, local residents, Dong Dang Market Traders, and representatives of the Women’s Union (WU), Farmers Union, and Veterans Union. The list of participants are found in Appendix A. There was no opposition raised against the project, and there was general agreement that the subcomponents will be beneficial to the local economy and inhabitants. The feedback and concerns raised regarding environmental impacts are summarized in the Table 8. Included in Table 8 are the environmental management measures that will be taken to address the stakeholder concerns that are within the scope of the project.
Table 8. Stakeholder comments on project in Dong Dang.
Item Feedback Response of Project Movement of There is seasonal influx of people, mainly during The potential changes to people festival months. import privileges of local Many people move through the border area; local residents are outside residents have a special card allowing them to scope of the project. move more easily across the border, and they The potential effects of are allowed to import 2.5 million VND/goods/day expanded commerce on tax-free. Minor concern over how these local competition is privileges may be affected. outside scope of project. More new people are coming to the area to take part in trade; Dong Dang is expanding, with people coming from neighboring districts and provinces. Concern about competition with newcomers to the area. Social concerns Had an HIV awareness/human trafficking/drug The strategy of using user campaign through UNICEF (2004-2008) local worker force during managed by the provincial Women’s Union; it construction to minimize was viewed as successful. People would like to potential increase in HIV expand such activities supports campaign of Job creation viewed as important. WU, and job creation. 10% of people involved in agriculture; 90% involved in trade/service.
Border gate Many market traders go everyday to cross the The potential change in facility border to buy/trade goods in China. They have the use of the ―informal‖ passports and cross legally. They recognize crossings is outside more informal crossings and networks, stating scope of project. simply ―it’s usually the people who carry goods to A detailed resettlement avoid taxes.‖ plan (RP) for the project
Item Feedback Response of Project Concerns raised that any improvements of the has been prepared border gate would entail resettlement. under separate cover. Environment Environment and sanitation are perceived The rehabilitation of the and drainage important issues in Dong Dang. drainage in market area For the drainage system, the outlets needs to first will include the drainage be improved before dealing with the market outlets. drainage. Improved solid waste Solid waste management should be improved to management will be avoid clogging the drainage system. included in training and capacity development for maintenance of rehabilitated drainage system. Market activity Most of the merchants in the market area are Effort will be taken to not with average monthly income of 16-20 million schedule construction VND/month. activities during peak Construction should be done during March to business periods and June since visitors and tourists are fewer during holidays such as Tet. these months. Construction during Tet should not be undertaken to avoid loss of income in the market. Garbage Solid waste collection system can be improved; Solid waste collection consider having a market collective that assigns management is outside garbage pick up to an independent entity. the scope of the project. Waste management program was started 3 years Improved management ago; it was perceived as being a good system. practices for the Problem viewed as being more the drainage and rehabilitated drainage flooding (even though floods are reported to system will be retreat quickly). introduced as part of the People’s awareness need to be raised about training and capacity importance of proper garbage handling and development. disposal. Water borne diseases not perceived to be a major problem. River 70 households along the Ky Cung river are The embankment that embankment affected by the flood every year; the highest project will build along flood level is 1.5 m, and lowest at 0.5 m (floor Ky Cung river is level). designed to reduce Local residents recommend improving the local flooding. embankment and make it higher. Solid waste collection should be improved to be avoid clogging the river.
86. Wider information disclosure regarding the Dong Dang project subcomponents will be done through dissemination of the IEE report through the Dong Dang PMU, and on-line through the ADB website (www.adb.org). During implementation, the monitoring reports for the environmental safeguards will be made available through the PMU.
A. Stakeholder involvement during project implementation
87. As part of information disclosure and grievance mechanism during project implementation (see chapter IX) further interaction of the stakeholders with the CPCs during
implementation will occur. The stakeholder interaction already completed is meant to form the basis for additional interactions between stakeholders and the CPC as the project is implemented.
VII. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
A. Project Benefits
88. The upgrading of the infrastructure and facilities at the Huu Nghi border gate, following the government’s master plan for area, is expected to produce significant socio-economic benefits through facilitating the growing trade between China and Vietnam. The improved border gate will also serve as an important gateway for goods from neighboring Laos and Cambodia to reach the China market. It will provide increased income opportunities for the local population. In any case, the improvement of the Huu Nghi gate is in conformity with bilateral agreements between China and Vietnam to speed up and coordinate the improvement of their respective border facilities; the facilities on the China side of the Huu Nghi border are now ahead in terms of readiness as compared to the Vietnam side.
89. The opening of a new route into China (which will link up with a road already nearing completion there), combined with efficiency improvements in customs procedures, will speed up the passage or trans-shipment of goods exchanged through the border. Specifically, this new road is planned to be exclusively used for the movement of bulk cargo and container trucks, thereby freeing up the existing road for the movement and processing of travelers. Reduced time spent in moving cargo in and out of the area will translate to lower vehicle operating times and therefore reduced total emissions (even though this effect will be offset by an eventual increase in vehicle number and traffic as a result of increased trade).
90. Complementary improvements of the ancillary facilities, including provision of adequate parking and waiting areas, walkways, and sanitation facilities for transit workers and travelers will enhance overall living conditions. The separation of lanes used for the movement of travelers and of cargo trucks will reduce safety hazards posed to pedestrians by the continuous movement of heavy vehicles.
91. Improvement of the border gate is intended to also enable the planned development of outlying areas for commercial development (e.g., duty free zone) and logistics services. Specifically, the improvement of the Huu Nghi gate will accompany, if not actually induce, the transformation of a 10-km road and railway corridor between Dong Dang town and Lang Son city into an economic development corridor. This induced effect of the border gate improvement is consistent with the government’s master plan for the development of the border region and its role as an international gateway for goods and travelers.
92. Improvement of the drainage system in the market area of Dong Dang will reduce the frequency and severity of local flooding in the area, which translates to less disruption of business activities in the market as well as avoided property losses for both commercial establishments and nearby households. The removal of debris and obstructions in the Ky Cung River, combined with raising and strengthening of the retaining wall to protect against floods, will reduce damages and threat to lives posed by flash floods.
B. Project Impacts and Mitigations
93. The negative environmental impacts of the project are associated primarily with the construction phase and secondarily with the pre-construction and operation phases of the project. The potential impacts and mitigations for each of three project stages are discussed below.
1. Pre-construction Phase
94. Impacts associated with the pre-construction phase of the Huu Nghi border upgrades and Dong Dang drainage rehabilitation concern primarily land and asset loss, and resettlement. Land and asset losses or reductions include area for agriculture and home gardens, aquaculture, and business practice. These impacts and management actions are addressed in the Resettlement Action Plan (RAP) for the project which is under separate cover. During the pre-construction phase impact mitigations and required environmental monitoring which form the environmental management plan (EMP) are finalized with the detailed designs of the project.
a. Mitigations
95. The key mitigation measure of the pre-construction phase is the update and initiation of the EMP. The EMP is updated to more accurately address the detailed designs of the Huu Nghi border gate, and market drainage rehabilitation. Initiation of the EMP involves articulation of sub-plans to manage potential impacts such as erosion, sedimentation of surface waters, noise, dust and air quality, spoil disposal, traffic, and worker and public safety at the project sites. Details of the mitigations of the pre-construction phase are detailed in Table 10 of the EMP (below).
2. Construction Phase
a. Common potential impacts
96. The negative impacts of the redevelopment of the Huu Nghi border crossing and the rehabilitation of the drainage in the Dong Dang market are primarily associated with the construction phase activities and minimally with the operation of the upgraded facilities and infrastructure. The construction activities including the transport of construction materials will occur near where people live and work.
97. Common potential negative impacts of civil works associated with the two project components consist of reduced and/or blocked public access, disrupted business and recreation, noise, dust and air pollution from NOx, SOx, and CO caused by increased truck traffic and heavy equipment use, soil and surface water and groundwater pollution caused by equipment operation and maintenance, public and worker accidents, increased traffic accidents, land erosion and surface water sedimentation, solid waste and domestic pollution from worker camps, social and community problems caused by migrant workers.
i. Common mitigation measures
98. Management measures to mitigate potential common impacts associated with the construction-upgrade phase of the Huu Nghi border crossing, and rehabilitation of the market drainage infrastructure are introduced below. Table 10 of EMP provides much more detail.
1) Care must be taken to ensure that sites for earthworks (e.g., road grading, excavations, trenches) that are suspected to have unexploded ordnance should be surveyed by the military prior to construction. If such ordnance is detected clearing work will need to be commissioned prior to undertaking civil works following procedures mandated by the Ministry of Defense (Decision 117/2007/QD-BQP). 2) Open excavations should be fenced, and trenches covered where public walkways or vehicles must cross. 3) Regular use of wetting agents should be employed at construction sites to minimize dust. 4) All construction vehicles and equipment should be maintained in proper working order, and not operated at night if possible to minimize noise. 5) Speed limits should be posted and adhered to by construction vehicles. 6) Where possible construction vehicles should use different roads or dedicated lanes of roads shared by the public. 7) Trees and other vegetation along construction sites should be protected. 8) Present and past land use should be reviewed to assess whether excavated soils are contaminated spoil. Contaminated spoil should be disposed at a landfill or a location agreed upon with Lang Son DoNRE. 9) Berms and/or silt curtains should be constructed around excavation/trench sites and along all surface waters (i.e.,, Ky Cung river) to prevent soil erosion. 10) Local workers should be used as much as possible to prevent or minimize influx of migrant workers, and incidence of social disease and community unrest. 11) Worker camps must have adequate domestic waste collection facilities and sufficient pit latrines that are located away from public areas and surface waters. 12) Dedicated fuel storage areas must be established away from public areas and marked clearly. 13) To protect the urban environment and minimize the impact of construction on the public, workers, and existing directives of the DoT and MoLISA that govern the safe and orderly operation of road works in Lang Son should be consulted (Table 9). 14) Construction site safety guidelines provided by the World Bank (2007) should be applied (Table 9). At a minimum, workers should wear safety approved construction helmets, and proper footwear.
15) Aggregates (e.g., sand, gravel, rock) that are transported by truck should be covered.
16) Prolonged use of temporary storage piles of file should be avoided, or covered, or wetted regularly to prevent dust and erosion.
17) Sand extraction in rivers for road embankment fill should be done at licensed areas only.
18) Storage of bulk fuel should be on covered concrete pads away from the public and worker camp. Fuel storage areas and tanks must be clearly marked, protected and lighted. Contractors should be required to have an emergency plan to handle fuel and oil spillage.
b. Hill removal at Huu Nghi border gate
99. Earthwork activities for the road improvement in Huu Nghi gate is not expected to generate significant alterations of the terrain since much of the existing road alignment is situated on the floor of the narrow valley that forms the area. However, the 500 meter extension of a four-lane road branch that would open up a new route into China on the east side of the gate will necessitate cutting into a low hill.
100. Because of the relatively steep hillside through which the road extension will pass, much of the road base is expected to be constructed on the cut, rather than on an embankment that balances the cut and fill. In this case, the cutting of the hillside will produce significant quantities of excavated soil during construction (although erosion and slumping of the cut will be prevented by structural measures to stabilize the slope).
Table 9. Applicable Laws, Directives and Environmental Standards.
Laws Law on Environmental Protection (LEP) No. 52/2005/QH11. (see section IV above) Law on Construction (LoC) No. 16/2003/QH11 Biodiversity Law 20/2008/QH12 dated 13th November 2008; Land Law No.13/2003/QH11 dated 26th November 2003 Construction / Ministry of Labour, Invalids and Social Affairs Decree No. 12/2009/ND-CP on managing construction and investment projects Decree No. 209/2004/ND-CP dated 16th December 2004 on managing the quality of construction projects. Decree 110/2002/ND-CP, supplementing some articles of Decree 06/1995 on labour code of occupational safety and health Decree 06/1995, Elaborating provisions of labour code on occupational safety and health International Guidelines World Bank Group, 2007. Environmental Health and Safety Guidelines, Wash. DC. Environmental Protection Standards QCVN 08:2008/BTNMT: national regulation on surface water quality QCVN 05:2009/BTNMT: national technical regulation on ambient air quality QCVN 09/2008/BTNMT: national regulation on groundwater quality QCVN 14:2008/BTNMT: national technical regulation on domestic wastewater QCVN 15/2008/BTNMT: national regulation on allowable pesticide residues in soil QCVN 03/2008/BTNMT: national regulation heavy metals concentrations in soil TCVN 6962:2001: allowable vibration and shock from construction activities TCVN 5949:1998: allowable noise levels in residential and public areas
i. Mitigations
101. The spoil from the hillside road construction can be stored and used as fill material for road embankments to be improved in other parts of the border gate. However, some portion of the excavation spoil may find its way to the nearby Ky Cung River. Such sediment load, if not controlled, will be carried downstream toward Dong Dang. As the latter is already experiencing flooding due to overtopping of the city’s low river dyke, it is important that erosion and sediment production due to land leveling for road construction at the border gate be mitigated in order to prevent further siltation of the river downstream, as this would increase the vulnerability of Dong Dang to flooding.
3. Operation Phase
102. Potential direct negative environmental impacts from the operation of the completed Huu Nghi gate are restricted to increased minor road accidents due to the overall increase in vehicle traffic that is expected to follow the improved crossing facilities, increased air pollution and noise from the increased vehicle traffic, and a potential increase in spills of liquid and solid cargo that is transported and parked at the border crossing. A potential negative effect of the improved border gate is use of the border to increase transport and trade of illegal animals.
The operation of the upgraded drainage infrastructure and flood control in the market area is not expected to cause any potential direct negative environmental impacts in Dong Dang.
i. Mitigations
103. Well marked and enforced speed limits must be posted through the border gate. Guidelines for the transport, handling, and temporary storage of cargo at the crossing should be developed. Extensive idling of vehicles at the gate should be prohibited. Customs personnel should increase search and surveillance for illegal transport of animals across the border.
4. Induced Impacts
104. Potential induced environmental impacts created primarily by the upgraded and expanded Huu Nghi border crossing could arise at different spatial scales. Potential induced impacts associated with the rehabilitated market drainage are considered contributing, but relatively minor and limited to urban Dong Dang.
105. At the local level the desired subproject outcome of improved and expanded border and customs services causing increased trade traffic will stimulate increased development of ancillary facilities and nearby commerce which will both support and benefit from the busier border. That local economic and social development could lead to increased land development, natural resource loss, and environmental degradation. Economic development is commonly linked to environmental degradation such as air and water pollution, and natural resource consumption. Socioeconomic development of an area is normally manifest by population growth and the increase in living standards. This can lead to increased individual and family consumption leading to directly and indirectly to increased natural resource consumption, and waste production – leading to environmental pollution.
106. The drier more favourable conditions created by the market drainage rehabilitation will foster commercial growth in the Dong Dang. This in turn could lead to increased influx of consumers from a greater area. To a relatively smaller degree the increase in market commerce and consumerism and goods exchange could contribute to local environmental degradation and
resource consumption in like manner as the increased development activity near the Huu Nghi border.
107. At the regional level potential induced environmental impacts of the subproject essentially extend the local environmental impacts. The subproject impact of socioeconomic development outside Ha Noi directly and indirectly stimulated by increased activity at the Huu Nghi border could cause natural resource consumption and environmental degradation in areas that have been developed as a result of trade across the border. Similar to the local level, economic development is commonly linked to environmental degradation such as air and water pollution, and natural resource consumption.
108. As introduced above the enhanced border may increase the transport of illegal animals across to and from China. This would affect all areas of Viet Nam.
5. Cumulative Impacts
109. The outcome and impact of the Dong Dang subproject of increased border services and regional socioeconomic development will combine with the outcomes and similar impacts of the other two subprojects (Viet Tri and Hung Yen) of the CSUD. By design the combined impact of the three subprojects is social and economic development outside of Ha Noi as a means to reduce, inter alia, rural emigration to Ha Noi. Thus, the potential cumulative impact is the combined and far reaching effects of the three subprojects CSUD on natural resources and environmental quality in northern Viet Nam.
110. In addition to the other two CSUD subprojects are the potential combined effects of other ongoing economic development projects underway in the region. For example are the ADB projects in southern PRC located in the NSEC, namely, The Guangxi Beibe Gulf Cities Development Project, and the Guangxi Southwestern Cities Development project. The enhanced Huu Nghi border will benefit those projects which in turn will act to accelerate local and regional development surrounding the three subproject cities of the CSUD.
6. Strategic Assessment
111. At the regional level ongoing planning such the GoV provincial and national Socioeconomic Development Plans (SEDP), Master Plans for Urban Development, and large spatial and temporal scale development strategies such as ADB’s Regional Cooperation Strategy and Program for the GMS should be assessed for potential environmental and natural resource impacts. This IEE along with the IEEs for Dong Dang and Hung Yen subprojects should represent the project-level environmental assessments that stem from the strategic environmental assessments (SEA) of the underlying socioeconomic development plans. It appears that SEA was not applied to the parent development plans.
VIII. INFORMATION DISCLOSURE AND PUBLIC GRIEVANCE MECHANISMS
A. Project Information
112. Information on the project components was provided to stakeholders during a stakeholder consultation meeting held at Dong Dang PC office (CPC) on January 13th. A verbal and written presentation of the project was provided to the all participants.
113. The formal disclosure of information to affected persons and stakeholders during the IEE is meant to form the beginning of continued information disclosure and stakeholder involvement as the project is implemented. Regular information exchange meetings with stakeholders and the Long Son PPC, and three implementing units are strongly encouraged.
B. Grievance Process
114. Future grievances related to any aspect of the Project will be handled through negotiation aimed at achieving consensus. Complaints and grievances may pass through two stages of resolution. The Lang Son PPC, through the subproject implementing Units (section IV), should pay for all administrative costs that might be incurred in the resolution of such grievances and complaints. This mechanism will be integrated with that which will be used to settle grievances related to resettlement and compensation.
115. The first stage venue for raising and resolving complaints and grievances are the community-based monitoring committee (CBMC) to be established by the PPC. An aggrieved party may bring a complaint or petition before any member of the CBMC in writing or verbally. Grievances may also be raised during follow-up consultations with local residents. The CBMC first investigates the complaint and, if warranting project management action, notifies the relevant implementation Unit. The Unit will then meet with the complainant--arranged and facilitated by the CBMC. The Unit will have 15 days after the lodging of the complaint to resolve the grievance, say, by requiring contractors to remedy the complaint or submit a plan of action. The unit may get assistance from the DONRE in evaluating the technical basis of complaints related to environment-related impacts (e.g., vehicle emissions, dust, noise, vibration). The CBMC will record all complaints that are lodged with the local committees.
116. The aim is for community grievances to be resolved at the level of Unit. However, if not resolved at that level, the second venue is the PPC. If after 15 days the aggrieved party or complainant does not hear from the Unit/PPC, or if the complainant is not satisfied with the decision, the affected party may bring the case to any member of the PPC. The PPC has 15 days within which to resolve the complaint to the satisfaction of the concerned parties. The PPC secretariat is responsible for documenting and keeping a record of all complaints lodged with the committee.
117. In the event that the grievance remains unresolved the final proposed resort is mediation of grievance by a third party selected by the PPC and CBMC.
C. Access Hotline
118. In support of the process described above the Unit/contractors need to establish a telephone HOTLINE to provide easy and instant contact with the Unit/PPC by the public. A clearly marked phone number for a responsive Unit/PPC officer office should be placed at all construction sites of the road components. The purpose of the HOTLINE is to enable affected persons to convey to Unit/PPC at any time their concerns or issues of the project during the construction and operation phases with the construction phase being most important.
IX. ENVIRONMENTAL MANAGEMENT PLAN
A. Institutional Arrangements and Responsibilities
119. The environmental management of the project will occur in accordance with GoV policy on decentralization pursuant to Decree 131/2006/ND-CP on management and utilization of Official Development Assistance. The primary framework for the environmental management plan (EMP) will be defined by the: 1) provincial people’s committee (PPC) of Lang Son province who is both the executing agency (EA) or the line agency (LA) in Vietnamese, and the implementing agency (IA) or the project owner (PO) in Vietnamese, and 2) three Implementing Units defined by: a) the Provincial PMU who will manage construction of the border gate buildings; b) the Border Gate Economic Zone who will manage construction of the border gate infrastructure; and c) the Provincial Water Supply and Drainage Company who will rehabilitate the drainage infrastructure in Dong Dang market.
120. The Department of Natural Resources and Environment (DoNRE) is the provincial agency which oversees environmental management of Dong Dang. The DoNRE, inter alia, provides direction to project proponents on the requirements for conducting EIA according to the LEP (2005), and guidance on use of the environmental quality standards that are in place protect the environment (e.g.Table 9).
121. The EMP for Dong Dang subproject will be implemented by the three Implementing Units defined above under direction by the PPC with assistance provided by the project implementation consultant team. The project implementation consultant will provide, amongst others, two key roles defined by detailed design consultant support (DDC), and project supervision consultant support (PSC). The project implementation consultant will review and finalize the detailed designs, ensure mitigation and monitoring safeguards of the EMP are updated to serve the detailed engineering designs, ensure proper implementation of the EMP by Implementation Units including preparation of monitoring reports, and oversee necessary training/capacity building of Implementing Units.
122. The Implementing Units are responsible to ensure that the updated safeguards are incorporated into the bid documents and construction contract documents, and to ensure that prescribed mitigation measures are implemented during construction phases of project by the contractors. The implementation Units/PPC will be responsible to respond to all public complaints associated with the construction phase of the project.
123. Environmental sub-units will need to be assigned by PPC to each Implementation Unit to assist with the EMP. It is expected that the three environment units will need to hire a shared environmental consultant/institute on a part-time basis to implement the environmental monitoring requirements of the EMP.
124. The DONRE may independently conduct random environmental monitoring and inspection before, during, and after construction, as well as in the event of emergencies or public complaints. It will also review the monitoring reports submitted by the implementing units. If violations to government regulations are found, the DONRE may impose fines and issue a notice of rectification with a specific deadline to the responsible contractors. If complaints are formally received from the public through the PPC-Implementation Unit the DONRE will carry out verification inspections, as described in the grievance redress mechanism.
125. Important duties of the environmental sub-units as supported by the Implementing Units/PPC will be:
Prepare an updated environmental management plan (EMP) during detailed design and engineering with assistance from the project implementation consultant, and ensure that contractors prepare their respective site-specific plans based on the EMP and the actual site conditions. Check that the safeguards are adequately addressed in the bidding documents (instruction to bidders), and in the evaluation criteria for awarding contracts; With PMU oversee successful implementation of all impact mitigation measures of EMP by the construction contractors; Coordinate with the DONRE on periodic regulatory compliance issues (e.g., for air quality, and surface water quality affected by construction, drainage or erosion from storage areas for road embankment fill, noise and vibration from construction sites, sanitation in workers campsite, etc); Prepare terms of reference for the survey of the road alignment/route to detect unexploded ordnance, and ordnance disposal if found; Prepare TOR for the conduct of water and air quality sampling, including follow-up interviews with local residents on issues and concerns arising during project construction; Advise the Unit head on environment-related concerns arising during project construction, and recommend corrective measures; Disseminate to stakeholders the results of environment quality monitoring and implementation of safeguards, especially among households or small businesses near the road construction works; Conduct follow-up consultations and interviews with local residents to identify concerns or grievances arising during road construction. Prepare a quarterly status report on environment and public safety protection to be submitted (through the Unit head) to the PPC and DONRE.
B. Mitigation Plan
126. The mitigation measures of the EMP are formulated into the comprehensive mitigation plan for the project which is summarized in Table 10. The plan includes the environmental issues and concerns raised at the stakeholder meetings. The plan identifies responsible parties, location, and indicative costs, and timing.
127. The mitigation plan identifies management subplans for different areas of potential impact. The subplans need to be updated to meet the detailed designs. The mitigation plan combines the construction phase activities common to all components while highlighting activities and mitigations specific to a single component. .
Table 10. Environmental Impact Mitigation Plan10
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation Pre-Construction, Design Completion Phase Confirmation of No negative 1. Affected persons well informed well ahead of Affected Before See See resettlement PPC Resettlement required environmental project implementation. persons in project resettlement plans committees resettlement and impacts project area implemented plans temporary relocations Disclosure, and No community 2. Implement Information Disclosure and For all Beginning of Quarterly No marginal cost PPC PPC and IU11 engagement of impacts Grievance process of IEE construction project community sites. GoV approvals No negative impact 3. Notify DoNRE of project initiation to complete Entire project Before As required No marginal cost PPC and PPC GoV EIA requirements , and obtain required construction PSC12 project permits and certificates. Detailed designs Minimize negative 4. Work with design Institutes to complete detailed DD1 and Before Once with No marginal cost DDC13 PPC and IU of project, environmental designs for Huu Nghi border gate and market DD2 construction detailed impacts drainage rehabilitation that incorporate the initiated designs following measures: documents a) drainage designs for road at border gate and market that can handle 100 yr storm events; b) no disturbance or damage to culture property and values; c) minimal acquisition of agriculture and forested lands; d) locate aggregate borrow pits and rock supply areas away from human settlements with fencing and access barriers; e) no or minimal disruption to water supply, utilities, and electricity with contingency plans for unavoidable disruptions; f) no or minimal disruption to normal pedestrian and vehicle traffic along all road segments with contingency alternate routes; g) For Dong Dang market include specific plan to notify and provide merchants and residents
10 To be reviewed and updated to serve detailed designs 11 IU are the three implementing units for the Border gate and Dong Dang market drainage rehabilitation (see section X, A) 12 PSC is project implementation support role of Project Implementation Consultant 13 DDC is detailed design support role of Project Implementation Consultant
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation of drainage rehabilitation schedule to minimize disruption to normal commercial and residential activities in the urban area. Update EMP Positive 5. Update mitigation measures and monitoring DD1 and Before Once with No marginal cost PSC PSC, PPC, and IU environmental requirements of EMP where necessary to meet DD2 construction detailed impacts detailed designs. initiated designs 6. Identify any new potential impacts of project documents and include in EMP. 7. Submit updated EMP with new potential impacts to ADB to review. 8. Develop individual management subplans for: a) Drainage; b) Erosion; c) Noise and Dust; d) Contaminated Spoil Disposal; e) Solid and Liquid Waste Disposal; f) Construction and Urban Traffic; g) Utility and Power Disruption; h) Worker and Public Safety; i) Tree and Vegetation Removal and Site Restoration; j) Construction Materials Acquisition, Transport, and Storage. UXO survey, and Injured worker or 9. Ensure military is consulted and clears areas All Beginning of Once $125.00 / ha PPC and military removal public where necessary construction project military sites. Develop bid No negative 10. Ensure updated EMP is included in contractor All project Before Once for all No marginal cost PSC PPC and IU documents environmental impact tender documents, and that tender documents areas construction tenders specify requirements of EMP are budgeted. begins 11. Specify in bid documents that contractor must have experience with implementing EMPs, or provide staff with the experience. Capacity No negative 12. Develop and schedule training plan for IU All project Before Initially, No marginal cost PSC PPC and IU development environmental impact (Environmental Units) to be able to fully areas construction refresher implement EMP, and to manage implementation begins later if of mitigation measures by contractors. needed 13. Create awareness and training plan for contractors whom will implement mitigation measures. Recruitment of Spread of sexually 14. Use local workers as much as possible, All work Throughout Worker No marginal cost PPC Contractor’s bid workers transmitted disease reducing #s of migrant worker forces. construction hiring stages documents phase Construction Phase of DD1 and DD2
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation Initiate EMP and Prevent or minimize 15. Initiate updated EMP including individual For all Beginning of Once No marginal cost PSC IU and contractors subplans, impacts management subplans for different potential construction construction impact areas that are completed in pre- sites construction phase (see subplan guidance below). Obtain and Prevent or minimize 16. Contractors to comply with all statutory For all Beginning of Once No marginal cost PSC IU and contractors activate permits impacts requirements set out by DoNRE for use of construction construction and licenses construction equipment, and operation sites construction plants such as concrete batching.
Worker camps Pollution and social 17. Locate worker camps away from human All worker Throughout Monthly No marginal cost PSC and IU contractor problems settlements. camps construction 18. Ensure adequate housing and waste disposal phase facilities including pit latrines and garbage cans. 19. A solid waste collection program must be established and implemented that maintains a clean worker camps 20. Locate separate pit latrines for male and female workers away from worker living and eating areas. 21. A clean-out or infill schedule for pit latrines must be established and implemented to ensure working latrines are available at all times. 22. Worker camps must have adequate drainage. 23. Local food should be provided to worker camps. Guns and weapons not allowed in camps. 24. Transient workers should not be allowed to interact with the local community. HIV Aids education should be given to workers. 25. Camp areas must be restored to original condition after construction completed. Training and Prevent of impacts 26. Implement training and awareness plan for IU PPC offices, Beginning of After each No marginal cost PSC PSC and IU capacity through education (Environmental Units) and contractors. construction construction event sites Implement Pollution, injury, 27. All borrow pits and quarries should be approved For all Throughout Monthly No marginal cost PSC and IU contractor Construction increased traffic, by DoNRE. construction construction materials disrupted access 28. Select pits and quarries in areas with low areas. phase acquisition, gradient and as close as possible to transport, and construction sites. storage subplan 29. Required aggregate volumes must be carefully
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation calculated prior to extraction to prevent wastage. 30. Pits and quarries should not be located near surface waters, forested areas, critical habitat for wildlife, or cultural property or values. 31. If aggregate mining from fluvial environments is required small streams and rivers should be used, and dry alluvial plains preferred. 32. All topsoil and overburden removed should be stockpiled for later restoration. 33. All borrow pits and quarries should have a fence perimeter with signage to keep public away. 34. After use pits and quarries should be dewatered and permanent fences installed with signage to keep public out, and restored as much as possible using original overburden and topsoil. 35. Unstable slope conditions in/adjacent to the quarry or pit caused by the extractions should be rectified with tree planting. 36. Define and schedule how materials are extracted from borrow pits and rock quarries, transported, and handled and stored at sites. 37. Define and schedule how fabricated materials such as steel, wood structures, and scaffolding will be transported and handled. 38. All aggregate loads on trucks should be covered. 39. Piles of aggregates at sites should be used/or removed promptly, or covered and placed in non traffic areas. Concrete and Air pollution, land 40. Locate concrete mixing and asphalt plants well For all Throughout Monthly No marginal cost PSC and IU contractor asphalt and water away from all human activity and settlements, construction construction production, contamination, and and cultural (e.g., schools, hospitals), and areas. phase transport, and use traffic and access ecological receptors. Bitumen production and problems, handling areas should be isolated. 41. Contractors must be well trained and experienced with the production, handling, and application of bitumen. 42. All spills should be cleaned immediately and handled as per hazardous waste management plan, and according to GoV regulations. 43. Bitumen should only be spread on designated
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation road beds, not on other land, near or in any surface waters, or near any human activities. 44. Bitumen should not be used a fuel. Implement Spoil Contamination of 45. Uncontaminated spoil to be disposed of in All Throughout Monthly No marginal cost PSC and IU, contractor management land and surface DoNRE-designated sites, which must never be excavation construction and DoNRE subplan waters from in or adjacent surface waters. Designated sites areas phase Testing of excavated spoil, and must be clearly marked and identified. contaminated soil construction waste 46. Spoil must not be disposed of on or near water $5,000.00 courses, steep-sloped land, near cultural property or values, ecologically important areas, or on/near any other culturally or ecologically sensitive feature. 47. Where possible spoil should be used at other construction sites, or disposed in spent quarries or borrow pits. 48. A record of type, estimated volume, and source of disposed spoil must be recorded. 49. Contaminated spoil disposal must follow GoV regulations including handling, transport, treatment (if necessary), and disposal. 50. Suspected contaminated soil must be tested, and disposed of in designated sites identified by DoNRE as per GoV regulations. 51. Before treatment or disposal contaminated spoil must be covered with plastic and isolated from all human activity. Implement Solid Contamination of 52. Management of general solid and liquid waste All Throughout Monthly No marginal cost PSC and IU, contractor and liquid land and surface of construction will follow GoV regulations, and construction construction and DoNRE construction waters from will cover, collection, handling, transport, sites and phase waste subplan construction waste recycling, and disposal of waste created from worker construction activities and worker force. camps 53. Areas of disposal of solid and liquid waste to be determined by DoNRE. 54. Disposed of waste should be catalogued for type, estimated weigh, and source. 55. Construction sites should have large garbage bins. 56. A schedule of solid and liquid waste pickup and disposal must be established and followed that ensures construction sites are as clean as possible. 57. Solid waste should be separated and
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation recyclables sold to buyers in community. Hazardous Waste 58. Collection, storage, transport, and disposal of hazardous waste such as used oils, gasoline, paint, and other toxics must follow GoV regulations. 59. Wastes should be separated (e.g., hydrocarbons, batteries, paints, organic solvents) 60. Wastes must be stored above ground in closed, well labeled, ventilated plastic bins in good condition well away from construction activity areas, all surface water, water supplies, and cultural and ecological sensitive receptors. 61. All spills must be cleaned up completely with all contaminated soil removed and handled with by contaminated spoil subplan. Implement Noise Dust 62. Regularly apply wetting agents to exposed soil All Fulltime Monthly No marginal cost PSC and IU contractor and dust subplan Noise and construction roads. construction 63. Cover or keep moist all stockpiles of sites. construction aggregates, and all truck loads of aggregates. 64. Minimize time that excavations and exposed soil are left open/exposed. Backfill asap. 65. As much as possible restrict working time between 07:00 and 17:00. In particular are activities such as pile driving. 66. Maintain equipment in proper working order 67. Replace unnecessarily noisy vehicles and machinery. 68. Vehicles and machinery to be turned off when not in use. 69. Construct temporary noise barriers around excessively noisy activity areas where possible. Implement Utility Loss or disruption of 70. Develop carefully a plan of days and locations All Fulltime Monthly No marginal cost PSC and IU contractor and power utilities and services where outages in utilities and services will construction and Utility disruption subplan such as water supply occur, or are expected. sites. company and electricity 71. Contact local utilities and services with schedule, and identify possible contingency back-up plans for outages. 72. Contact affected community to inform them of planned outages.
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation 73. Try to schedule all outages during low use time such between 24:00 and 06:00. Implement Tree Damage or loss of 74. Contact local forestry department for advice on All Beginning Monthly No marginal cost PSC and IU contractor and vegetation trees, vegetation, how to minimize damage to trees and construction and end of removal, and site and landscape vegetation. sites. project restoration 75. Restrict tree and vegetation removal to within subplan RoWs. 76. Within RoWs minimize removals, and install protective physical barriers around trees that do not need to be removed. 77. All RoWs to be re-vegetated and landscaped after construction completed. Consult forestry department to determine the most successful restoration strategy and techniques. Implement Land erosion 78. Berms, and plastic sheet fencing should be All Throughout Monthly No marginal cost PSC and IU contractor Erosion control placed around all excavations and earthwork construction construction subplan areas. sites phase 79. Earthworks should be conducted during dry periods. 80. Maintain a stockpile of topsoil for immediate site restoration following backfilling. 81. Protect exposed or cut slopes with planted vegetation, and have a slope stabilization protocol ready. 82. Re-vegetate all soil exposure areas asap. Implement worker Public and worker 83. Proper fencing, protective barriers, and buffer All Fulltime Monthly No marginal cost PSC and IU contractor and public safety injury, and health zones should be provided around all construction subplan construction sites. sites. 84. Sufficient signage and information disclosure, and site supervisors and night guards should be placed at all sites. 85. Worker and public safety guidelines published by MoLISA should be followed. 86. Population near blast areas should be notified 24 hrs ahead, and evacuated well before operation. Accepted GoV blast procedures and safety measures implemented. 87. Speed limits should be imposed on all roads used by construction vehicles. 88. Standing water suitable for disease vector breeding should be filled in. 89. Worker education and awareness seminars for
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation construction hazards should be given. A construction site safety program should be developed and distributed to workers. 90. Appropriate safety clothing and footwear should be mandatory for all construction workers. 91. Adequate medical services must be on site or nearby all construction sites. 92. Drinking water must be provided at all construction sites. 93. Sufficient lighting be used during necessary night work. 94. All construction sites should be examined daily to ensure unsafe conditions are removed. Civil works Degradation of water 95. Protective coffer dams, berms, plastic sheet All Throughout Monthly No marginal cost PSC and IU contractor quality and aquatic fencing, or silt curtains should be placed construction construction resources, including between all earthworks and surface waters. sites phase Ky Cung river 96. Erosion channels must be built around aggregate stockpile areas to contain rain- induced erosion. 97. Earthworks should be conducted during dry periods. 98. All construction fluids such as oils, and fuels should be stored and handled well away from surface waters. 99. No waste of any kind is to be thrown in surface waters. 100. No washing or repair of machinery near surface waters. 101. Pit latrines to be located well away from surface waters. 102. No unnecessary earthworks in or adjacent to water courses. 103. No aggregate mining from rivers or lakes. 104. All irrigation canals and channels to be protected the same way as rivers, streams, and lakes Civil works Degradation of 105. All construction sites should be located away All Throughout Monthly No marginal cost PSC and IU contractor terrestrial resources forested or all plantation areas as much as construction construction possible. sites phase 106. No unnecessary cutting of trees. 107. All construction fluids such as oils, and fuels should be stored and handled well away from
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation forested and plantation areas. 108. No waste of any kind is to be discarded on land or in forests/plantations. Implement Traffic disruption, 109. Schedule construction vehicle activity during All Fulltime Monthly No marginal cost PSC and IU contractor Construction and accidents, public light traffic periods. Create adequate traffic construction urban traffic injury detours, and sufficient signage and warning sites subplan lights. 110. Post speed limits, and create dedicated construction vehicle roads or lanes. 111. Inform community of location of construction traffic areas, and provide them with directions on how to best co-exist with construction vehicles on their roads. 112. Increase the number of pedestrian crossings away from construction areas. 113. Increase road and walkway lighting. Implement Loss of drainage and 114. Provide adequate short-term drainage away All areas with Design and Monthly No marginal cost PSC and IU contractor Construction flood storage from construction sites to prevent ponding and surface construction Drainage subplan flooding. waters phases 115. Manage to not allow borrow pits and quarries to fill with water. Pump periodically to land infiltration or nearby water courses. 116. Install temporary storm drains or ditches for construction sites 117. Ensure connections among surface waters (ponds, streams) are maintained or enhanced to sustain existing stormwater storage capacity. 118. Protect surface waters from silt and eroded soil. Civil works Damage to cultural 119. As per detailed designs all civil works should All At the start , Monthly No marginal cost property or values, be located away from all cultural property and construction and PSC and IU contractor and chance finds values. sites throughout 120. Chance finds of valued relics and cultural construction values should be anticipated by contractors. phase Site supervisors should be on the watch for finds. 121. Upon a chance find all work stops immediately, find left untouched, and PPC is notified. If find deemed valuable, provincial cultural authorities must be notified. 122. Work at find site will remain stopped until authorities allow work to continue.
Potential Estimated Responsibility Environmental Activity Marginal Cost Project Activity Impacts Proposed Mitigation Measures Location Timing Reporting for Project ($) Supervision Implementation Post-construction Operation of Huu Nghi Gate and Dong Dang Market Operation of Increased illegal 123. Along with improved custom clearance Customs Continuously Biannual No marginal cost Customs border gate animal transport procedures, strengthen inspections for illegal area animals Operation of Increased risk of 124. Enforce well marked speed limits, with guard Entire Fulltime Biannual No marginal cost Customs and DoT new approach accident or injury. rail along approach road. No extensive vehicle approach road Increased air pollution idling should be allowed. road and noise 125. Guidelines for transport, handling, and temporary storage of cargo at the border crossing should be developed. Solid waste Continued clogging of 126. As part of the training and capacity Market Fulltime Regular No marginal cost Provincial Water Supply and management rehabilitated drains development the importance and best practices drainage reporting Drainage Company for keeping drainage system clear of solid waste area schedule will be delivered. DD = Dong Dang, DONRE = Department of Natural Resources and Environment, DOT = Department of Transport, EMP – environmental management plan, GoV = Government of Vietnam, ha = hectare, IEE = initial environmental examination, IU = implementing unit, MOLISA = Ministry of Labour, Invalids, and Social Affairs, PPC = provincial peoples’ committee, PSC = project supervision consultant, ROW = right-of-way.
C. Monitoring Plan
128. The environmental monitoring plan for the EMP is provided in Table 11. Sampling sites for air and surface water quality are shown in Figure 7. The monitoring plan focuses on the construction phase of the project and consists of environmental indicators, the sampling locations and frequency, method of data collection, responsible parties, and the estimated costs. The purpose of the monitoring plan is to determine the effectiveness of the impact mitigations, and to document any unexpected positive or negative environmental impacts of the project. The three implementation Units (Border Gate Economic Zone, Provincial Drainage and Water Supply Co., and provincial PMU) will be required to oversee the implementation of environmental monitoring plan.
129. Monitoring the success of the resettlement the few households that have to be moved, and the temporary relocation of secondary structures will be undertaken as part of the separate resettlement plan prepared for the project.
1. Reporting
130. Regular reporting on the implementation of mitigation measures, and on monitoring activities during construction phase of the project is required. Reporting is the responsibility of three implementation units and should be conducted in conjunction with the regular meetings with stakeholders as requested by the public meetings. The mitigation and monitoring plans (Tables 10 and 11) summarize proposed timing of reporting. Environmental monitoring reports will be prepared quarterly for the EA by the PIUs and sent to the DoNRE, and ADB. The reports will table all indicators measured from the monitoring plan of EMP, and will include relevant GoV environmental quality standards (e.g., QCVN and TCVN).
2. Estimated Cost of Mitigation and Monitoring Plans
131. The marginal costs for implementing the mitigation measures during the construction phase of the project (Table 11) are estimated to be approximately $5,000.00. Estimated costs for field sampling and laboratory analyses for the monitoring plan are $4, 200.00 to supplement the baseline during pre-construction phase, and $21,000.00 annually to the end of construction phase. Costs for follow-up monitoring during the operation of the new roads and solid waste collection equipment are estimated at $4,400.00 annually for 5 years. The estimated costs are based on the national cost norms for environmental sampling and analyses (Circular 83/2002/TT-BTC). All cost estimates will need to be updated at detailed design stage.
D. Institutional Capacity Review and Needs
132. The capacity of the three implementing Units in for environmental management is expectedly weak, and likely will need to be strengthened. Full-time staff dedicated to environmental management normally does not exist in these project management units, and is usually outsourced. Outsourcing is either from other line departments or from the institute sector. Understanding of potential project environmental impacts and their management will be required by the Units in order to implement the EMP.
133. Moreover, environmental assessment competence will be needed in order to fulfill subproject obligations pursuant to the LEP (2005) including implementation of GoV
environmental safeguards. Anticipated is a GoV EIA for the entire Huu Nghi border gate upgrades and a GoV EPC for the Dong Dang market drainage rehabilitation.
134. As part of the institutional capacity development plan for the project an environmental specialist should be outsourced and trained on the LEP (2005) where necessary. The training should include environmental assessment process, and most specifically development and implementation of an EMP. Required skills and capacity development of the three implementation units for environmental management will also be provided by the environmental specialists of the implementation consulting team whom will assist the implementation units with updating the EMP in accordance with the detailed designs of the project
135. If formal training on the implementation of an EMP is required coursework should focus on two thematic areas. The first area should be principles environmental management focused on the potential impacts of infrastructure development on the natural and social environment. The second area should be environmental safeguard requirements of the ADB and GoV with specific focus on the EMP.
Figure 7. Air and surface water quality monitoring sampling sites.
Table 11. Environmental Monitoring Plan
ENVIRONMENTAL EFFECTS MONITORING Responsibility Supervision / Implementation Estimated Environmental Indicators Location Means of Monitoring Frequency Reporting Supervision Implementation 14 Cost ($) Pre-construction Phase – Update Baseline Conditions Update baseline on sensitive DD1 and DD2 Original field work, community Once Once PSC and Monitoring $1,000. receptors at Huu Nghi Border gate consultations PPC Consultant (e.g., cultural property and values, new schools or hospitals, rare/endangered species, critical habitat), and aquatic resources of nearby Ky Cung river. A) Air quality: dust, CO, NOx, SOx, Using field and analytical methods One baseline PSC and IU Monitoring A) $700. noise, wind, temperature, and A and B): See Figure 7 for air and water described in QCVN and TCVN (A - B): supplement Consultant vibration levels quality sampling sites. standards for ambient air and One day and report before B) $700. surface water quality monitoring. one night construction B) Surface water quality: TSS, heavy measuremen phase starts metals (As, Cd, Pb,) oil and grease, t during rainy faecal and total coliform, pH, DO, and dry BOD, temperature, and nutrients seasons. (NandP) . Inventory of present and past land Possible contaminated lands of DD1 and Use field and analytical methods Once Once PSC and IU Monitoring $1,000. uses that could cause contaminated DD2 described in QCVN and TCVN Consultant soil. standards for soil quality monitoring. Analysis of soil quality (heavy Possible contaminated lands of DD1 and Use field and analytical methods D): Once if Once PSC and IU Monitoring $800. metals (As, Cd, Pb, oil and grease, DD2 described in QCVN and TCVN needed Consultant hydrocarbons). standards soil quality monitoring. Construction of Huu Nghi Border and Dong Dang market A) Air quality: dust, CO, NOx, SOx, noise, wind, temperature, and A and B) See Figure 7 for air and water A – C : Using field and analytical (A – B): Monthly A) vibration levels quality sampling sites. methods described in QCVN and Quarterly $8,400. /yr B) Surface water quality: TSS, heavy TCVN standards for ambient air and during (A - D): metals (As, Cd, Pb,) oil and grease, surface water quality monitoring. construction faecal and total coliform, pH, DO, C) At sites where contaminated soil is periods IU Monitoring B) BOD, temperature, and nutrients suspected at DD1 and DD2 Consultant $8000. /yr (NandP) Include visual observations of dust Daily visual C) Analysis of soil quality (heavy D) All construction sites and worker camps and noise from contractor and public records
14 Estimated field sampling and laboratory analysis costs include field and laboratory technicians. Cost for part-time national monitoring consultant to assist PMU with EMP will be part of cost estimate for project implementation consultants.
ENVIRONMENTAL EFFECTS MONITORING Responsibility Supervision / Implementation Estimated Environmental Indicators Location Means of Monitoring Frequency Reporting Supervision Implementation 14 Cost ($) metals (As, Cd, Pb, Hg, Mn), reports . C) hydrocarbons. C) Once at $3,600. /yr D) Domestic (worker) and start of construction solid waste inside and E) Using hotline number placed at excavations outside construction sites including construction areas D) Visual observation D) Monthly D) With A-C worker camps. (no marginal F) At all construction areas E) cost) E) Public comments and complaints Continuous E and F) and daily observations: public input E) F) Incidence of worker or public E) Information transferred by F) PPC and IU IU $1,000. / yr accident or injury telephone hotline number Continuous
F) regular reporting by F) contractors/IU No marginal cost Operation of Huu Nghi Border and Dong Dang market Air quality: dust, CO, NOx, SOx, Customs and DoNRE noise and vibration levels See Figure 7 for air quality sampling sites Using field and analytical methods Quarterly for Biannual $2,400.00 / described in QCVN and TCVN 5 years yr standards for ambient air quality monitoring. Incidence of flooding Dong Dang market area. Surveys, public complaints Seasonal for Seasonal Provincial Water Supply and $2,000.00 /yr 5 years Drainage Company BOD = biological oxygen demand, DD = Dong Dang, DONRE = Department of Natural Resources and Environment, PPC = provincial peoples’ committee, PSC = project supervision consultants, TSS = total suspended solids.
X. CONCLUSIONS AND RECOMMENDATION
136. The evaluation of the two project components (DD1 and DD2) which included input from a public meeting with stakeholders indicates that the potential direct environmental impacts of the project are minor, short-term civil construction related impacts that can be mitigated. The civil construction impacts of elevated dust, noise, traffic disruptions, erosion and sedimentation, and public and worker safety can be managed effectively with existing municipal-provincial, national, and international construction management directives and guidelines.
137. The public meeting in Dong Dang underscored the need for effective management of noise, dust, traffic disruptions, and safety during the construction phase of the project. A HOTLINE telephone number to a responsive implementation Unit/PPC office that is clearly posted at all construction areas is proposed. Follow-up meetings with the consulted stakeholders to address any construction-related issues are also proposed.
138. The reported absence of critical habitats, rare or endangered species, biodiversity values, ecological protected areas, or affected cultural or heritage structures in the project areas focuses the short-term impacts of the project on communities and construction workers that will be directly affected by the construction and facilities rehabilitation activities. The published guidelines and regulations of MoLISA and the DoT that govern workplace and public safety should be applied to the project.
139. However, the presence or absence of ecologically sensitive and valued receptors right at the Huu Nghi border crossing site that could be affected by the development of the border facilities needs to be confirmed with supplementary survey data. Similarly, the aquatic resources and human uses of the Ky Cung river near the border gate adjacent to the market area in Dong Dang need to be documented. Currently no data or information exists for these valued ecosystem components at the specific project areas. This information should be obtained when the EMP is updated to meet the detailed designs of the project components.
140. The IEE concludes that the description of the feasibility design of the project combined with available information on the affected environment is sufficient to identify the scope of potential environmental impacts of the project. Providing that no significant changes occur to the design of one or more of the project components, and the supplemental ecological data at the border gate and in Ky Cung river are obtained for review, further detailed environmental impact assessment (EIA) of the project is not required.
141. The EMP developed for the project provides an impacts mitigation plan, an environmental monitoring plan, and specifies the institutional responsibilities and capacity needs for the environmental management of the project. The PPC with three implementing Units will be responsible for implementing the EMP with the assistance of external consultant/institute.
142. The IEE recommends that the EMP be reviewed at the detailed design phase to ensure that it addresses fully the final project designs.
XI. REFERENCES AND INFORMATION SOURCES
ADB, 2011. Memorandum of Understanding of Loan Fact Finding Mission for CSUD, May 20, 2011.
ADB 2010. Concept Paper for the Comprehensive Socioeconomic Development Project, Project No. 41462, 4 pgs, + 5 Appendices.
ADB, 2009. Safeguard Policy Statement, ADB Policy Paper.
ADB, 2003, Environmental Assessment Guidelines of the Asian Development Bank.
DoNRE, 2011. Environmental status of Lang Son, report prepared by Lang Son DoNRE Lang Son
Groupe Huit - Primex – SCC, 2011. Draft Final Report on the Socioeconomic Development Project: Viet Tri, Hung Yen, Dong Dang, submitted to ADB, TA 7516-VIE.
Thanh Trinh Thi, 2011. Report on Dong Dang subproject prepared for TA 7516.
Nguyen Van Song 2008. Wildlife Trading in Vietnam: Situation, Causes, and Solutions, Journal of Environment and Development, June 2008, 17: 145-165.
Nguyen Van Song, 2008. Wildlife Trading in Vietnam: Why It Flourishes, Economy and Environment Program for Southeast Asia, 2003.
Report on the Review of Vietnam’s Wildlife Trade Policy, CRES/FPD/UNEP/CITES/IUED, Hanoi, Vietnam, 2008. CITES refers to the Convention on International Trade in Endangered Species of Flora and Fauna.
XII. APPENDIX A: PARTICIPANTS OF STAKEHOLDER CONSULTATION15
List of participants attended in the public consultation In Lang Son Province No Name Organization 1 Mr. Duc Anh Vice Director of Construction Department 2 Mrs.Nguyen Hoai Thuong Department of Environment – Lang Son Province 3 Dang thi Ngan Shopman in Dong Dang market 4 Dong thi Tho Shopman in Dong Dang market 5 Pham thi Hiep Shopman in Dong Dang market 6 Ha thi Thoan Shopman in Dong Dang market 7 Hoang thi Tam Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 8 Au thi Linh Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 9 Lang van Khau Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 10 Lang thi Ninh Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 11 Lang thi Ha Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 12 Lang van Khau Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 13 Lang van Khi Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 14 Sam thi Che Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 15 Ly thi Kin Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 16 Lang van Long Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 17 Au thi Ly Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 18 Hoang thi En Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 19 Nguyen van Thang Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 20 Vy van Sang Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 21 Vy van Un Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 22 Vy van Ty Affected family/ affected people in Keo Kham village of Dong Dang, Huu Nghi. 23 Nong ky Han Chaiman of Keo Kham village 24 Ha duc Thien Chaiman of farmer association
15 See footnote 6