Initial Environmental Examination (DRAFT)

Ensuring Inclusiveness and Service Delivery for Persons with Disabilities (RRP MON 48076)

November 2017

MONGOLIA: Ensuring Inclusiveness and Service Delivery for Persons with Disabilities Project

Prepared by the Ministry of Labor and Social Protection for the Asian Development Bank.

CURRENCY EQUIVALENTS (as of 17 October 2017)

Currency unit – togrog (MNT)

MNT1.00 = $0.0004 $1.00 = MNT 2,459.50

ABBREVIATIONS

ACM – asbestos-containing material ADB – Asian Development Bank ASI – agency for specialized inspection CWD – child with disabilities DEIA – detailed environmental impact assessment DPO – disabled people’s organization EA – executing agency EEE – external environmental expert EIA – environmental impact assessment EMP – environment management plan ES – environmental specialist GASI – general agency for specialized inspection GEIA – general environmental impact assessment GIC – grant implementation consultant GoM – Government of Mongolia GRM – grievance redress mechanism IEE – initial environmental examination IEM – independent environment monitor IFC – International Finance Corporation HSMP – Health and Safety Management Plan LEED – United States Green Building Council’s Leadership in Energy and Environmental Design MECS – Ministry of Education, Culture, Science and Sports MEGD – Ministry of Environment and Green Development MLSP – Ministry of Labor and Social Protection MNS – Mongolian national standards MOH – Ministry of Health NGO – nongovernmental organization PCU – project complaint unit PIU – project implementation unit PSC – project steering committee PWD – person with disabilities TA – technical assistance UB – Ulaanbaatar

WEIGHTS AND MEASURES

°C – degree Celsius dB – decibel km – kilometer kWh – kilowatt hour m – meter

GLOSSARY

aimag – province soum – aimag subdistrict khoroo – Ulaanbaatar subdistrict

NOTES

In the report, “$” refers to US dollars.

This initial environment 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. Your attention is directed to the “terms of use” section of this website.

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.

CONTENTS I. EXECUTIVE SUMMARY ...... 1

A. INTRODUCTION AND PURPOSE ...... 1 B. IMPACT, OUTPUT, OUTCOMES, SAFEGUARD CATEGORIZATION ...... 2 C. PROJECT BENEFITS ...... 4 D. ADVERSE IMPACTS AND MITIGATION MEASURES ...... 4 E. CONSULTATION, INFORMATION DISCLOSURE, GRIEVANCE REDRESS MECHANISM (GRM) . 6 F. RISKS AND ASSURANCES ...... 7 G. CONCLUSION ...... 7 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 8

A. MONGOLIA ENVIRONMENTAL POLICY AND LEGAL FRAMEWORK ...... 8 B. APPLICABLE MONGOLIAN ENVIRONMENTAL STANDARDS ...... 14 C. APPLICABLE ADB POLICIES, REGULATIONS AND REQUIREMENTS ...... 21 D. OTHER RELEVANT GUIDELINES ...... 22 III. DESCRIPTION OF THE PROJECT ...... 23

A. PROJECT RATIONALE, LOCATION AND BENEFICIARIES ...... 23 B. PROJECT OUTPUTS ...... 26 C. IMPLEMENTATION ARRANGEMENTS ...... 27 D. PROJECT ORGANIZATION STRUCTURE ...... 30 E. PROJECT AREA OF INFLUENCE, PROJECT IMPLEMENTATION SCHEDULE ...... 30 IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE) ...... 35

A. URBAN FORM, SOCIO-ECONOMIC CONDITIONS ...... 35 B. PHYSICAL CONDITIONS WITHIN THE PROJECT AREAS ...... 37 C. ECOLOGICAL AND PHYSICAL CULTURAL RESOURCES WITHIN THE PROJECT AREAS ...... 45 V. ALTERNATIVE ANALYSIS ...... 49

A. NO ACTION ALTERNATIVE ...... 49 B. LOCATION ALTERNATIVES ...... 49 VI. ANTICIPATED IMPACTS AND MITIGATION MEASURES ...... 53

A. IMPACTS ASSOCIATED WITH PROJECT LOCATION, PLANNING AND DESIGN ...... 53 B. ENVIRONMENTAL IMPACT AND MITIGATION MEASURES DURING CONSTRUCTION ...... 54 C. ENVIRONMENTAL IMPACT AND MITIGATION MEASURES DURING OPERATION ...... 60 D. CUMULATIVE, INDIRECT IMPACTS ...... 61 E. CLIMATE RISK, ADAPTATION TO CLIMATE VARIABILITY AND CHANGE ...... 62 F. SEISMIC RISKS ...... 62 VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS ...... 63

A. INFORMATION DISCLOSURE AND CONSULTATION DURING PROJECT PREPARATION ...... 63 B. FUTURE PUBLIC CONSULTATION AND INFORMATION DISCLOSURE ...... 65 VIII. GRIEVANCE REDRESS MECHANISM ...... 66

A. INTRODUCTION ...... 66 B. PROPOSED GRIEVANCE REDRESS SYSTEM ...... 66 C. GRM STEPS AND TIMEFRAME ...... 66 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 69 X. CONCLUSIONS ...... 70

APPENDIXES

- APPENDIX 1: ENVIRONMENTAL MANAGEMENT PLAN (EMP) - APPENDIX 2: ENVIRONMENTAL BASELINE REPORT - APPENDIX 3: PUBLIC CONSULTATION REPORT

I. EXECUTIVE SUMMARY

A. Introduction and Purpose

1. The proposed project will support the Government of Mongolia in addressing a major social and rights issue by ensuring inclusiveness and delivery of services for persons with disabilities (PWD) in Ulaanbaatar and at the aimag (province) level. The overall aim of the project is to ensure access by PWD to employment to increase their autonomy and contribution to the economy and society in general. The project will support the government to comply with the United Nations Convention on the Rights of Persons with Disabilities and the Incheon Strategy, and to implement the new Law on the Rights of People with Disabilities adopted by the Parliament in February 2016.1

2. Disability prevalence estimates of around 4% based on the 2010 census is likely to underestimate the actual incidence. Early diagnosis and identification of developmental delay in children is underdeveloped and disability assessment is based on an outdated, narrow medical approach to determine work ability loss. Older people are not recognized as disabled even if they require long-term care. PWD in Mongolia and their households represent a population subgroup with substantially higher poverty and lower human development indicators than the rest of the population.2

3. Typically, PWD, especially those with intellectual disabilities, lack access to education, health care, social protection, employment, and suffer from marginalization in society. Early diagnostic and intervention services for the majority of children with disabilities (CWD) are either unavailable or of poor quality. Poor access to education at all levels means that PWD are comparatively poorly prepared for employment compared to other people. Poor physical access to (i) public buildings including government offices, hospitals, and schools; and (ii) transportation facilities are major constraints due to lack of enforcement of existing rules and limited investment. These are all major impediments in the life of PWD, which often prevents them from accessing basic municipal and social services or nearby workplaces. PWD face huge barriers in entering job markets due to lack of skills but also due to the unpreparedness of companies.

4. The Government of Mongolia demonstrates strong commitment to international rights frameworks and development goals on disability.3 This is especially reflected in its active engagement with the disabled people’s organizations (DPOs) community and the adoption of a new Law on the Rights of People with Disabilities in February 2016, which moves the sector paradigm from a health and social welfare model based on a medical understanding of disability to a rights-based model built on a bio-psycho-social understanding of disability underpinned by the International Classification of Functioning.4

5. The project is strongly aligned with the 2001 Social Protection Strategy and the Social Protection Operational Plan, 2014–2020.5 It will support the renewed emphasis on social protection in

1 United Nations. 2006. Convention on the Rights of Persons with Disabilities. New York; United Nations, Economic and Social Commission for Asia and the Pacific. 2012. Incheon Strategy to “Make the Right Real” for Persons with Disabilities in Asia and the Pacific. Bangkok. 2 ADB. 2016. Poverty and Social Analysis. Ulaanbaatar (TA 8850- MON). 3 International rights frameworks and development goals on disability include the United Nations Convention on the Rights of Persons with Disabilities ratified by Mongolia in 2008 and The Incheon Strategy to “Make the Right Real” for Persons with Disabilities in Asia and the Pacific (2013–2020), as well as, Sustainable Development Goals set out in the 2030 Sustainable Development Vision in Mongolia. 4 The ICF is a way of understanding disability as a social construct rather than a medical problem. Introducing the ICF will enable Mongolia to develop policies and programs for removing barriers to participation in society of PWD. 5 ADB. 2001. Social Protection Strategy. Manila; ADB. 2013. Social Protection Operational Plan, 2014–2020. Manila.

the midterm review of Strategy 2020 to protect the most vulnerable members of society.6 The proposed project is also in line with the interim country partnership strategy to support PWD through social protection and the strengthening of social safety nets to ensure decent living standards for all.7

6. The geographical focus of the project will be on Ulaanbaatar and six aimags (Arkhangai, Darkhan-uul, Dornod, Dundgovi, Khovd, and Khovsgol). New services will be created in the aimag centers and outreach services will be provided to CWD and PWD in the soums and khoroos. Some project activities focusing on strategic issues will have national reach.

B. Impact, Output, Outcomes, Safeguard Categorization

7. The impact will be equal participation for PWD. The outcomes will be increased access to services and employment for PWD. The project will have five outputs that address the need for services and support across the full life-cycle of CWD and PWD.8

8. Output 1: Early identification of CWD strengthened and institutionalized. The project will (i) institutionalize the current model initiated by the Ministry of Labor and Social Protection (MLSP), (ii) facilitate the shift from a medical to a social model to identifying CWD by broadening the skills of persons involved in early identification. Supported by appropriate interventions, early intervention will minimize the effects of, and possibly prevent, disability which can lead to greater ability and inclusion in education, employment and society in general.

9. Output 2: Service delivery for PWD improved. The project will: (i) implement a model of interactive parent–child–facilitator education in early childhood; (ii) establish six model aimag Rehabilitation and Development Centers9 for CWD and PWD (infrastructure, equipment, management system, staffing, capacity building); (iii) establish a disability workforce with national level curricula introduced for occupational and speech therapy, physiotherapy and orthopaedic technicians as well as disability social workers, (iv) strengthen the role of social workers in support to PWD; and (v) establish hotlines for PWD. Early detection supported by appropriate interventions and service delivery, are the starting point for ensuring access by CWD to society, to education and later to employment. Early detection and delivery of better and more appropriate services for CWD may also allow family members especially women10 to take an active role in the economy.11 Improved services will include: individual case management by disability social workers, Portage12, physiotherapy, speech and occupational therapy, assistive devices, personal assistants and other independent living services. The output will include the building of 6 small development and rehabilitation centers for PWD in 6 provincial capitals (aimags) in order to increase the service availability for disabled citizens and to improve social services. These will be small structures with a footprint of below 1,000 m² each, the usable surface will be 1550 m².

10. Output 3: Improved access to the physical environment. This output will (i) develop the capacity

6 ADB. 2014. Midterm Review of Strategy 2020: Meeting the Challenges of a Transforming Asia and Pacific. Manila. 7 ADB. 2014. Interim Country Partnership Strategy: Mongolia, 2014–2016. Manila. 8 Except education as this is being addressed by JICA through its START project 9 The development and rehabilitation center is staffed with a multi-disciplinary team delivering a range of centre-based and mobile habilitation and rehabilitation, early intervention and independent living services for PWD and CWD 10 According to the household survey 4 out of 5 caregivers are women. 11 DFID, 2000, Disability, Poverty and Development‟, DFID. http://www.handicapinternational.fr/bibliographie- handicap/4PolitiqueHandicap/hand_pauvrete/DFID_disability.pdf: The UN has estimated that a quarter of the world‟s population is adversely affected as a result of disabilities. 12 A model of interactive parent–child–facilitator education in early childhood that is being adapted for Mongolia with support from the JICA START project and piloted in one district of UB.

of decision makers and strengthen institutions involved in developing and enforcing the legal and regulatory framework on physical accessibility norms (infrastructure, transportation, information); (ii) ensure wide inclusion of PWD in enforcement mechanisms; (iii) ensure access to affordable quality orthopedic devices and assistive technology, including in aimags. The activities that will be implemented to achieve this output will facilitate implementation of regulations that reduce barriers to the environment and improve mobility and access to information, public buildings and transportation. Increased access to assistive devices and services will reduce participation barriers affecting PWD and enable them to engage actively in employment.

11. Output 4: Improved work and employment for PWD. This output will (i) set up models to increase the skills of PWD to enter selected industries and improve general job brokerage for PWD; (ii) facilitate inclusive business and organize support systems for PWD to access regular jobs and self- employment; and (iii) strengthen participation of PWD in monitoring compliance with regulation on employment for PWD. The activities are focused on making policies and practices of public employment and DPO services more effective in creating individual pathways into employment (case management, job coaching); supporting the development of a DPO Employment Resource Center in UB (infrastructure13, equipment, training and capacity building) that can provide services to PWD, employers and to public employment offices and (one new 6-storey Employment Resource Center for DPO will be built in Ulaanbaatar); supporting employers and PWD in the enforcement of legislation regarding employment quotas for PWD.

12. Output 5: Strategic development to support PWD. The project will: (i) raise awareness and change attitudes towards PWD; (ii) reform the welfare system to improve targeting and financial support for PWD to access services and equipment; (iii) conduct a strategic review of the national program; (iv) introduce the ICF in line with needs and available resources; (v) align National Statistical Office statistics with information needs in relation to disability. Indirect interventions leading to improved inclusion will be achieved through public campaigns to support a gradual change of attitudes towards PWD, a better understanding of disability through the introduction of ICF, better statistics and information on challenges faced by PWD.

13. Categorization. The project was recategorized as “B” for environment, involuntary resettlement and Indigenous Peoples safeguards in accordance with ADB’s Safeguard Policy Statement (2009).14 The project will have no negative impact on indigenous peoples in the project areas, and will not require temporary or permanent land acquisition. Considering potential impacts given by (i) six small integrated development center and (ii) construction of a 6 storey employment resource center, it was recommended that the project will be re-classified as Category B for environment. This IEE, including the environmental management plan (EMP), was prepared by the TA consultant on behalf of the MLSP, the Executing Agency (EA). The EMP is presented in Appendix 1 of this IEE.

14. Domestically, General EIAs (GEIA) for the aimag project sites were issued, screened and accepted. For the DPO building a draft General EIA was prepared. The MDPSP will have to send an official letter requesting to conduct GEIA to the Municipal Environment and Green development department. This application will include the project approved design, the environmental baseline report with the supporting aerial and topographic photos, the land certification with the registering map (cadaster) as an attachment and the supporting letter from the District Governor’s office to the Municipal Environmental department. The GEIA conclusions have required that no detailed EIAs (DEIAs) are needed.

13 The DPO Employment Resource Center infrastructure will be partly funded by a JFPR co-financing grant. 14 ADB. 2009. Safeguard Policy Statement. Manila.

C. Project Benefits

15. The project will directly benefit PWD and their families, a population subgroup whose poverty rates are more than twice as much those of others: 42% versus 18%. Employment to population rate for 15-59 year old PWDs is only 28%, compared with 69% for the rest of the population. In general PWD have significantly lower human development indicators than others: 53% of 6-18 year old CWDs are unable to read, as compared with 4% for other children. Almost 100,000 PWD could benefit from improved employment services and by the end of the project at least 5,000 more PWD are expected to enter the labor market than in 2014. Social welfare reforms should result in better services being provided to all PWDs and their families, covering indirectly more than 400,000 people. Some of the project activities, including early identification and improved services, will focus on target regions that cover more than 50% of PWD living in poverty and have been identified to maximize coverage of PWD especially those living in poverty. It is expected that 17,000 children and 62,000 adults will benefit from these new services in the project target areas

D. Adverse Impacts and Mitigation Measures

16. Findings of the IEE show that the project does not have any predicted significant, long term or irreversible impacts on the physical, biological or socio-economic environment of the four project cities. The project will build 6 small development and rehabilitation centers for PWD in 6 provincial capitals (aimags) These integrated centers will be constructed on government-owned, barren land. Impacts that will arise from civil works will be minimal, temporary and localized (dust, noise, construction site safety). The centers will not involve the production or handling of potential pollutants (e.g. no laboratory, no medical services).Water, wastewater and solid waste services will be connected to existing municipal services.

Figure I.1: Sketch of the planned standardized integrated Development Center for disabled citizens

17. Additionally one new 6-storey Employment Resource Center for DPO will be built in Ulaanbaatar. The building will have a footprint of below 800 square meters and a usable surface of

3,500m². The building will be located on existing land of the government and will be connected to the city water, waste water and waste management system. The new building will act as service and business incubator for PWD and will include offices, multi-functional workshop spaces for small enterprises15 including potential for some light manufacturing. It will not work with or produce hazardous materials at the workplaces.

Figure I.2: Sketch of the planned Business Incubator Center for DPO in UB

18. During construction, the project will have short-term impacts which can be mitigated to an acceptable level through mitigation measures which seek to reduce the potential for harm to the environment and human health. Dust and noise generated by construction activities are not expected to significantly impact local residents and businesses as they are not within the project area of influence. Waste arising is an inevitable consequence of construction activities. In order to manage this sustainably and with least risk to the environment and human health, a Waste Management Plan will be developed and adhered to by the contractor. Mitigation measures specified in the EMP will manage the impacts to acceptable levels.

19. During operation, no significant adverse environmental impact is anticipated. All buildings will be designed following the universal design concept16. Universal design is understood as a design of buildings, environment and services usable by all people, to the greatest extent possible, without the need for adaptation or specialized design. Further, for all buildings the “Green Building” concept will be

15 The small enterprises will be set up and managed by disabled persons and provide working places suitable for persons with disabilities. No environmental impact is anticipated by this enterprises. 16 For universal design, please refer to the PAM: APPENDIX A: UNIVERSAL DESIGN PRINCIPLES.

applied17. Examples will be the usage of solar panels and natural lighting to reduce electricity needs, triple glazing and avoidance of thermal bridges to reduce heating demands and water saving measures such as rainwater harvesting for irrigation.

20. Environment management plan (EMP). An EMP has been defined which specifies the roles and responsibilities of key project stakeholders, including the project Executing Agency (EA) which is the Ministry of Labor and Social Protection (MLSP); the Implementing Agencies (IAs), including the EA and the Ministry of Health (MOH), the disabled people’s organizations (DPOs); the detailed design engineering firm which prepares designs, drawings and specifications of buildings, the construction supervision engineers and the environment civil works contractors.

21. In addition, the PIU will also procure the services of an independent environment specialist (ES). The ES will conduct independent EMP implementation verification and environment quality monitoring during project construction in compliance with the monitoring plan and define recommendations for actions to be taken to resolve problems or improve environment management performance of various stakeholders.

22. EMP implementation responsibilities. The EMP specifies the roles and responsibilities of key project stakeholders. The EA will be responsible for the overall implementation and compliance with the EMP. The EA will establish a Project Implementation Unit (PIU), which will have the overall responsibility delegated by the EA for supervising the implementation of mitigation measures and the reporting to ADB. The EA will coordinate activities and inputs of the project stakeholders, including the MOH, DPOs, contractors and consultants, to make their contribution to environmental management plan and monitoring arrangements and will ensure that the national environmental, health and safety laws, regulations, procedures, and guidelines as well as the design standards and codes will be followed. The PIU will further provide training on EMP supervision to contractors and training on the establishment of grievance redress mechanisms (GRMs) for each project site.

E. Consultation, information disclosure, grievance redress mechanism (GRM)

23. The stakeholder consultation process conducted during the development of the GEIAs and this IEE, particularly with aimag representatives, demonstrated that the project has strong local support. In the framework of the GEIAs, some 280 people were consulted through public meetings. Citizens overwhelmingly support the project.

24. In compliance with ADB’s Safeguard Policy Statement (2009), environmental information related to the project will be disclosed as follows: (i) this initial environmental examination (IEE) is disclosed on ADB’s project website (www.adb.org), and will be available in the aimag’s and PIU’s office; (ii) the general environmental impact assessments (GEIAs) are available from the PIU’s office; and (iii) annual reports on project’s compliance with the EMP will be available at www.adb.org.

25. Environmental grievance redress mechanism. Environment safeguards related complaints or disputes will be handled in accordance with grievance redress mechanisms (GRM) established for each project site.

17 As there is no worldwide agreed upon consistent definition for “Green building” and no definition in Mongolia, the principles of the United States Green Building Council’s Leadership in Energy and Environmental Design (LEED) will be observed to ensure a resource efficient construction and operation of the buildings (http://www.usgbc.org/leed).

F. Risks and assurances

26. Risks and risk mitigating measures have been identified in the risk assessment and risk management plan. The GoM, MLSP and the aimag governments have assured ADB that implementation of the project shall conform to all applicable ADB policies including those concerning anticorruption measures, safeguards, procurement, consulting services, and disbursement as described in detail in the project administration manual and in the draft loan agreement. In addition to these standard assurances, the GoM has agreed with ADB on a series of assurances, defined in the draft project agreement.

G. Conclusion

27. The IEE concludes that: (i) the inherent features of the proposed project sites do not pose any significant constraints that would require costly special mitigation measures; (ii) the adverse environmental impacts of the project, as a whole, will be minor or moderate; and temporary; (iii) the measures to mitigate the adverse impacts can be provided and instituted without difficulty through proper engineering design and environment-friendly management of construction activities and operation; (iv) the adverse impacts can be further mitigated with efficient environmental management and monitoring, prior to construction, and during construction and operation; and (v) the adverse impacts will be greatly offset by the significant socio-economic benefits that will be derived from the project. The project was re-categories as B for environment which is confirmed. The project is feasible from an environment safeguards point of view.

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. Mongolia Environmental Policy and Legal Framework

28. Mongolia has enacted a comprehensive policy and legal framework for environmental assessment and management. It has policies, legislation and strategies in place to manage protected areas such as national parks, to satisfy its international obligations, and to protect the quality of the environment for the health and well-being of its citizens. The hierarchy of policies and legislative provisions for environmental management in Mongolia comprises the Constitution, international treaties, policies, and environment and resource protection laws.18

1. Legal Framework

29. Environmental policy reform undertaken since the early 1990s has resulted in important progress in developing a large number of environmental laws, ratifying most international environmental conventions, conserving a substantial area of the country in the protected area system and an increased presence of Non-Governmental Organizations (NGOs). Over 30 environmental laws have been passed, as well as several hundred environmental regulations and bylaws.19 More recently the State Great Hural (State Assembly) amended existing laws and also introduced new laws in 2012. The purpose of the review was to reduce duplication and improve the quality of regulation, ensuring responsible, environmentally-friendly and sustainable development, improving economic efficiency and introducing international standards in environmental auditing and the “polluter pays” principle. The new laws also, increase public participation in environmental decision-making, and security for environmental protection. A summary of relevant environmental legislation is presented in Table II-1.

30. The Constitution. Article 16.1.2 of the Constitution of Mongolia (1992) states that everyone has the right to live in a healthy and safe environment and to be protected against environmental pollution and ecological imbalance.

31. Law on Environmental Protection. The Law on Environmental Protection (2012) is an overarching law for all environmental legislation. It is the principal law that regulates activities associated with the protection of the environment with special emphasis on ‘Natural Resource Reserve Assessment’ and ‘Environmental Impact Assessment’. It governs the land and subsoil, mineral resources, water resources, plants, wildlife and air, and requires their protection against adverse effects to prevent ecological imbalance. The environmental protection law regulates the inter-relations between the state, citizens, economic entities and organizations, with a guarantee for the human right to live in a healthy and safe environment. It aims for an ecologically balanced social and economic development, the protection of the environment for present and future generations, the proper use of natural resources, including land restoration and protecting land and soil from adverse ecological effects. There are provisions that enable the development of state and local rights on environmental protection; environmental protection rights and obligations of citizens; environmental carrying capacity; to specify the maximum level of natural resources use; to provide for ecological training and education; to specify state environmental guidelines and principles and to provide for environmental assessment, databases and research and financing. National policy to protect ecologically significant aspects of the environment and to restore natural resources is prepared under the Law on Environmental Protection.

32. Law on Environmental Impact Assessment. The Law on Environmental Impact Assessment

18 UNDP. 2008. Institutional Structures for Environmental Management in Mongolia. Ulaanbaatar and Wellington. 19 UNDP 2011. Strengthening Environmental Governance In Mongolia Phase II.

(2012) stipulates the EIA requirements of Mongolia. The purpose of this law is environmental protection, the prevention of ecological imbalance, the regulation of natural resource use, the assessment of environmental impacts of projects and procedures for decision-making regarding the implementation of projects.

Table II-1: Relevant Environmental Laws in Mongolia

Current Laws Latest Changes Law on Environmental Protection Revised, 2012 Law on Environmental Impact Assessment Revised, 2012 Law on Atmosphere Revised, 2012 Consolidated and repealed, 2012 Law on Water Revised, 2012 Consolidated and repealed, 2012 Law on Waste Consolidated and repealed, 2012 Consolidated and repealed, 2012 Consolidated and repealed, 2012 Law on Hazardous Substances and Chemicals Revised, 2006 Law on Land Submitted as new packages of land laws in 2013 and amended as of February 2015 Civil Code of Mongolia 2002 and amended December 2014 Law on Cadastre Mapping and Land Cadastre Amended 2011 Law on Subsoil Amended, 1995 Law on Soil Protection and Combating Desertification Newly created, 2012 Law on Special Protected area Amended, 2014 Law on Buffer Zones Created 1997 Law on Protection of Plants Amended, 2011 Law on Natural Plants Amended, 2010 Law on Fire Safety Amended, 2015 Law on Sanitation Renewed, 2012 Mongolian Protection of Cultural Heritage Renewed 2014 Law on Labour Safety and Hygiene Amended, 2015 Source: PPTA consultants.

2. Environmental Policy Framework

33. A fundamental principle of the Mongolian state environmental policy is that economic development must be in harmony with the extraction and utilization of natural resources and that air, water and soil pollution will be controlled. In 1996 Mongolia’s National Council for Sustainable Development was established to manage and organize activities related to sustainable development in the country. The country’s strategy is designed for environmentally friendly, economically stable and socially wealthy development, which emphasizes people as the determining factor for long-term sustainable development.

34. Mongolia has also developed a number of key policy documents, including:

i) State Environmental Policy, 1997; ii) Mongolian Action Program for the 21st Century (Map21), 1998; iii) National Action Plan for Climate Change, 2000; iv) National Plan of Action for Protected Areas

v) National Environmental Action Plan, 1996, 2000; and vi) Green Development Policy of Mongolia, 2013.

35. In addition, other guidance documents with important environmental repercussions were developed under the auspices of other ministries and these include the Power Sector Master Plan, the Tourism Master Plan, and the Renewable Energy Master Plan. Other documents, such as the annual Human Development Reports have increasingly incorporated environmental aspects.

3. Environmental Institutional Framework

36. The State Great Khural of Mongolia is the highest organ of State power and the supreme legislative power. The State Great Khural is unicameral and consists of 76 members elected by the mixed electoral system.

37. The Ministry of Environment, Green Development and Tourism (MEGDT) is the agency primarily responsible for the implementation of environmental policy in Mongolia. Agencies under the MEGDT with responsibility relevant for the project include:

i) The Department of Sustainable Development and Strategic Planning, responsible for the elaboration of strategic and sustainable development policies, plans, programs, and projects in areas within the mandate of the MEGDT. The department’s functions include developing principles and policies and creating a positive legal environment for the preservation of ecological balance, in accordance with sustainable development objectives, by conducting policy research and developing policy options, designing projects and programs, offering policy leadership, and planning and initiating Mongolia's participation and actions with regard to major ecological issues at regional and international levels.

ii) The Department of Environment and Natural Resources is responsible for the planning and implementation of actions to reduce environmental degradation and adverse environmental impacts, and ensuring the appropriate use of natural resources. Its functions include implementing laws and regulations, policy, programs, and activities related to the conservation and appropriate use of natural resources; restoring areas that have suffered from degradation; organizing and coordinating biological conservation activities; conducting environmental assessments and maintaining the Environmental Information Databank; and organizing training and public awareness activities related to environmental conservation. The department will be consulted in regard to all activies related to the EIA process.

iii) The Ecologically Clean Technologies and Science Division is responsible for developing and promoting clean technologies in Mongolia by introducing cleaner production technology to all aspects of production and services. The division will be consulted in view of the “Green Building” concept based on LEED.

iv) The National Agency for Meteorology, Hydrology and Environmental Monitoring is responsible for managing a national, integrated hydrological, meteorological, and environmental monitoring network; ensuring preparedness for potential natural disasters or major pollution incidents; establishing conditions to permit the full and complete use of meteorological and hydrological resources; continuously monitoring radioactivity, air and water pollution, and soil contamination levels; and providing essential hydrological, meteorological, and environmental data to state and government officials, businesses, and individuals. The agency will be consulted in the frame of construction activities if a need arises.

4. International Environmental Commitments

38. Mongolia is a party to the international environmental conventions and protocols. It has passed state laws that implement the terms of these international conventions, with provision that: “If an international treaty to which Mongolia is a party is inconsistent with this law then the provisions of the international treaty shall prevail”. Relevant international conventions in the environment areas are shown in Table II-2.

Table II-2: Relevant International Environmental Conventions

International Convention / Protocol Year of Party United Nations Framework Convention on Climate Change 1993 (r) Kyoto Protocol 1999 (a) Vienna Convention for the Protection of the Ozone Layer 1996 (a) Montreal Protocol on Substances That Deplete the Ozone Layer 1996 (a) Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and 2001 (r) Pesticides in International Trade Stockholm Convention on Persistent Organic Pollutants 2004 (r) Note: (a) accession; (e) entry into force; (r) ratification.

39. In addition, the Mongolia has ratified the following International Labor Organization (ILO) core labor standards:

 Abolition of Forced labor (C105);  Child Labor (C182);  Discrimination (C111);  Freedom of Association and the Right to Organize (C87);  Equal Remuneration (C100);  Minimum Age (C138); and  Right to Organize and Collective Bargaining Convention, 1949 (C098).

40. Climate change policy. Mongolia has joined 14 environment-related UN Conventions and Treaties, including the UN Framework Convention on Climate Change (UNFCCC). Nationally, the Mongolian Action Program for the 21st Century (MAP 21) includes considerations and recommendations related to climate change adaptation and the mitigation of greenhouse gas (GHG) emissions. In order to comply with the obligations and commitments under the UNFCCC as well as to address challenges relevant to climate change, Mongolia has developed its National Action Program on Climate Change, which received GoM approval in 2000 and was updated in 2010. The action program includes the national policy and strategy to tackle impacts of climate change and to mitigate GHG emissions. It also sets priorities for action and to integrate climate change concerns into other national and sectorial development plans. In order to fulfill the requirements of the National Program on Climate Change, an inter-disciplinary and inter-sectorial National Climate Committee has been established by the government and is led by MEGDT. The Committee coordinates and guides national activities and measures aimed at adapting to climate change and mitigating GHG emissions.

28. Regarding climate change mitigation, the government has undertaken to mitigate GHG emissions through a range of strategies for sustainable development covering different sectors

including energy, waste, transportation and agriculture. Of specific relevance to the project is the strategy for 'Improvement of energy efficiency in Industry'. Policy measures which will implement this strategy relate to (i) equipment efficiency improvements and good housekeeping; and (ii) technology changes.20

41. Regarding climate change adaptation, the GoM has outlined strategies relating to the following sectors: animal husbandry, arable farming, water resources, human health, and forestry. Each sector has a number of strategies and policies and measures relating to the strategy.

5. Environmental Impact Assessment Legal Framework and Procedures

42. The Law on Environmental Impact Assessment (1998, amended 2002, and amended 2012) regulates Mongolian EIA requirements. The most recent amendment to the law was adopted in 2012 and was brought into force in 2013, implemented through a new Environmental Impact Assessment Regulation.21 The purpose of the EIA law is environmental protection, the prevention of ecological imbalance, the regulation of natural resource use, the assessment of environmental impacts of projects and procedures for decision-making regarding the implementation of projects.

43. The terms of the law apply to all new projects, as well as rehabilitation and expansion of existing industrial, service, or construction activities and projects that use natural resources. Depending on the type and size of the planned activity, the responsible party for implementing the EIA law will be either MEGDT or aimag government (provincial government). Figure II-1 presents a simplified diagram of the EIA procedure in Mongolia.

20 Mongolia’s Second National Communication on Climate Change. 21 The new EIA Regulation revokes 2 Regulations and 1 Guideline document which do not meet the requirements of the EIA Law. The revoked legislation is: Regulation on the Environmental Impact Assessment Committee (2006); Guidelines on Formulating EPPs and EMPs (2000); and Regulation on Detailed EIA Appraisal (2006). These regulations are superseded by the EIA Law.

Projects Requiring EIA Screening - New projects, renovation/expansion of industrial, service & construction activities, projects using natural resources

Project Implementer submits documents to MEGDT or aimag - Project description, Environmental Baseline, Technical & Economic Feasibility, drawings, other related documents

MEGDT or aimag expert - Conducts General EIA (screening) within 12 days Makes 1 of 4 decisions

Decision 1 - Project Can Project can be implemented without detailed EIA Progress

Decision 2 - Project Can Progress Project can be implemented with specific conditions With conditions

Decision 3 - Project implementer - selects Detailed EIA Required Authorised Company for Detailed EIA

Decision 4 - Submit Detailed EIA - MEGD or Project rejected because of non-conformity or impacts aimag expert decision within18 days

Figure II-1: EIA Process in Mongolia

Source: Law on EIA (2012)

44. The type and size of the planned activity define responsibility as either MEGDT or aimag (provincial) environment protection authorities. There are two types of EIA defined in the Law:

(i) General EIA (screening) - to initiate a General EIA, the project implementer submits to MEDGT (or aimag government) a brief description of the project including feasibility study, environmental baseline, technical details, drawings, and other information. The General EIA may lead to one of four conclusions: (i) no detailed EIA is necessary, (ii) the project may be completed pursuant to specific conditions, (iii) a Detailed EIA is necessary, or (iv) project cancellation. The review process of the General EIA usually takes up to 12 working days. (ii) Detailed EIA – the scope the Detailed EIA is defined by the MEGDT through the approval of the General EIA. The Detailed EIA report must be produced by a Mongolian company which is authorized by MEDGT by means of a special procedure. The developer of the Detailed EIA should submit it to MEDGT (or aimag government). An expert of the organization who was involved in conducting General EIA should make a Experts selected by the MEGDT (or aimag environmental authorities) will review of the Detailed EIA and provide their comments and recommendations within 18 working days . Based on the conclusion of the experts, the MEDGT (or aimag authorities) will make a

decision about approval or disapproval of the project. (iii) The Detailed EIA must contain the following chapters: (i) Environmental baseline data; (ii) Project alternatives; (iii) Recommendations for minimizing, mitigation and elimination of impacts; (iv) Analysis of extent and distribution of adverse impacts and their consequences; (v) Risk assessment; (vi) Environmental Protection Plan; (vii) Environmental Monitoring Program; and (viii) Opinions of residents on whether the project should be implemented.

B. Applicable Mongolian Environmental Standards

45. Key standards applied in the DEIA and the IEE include the following: (i) Surface water quality standard (MNS 4586:1998); (iii) Ambient air quality standards; (iv) Soil Quality, Soil Pollutant Elements and Substances Standard (MNS 5850:2008); (vi) Ambient Noise Standard (MNS 4585:2007); and (vii) the occupational health and safety standard (MNS 5002:2000). These standards are generally compliant with, or more stringent than, guideline values defined in the IFC (International Finance Corporation) Environment, Health and Safety (EHS) Guideline. The guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice. No specific sector guidelines exist for this project, the most relevant are the EHS Guidelines for Health Care Facilities.22 The Mongolian standards on Water, were further compared with the Chapter 3 of the EHS Guideline (Community Health and Safety) and showed that they are compliant.

1. Water

46. Table II-3 summaries Mongolian drinking water standards MNS 0900: 2005. Table II-4 summarizes effluent wastewater quality standards MNS 4943: 2011.

Table II-3: Mongolian Drinking Water Standard

Parameter Unit Standard Physical Quality pH mg/l (milligrams/litre) 6.5-8.5 Hardness mg equivalent/l 7.0 Total Dissolved Solids (TDS) mg/l 1000.0 Turbidity mg/l 1.5 Taste Score 2.0 Odour Score 2.0 Colour Degree 20 Inorganic Quality Molybdenum (Mo) mg/l 0.07 Barium (Ba) mg/l 0.7 Boron (B) mg/l 0.5 Copper (Cu) mg/l 1.0 Calcium (Ca2+) mg/l 100.0 Magnesium (Mg2+) mg/l 30.0 Manganese (Mn) mg/l 0.1 Sodium (Na) mg/l 200.0 Phosphate (PO43-) mg/l 3.5 Fluoride (F) mg/l 0.7-1.5 Selenium (Se) mg/l 0.01

22 Environmental, Health, and Safety Guidelines for Health Care Facilities, IFC, April 30, 2007.

Parameter Unit Standard Strontium (Sr) mg/l 2.0 Sulfate (SO42-) mg/l 500.0 Chloride (Cl) mg/l 350.0 Arsenic (As) mg/l 0.01 Hydrogen sulphide (H2S) mg/l 0.1 Chromium (Cr) mg/l 0.05 Dry residue mg/l 1000.0 Uranium (U) mg/l 0.015 Beryllium (Be) mg/l 0.0002 Cadmium (Cd) mg/l 0.003 Total mercury (Hg) mg/l 0.001 Total cyanide (CN-) mg/l 0.01 Ammonium ion, (NH4+) mg/l 1.5 Nitrate ion, (NO3-) mg/l 50.0 Nitrite ions (NO2-) mg/l 1.0 Phosphate ions, (PO43-) mg/l 3.5 Silver (Ag) mg/l 0.1 Iodine (I2) mg/l 1.0 Vinyl chloride mg/l 0.0003 Nickel (Ni) mg/l 0.02 Lead (Pb) mg/l 0.01 Aluminium mg/l 0.5 Antimony (Sb) mg/l 0.02 Total iron (Fe) mg/l 0.3 Zinc (Zn) mg/l 5.0 Organic Quality Benzene mg/l 0.01 Xylenes mg/l 0.5 Nitrile 3 acetic acid mg/l 0.2 2 chlorinated methane mg/l 0.02 2 chlorinated ethane mg/l 0.03 3 chlorinated ethane mg/l 0.07 4 chlorinated ethane mg/l 0.04 Phenolic compounds mg/l 0.002 Styrene mg/l 0.02 Toluene mg/l 0.7 Ethyl benzene mg/l 0.3 Pesticides Atrazine mg/l 0.002 Carbofuran mg/l 0.007 Lindane mg/l 0.002 Molinat mg/l 0.006 Endrin mg/l 0.00006 Microbial Quality Total Coliform Coli / ml 100 (at source) 20 (at supply) E.Coli E.Coli / 100ml E.Coli / 100ml Radiological Quality Total α radioactivity Bq/l 0.1 Total β radioactivity Bq/l 1.0 Source: MNS 0900:2005

Table II-4: Mongolian Effluent Wastewater Quality Standard

Parameter Unit Standard Water temperature Co 20 pH - 6-9 Odour Sense No smell Total Suspended Solids (TSS) mg/l 50 BOD mg O2/l 20 COD mg O2/l 50 Permanganate oxidizing capacity mg O2/l 20 Total Dissolved Solids (TDS) mg/l 1,000 * Ammoniacal Nitrogen (NH4) mg N/l 6 Total Nitrogen (TN) mg/l 15 Total phosphorous (TP) mg/l 1.5 Organic phosphorous (DOP) mg/l 0.2 Hydrogen sulphide (H2S) mg/l 0.5 Total iron (Fe) mg/l 1 Aluminium (Al) mg/l 0.5 Manganese (Mn) mg/l 0.5 Total Chromium (Cr) mg/l 0.3 Hexavalent chromium (Cr6+) mg/l Absent Total cyanide (CN) mg/l 0.05 Free cyanide mg/l 0.005 Copper (Cu) mg/l 0.3 Boron (B) mg/l 0.3 Lead (Pb) mg/l 0.1 Zinc (Zn) mg/l 1 Cadmium (Cd) mg/l 0.03 Antimony (Sb) mg/l 0.05 Mercury (Hg) mg/l 0.001 Molybdenum (Mo) mg/l 0.5 Total Arsenic (As) mg/l 0.01 Nickel (Ni) mg/l 0.2 Selenium (Se) mg/l 0.02 Beryllium (Be) mg/l 0.001 Cobalt (Co) mg/l 0.02 Barium (Ba) mg/l 1.5 Strontium (Sr) mg/l 2 Vanadium (V) mg/l 0.1 Uranium (U) mg/l 0.05 Oil and grease mg/l 1 Fat mg/l 5 Surface active agents mg/l 2.5 Phenol (C6H5OH) mg/l 0.05 Trichloroethylene (C2HCl3) mg/l 0.2 Tetrachloroethylene mg/l 0.1 Chlorine remains (Cl) mg/l 1 Bacteria triggering water-borne disease - Absent in 1mg of water Source: MNS 4943: 2011

2. Surface water.

47. The surface water quality standard in Mongolia is presented in Table II-5. No comparable standard identified/suggested in the IFC EHS guideline.

Table II-5: Mongolian Surface water quality standard

Source: MNS 4586:1998

3. Groundwater

48. The Mongolian Standard outlining the general requirements for protection of groundwater (MNS 3342, 1982) indicates that the contamination of groundwater with industrial raw materials, products and municipal wastes during transportation and storage is prohibited. No comparable standard identified/suggested in the IFC EHS guideline. The national groundwater quality standard are shown in Table II-6 and relevant requirements in the standard include:

i) Raw materials and products for industrial and municipal waste storage tanks with potential to contaminate groundwater resources should comply with following:

➢ Geological - hydrogeological investigations of the storage tank construction, potential soil infiltration estimates of geological materials, groundwater protection measures to be developed based on the amount and characteristics of the chemicals stored. ➢ Storage tanks to be tested for leakage prior to use. ➢ For areas at the base of mountains, loops of rivers, river beds and highly fractured parts of geological sediments which are used for drinking water, storage tanks cannot be established in these regions.

ii) In case of ground water contamination due to accidents, the damaged area should be protected, spill gathered without further distribution, the prohibition of drinking water collection from this area, and quick organization and removal of traces of contamination.

iii) In the event of ground water pollution or when the contamination reaches dangerous levels, the method of observation and control will depend on the ground water quality, its intended use and the potential consequences of the pollution.

Table II-6: Mongolian groundwater quality standard

4. Ambient Air Quality

49. The Mongolian Law on Air regulates protection of ambient air, prevention from pollution, and reduction and monitoring of emissions of air pollutants. The Mongolian ambient air quality standards are presented in MNS 4585: 2007 and are summarized in Table II-7. Standard values are comparable to WHO23 and USEPA standard values.

Table II-7: Mongolian Ambient Air Quality Standard

Mongolian Standard Pollutant Averaging Period (ug/m3) Nitrogen Dioxide (NO2) 20 Minute 85 1 hour - 24 hour 40 Annual 30 Sulphur Dioxide (SO2) 10 Minute 500 15 Minute - 20 Minute 450 1 Hour - 24 hour 20 Annual 10 Particulate Matter (PM10) 24 hour 100 Annual 50 Particulate Matter (PM2.5) 24 hour 50 Annual 25 Carbon Monoxide (CO) 30 Minute 60,000 1 hour 30,000 Running 8 Hour Mean 10,000 Hydrogen Fluoride (HF) 1 hour - Annual - Hydrogen Chloride (HCl) 1 hour - MNS 4585: 2007

23 WHO: Ambient (outdoor) air quality and health, Fact sheet, Updated September 2016 (http://www.who.int/mediacentre/factsheets/fs313/en/)

5. Soil Quality Standard.

50. The soil quality standard of Mongolia is presented in Table II-8. No comparable standard identified/suggested in the IFC EHS guideline.

Table II-8: Soil quality standard

Source: MNS 5850:2008

6. Noise Standard

51. Mongolian National Standard for Ambient Noise MNS 4585:2007 sets an allowable limit for noise in daytime at 60 dB, and night at 45 dB, with night being 10pm-6am according to the Act on Labor. These standards can be compared to the more detailed WHO guidelines which recommend that indoor noise levels should not exceed 30 dB (average equivalent over 8 hours LAeq) and 45 dB (maximum for an individual noise event), and outdoor sound levels should not exceed 50 dB LAeq. Comparison is made with IFC EHS standard values in Table II-9, which shows that IFC guidelines are slightly more stringent that the national standard for residential day time permissible levels. The IFC guideline shall be followed.

Table II-9: Mongolian Noise Standard

Source: MNS 4585: 2017

C. Applicable ADB Policies, Regulations and Requirements

52. The major applicable ADB policies, requirements and procedures for EIA are the Environmental Safeguards – A Good Practice Sourcebook (2012), and the Safeguard Policy Statement (SPS, 2009), which jointly provide the basis for this IEE. The policy is underpinned by the ADB Operations Manual for the SPS (OM Section F1, 2010) and it promotes international good practice as reflected in internationally recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines.24

53. The SPS establishes an environmental review process to ensure that projects undertaken as part of programs funded through ADB loans are environmentally sound, are designed to operate in line with applicable regulatory requirements, and are not likely to cause significant environment, health, social, or safety hazards.

54. At an early stage in the project cycle, typically the project identification stage, ADB screens and categorizes proposed projects based on the significance of potential project impacts and risks. A project’s environment category is determined by the category of its most environmentally sensitive component, including direct, indirect, induced, and cumulative impacts. Project screening and categorization are undertaken to:

i) reflect the significance of the project’s potential environmental impacts;

ii) identify the type and level of environmental assessment and institutional resources required for the safeguard measures proportionate to the nature, scale, magnitude and sensitivity of the proposed project’s potential impacts; and,

iii) determine consultation and disclosure requirements.

55. The SPS requires that project activities will not be implemented in areas of critical habitat which includes areas with high biodiversity value, including habitat required for the survival of critically endangered or endangered species; areas having special significance for endemic or restricted-range species; sites that are critical for the survival of migratory species; areas supporting globally significant concentrations or numbers of individuals of congregatory species; areas with unique assemblages of species or that are associated with key evolutionary processes or provide key ecosystem services; and areas having biodiversity of significant social, economic, or cultural importance to local communities. ADB assigns a proposed project to one of the following categories based on the potential environmental impacts:

i) Category A. Proposed project is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented; impacts may affect an area larger than the sites or facilities subject to physical works. A full-scale environmental impact assessment (EIA) including an environmental management plan (EMP), is required.

ii) Category B. Proposed project’s potential environmental impacts are less adverse and fewer in number than those of category A projects; impacts are site-specific, few if any of them are irreversible, and impacts can be readily addressed through mitigation measures. An initial environmental examination (IEE), including an EMP, is required.

24 New Version of the “World Bank Group Environmental, Health, and Safety Guidelines”, April 30, 2007, Washington, USA. http://www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines.

iii) Category C. Proposed project is likely to have minimal or no adverse environmental impacts. No EIA or IEE is required although environmental implications need to be reviewed.

56. This project was re-categorized as category B for environment by ADB. This IEE, including the EMP, was prepared by the TA consultant on behalf of the MLSP, the Executing Agency (EA).

D. Other Relevant Guidelines

57. During the design, construction, and operation of a project the ADB SPS requires the borrower to follow environmental standards consistent with good international practice (GIP), as reflected in internationally recognized standards such as the World Bank Group’s Environment, Health and Safety Guidelines (hereafter referred to as the EHS Guidelines).25 The EHS Guidelines contain discharge effluent, air emissions, and other numerical guidelines and performance indicators as well as prevention and control approaches that are normally acceptable to ADB and are generally considered to be achievable at reasonable costs by existing technology. When host country regulations differ from these levels and measures, the borrower/client is to achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the borrower/client is required to provide justification for any proposed alternatives. The EHS Guidelines include General EHS Guidelines (covering environment; occupational health and safety; and community health and safety) and Industry Sector Guidelines. A comparison between IFC guideline values and MON environment quality or emission standards confirmed that MON requirements are generally compatible with levels recommended in the IFC or EHS Guidelines. EHS has guidelines for wastewater, though with limited parameters compared to MON standard; regulated noise levels are more stringent in Mongolia; and there are no EHS guidelines for soil quality, and surface and ground water quality. Surface quality regulations in Mongolia are very stringent, significantly more stringent than regulated values of many industrialized countries. Given the fact that the G0204 project adheres to MON standards, the use of country standards for the proposed additional financing loan is justified.

58. Occupational health and safety standard (MNS 5002:2000). Article 16 of the National Constitution of Mongolia states that every employee has the right to ‘suitable conditions of work’. The GoM adopted a National Program for Occupational Safety and Health Improvement in 2001 and national standards are also adopted such as the National Standard on Occupational Health and Safety MNS 5002:2000 which support the Law on Labor Safety and Hygiene (2008) which sets out policies, rules and regulations on occupational safety and health, and the most common requirements for workplace safety. During construction and operation of the project, it will be ensured that this standard will apply.

25 Please see footnote 24.

III. DESCRIPTION OF THE PROJECT

A. Project rationale, location and beneficiaries

55. The proposed project will support the Government of Mongolia in addressing a major social and rights issue by ensuring inclusiveness and delivery of services for persons with disabilities (PWD) in Ulaanbaatar and at the aimag (province) level. The overall aim of the project is to ensure access by PWD to employment to increase their autonomy and contribution to the economy and society in general. The project will support the government to comply with the United Nations Convention on the Rights of Persons with Disabilities and the Incheon Strategy, and to implement the new Law on the Rights of People with Disabilities adopted by the Parliament in February 2016.26

56. Disability prevalence estimates of around 4% based on the 2010 census is likely to be underestimate the actual incidence. Early diagnosis and identification of developmental delay in children is underdeveloped and disability assessment is based on an outdated, narrow medical approach to determine work ability loss. Older people are not recognized as disabled even if they require long-term care. PWD in Mongolia and their households represent a population subgroup with substantially higher poverty and lower human development indicators than the rest of the population.27 For instance, 42% of households with PWD live in poverty compared to 18% of households without PWD, 26% of PWD aged 15–59 years are in employment compared to 63% of those without disabilities, and 43% of PWD aged 6–18 years are unable to read a letter compared to only 4% for people without disabilities. PWD and the families of CWD incur higher expenditure for health services than nondisabled people including for medicines, diagnostic procedures and for travel costs associated with visiting the capital for tests that are not available in aimag health centers. This increased consumption contributes to greater levels of poverty among households with PWD. The quality of education services for CWD is considered low by parents, and disabled people’s organizations (DPOs) report poor access for PWD to tertiary education. The aimags targeted by the project (Arkhangai, Darkhan-uul, Dornod, Dundgovi, Khovd, and Khovsgol) are characterized by a large proportion of PWD and high poverty ratio among people with disabilities.

57. Typically, PWD, especially those with intellectual disabilities, lack access to education, health care, social protection, employment, and suffer from marginalization in society. Early diagnostic and intervention services for the majority of CWD are either unavailable or of poor quality. Poor access to education at all levels means that PWD are comparatively poorly prepared for employment compared to other people. Poor physical access to (i) public buildings including government offices, hospitals, and schools; and (ii) transportation facilities are major constraints due to lack of enforcement of existing rules and limited investment. These are all major impediments in the life of PWD, which often prevents them from accessing basic municipal and social services or nearby workplaces. PWD face huge barriers in entering job markets due to lack of skills but also due to the unpreparedness of companies. Access to orthopedic equipment and assistive devices is very limited, especially to new technologies and information and communication technology-based devices, reducing potential for PWD to compensate their disabilities and perform at school or in the workplace. PWD to face a general societal attitude that does not recognize PWD as individuals capable of living independently and contributing

26 United Nations. 2006. Convention on the Rights of Persons with Disabilities. New York; United Nations, Economic and Social Commission for Asia and the Pacific. 2012. Incheon Strategy to “Make the Right Real” for Persons with Disabilities in Asia and the Pacific. Bangkok. 27 ADB. 2016. Poverty and Social Analysis. Ulaanbaatar (TA 8850- MON).

positively to society. This is a major source of frustration for PWD leading to feelings of vulnerability and rejection. The successive barriers encountered by PWD during their lifetime underline the need for early support beginning in childhood, and sustained during school and professional life to ensure their successful inclusion in society.

58. The Government of Mongolia demonstrates strong commitment to international rights frameworks and development goals on disability.28 This is especially reflected in its active engagement with the DPO community and the adoption of a new Law on the Rights of People with Disabilities in February 2016, which moves the sector paradigm from a health and social welfare model based on a medical understanding of disability to a rights-based model built on a bio-psycho-social understanding of disability underpinned by the International Classification of Functioning (ICF). 29 The new law represents an opportunity to address the poor human development indicators for PWD. The priority areas for improvement identified by DPOs, government, and experts are (i) early identification of disability, including prenatal and postnatal screening services, to ensure early intervention to minimize the impact on child development and subsequent education outcomes; (ii) maximum functioning and active economic participation with support from social services, habilitation, and rehabilitation;30 (iii) inclusive education and employment services; (iv) improved enforcement of legislation on accessibility to the physical environment, transport, and information and increased availability of assistive devices and technology; and (v) addressing a range of strategic issues such as changing attitudes towards PWD, reforming the social welfare system to make it more equitable and targeted, using the ICF in assessing disability and planning services, and defining disability in monitoring and data frameworks.

59. PWD in rural areas and people with intellectual disabilities appear to be underrepresented by the Ulaanbaatar-based DPOs. DPOs are providing some types of services to PWDs in Ulaanbaatar and in some aimags, however the role being played by DPOs in employment promotion, compared to other countries, is very limited. DPO services are focused mainly on supporting segregated forms of employment such as sheltered employment and self-employment, largely because (i) DPOs and public employment services lack knowledge and skills on effective methods for supporting individual pathways into mainstream employment for PWD, and (ii) the regulatory framework for involving DPOs in the provision of employment and social services is not well developed.

60. The project is strongly aligned with the 2001 Social Protection Strategy and the Social Protection Operational Plan, 2014–2020.31 It will support the renewed emphasis on social protection in the midterm review of Strategy 2020 to protect the most vulnerable members of society. 32 The proposed project is also in line with the interim country partnership strategy to support PWD through social protection and the strengthening of social safety nets to ensure decent living standards for all.33

28 International rights frameworks and development goals on disability include the United Nations Convention on the Rights of Persons with Disabilities ratified by Mongolia in 2008 and The Incheon Strategy to “Make the Right Real” for Persons with Disabilities in Asia and the Pacific (2013–2020), as well as, Sustainable Development Goals set out in the 2030 Sustainable Development Vision in Mongolia. 29 The ICF is a way of understanding disability as a social construct rather than a medical problem. Introducing the ICF will enable Mongolia to develop policies and programs for removing barriers to participation in society of PWD. 30 The primary difference between habilitation and rehabilitation is that habilitation focuses on learning new skills, whereas rehabilitation focuses on regaining lost skills. 31 ADB. 2001. Social Protection Strategy. Manila; ADB. 2013. Social Protection Operational Plan, 2014–2020. Manila. 32 ADB. 2014. Midterm Review of Strategy 2020: Meeting the Challenges of a Transforming Asia and Pacific. Manila. 33 ADB. 2014. Interim Country Partnership Strategy: Mongolia, 2014–2016. Manila.

The project supports the implementation of the 2030 Sustainable Development Vision in Mongolia. The Asian Development Bank (ADB) is coordinating project inputs with the Japan International Cooperation Agency (JICA), which is also implementing two technical assistance (TA) projects on disability in Mongolia, and a memorandum of understanding will be signed prior to project implementation to ensure complementarity and avoid duplication.34

61. Disability puts women at a particular disadvantage. Several factors such as gender, aging, and poverty reinforce each other to accentuate the gender gap. For instance, the disability rate for women, particularly with severe disability, is higher than for men at any age. Poverty rates of women are typically higher than men and poverty and disability are associated. Analysis conducted during the preparation of the project has shown that disability among girls and women appears to be under- reported (males being 28% more likely to be disabled than women) and while 30% of men with disabilities aged 15–59 years work this percentage is only 25% for women. Moreover, 80% of people caring for PWD are women who often do not receive adequate social protection and support services.

62. ADB has a successful track record in the area of social protection and welfare in Mongolia however, has limited experience in the area of disability as an issue that cuts across a range of ADB sectors (health and education), and other areas including infrastructure development, social protection, social services and care, and employment. The proposed project represents a learning opportunity for ADB in an area of increasing international importance especially in relation to the United Nations Convention on the Rights of PWD (2006) and in relation to aging populations resulting in increased numbers of PWD. Specific ADB support for PWD in Mongolia includes a grant provided by the Japan Fund for Poverty Reduction for Expanding Employment Opportunities for Persons with Disabilities (Grant 9014-MON) implemented in 2002–2006; and the Social Sector Security Development Program, which assisted in developing the manufacturing capacity of prosthetics and establishing community care centers. ADB’s work in the health and education sectors in Mongolia, although extensive, has not focused on disability. In 2005, ADB published the “Disabled People and Development” as an attempt to integrate disability into poverty reduction and development strategies, and into other relevant sectors. This has not led to operations directed at disability.

63. International development partners include JICA which has been implementing a $3 million, 4- year TA in support of the Ministry of Education focused on education for CWD since August 2015 and a $3 million, 4-year TA on social participation for PWD in Ulaanbaatar which is due to start in June2016. AIFO (an Italian nongovernment organization) has been focusing on the development of community- based rehabilitation. The People’s Republic of China is providing funding for the construction of a National Children’s Rehabilitation Center in the Bayongol district of Ulaanbaatar and the Ministry of Labor and Social Protection (MLSP) plans to request further external support to build development centers in the remaining 15 aimags not covered by the project, using the design developed under the proposed project. The US State Department supported the MLSP in drafting the new Law on the Rights of People with Disabilities and an European Union project is assisting with the drafting of a national program to implement the law and standards for the implementation of social welfare services.35

34 In August 2015, JICA launched Strengthening Teachers’ Ability and Reasonable Treatments (START) for CWD, a $3 million, 4-year TA in support of the Ministry of Education, focused on education for CWD, and a $3 million, 4-year TA on social participation for PWD in Ulaanbaatar which started in June 2016. 35 European Union, Economic Governance for Equitable Growth (EG4EG) Project for Mongolia, 3 year project begun in August 2015 focused on macro economic planning, but also has social protection and employment components.

64. The geographical focus of the project will be on Ulaanbaatar and six aimags (Arkhangai, Darkhan-uul, Dornod, Dundgovi, Khovd, and Khovsgol). New services will be created in the aimag centers and outreach services will be provided to CWD and PWD in the soums and khoroos. Some project activities focusing on strategic issues will have national reach. The project will directly benefit PWD and their families, a population subgroup whose poverty rates are more than twice as much those of others: 42% versus 18%. Employment to population rate for 15-59 year old PWDs is only 28%, compared with 69% for the rest of the population. In general PWD have significantly lower human development indicators than others: 53% of 6-18 year old CWDs are unable to read, as compared with 4% for other children. Almost 100,000 PWD could benefit from improved employment services and by the end of the project at least 5,000 more PWD are expected to enter the labor market than in 2014. Social welfare reforms should result in better services being provided to all PWDs and their families, covering indirectly more than 400,000 people. Some of the project activities, including early identification and improved services, will focus on target regions that cover more than 50% of PWD living in poverty and have been identified to maximize coverage of PWD especially those living in poverty. It is expected that 17,000 children and 62,000 adults will benefit from these new services in the project target areas.

B. Project Outputs

65. The project will have five outputs that address the need for services and support across the full life-cycle of CWD and PWD36:

66. Output 1. Early identification of children with disabilities strengthened and institutionalized. The project will (i) institutionalize the current model initiated by MLSP, (ii) facilitate the shift from a medical to a social model in identifying CWD by broadening the skills of persons involved in early identification. Supported by appropriate interventions, early intervention will minimize the effects of, and possibly prevent, disability which can lead to greater ability and inclusion in education, employment and society in general.

67. Output 2. Service delivery for persons with disabilities improved. The project will (i) implement a model of interactive parent–child–facilitator education in early childhood; (ii) establish six model aimag development and rehabilitation centers for CWD and PWD (infrastructure, equipment, management system, staffing, capacity building); (iii) establish a disability workforce with national level curricula introduced for occupational and speech therapy, physiotherapy and orthopedic technicians as well as disability social workers, (iv) strengthen the role of social workers in support to PWD; and (v) establish hotlines for PWD. Early identification supported by appropriate interventions and service delivery, are the starting point for ensuring access by CWD to society, to education and later to employment. Early identification and delivery of better and more appropriate services for CWD may also allow family members especially women to take an active role in the economy.37 Improved services will

36 Except education as this is being addressed by JICA through its START project. 37 According to the household survey, 4 out of 5 caregivers are women. Department for International Development. 2000. Disability, Poverty and Development. http://www.handicapinternational.fr/bibliographie-handicap/4PolitiqueHandicap/hand_pauvrete/DFID_disability.pdf The UN has estimated that a quarter of the world’s population is adversely affected as a result of disabilities.

include: individual case management by disability social workers, portage, physiotherapy, speech and occupational therapy, assistive devices, personal assistants and other independent living services.38

68. Output 3. Access to the physical environment improved. This output will (i) develop the capacity of decision makers and strengthen institutions involved in developing and enforcing the legal and regulatory framework on physical accessibility norms (infrastructure, transportation, information); (ii) ensure wide inclusion of PWD in enforcement mechanisms; (iii) ensure access to affordable quality orthopedic devices and assistive technology, including in aimags. The activities that will be implemented to achieve this output will facilitate implementation of regulations that reduce barriers to the environment and improve mobility and access to information, public buildings and transportation. Increased access to assistive devices and services will reduce participation barriers affecting PWD and enable them to engage actively in employment.

69. Output 4. Work and employment for persons with disabilities improved. This output will (i) set up models to increase the skills of PWD to enter selected industries and improve general job brokerage for PWD; (ii) facilitate inclusive business and organize support systems for PWD to access regular jobs and self-employment; and (iii) strengthen participation of PWD in monitoring compliance with regulation on employment for PWD. The activities are focused on making policies and practices of public employment and DPO services more effective in creating individual pathways into employment (case management, job coaching); supporting the development of a DPO Employment Resource Center in UB (infrastructure39, equipment, training and capacity building) that can provide services to PWD, employers and to public employment offices and; supporting employers and PWD in the enforcement of legislation regarding employment quotas for PWD.

70. Output 5. Strategic development to support persons with disabilities implemented. The project will (i) raise awareness and change attitudes towards PWD, (ii) reform the welfare system to improve targeting and financial support for PWD to access services and equipment, (iii) conduct a strategic review of the national program, (iv) introduce the ICF in line with needs and available resources, and (v) align National Statistical Office data with information needs in relation to disability. Indirect interventions leading to improved inclusion will be achieved through public campaigns to support a gradual change of attitudes towards PWD, a better understanding of disability through the introduction of the ICF, and better statistics and information on challenges faced by PWD.

C. Implementation Arrangements

71. The Ministry of Labor and Social Protection (MLSP) of Mongolia will be the Executing Agency (EA) of the Project. It will provide (i) strategic, policy, and overall oversight of the project; and (ii) coordination support for preparation and implementation of the project, including participation in relevant working groups. The Policy Development MLSP will be responsible for implementation of outputs 2, 3, and 5, providing oversight and guidance for outputs 1 and 4. MLSP subagencies, National Rehabilitation Center and NCRC, will support implementation of activities to support service

38 A model of interactive parent–child–facilitator education in early childhood that is being adapted for Mongolia with support from the JICA START project and piloted in one district of Ulaanbaatar. 39 The DPO Employment Resource Center infrastructure will be partly funded by a JFPR co-financing grant, the SPS requirements will remain to be applied.

development and the work of the children’s commissions, as well as the introduction of the ICF through an ICF implementation unit based at NCRC. MLSP subagency, the National Authority for Children, will support implementation of the activities to introduce parent–child–facilitator programs in early childhood.

72. The responsibility of the project implementation unit (PIU) of the MLSP will be for project coordination and day-to-day implementation of project activities including financial matters, procurement, recruitment of consultants, review and monitoring and progress reporting. The PIU will consult closely with implementing agencies, other relevant ministries and agencies, and international partners. The PIU will be staffed by a project coordinator, 6 project sub coordinators responsible for activities implemented at aimag level (The 6 project sub-coordinators, will be the PIU staff in the aimags (provinces) covered by the project. The sub-coordinators will be in charge of day-to-day project implementation management in the project aimags), a procurement specialist, a financial management specialist, two field specialists in disability, a monitoring and evaluation specialist and a secretary. One of the field specialists in disability will focus on the new multi-disciplinary and early childhood services, social welfare reform and ICF and the other on employment, accessibility and awareness raising and attitude change.

73. The Project Steering Committee (PSC) of the overall project will oversee the implementation of the project and give strategic direction. It will be chaired by the state secretary of MLSP and include representatives of the Ministry of Finance, DPOs representing the full range of disabilities and issues and other government agencies and ministries involved in implementation: Ministry of Health (MOH), National Authority for Children, National Children’s Rehabilitation Center (NCRC), National Employment Service Research and Information Center (NESRIC), National Rehabilitation Center, and ADB. The PSC will meet quarterly and be responsible for providing strategic orientation, approving the annual budget and activity plan, and reviewing and advising on implementation progress. Six project steering subcommittees will also be established in the target aimags chaired by the governor and representing the aimag health, education, and social protection committees and DPOs. The project steering subcommittees will have oversight of the implementation of project activities in each aimag, including the hiring of staff for new services, training of staff in health, employment and social welfare services, and civil works. The project steering subcommittees will meet quarterly and report on progress and problems arising to the PSC.

74. Implementing agencies will be the Ministry of Health (MOH) on early identification of CWD and the and MLSP’s Policy Development Department on employment of PWDs. MOH will also play an important role in activities to expand the list of assistive devices and equipment that can be reimbursed through the health and social insurance system or by the social welfare fund. Based on the social insurance law, the responsibility lies with the Health Insurance National Council, which is basically under MLSP, but interaction with MOH is important in the tasks envisioned in the project for the expert on health risk and assistive devices, and health insurance.

75. The Roles and Responsibilities of the Project Implementation Organizations are as follows:

Project implementation organizations Management Roles and Responsibilities

Executing Agency ➢ Provide strategic, policy, and overall oversight of the project and provide coordination support for preparation and implementation of the project. MLSP ➢ Chair and organize the project steering committee ➢ Responsible for all project financial matters and PIU staff. The responsibility for procurement and consultant recruitment will be agreed on by the government and ADB. ➢ MLSP is the executing agency for the entire project and the implementing agency for outputs 2, 3, 4 and 5. Project specific management body ➢ Advises the executing agency by providing strategic, policy, and general oversight of Project steering committee the project ➢ Meets at least quarterly

Implementing unit 1 ➢ Implementing agency for output 2, 3, 4, and 5; in particular, it will be responsible for guiding the development of the DPO employment resource center MLSP’s Policy and Development Department Implementing agency 2 ➢ Implementing agency for output 1 and the introduction of the ICF under output 5, including leading the ICF Task Force MOH PIU ➢ The unit will be responsible for project coordination and day-to-day implementation of project activities, including financial management, review and monitoring, and progress reporting under supervision of the MLSP ➢ Responsible for the day-to-day administration of procurement and recruitment of consultants in support of the MLSP ➢ Responsible for monitoring the implementation of the GAP, EMP, and DMF ➢ Responsible for day-to-day supervision and management of consultants and ensuring quality in execution of all contracts ➢ Prepare and submit quarterly and annual project reports to MLSP and ADB ➢ Responsible, on behalf of the MLSP, for overseeing implementation of the communication strategy and convening and servicing the Media Strategy Group ➢ Responsible for liaising, on behalf of the MLSP, with MOH and with other ministries and government agencies involved in implementation – Ministry of Roads and Transportation, Ministry of Construction and Urban Development, Government Agency for General Inspection, NRC, NCRC, NAC ➢ The project coordinator of the PIU will be responsible to supervise and manage the six project subcoordinators responsible for activities implemented at aimag level ➢ Responsible, on behalf of the executing agency, for establishing and maintaining the imprest account, submitting the withdrawal applications, monitoring contract awards and disbursement, retaining supporting documents, submitting quarterly and annual reports, as well as annual audit reports and financial statements ➢ Attend portfolio meetings and reviews organized by ADB

Consultants (national and international) ➢ Provide technical inputs in support of project implementation ➢ Submit quality reports in accordance with consultant contracts ADB ➢ Administer the project and ensure compliance by executing and implementing agencies of their obligations and responsibilities for project implementation in accordance with ADB’s policies and procedures

ADB = Asian Development Bank, DMF = design and monitoring framework, DPO = disabled people’s organization, EMP = environmental management plan, GAP = gender action plan, MOH = Ministry of Health, MLSP = Ministry of Labor and Social Protection, NAC = National Authority for Children, NCRC = National Children’s Rehabilitation Center, NRC = National Rehabilitation Center, PIU = project implementation unit. Source: ADB.

D. Project Organization Structure

Executing Agency Ministry of Labor and Project Steering Social Protection (MLSP) Committee

Ministry of Health Working groups Policy Development (Implementing Agency) Department of MLSP (Implementing Unit)

Project Implementation Unit

International and national consultants

Advises (for project purposes)

Oversees (for project purposes)

E. Project Area of Influence, Project Implementation Schedule

76. Sites visits were conducted during July-October 2016 for the preparation of this IEE and GEIAs with particular attention paid to: (i) sensitive natural environmental receptors such as water bodies and natural/critical habitats; (ii) sensitive human receptors; and (iii) cultural and heritage sites. The project’s area of influence was defined based on the definition provided in ADB’s Safeguard Policy Statement (2009) as follows:

(1) Primary project site(s) and related facilities: These include the proposed 6 small development and rehabilitation centers for PWD in 6 provincial capitals (aimags) and the new 6-storey Employment Resource Center for DPO which will be built in Ulaanbaatar.

(2) Associated and existing facilities: Under ADB's Environment Safeguards Sourcebook, Associated Facilities are those which are ''not funded as part of a project but whose viability and existence depend exclusively on the project and whose goods and services are essential

for successful operation of the project''. Essential services for the successful operation of the project include power supply, water supply, waste water discharge, district heating (if applicable) and waste services. During the site assessment and selection the responsible government persons from the respective aimags confirmed that these services are and will be available and are operated in accordance with the national laws and regulations.Areas and communities potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location: It is not anticipated that the centers will cause any unplanned developments. All subcomponents under the project are site- specific and not likely to cause additional developments.

29. Implementation schedule. The tentative project implementation plan for the project is set out in the schedule shown in Table III-6.

Table III-6: Project implementation schedule

Year 1 Year 2 Year 3 Year 4 Year 5

2017 2018 2018 2018 2018 2019 2019 2019 2019 2020 2020 2020 2020 2021 2021 2021 2021 2022 2022

Activities 2017

------

Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 A. DMF

Output 1: Early identification of children with disabilities strengthened and institutionalized

1.1 Institutionalize the current early identification model initiated by X X X X X X X X X X X X X X X X the Ministry of Labor and Social Protection

1.2 Facilitate the shift from a medical to a social model to X X X X X X X X X X X X X identifying CWD by broadening the skills of persons involved in early identification

Output 2: Service delivery for PWDs improved

2.1 Implement a model of interactive parent–child–facilitator X X X X X X X X X X X X X X X X X X education during early childhood

2.2 Establish six model aimag development and rehabilitation centers for CWD and PWDs (infrastructure, equipment, X X X X X X X management system, staffing, capacity building, and financing)

2.3 Establish a disability workforce with national level curricula introduced for occupational and speech therapy, X X X X X X X X X X X X X X X X X X physiotherapy, and orthopedic technicians, as well as, disability social workers

2.4 Strengthen the role of the social workers in support to PWDs (capacity building and service delivery) X X X X X X X X X X X X X X X X X X

Year 1 Year 2 Year 3 Year 4 Year 5

2017 2018 2018 2018 2018 2019 2019 2019 2019 2020 2020 2020 2020 2021 2021 2021 2021 2022 2022

Activities 2017

------

Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 2.5 Establish hotlines for PWDs X

Output 3: Improved access to the physical environment improved

3.1 Develop capacity of decision makers and strengthen institutions involved in developing and enforcing the legal and X X X X X X X X regulatory framework on physical accessibility norms

(infrastructure, transportation, information)

3.2 Ensure wide inclusion of PWDs in enforcement mechanisms X X X X X X X X X X X X X X X

3.3 Ensure access to affordable quality orthopedic devices and X X X X X X X X X X assistive technology, including in aimags

Output 4: Work and employment for PWDs improved

4.1 Set up models to increase the skills of PWDs to enter selected X X X X X X X X X X X industries and improve general job brokerage for PWDs

4.2 Facilitate inclusive business and organize support systems for X X X X X X X X X X X X PWDs to access regular jobs and self-employment

4.3 Strengthen participation of PWDs by monitoring for compliance X X X X X X X X X X X X with regulation on employment for PWDs

Output 5: Strategic development to support PWDs implemented

5.1 Raise awareness and change attitudes towards PWDs X X X X X X X X X X X X X X X X X X X

5.2 Reform the welfare system to improve targeting and financial X X X X X X X X X X X support for PWDs to access services and equipment

Year 1 Year 2 Year 3 Year 4 Year 5

2017 2018 2018 2018 2018 2019 2019 2019 2019 2020 2020 2020 2020 2021 2021 2021 2021 2022 2022

Activities 2017

------

Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Output 5: Strategic development to support PWDs implemented

5.1 Raise awareness and change attitudes towards PWDs X X X X X X X X X X X X X X X X X X X

5.2 Reform the welfare system to improve targeting and financial X X X X X X X X X X X support for PWDs to access services and equipment

5.3 Conduct a strategic review of the national program X X X X X X X X X X X X

5.4 Introduce the International Classification of Functioning in line X X X X X X X X X X X X X X X X X X X with the needs and available resources

5.5 Align National Statistical Office data with the information needs X X X X X in relation to disability

B. Management Activities Procurement plan key activities to procure contract packages X X X X X X X X X X X X X

Consultant selection procedures X X X

Environment management plan key activities X X X X X X X X X X X X X

Gender action plan key activities X X X X X X X X X X X X X X X X X X X X X X X X X X

Communication strategy key activities X X X X X X X X X X X X X X X X X X X X X X X X X X

Annual/Midterm review X X X X X

Project completion report X CWD = children with disabilities, PWD = person with disabilities, Q = quarter. Source: ADB estimates.

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE)

A. Urban Form, Socio-economic Conditions

77. Location & Administration. Administratively, Mongolia is divided into 21 aimags (provinces) and the capital city Ulaanbaatar. Aimags are divided into soums which are further divided into baghs. The geographical focus of the project will be on Ulaanbaatar and six aimags (Arkhangai, Darkhan-uul, Dornod, Dundgobi, Khovd, and Khuvsgul). The location of the project cities is highlighted in Figure IV.1

Figure IV.1: Sites of the proposed interventions

(1) Darkhan city of Darkhan-uul aimag: Darkhan city of Darkhan-uul aimag is situated approximately 220 km from Ulaanbaatar. The city of Darkhan (now Old Darkhan) was founded in 1961 with construction of New Darkhan commencing one year later. New Darkhan is located about 2 km to the south of Old Darkhan, from which it is separated by a small range of hills.

(2) Khuvsgul province – Moron city: Khuvsgul aimag borders on the North with Russian Federation. The altitude of high mountains of Burenkhaan, Khordil saridag, Erchim range, Tagna, and Soyon is up to 11,483 feet (3,500 m.) above sea level. The total territory is 38, 842 sq. miles (100,600 sq. km) and Moron city is located 430 miles (692 km) from Ulaanbaatar.

(3) Arkhangai province – Tsetserleg city: Tsetserleg (Arkhangai aimag) lies on the northeastern slopes of the Khangai Mountains, 600 km southwest of Ulaanbaatar. In 1992 Tsetserleg was designated as Erdenebulgan sum, which has an area of 536 km². Tsetserleg is located in the Orkhon River basin, which is part of the Arctic basins cluster. The Mongolian National Atlas

(2009) attributes Tsetserleg to the natural zone of forest-steppe, with 15.1 % of the total area belonging to the forest-steppe zone.

(4) Dundgobi province – Mandalgobi city: The town is located on the transition zone of scattered bunch grass of the great Gobi (desert) about 186 miles (300 km) south of Ulaanbaatar.

(5) Khovd province – Khovd city: Khovd is one of the 21 aimags (provinces) of Mongolia, located in the west of the country. Its capital is also named Khovd. The Khovd province is approximately 1,580 km from Ulaanbaatar, Mongolia's capital. It takes its name from the Khovd River, which is located in this province. Geographically the Khovd city located in the Buyant sum, but is administered as independent Jargalant sum. As a result of administrative reforms in 1992, Khovd was accorded the status of Jargalant sum. City area is 80 km2.

(6) Dornod province – Choibalsan city: The province of Dornod has borders with the Russian Federation and with the People’sRepublic of China. Green pastures grow on black and brown soils. River basins are very fertile. The province of Dornod has quite well developed infrastructures. 81,3 % of the arable land, that’s to say about 10 million hectares, are cultivated or used for pasture.

(7) Capital Ulaanbaatar city - Khan-uul district: The territory of Khan-uul district of the Capital Ulaanbaatar city is 48,466 hectares, and it borders mainly on the Capital’s Songinohairkhan and Bayanzurkh districts, and the territory of Sergelen soum, Tuv province.

78. Population. With the exception of Ulaanbaatar and Darkhan, in all the project aimags, about one third of the total population of the aimag lives in the aimag centers.

• Darkhan city of Darkhan-uul aimag: About 76 percent of the population of Darkhan-uul aimag lives in Darkhan city, of which 86 percent lives in residential apartments. Total population was 79,938 by end of 2014. During the period 2003 to 2010 the slow out- migration from Darkhan was being compensated for by the natural population increase.

• Khuvsgul province – Moron city: The population of the aimag is 124,500, the population density about 1,24 p/sq. km. Ethnic groups include Khalkh, Buryat, Tsaatan, Uriankhai and Darkhad.

• Arkhangai province – Tsetserleg city: The population of Tsetserleg city was in 2010 about 21,091 with a total population of 84,584 in the aimag.

• Dundgobi province – Mandalgobi city: The population of Dundgobi province is about 38,821, of this about 10,299 live in Mandolgovi city.

• Khovd province – Khovd city: The population of Khovd aimag is 118,000. The total area is 76,100 km². It borders Uvs, Bayan-Ulgii and Gobi-Altai aimag. The city has a population of 26,023 (2000 census), 30,479 (2003, est.), 28,601(2007). In 2005, Jargalant sum (the centre of Khovd Aimag) had 32,351 inhabitants (6,675 households), belonging to more than ten ethnic groups and nationalities such as Uuld, Khalkh, Zakhchin, Torguud, Uriankhai, Myangad, Durvud, Bayad, Kazak, Chantuu and Üzemchin.

• Dornod province – Choibalsan city: Dornod aimag has a population of 69,552. The

province center, Choibalsan, has a population of 38,150. The Khalkhas are predominant in the province, but Buryat and Bargapopulations also live there, especially in the sums of Ereentsav, Bayandun, Dashbalbar, and Tsagaan–Ovoo. The sums of Gurvan Zagal and Khuluunbuir are populated by Uzemchins.

• Capital Ulaanbaatar city - Khan-uul district: In the first half of 2010, the population of Khan-Uul district included a population of 105,993 from 182,000 households. In total, 3,732 enterprises and organizations run activities within the territory of Khan-Uul district.

79. Water and wastewater sector assessment. Water supply and wastewater management are the responsibility of the Public Urban Services Organization (PUSO) for the project cities.

80. Water supply. The core areas of each of the project cities are served by a reticulated water supply system supplied from networks of boreholes providing groundwater which is generally of good drinking water quality. The raw water is generally pumped to ground tanks from which supply is made to: (i) commercial and institutional establishments within the core areas of the cities; (ii) households (mainly apartments) which have a household connection to the supply; and (iii) water kiosks which serve some of the ger areas. In all project cities there are also water kiosks in ger areas which are served by tanker trucks.

81. Sewer systems. All project cities have a sewerage network which serves the core area. These are separate sewer systems, with sanitary sewage and stormwater drainage being served by independent networks. The sewers are generally of between 150 and 350 mm in diameter, of varying materials and constructed over the past 30 years. Most of the materials used are concrete and PVC.

B. Physical Conditions within the Project Areas

1. Location, Topography, Geology and Soil

82. MEGDT classifies Mongolia’s river basins in six clusters of similar climate conditions, geographical characteristics, basin type (surface water, groundwater, or combined), and land cover (Figure IV.2).40

40 Government of Mongolia, Kingdom of the Netherlands. 2012. Integrated Water Management. National Asessment Report, Vol. II. Ulaanbaataar, Mongolia.

Figure IV.2: The river basin clusters in Mongolia (Source: GoM, KoNL, 2012)41

Figure IV.3: Natural zones of Mongolia (Source: Biodiversity Assessment, WWF, 2003)

(1) Darkhan city of Darkhan-uul aimag: Darkhan is at an elevation of around 700m above sea level. The east of the city is characterized by rolling hills which are used as pasture land for herders. The west is clearly defined by the Kharaa River and its floodplain which at Darkhan city is approximately 2-3 km wide. The river basin lies in an area where intrusive rocks of leucocratic granite and granodiorite have intruded into sediments. In places where this intrusion has occurred, gold deposits can be found in the Kharaa river basin. The project area is dominated by (i) fluvisols - typically found on flat land associated with flood plains, (ii)

41 Footnote 40.

kastanozems - are humus-rich soils that were originally covered with early-maturing native grassland vegetation, which produces a characteristic brown surface layer, found in relatively dry climatic zones

(2) Khuvsgul province – Moron city: The aimag is considered to be one of the most beautiful places of Mongolia with its snowcapped majestic mountain ranges, deep blue lakes, thick forests, vast river valleys. The 24 sums are divided into three regions, High Mountain, Low Mountain, and Forrest-Steppe. Khuvsgul aimag is rich with mineral resources. Deposits containing many thousands of tons of phosphate, coal, graphite, gold, iron ore, lime stone, mineral colors, marble, and granite have been explored in this region. By natural zonation the area is the forest steppe zone and belongs to province of Khangai vaulted massive mountain with the typical dark chesnut soil type of steppe valley and depression group. The area belongs to the sporadic permafrost region according to permafrost zones.

(3) Arkhangai province – Tsetserleg city: The highest point of Arkhangai province is Kharlagtai Peak at 3,529 m (11,578 ft), while the lowest point is the area on the confluence of the Orkhon and Tamir rivers at 1,290 m (4,232 ft). The most well-known mountain is the extinct volkano Khorgo, which is part of the Khorgo-Terkhiin Tsagaan Nuur National Park. Soil is mainly scattered grey, sandy, brown, black, and black brown soils of pasture land and forests, classified as mountain-steppe brown soil.

(4) Dundgobi province – Mandalgobi city: Dundgobi aimag lays in the middle of Central, Eastern Steppe and Gobi and region of Mongolia in terms of climatic and geophysical rate factors. In this region, moisture availability and arable soils are major limiting factors to agricultural production. Except in irrigated oases suitable for the production of vegetables and melons, agricultural is limited primarily to using sheep, goats and camels to harvest grazing land forage. The region is the center of a cashmere goat industry. The city belongs to province of Central Mongolian prostrate and base high plains, flat hollows, restored relict massive mountains with the semi desert steppe zone, by sub-zone decertified steppe natural zone. The soil cover belongs to typical light chestnut with light chestnut solonetzic and stony light chestnut type of the steppe valley and depression group. In the area dominates permafrost zone of seasonal freezing type. According to desertification map the Mandalgobi city belongs to area with middle and strong desertification status.

(5) Khovd province – Khovd city: Khovd aimag belongs to the Altai Region, which is the high mountain region in western Mongolia. Agricultural production in the region is limited to using cattle, sheep, goats and yaks to harvest grazing land forage with pastoral grazing management strategies. Khovd aimag is almost cut in half by the mighty Mongol Altai Nuur range; away from the mountains the land is a barren semi-desert dotted with salt lakes and smaller mountains. The melting snow from the mountains recharges the water table every spring, providing Khovd with more than 200 fast-moving rivers (and dozens of lakes), none of which has an outlet to the sea. All the rivers simply disappear beneath the sands or run into large saltwater marshes, which serve as giant evaporating ponds.

(6) Dornod province – Choibalsan city: The landscape is characteristic of the semi arid high steppe that is typical of the Eastern Steppe. Small conical hills and gently sloping plains, with various species of grasses and rare stands of birch and aspen are common. The area has a low to moderate topographic relief, with elevations between 900 to 1100 m above sea level (asl). The vast steppes of Menen, Matad, and Tamsag stretch on 300 kilometres (186,40 miles) long and up to 150 kilometres (93,20 miles) wide. The steppes stretch over 150-200 kilometres

(93,20 – 124,27 miles) along both banks of theKerulen River. The lowest point of Mongolia is located in the basin of Lake Khukh (560 metres, 1.837,27 feet) in the Northeast of the province. In the Southeast of the aimag, some parts of the Khyangan Mountain reach 1.000 to 1.600 metres (3.280,84 – 5,249,34 feet) above sea level.

(7) Capital Ulaanbaatar city - Khan-Uul district: Geologically the Ulaanbaatar region belongs to the Khentii geosynclinals depression. Ulaanbaatar City is mainly underlain by Cambrian, Devonian, and Carboniferous sandstone and mudstone. Ulaanbaatar City is located on an alluvial plain. MNET confirmed that in the City, soil is low in permeability and gullying and erosion is visible on steep slopes in the ger areas to the North of the City.

83. Permafrost. Permafrost formation is influenced by many factors such as seasonal changes, composition of soil deposits, water cycles on the ground surface, air temperature, precipitation, elevation above sea level, and surface relief. Frozen soil is classified into five basic groups in Mongolia: (1) continuous permafrost; (2) discontinuous permafrost; (3) scattered permafrost; (4) sporadic permafrost, and (5) seasonally frozen soil. Permafrost is distributed on some 60% of Mongolian territory. 42 Permafrost is found in Mongol-Altai, Gobi-Altai, Khangai, Khovsgol, and the Khentii Mountains, and most of it is discontinuous. (see Figure IV.6)

Figure IV-4: Regional distribution of permafrost in Mongolia. (Source: Footnote 42)

84. Earthquakes. Mongolia has experienced four major earthquakes (Ms>8) and many more moderate earthquakes (Ms 5.3-7.5) in the last century. The seismic activity in Mongolia is related to its location between the compressive structures associated with the collision of the Indian-Australian plate with the Eurasian plate on the one hand and the extensional structure associated with the Baykal rift system on the other. The historical records (1903 onward) of the seismicity in Mongolia show a high

42 Dashjamts D, Binderya Z, Altantsetseg J. 2013. Geotechnical problems of construction on permafrost in Mongolia. Sciences in Cold and Arid Regions 5(5): 0667–0676.

concentration of seismic activity along the Mongolian-Altay and Gobi-Altay ranges and the north western border with Russia and around Mogod east of Hangay mountain. The multi-organizational Global Seismic Hazard Assessment Program classifies Ulaanbaatar as low to moderate earthquake risk areas shown in the following Figure.

Figure IV-5: Seismic Risks In Mongolia and the PRC (Source: Footnote 43)

85. According to Earthquake Intensity Modified Mercalli Scale the UB city area lays in the area of Degree VI, which means strong intensity. Under the certain scenario (I), the MSK intensity ranged from 5.65 to 10.12 (VI-X), while in other scenario (II) ranged from 5.16 to 10.14 (V-X). In latter Scenario, compared to previous Scenario, it shows higher values in the north western side of the city and high value in north eastern side. This is due to these areas close to the source faults of the Scenario II, the Emeelt fault and the Gunjiin fault. However, in the central city area of UB, there is no remarkable difference between the Scenario I and II. For example, in the Sukhbaatar (now Chinggis Khaan) square, Scenario I shows intensity 8.6 while Scenario II shows intensity 8.7. In both scenarios, the obtained MSK intensity in the central city area is VIII-IX. In the case of Scenario I, because larger maximum magnitude of earthquake estimated on the Hustai fault, the MSK intensity is VIII-IX in the central city, even though the distances of about 30 km from the source fault. On the other hand, even though the estimated earthquake on the Emeelt fault is smaller than that of the Hustai fault, due to it relatively closes to the city area, resulted similar result of ground motion evaluation with the Scenario I.

2. Climate

86. Temperature, Precipitation. Mongolia has an extreme continental climate with long, cold winters and short summers, during which most precipitation falls. The country averages 257 cloudless days a year, and it is usually at the center of a region of high atmospheric pressure. Precipitation is

43 Source: Global Seismic Hazard Assessment Program. Global Seismic Hazard Map

highest in the north, which averages 200 to 350 millimeters per year, and lowest in the south, which receives 100 to 200 millimeters. The extreme south is the Gobi Desert, some regions of which receive no precipitation at all in most years. Average temperatures over most of the country are below freezing from November through March and are about freezing in April and October. January and February averages of −20 °C are common, with winter nights of −40 °C occurring most years. Summer extremes reach as high as 38 °C in the southern Gobi region and 33 °C in Ulaanbaatar.

87. Wind. Wind direction and speed depend on circuit flow of the atmosphere, air pressure, and the local bio-physical conditions. The maximum wind speed in March and April can reach 30 m/s.

88. Surface water. As described above, the seven project cities are located in the river basins belonging to different river basin clusters.

89. Groundwater. Mongolia has substantial groundwater resources, which are unevenly distributed over the country - abundant in the north and very scarce, or non-existent, in the south. Southeast Gobi has no perennial fresh water resources and relies exclusively on groundwater resources for water supply. The hydrogeology of Southeast Gobi consists of upper aquifers with limited recharge and deeper aquifers containing fossil water, often with poor water quality. Air Quality

90. Ambient air quality. The Central Laboratory for Environmental Measurement publishes annual average ambient air quality in all aimag capitals, including the four project cities. The results indicate that air quality in most of the cities is generally good and in compliance with the MNS 4585:2007 standard for sulfur dioxide and nitrogen dioxide, with exception of Murun and Darkhan where annual average nitrogen dioxide and sulfur dioxide concentration in 2012 exceeded the standard (Figure IV.6 and Figure IV.7).

Figure IV.6: Ambient sulfur dioxide concentrations of aimag capitals, in microgram per cubic meter (Source: Baseline Report for Tsetserleg WWTP; Undurkhaan Trade LLC)

Figure IV.7: Ambient nitrogen dioxide concentrations of aimag capitals, in microgram per cubic meter (Source: Baseline Report for Tsetserleg WWTP; Undurkhaan Trade LLC)

91. Air pollution levels in Ulaanbaatar have been continuously increasing due to intensive industrial development, increased population density, use of coal in ger districts, increased number of automobiles, etc. Violations of permissible air quality levels are also increasing with particulate pollution particularly problematic. The City of Ulaanbaatar estimates that 5.2 million tons of coal is used per year in the city, with 3.6 million tons used for the thermal power stations, 1.0 million tons in the low pressure boilers, and the remaining 600 thousand tons in the ger district households. The combustion of 5.2 million tons of coal is estimated to produce 719.0 thousand tons of SO2, 573.0 thousand tons of NO2, 1.7 million tons of dust, and 13.9 million tons of CO2, and all these substances play the major role in the air pollution of the City of Ulaanbaatar.

92. The current measured air pollution levels are significantly high for all major pollutants including CO2, NO2, SO2, and ozone. Particulate pollution from dust and other anthropogenic sources is extremely high for many months of the year. The air pollution in the city of Ulaanbaatar is particularly severe in the winter months, due to the natural constraints in the layout of the city, surrounded by mountains, and the meteorological conditions with low temperatures and low mixing heights for most part of the year, which limits the dispersion of pollutants and enhancing their ambient concentrations.

93. Climate in the project aimags.

• Darkhan city of Darkhan Uul aimag: The climate is cold and temperate. In winter, there is much less rainfall than in summer. The climate here is classified as Dwb by the Köppen- Geiger system44. The temperature averages -0.6 °C. The rainfall averages 309 mm. The driest month is February, with 2 mm of rain. Most precipitation falls in July, with an average of 83 mm. July is the warmest month of the year. The temperature in July averages 19.2 °C. In January, the average temperature is -24.7 °C. There is a difference of 81 mm of

44 The Köppen climate classification is one of the most widely used climate classification systems. It was first published by Russian German climatologist Wladimir Köppen in 1884 with several later modifications. (https://www.britannica.com/science/Koppen-climate-classification).

precipitation between the driest and wettest months. The average temperatures vary during the year by 43.9 °C. Based on 30 years of data, the predominant direction of wind in Darkhan is north and the average wind speed is 3.4 m/sec.

• Khovsgol province – Moron city: Moron is influenced by the local steppe climate. There is little rainfall throughout the year. According to Köppen and Geiger, this climate is classified as BSk. The average temperature in Moron is -0.9 °C. The rainfall here averages 230 mm. The driest month is January, with 1 mm of rainfall. The greatest amount of precipitation occurs in July, with an average of 69 mm. The warmest month of the year is July, with an average temperature of 16.8 °C. The lowest average temperatures in the year occur in January, when it is around -21.7 °C. The difference in precipitation between the driest month and the wettest month is 68 mm. The variation in temperatures throughout the year is 38.5 °C.

• Arkhangai province – Tsetserleg city: The climate is cold and temperate. In winter, there is much less rainfall in Tsetserleg than in summer. The climate here is classified as Dwc by the Köppen-Geiger system. In Tsetserleg, the average annual temperature is 0.5 °C. Precipitation here averages 336 mm. The driest month is January, with 2 mm of rain. With an average of 90 mm, the most precipitation falls in July. July is the warmest month of the year. The temperature in July averages 14.6 °C. January has the lowest average temperature of the year. It is -14.8 °C. There is a difference of 88 mm of precipitation between the driest and wettest months. During the year, the average temperatures vary by 29.4 °C. Prevailing wind direction is from north and west-north, maximum wind speed reaches up to 20-24m/s in March and April with the frequency of 74 percentage.

• Dundgobi province – Mandalgobi city: The climate here is "desert." During the year, there is virtually no rainfall in Mandalgobi. According to Köppen and Geiger, this climate is classified as BWk. The average annual temperature in Mandalgobi is 1.7 °C. The rainfall here averages 156 mm. The driest month is January, with 1 mm of rain. Most precipitation falls in August, with an average of 45 mm. July is the warmest month of the year. The temperature in July averages 19.2 °C. In January, the average temperature is -17.5 °C. It is the lowest average temperature of the whole year. There is a difference of 44 mm of precipitation between the driest and wettest months. The average temperatures vary during the year by 36.7 °C. Dundgobi is increasingly vulnerable to natural disasters in winter. This has been triggered by natural environmental changes such as drought and by socio- economic changes such as the transition to a market economy, which led to over-grazing.

• Khovd province – Khovd city: The northern part of Khovd province is located in a sheltered position (Tannu Ola Mountains north, Khangay Mountains east, Gobi Altai south, and Mongolian Altai west) that causes an extremely continental and dry climate supporting the maximum northern extent of desert vegetation up to the Uvs Nuur Basin. The climate here is classified as BWk by the Köppen-Geiger system. The Pacific monsoon effects can only be traced up to 110-120° E, without ever reaching the province territory of Khovd. The stable Siberian anticyclone causes long, cold, and dry winters with mean January temperatures of -22 °C. The climatic factors, relevant for plant growth. Summers are short and warm at mean July temperatures of 19 °C. About 70-90 % of annual precipitation occurs in summer, even though quantities may vary considerably over the years. For example, mean annual precipitation in the lowlands of northern desert steppe amounts to 135 mm, but only 78 mm occurred in 2002 as opposed to 223 mm in 2003 (Climate Station Khovd 1983-2004).

• Dornod province – Choibalsan city: Choibalsan is considered to have a desert climate, the climate here is divers, but predominately classified as BWk by the Köppen-Geiger system. There is virtually no rainfall all year long in the city. The average annual temperature in Choibalsan is 1.2 °C. About 132 mm of precipitation falls annually. The least amount of rainfall occurs in January. The average in this month is 2 mm. With an average of 31 mm, the most precipitation falls in July. The temperatures are highest on average in July, at around 20.5 °C. January has the lowest average temperature of the year. It is -19.9 °C. The variation in the precipitation between the driest and wettest months is 29 mm. During the year, the average temperatures vary by 40.4 °C. The eastern steppe region is the most windy place in Mongolia and annual mean wind speed is over 3.0 m/s, but within mountainous parts in the north, it varies from 2-3 m/s.

• Capital Ulaanbaatar city - Khan-uul district: Ulaanbaatar is the coldest national capital in the world, with temperatures ranging from approximately -30°C to +25°C (Köppen-Geiger classification: BSk). Ulaanbaatar is located at 1,350m altitude in the valley of four mountain ranges which rise to 1,650 to 1,949m altitude. Due to its location the city experiences many temperature inversions. At least 80% of these inversions occur from October to April when air temperatures are from 7.5 to 11.7°C and land temperatures are from minus 21°C to minus 39°C. Precipitation is highest in the north, including Ulaanbaatar (average of 200 to 350 mm per year) and lowest in the south, which receives 100 to 200 mm annually. In Ulaanbaatar, 95-97 percent of precipitation falls during the warm season, including 75-80 percent in the summer. In winter, the precipitation ranges from 1 to 3 mm, whereas in July it ranges from 100 to 120 mm. In average it rains 40-70 days a year, snow falls on 25-30 days, and land is covered with snow for 140-170 days. In Ulaanbaatar, wind blows mostly from the north and northwest and average wind velocities are usually lower than in other parts of Mongolia. Monthly wind velocities average 1.6 – 4.4 m/s, with an average of 7 to 9 days per year where wind velocities exceed 10 m/s.

C. Ecological and physical cultural resources within the project areas

1. Protected Areas and Endangered Species

94. The Integrated Water Management National Assessment Report mapped internationally and nationally protected sites including RAMSAR sites, national conservation parks, nature reserves, strictly protected areas and important monuments for all basin clusters.45 There are no legally protected sites of national or international importance in the vicinity of the project areas and no receptors. . The closest areas of potential relevance are discussed below.

• Darkhan city of Darkhan-uul aimag: Darkhan is one of three provinces in Mongolia which does not have any Specially Protected Areas (Strictly Protected Area, National Conservation Parks, Nature Reserves and Monuments). Locally however Darkhan-Uul aimag authorities have a local nature reserve status for two local areas of the Kharaa River: (i) Khongor soum, the east side of the river bank bagh 1,3; and (ii) Darkhan soum the east side of the river bank in bagh 2 and 3, 500 m from Ukhaa hoshuu river. Both are not in the vicinity of the project with a distance of more than 3 km.

• Arkhangai province – Tsetserleg city: The Bulgan mountain State Natural Monument is located in the north of the city. Ogii Nuur is a freshwater lake located in the valley of the

45 Footnote 40.

Orkhon River, some 100 km from Tsetserleg, comprising extensive alluvial areas of grassland, river channels, pools and marshes surrounded by grassy steppe. It was designated as RAMSAR site in 1998.

• Khovd province – Khovd city: There are several important protected areas in Khovd aimag but not in close vicinity of the project site with a distance of >50 km. This include: Bulgan Gol Natural Reserve (1840 hectares). On the south-western border with China, it was established to help preserve mink (beavers), sable and stone marten; Great Gobi Strictly Protected Area (also known as 'Gobi B'). Created to protect khulan (wild ass - Equus hemionus hemionus)), gazelles, jerboas and takhi (wild horses); Khar Us Nuur National Park (850,272 hectares). Protects the breeding grounds for antelopes and rare species of migratory pelicans, falcons and bustards; Khokh Serkh Strictly Protected Area (65,920 hectares). On the north-west border with Bayan Olgii. helps protect argali sheep, ibex and snow leopards; Mankhan Natural Reserve Directly. South-east of Khovd city, preserves an endangered species of antelop; Tsambagarav Uul National Park (110,960 hectares). Established in 2000, on the border with Bayan-Olgii. It protects the snow leopard habitat.

• Dornod province – Choibalsan city: Dornod is currently the base of a multi-million dollar environmental protection project in an attempt to protect one of the world's last undisturbed grasslands. Large Strictly Protected Areas (SPA) were established in the aimag in 1992: Dornod Mongol (570,374 hectares), Nomrog (Numrug Preserve) (311,205 hectares), Mongol Daguur (103,016 hectares). The Yakhi Lake National Park. This region was made into a preservation area in 1998 with the purpose of protecting the land through which white antelopes and aquatic birds pass; Ugtam Mountain National Park. The Ugtam Mountain region was made into a preservation area in 1993 with the purpose of protecting the natural environment and its flora and fauna; Toson Khulstai National Park. Surrounding Toson Khulstai Lake, this 4700 square kilometer area in Tsagaan-Ovoo, Khulunbuir and Bayantumen soums was made into a preservation area in 1998 as the main reserve for white antelopes. All protected areas are not in close vicinity of the project site with a distance of >50 km .

• Capital Ulaanbaatar city - Khan-uul district: No protected sites.

2. Flora and Fauna at project sites

95. The land cover of the aimags where the project cities are located was discussed above. The vast majority is pasture land or semi-desert land. Sheep-grazing is dominant, although the number of goats raised has increased due to the high prices for cashmere wool. Goats eat a wider range of plant species than sheep, forage more aggressively and consume the whole plant; this has contributed to degradation of the grasslands over a widespread area.

96. Flora & Fauna: In the framework of the general environmental impact assessments conducted for the proposed project, rapid vegetation surveys were conducted at all sites in May 2015, and documented in the Environmental Baseline Reports. The animal species potentially present in the project areas were assessed based on aimag level inventories, as well as field observations at the proposed sites. The results are documented in the Environmental Baseline Assessment Reports, which conclude that the habitats around the proposed sites are already greatly disturbed by human activities.

• Darkhan city of Darkhan Uul aimag: The area is located in the Mongolian steppe or Mongolian-Manchurian grassland. 59% of the Kharaa River basin area is characterized by

grasslands. These grasslands are mainly in the lower reaches of the river, in which Darkhan is located. As the altitude of the basin increases, the vegetation changes to mountain forest steppe zone in the middle reaches and boreal coniferous in the mountainous upper reaches. The flora is dominated by feathergrass (Stipa baicalensis, S. capillata, and S. grandis), Sheep Fescue (Festuca ovina), Aneurolepidium chinense, Filifolium sibiricuman, and Cleistogenes sqarrosa. World Wildlife Fund (WWF) confirms that the only endemic bird to use the grassland type habitat is the brown eared pheasant and one of the most significant mammals in the grassland is the Mongolian Gazelle (Procapra gutturosa). However the IUCN Red List confirms that the pheasant is only present in the grasslands of the People’s Republic of China and the range of Procapra gutturosa does not extend as far north as the grasslands around Darkhan. Although approximately 20 species of birds may use the area around the project site for roosting or transiting, none of the species are on the IUCN red list and those that are present, such as crows and sparrows, are familiar with habitats which have been degraded by human activities. Information on a number of rodents which are common in Mongolia, such as the house mouse (Mus musculus) and Mongolian gerbil (Meriones unguiculatus), however the study also concludes that the presence of these mammals cannot be confirmed, and that the habitat is already greatly disturbed by human activities. Therefore, any species present are likely to be those which tolerate disturbance and do not need a habitat with a high ecological value.

• Khovsgol province – Moron city: There are 35 different species of 31 different genus’s, 13 different families and 5 different orders of mammals inhabit in Khuvsgul aimag. For example, furbearers like fox, wolf, moose, bear, steppe fox, musk deer, boar, deer, antelope, sable and marmot. Also, two different species of amphibians, 4 different species of reptiles, 400 different species of insects in this region.10 different species of fish are found in various rivers and lakes of Khuvsgul aimag. For example gray taimen which is the biggest fish in Mongolia and sturgeon. According to vegetation classification the Moron city belongs to Needlegrass-herb, needlegrass-sedge-herb with participation of Spiraea, peashrub type of the Mountain meadow steppe group. The 35.4% are covered with forest. The 90% of the forest consists of larch with remaining 10% of pain, asp, cedar eats. The aimag is rich with various species of edible plants such as blueberries, blackberries, red berries huckleberries, and strawberries different kinds of mushrooms, wild onions and nuts.

• Arkhangai province – Tsetserleg city: Remotely located in high latitude forest areas to the north of project site, musk deer, shrew, chipmunk and wood mouse are common. Squirrel and boars occur normally. Lynx and roe-deer occur rarely. Common weasel, corsac, rabbit and wolves occur in river valleys, rocky places and patchy forest; most of birds are migratory and some are permanent and most common species include bobwhite, hazel grouse, great grouse, cuckoo, flicker, kite, magpie, carrion crow, night owl, wooper swan, bluecap, Euroasian Sparrowhawk, upland buzzard, northern goshawk, hoopoe. Reptiles Eremias argus (lizard), Elaphe doine, Gloydius halys (snakes), as well as amphibians Bufo raddeic and Rana amurensis occur in these areas. No rare and endangered species of reptiles and amphibians are found in the center. In Tsetserleg, vegetation coverage at the project site is strongly impacted by human activity. 31 species from 23 genres of 11 families were registered during the site survey which included Salsola pestifera, Artemisia macrocephala, Heteropappus hispidus, Taraxacum dissectum, Carex duriuscula, Poa attenuate, Dracocephalumcf foetidum, Panzeria lanata, Astragalus sp, Plantago depressa, Chamaerhodos erectah

• Dundgobi province – Mandalgobi city: In the steppe areas of Mongolia, there was a

dramatic decrease in the number of saker falcons, a species that is valuable in the world market and only can be legally exported from Mongolia under license. Dundgobi and Dornogovi provinces experienced near 100 percent falcon population loss. Vegetation type - Needlegrass-lymegrass-herb (50%) in combination with complex steppe (40%): needlegrass-Cleistogenes (70%), lymegrass-sedge (20%), alkaligrass-Suaeda (10%) and achnatherum-lymegrass (10%) of the Steppe and dry steppe in flat area group.

• Khovd province – Khovd city: The lowlands around the lakes up to an altitude of 1460 m a.s.l. belong to desert steppe that represents the drier sub-belt. Northern desert steppe is tied to higher altitudes between 1400 to 1700 m a.s.l., receives higher precipitation, and is characterised by Caragana and Krascheninnikovia shrubs and steppe grasses such as Cleistogenes squarrosa, Stipa glareosa, Agropyron cristatum and Stipa krylovii. While the desert steppe is considered as the transition from Eurasian steppe zone to Central Asian desert zone in southward direction, it is explicitly referred to as Central Asian desert zone. Their high proportion of xerophilous grasses in a composition with onion geophytes and shrubs, a peculiarity of Mongolia’s desert steppe zone represents one reason for this dispute. The sparse vegetation of desert steppe s. str. covers between 5 and 15 % of soil surface, comprising approximately 83 species of vascular plants and is dominated in foliar cover by perennial dwarf semishrubs (e.g. Anabasis brevifolia, Artemisia xerophytica, Asterothamnus heteropappoides), small bunchgrasses (Stipa glareosa, Cleistogenes songorica), and onion geophytes (Allium mongolicum, Allium polyrrhizum).In transition to the northern desert steppe or under specific site conditions of dry valleys or steep inclined slopes rich in gravel and debris, shrub communities of Caragana leucophloea and Krascheninnikovia ceratoides appear.

• Dornod province – Choibalsan city: Ten percent of the flora registered in Mongolia grow in Dornod, along with more than 40 kinds of herbs and 10 kinds of useful plants. There are also plants with various ether oils that are indigenous to Mongolia. These herbs and plants could be used by the pharmaceutical industry to make drugs to cure respiratory and inflammatory diseases, to revitalize skin and to protect against the sun’s rays. Deer, elk, raccoons, wild boars, otters and white antelopes live in the basins of the Ononand Uulz Rivers and in the Khyangan range. Marmots rather live in the steppe. In the basin of Onon, we also find bears, boars and muskrats, whereas wolves and foxes can be seen everywhere, more rarely lynx and squirrels.

• Capital Ulaanbaatar city - Khan-Uul district: In the proposing area, weeds are the predominant vegetation with a density of 30-60%. With urbanization in this area of both projects, wildlife fauna and flora have completely disappeared, and flora in this area includes only common types found in populated zones. There are no animals included in the Mongolian red book or included in CITES second attachment.

V. ALTERNATIVE ANALYSIS

97. Under ADB’s Safeguards Policy Statement (2009) there is a requirement to examine alternatives to the project’s location, design, technology, and components and their potential environmental and social impacts. During the project preparation, various alternatives were considered, screened, and studied against technical, economic, social, and environmental criteria. The primary objective with respect to environmental criteria was to identify and adopt options with the least adverse environmental impacts and maximum environmental benefits.

A. No Action Alternative

98. The “Without Project Alternative” or “No Action Alternative” addresses the likely consequences of not undertaking the proposed action. For this project, the failure to develop and improve the services for PWD and their families, a population subgroup whose poverty rates are more than twice as much those of others, will result in a continuation of lower human development indicators of PWDs and no additional PWD are expected to enter the labor market. Not providing early identification and improved services will have the result that 17,000 children and 62,000 adults will not benefit from these new services in the project target areas. Therefore, it can be determined that the “No Action Alternative” is not a reasonable option if the Law on the Rights of People with Disabilities (February 2016) shall be implemented and the life situation of PWD be improved.

B. Location Alternatives

99. Site selection: For the selection of possible sites, several aspects were taken into consideration which included the accessibility for PWD under consideration of low distance to minimize transportation emissions (connectivitiy), existing infrastructure including supply of heat and water, good sewage connection and electricity supply to avoid the setup of decentral solutions with typically higher environmental impact, legacy of pollution and the need for site preparation. Additionally the potential impact from construction and operation on existing neighbors were taken into consideration. For all 6 aimags different sites were analyzed. The final location for all six centers were carefully chosen based on aimags’ city master plans and the before mentioned criteria. For Ulaanbaatar city it was decided to set up the new center on the premise of the already existing DPO site.

• Darkhan city of Darkhan-uul aimag: For Darkhan, Site 2 was selected as it is situated in the western part of the constructed area of the city, connection to infrastructure (water, waste water, heating) will create low impact compare with Site 1. In the north lies the main road to the ger area. Further, behind the road, it is planned to be built new districts of the town. Possible impacts might arise from a fuel station, which however is about 120m away to the northwest.

Site 1

Site 2

Figure V.1: Location of selected and alternative sites in Darkhan city

• Khuvsgul province – Moron city: The site 4 was selected as in the right side a new school was constructed and necessary infrastructure can be linked directly from the school building. The area is flat, healthy, with no industries around. The bust stop in the north will ensure easy access and the site is close to other public services.

Site 1

Site 2

Site 3

Site 4

Figure V.2: Location of selected and alternative sites in Moron city

• Arkhangai province – Tsetserleg city: The selected site 4 was selected as it is located in the left side of the kindergarten 8, is close to the main road and the slope of the ground is minimal. In the north of the site a football ground and stadium for the naadam festival is located. Infrastructure (water supply, waste disposal and electricity) will be connected from the existing system of newly established kindergarten.

Site 4

Site 1

Site 3

Site 2

Figure V.3: Location of selected and alternative sites in Tsetserleg city

• Dundgobi province – Mandalgobi city: Site 4 was selected as it is located directly in the north of the newly constructed TVET center and the entrance of the building can be constructed to the main road. Necessary infrastructure exists and environmental impact is low.

Site 3

Site 4 Site 2

Site 1

Figure V.4: Location of selected and alternative sites in Mandalgobi city

• Khovd province – Khovd city: The site 3 was selected as the area belongs to the aimag social care and service division and is located in the western part of the center of Khovd city along the main road to the north. Necessary infrastructure is available, distances are short.

Site 3

Site 1

Site 2

Figure V.5: Location of selected and alternative sites in Khovd city

• Dornod province – Choibalsan city: The site 5 was selected as this will be easily accessible, infrastructure is available and minimal leveling of land will be required.

Site 1

Site 2 Site 3

Site 5

Site 4

Figure V.6: Location of selected and alternative sites in Choibalsan city

VI. ANTICIPATED IMPACTS AND MITIGATION MEASURES

100. Potential project impacts, both positive and negative, were assessed through impact screening, site visits, technical analysis, consultations with government agencies and local communities. Positive impacts will include the demonstration of “Green Building” principles based on LEED which will result in better livings conditions (e.g. indoor air-quality) for PWDs and reduced environmental impact during construction and operation compared with buildings not following the “Green Building” principles. The reduced environmental impacts will additionally results in lower operation costs of the buildings, especially in regard to heating, electricity and water consumption.

A. Impacts Associated with Project Location, Planning and Design

101. Impacts associated with the project locations and design focus on the following key areas:

i) Locations of the new building will be consistent with cities plans to minimize transportation needs and will not include environmental sensitive areas; ii) Resource-efficiency: Ensuring that the existing infrastructure, to the extent possible, are utilized and integrated to conserve resources; iii) Land acquisition and resettlement: The project is categorized as C for the involuntary resettlement (IR) safeguard as the project will not cause any direct or indirect, permanent or temporary land acquisition and resettlement (LAR) impacts. The construction of the buildings will be done on state owned vacant land.

102. Mitigation measures and actions during design and pre-construction. The mitigation of impacts from these design issues are as follows:

i) The locations of the new buildings have been carefully selected considering many key factors including the development of the cities, existing public services, central location to reduce transportation and close to recreational areas; ii) Careful planning of connections of new buildings to the existing infrastructure to reduce impact from the connection of the new buildings to the infrastructure.

103. Actions will be implemented in the pre-construction phase of the project implementation to ensure the project’s environment management readiness. These include:

i) Appointment of one environment specialist to coordinate project EMP implementation; ii) Including EMP requirements in tender and contract documents; iii) Establishing grievance redress mechanisms (GRM) on the basis of the GRM defined in Chapter VIII of the IEE; and iv) Pre-construction consultations with APs on construction timing and approach to the EMP consultation plan, consulting and informing residents and key stakeholders near the construction sites regarding construction timing and approach.

104. Before the construction starts, each civil works contractor will prepare a site EMP (SEMP) which shall fully respond to the requirements set in the project EMP, and shall include a number of sub-plans, including: (i) soil erosion control plan; (ii) borrow and spoil management plan; (iii) water protection plan;

(iv) health and safety risk management plan; (v) spill management plan; and (vi) waste management plan:

i) The soil erosion protection plan will identify likely areas of soil erosion and the mitigation measures which the contractor will employ to minimize potential erosion around any excavations and construction areas; ii) The borrow and spoil management plan will specify location of borrow pits, quarries and spoil disposal sites, as needed. Contractors will ensure that (a) borrow areas will be located away from residential areas, water bodies and will avoid valuable pasture/grazing land, (b) after use borrow pit areas will be graded to ensure drainage and visual uniformity, and (c) borrow pit restoration will follow the completion of works in full compliance with all applicable standards and specifications; iii) The water protection plan will include measures to be taken during construction to avoid/mitigate pollution arising from construction site drainage (silt), use of chemicals, and other potential pollution sources; iv) The health and safety risk management plan (HSMP): For management of occupational health and safety, the contractor will prepare a HSMP for the construction workers. v) The spill management plan will document the specific requirements, protocols, responsibilities, and materials necessary to implement an emergency spill response following an incident; and vi) The waste management plan for construction sites will provide procedures for management of household type waste, hazardous waste, and sewage (if appropriate). It will evaluate the type and quantities of waste, as well as detail arrangements for storage and transportation of the waste to its disposal point. It will include agreements with the aimag authorities for waste disposal and consideration of the Waste Hierarchy. It will include a schedule for disinfection of all waste collection and storage areas.

105. Utilities Provision. It is not anticipated that the project will disrupt utilities or any municipal services during construction.

B. Environmental Impact and Mitigation Measures during Construction

1. Impact on Physical Resources

106. Impacts on Soil Resources. Three types of potential impacts on soil are anticipated, including: (i) soil erosion; (ii) soil contamination; and (iii) inappropriate management of borrow.

i) Soil erosion: Excavation of borrow pits and stockpiles from earthworks during ground works for the buildings may cause soil erosion. The factors that are expected to contribute to accelerated erosion in the project area are any exposed soil during periods of rainfall from June to August. ii) Soil contamination: Localized contamination of soil in the construction phase may result from the inappropriate transfer, storage, and disposal of petroleum products, lubricants, chemicals, hazardous materials, liquids and solid waste. These impacts are particularly associated with construction site chemical storage, and during refueling of plant and equipment. iii) Borrow: Borrow will be needed to provide fill for ground works.

107. Mitigation of impacts on soil. The impacts on soil will be mitigated through a number of measures, which are specified in the EMP and will also be incorporated in the bid documents and construction contracts. A summary of the mitigation activities defined in the EMP is as follows:

i) Soil erosion: (a) implement a soil erosion management plan prepared by each contractor prior to the start of construction which will be reviewed and approved by the PIU; (b) minimizing the area of soil clearance; (c) maintaining slope stability at cut faces by implementing erosion protection measures; (d) control silt runoff from construction sites; (e) cover soil stockpiles; and (f) properly stabilize slopes and re-vegetate disturbed surfaces. ii) Soil contamination: (a) store chemicals/hazardous products and waste on impermeable surfaces in secure, covered areas with clear labeling of containers and with a tray or bund to contain leaks; (b) regularly remove all construction wastes from the sites to approved waste disposal sites; (c) establish emergency preparedness and response plan (Spill Management Plan); (d) provide spill cleanup measures and equipment at each construction site; and (e) conduct training in emergency spill response procedures. iii) Borrow: (a) Develop and implement borrow management plan, specifying location of borrow pit; (b) ensure that borrow areas are located away from residential areas, water bodies and valuable pasture/grazing land; (c) after use, grade borrow areas to ensure drainage and visual uniformity, and (d) borrow pit restoration must follow the completion of works in full compliance with all applicable standards and specifications.

108. Impact on air quality. Moderate temporary air quality impacts during the construction stage of the project could be anticipated because of fugitive dust generation at construction sites. Minor increases in the level of nitrogen oxides (NOx) and sulfur oxides (SOx) from construction plants and machinery are expected. Air quality impacts during construction are likely to result from the following sources:

i) Emissions from construction machinery and equipment, movement of haulage trucks to all construction sites; ii) Fugitive dust from excavation activities; iii) Fugitive dust from earthworks such as establishment and use of borrow pits, and back- filling activities; iv) Fugitive dust and odor from concrete batching plants; and v) Dust created by strong wind from unprotected surfaces.

109. The key receptors for air quality impacts are people and livestock, who would need to be near the construction works before an impact will occur as the impacts will be localized.

110. Mitigation of impacts to air quality. The mitigation measures to minimize fugitive dust impacts are as follows:

i) Stockpiles management. Temporary stockpiles will be protected to reduce dust emissions. If a stockpile is within 150m of human receptors, additional precautions must be taken including using a reusable stockpile cover to prevent wind lifting and dispersing. ii) Construction site management: Water will be sprayed on construction sites and material handling routes where fugitive dust is generated, especially during strong windy days.

iii) Transport of materials: Trucks carrying earth, sand, stone or other loose materials will be covered with tarpaulins or other suitable cover. Construction vehicles and machinery will be maintained to a high standard to minimize emissions (note that local standards do not exist for vehicle emissions).

111. Noise. The major sources of noise pollution near the project area are the removal and replacement of existing surface materials during earthwork. Other noise sources will include the general movement of construction vehicles, concrete-mixing equipment, rollers during re-surfacing, and the use of generators. Construction activities are expected to produce noise levels up to 90 dB(A) within 5m of the construction machinery as shown in Table VI-1. At the proposed building sites, no human receptors other than construction workers will be this close to the machinery, and construction workers will use appropriate Personal Protective Equipment (PPE).

Table VI-1: Construction Machinery Noise Levels (dB(A))

Distance to Machinery Machine Type 5 m 10 m 20 m 40 m 60 m 80 m 100 m 150 m 200 m 300 m Loader 90 84 78 72 68.5 66 64 60.5 58 54.5 Vibratory Road Roller 86 80 74 68 64.5 62 60 56.5 54 50.5 Bulldozer 86 80 74 68 64.5 62 60 56.5 54 50.5 Land Scraper 90 84 78 72 68.5 66 64 60.5 58 54.5 Excavator 84 78 72 66 62.5 60 58 54.5 52 48.8 Roller 87 81 75 69 65.5 63 61 57.5 55 51.5 Mixing Equipment 87 81 75 69 65.5 63 61 57.5 55 51.5 Source: U.S. Federal Highway Administration

112. Construction noise mitigation. Noise will be mitigated through a number of activities defined in the EMP, which will be incorporated in the bid documents and construction contracts:

i) Source control: Maintain all exhaust systems in good working order; undertake regular equipment maintenance; ii) Locate sites for concrete-mixing and similar activities at least 300 m away from noise sensitive areas; iii) Operate high-noise activities between 8am-6pm only and reach an agreement with nearby businesses and residents regarding the timing of heavy machinery work, to avoid any unnecessary disturbances; iv) Provide advance warning to businesses and residents on timing of noisy activities. Seek suggestions from community members to reduce noise annoyance; v) Vehicles transporting construction materials or wastes will comply with posted speed limits at all times and will be limited to low speeds in construction sites; vi) Vehicles transporting construction materials or wastes will not use their horn when passing through or nearby sensitive locations, such as residential communities, schools and health care facilities; vii) Public notification of construction operations will incorporate noise considerations and

reference to the grievance redress mechanism; and viii) Ensure noise monitoring is undertaken at construction site boundaries and near sensitive receptors, in compliance with the monitoring plan.

113. Impacts to surface water quality. Construction activities might have the potential to cause significant short and long term impacts to surface and groundwater through stormwater runoff and erosion, accidental spills of hazardous materials, inappropriate disposal of domestic wastewater generated on site or at worker camps, inappropriate disposal of construction wastewater from drainage of excavation and drilling, washing aggregates, washing construction equipment and vehicles, oil- containing wastewater from machinery repairs, and poor waste management.

114. Impacts to groundwater quality. Construction activities identified above also have the potential to contaminate groundwater if accidental spills occur in areas of high water table. The water tables at the project sites is low, the soil layers, in general, will act as natural filtration system to clean any contaminated water and it should be clean by the time it reaches the aquifer..

115. Mitigation of impacts on surface water and groundwater. The potential adverse impacts on surface and groundwater will be mitigated through a number of measures defined in the EMP, and which will be incorporated in the bid documents and construction contracts:

i) Contractors will implement the approved soil erosion management plans (as specified in soil mitigation measures section above) during construction; ii) Contractors will be required to develop and implement contingency plans for control of spills of oil and other hazardous substances (Spill Management Plan) as part of the SEMP; iii) Adequate construction site temporary sanitary facilities with holding tanks will be provided for construction workers. Toilets will discharge to the existing wastewater treatment facilities; iv) Temporary drainage provision will be provided during construction to ensure that any storm water runoff from construction areas will be controlled; v) Enclosed drainage around chemical and fuel storage areas on construction sites and storage will be on hard standing; and vi) Groundwater quality will be monitored at existing boreholes and wells prior to and during project construction.

116. Flooding. A slight risks for flooding exists for the Ulaanbaatar site, the consultant desing engineer and the contractor will include necessary measures to minimize risks of potentials impacts for the building during floodings. There is the potential for rainfall or flash flooding to disrupt construction, especially for the construction site in Ulaanbaatar as it is on the bank of the river. To mitigate the risk of flood impacts during construction:

i) All works undertaken on Ulaanbaatar construction site will be timed to avoid the typical summer rainfall floods; and

ii) Rainfall forecasts will be monitored and work halted in the event that there is a flood risk.

117. Waste management and resource use. Minimizing waste conserves valuable natural resources. Disposal of construction wastes could have adverse impacts on soil, water and health of

contractors and the community. Waste streams will include inert construction wastes (e.g. soil, spoil, debris, concrete) and municipal type wastes (construction workers’ food and packaging wastes from construction consumables). Hazardous waste may include fuel containers, oil filters, oily rags.

118. Mitigation of impacts from solid waste and resource use. The potential impacts arising from solid and liquid waste production and disposal will be mitigated through a number of activities defined in the EMP, and which will be incorporated in the bid documents and construction contracts:

i) Waste hierarchy: Construction will be subject to the waste hierarchy to ensure efficient use and management of resources. (a) Prevention: The preference is for prevention of waste at source. This means the effective management of materials on site through good house-keeping and work planning, in order to generate less waste. Procurement options will play a role in waste prevention as the procurement of materials which have less packaging for example, would be preferable. (b) Waste minimization: waste reuse or recycling options will be considered prior to disposal; separate containers for recyclables will be used if there is a market for the materials. (c) Disposal: waste which cannot be reused or recycled shall be disposed at sites authorized by the aimag authorities; ii) Storage and containment: Provide appropriate waste storage containers for worker’s construction wastes; install enclosed storage points of solid and liquid wastes away from sensitive receptors, regularly haul to approved disposal facilities; iii) Use of contractors: Only contractors approved by the aimag authorities will be used to remove all wastes from construction sites; iv) General waste management: It’s strictly prohibited to burn any waste at any construction site. Waste must be collected and properly disposed according to the EMP.

2. Impact on Biological and Physical Cultural Resources

119. Flora and fauna. The potential impact of construction activities on biological resources is anticipated to be minimal as the environmental baseline assessment confirmed absence of critical habitats or protected species within the seven sites. The measures defined under “mitigation of impacts on soil” and “mitigation of impacts on surface and groundwater” will effectively protect ecological resources during construction activities.

120. Physical Cultural Resources. The environment baseline assessments for the seven sites confirmed that there is no physical cultural resource (PCR) of local, regional or national importance within one kilometer of the proposed sites. However, construction activities have the potential to disturb as yet unknown underground cultural relics. To address this issue:

i) construction activities will be immediately suspended if any PCRs are encountered; ii) destroying, damaging, defacing, or concealing PCRs will be strictly prohibited in accordance with Mongolian regulations; iii) the local Cultural Heritage Bureau will be promptly informed and consulted; and, iv) construction activities will resume only after thorough investigation and with the permission of the local Cultural Heritage Bureau.

3. Impact on Socio-economic Resources

121. Community health and safety. Health and safety risks to communities include noise, dust,

construction site safety, traffic safety. Dust and noise control mitigation measures have been discussed earlier. Other health and safety risks are discussed below.

122. Issues relating to community health and safety can be mitigated as follows:

i) Temporary traffic management and road safety awareness: During any works which involve crossing roads and affecting traffic movements, residents and business entities will be made aware of changes to traffic flows through clear signage in advance of construction and during construction at the site; ii) Construction site safety: Clear signs will be placed at construction sites in view of the public, warning people of potential dangers such as moving vehicles, hazardous materials and excavation and raising awareness on safety issues. Heavy machinery will not be used after day light and all such equipment will be returned to its overnight storage area/position before night. All sites will be made secure, discouraging access by the public through fencing or security personnel, whenever appropriate.

123. Occupational Health and Safety. Construction may cause physical hazards to workers from noise and vibration, dust, handling heavy materials and equipment, falling objects, work on slippery surfaces, fire hazards, chemical hazards such as toxic fumes and vapors, and others. The civil works contractors will implement adequate precautions to protect the health and safety of construction workers. The occupational health and safety risks will be managed by applying measures in the following order of preference: avoiding, controlling, minimizing hazards, and providing adequate protective equipment. Contractors will develop, as part of their SEMP, a Health and Safety Management Plan (HSMP), as well as to ensure that the requirements of the EMP are implemented. Each contractor will designate one responsible person for the implementation of the HSMP. The HSMP shall include at the least the following provisions:

i) Training. Provide adequate training to all workers, temporary or permanent workers, on occupational health and safety risks at construction sites, proper working procedures, proper use of PPEs, consequence of not following safety procedures, handling and disposal of hazardous wastes, incident reporting requirements, etc.; ii) Clean water. Provide a clean and sufficient supply of fresh water, for construction and for all houses, camps, offices, laboratories and workshops; iii) Sewage and wastewater. Provide adequate sanitation facilities at all work sites; iv) Solid waste. Provide garbage receptacles at all construction sites, which will be periodically cleared and disinfected; v) Personal protection. Provide PPE, such as safety boots, helmets, gloves, protective clothing, goggles, and ear protection device, in accordance with relevant health and safety regulations, for workers; vi) Emergency Preparedness and Response. An emergency response plan to take actions on accidents and emergencies, including public health emergencies associated with hazardous material spills and similar events will be prepared; vii) Safety communication. Ensure that safety, rescue and health matters are given a high degree of publicity to all persons regularly or occasionally at active construction sites. Posters in Mongolian and any other language appropriate for the contractors drawing attention to relevant occupational health regulations will be made or obtained from the appropriate sources and will be displayed prominently at construction sites.

C. Environmental Impact and Mitigation Measures during Operation

124. No significant negative environmental impact is anticipated during operation of the buildings. All new buildings will be connected to centralized electricity, heating, drinking water as well as waste water system. Contracts will be made with related organizations on supply of electricity, heating, drinking water, waste water as well as for solid waste management collection. The separation and recycling of valuable waste will be supported. The buildings will be designed under consideration of the LEEDs principles which will result in a high resource efficiency and low environmental impact. The detailed planned measures to be implemented can be found in the EMP (Overview LEEDs requirements integrated into the sites).

125. Most potentially adverse operational impacts will be mitigated through sound facility design. All buildings will be designed in compliance with relevant GOM’s design standards and codes for energy- efficient, safe buildings, including the Mongolian National Standard (MNS) 3838: 2008 and the Construction Norms and Rules, for Urban Planning and Construction (30.01.03) and on Heating, Air Exchange and Conditioning (41.01.11). Recommendations for green building provided by the United States Green Building Council’s Leadership in Energy and Environmental Design (LEED) will be observed. Included in the TOR of the engineering firm for detailed design will be the LEEDs requirements. Specifically it will include:

i) Erosion and dust control from the site by planting plants; ii) Ensuring the availability of alternative transportation including access to public transportation and provision of parking space for prams: iii) Stormwater Management by rainwater harvesting from at least 50% of the sealed surface; iv) Energy efficient Exterior design to reduce heat and cold islands; v) Water efficient landscaping and water use reduction by installing of water saving equipment such as double flush toilets; vi) CFC reduction in HVAC&R equipment; vii) Provision of storage space for the collection of recyclables; viii) Strengthening the usage of local/regional Materials; ix) Requesting the usage of certified wood for construction materials; x) Environmental Tobacco Smoke (ETS) Control; xi) Usage of low-VOC emitting materials; xii) Daylight & views, ensuring daylight in most spaces; xiii) Setting up of solar panels with a capacity of not less than 5 kW for the Aimag development centers and 10 kW for the DPO building.

126. Energy and resource efficiency measures: The conceptual design of project facilities has considered water conservation measures such as selecting water conservation materials, devices and equipment for the piping and the toilets. The heating provision and the electricity consumption will be the major sources of energy consumption. Energy efficiency measures will aim to improve the efficiency in heating provision and electricity consumption. The conceptual design has defined a set of measures to ensure energy and resource-efficiency of project facilities. These requirements, defined below, will be included in the technical specifications for detailed design of buildings.

A. building design

- The building location and alignment should be well selected to benefit from solar heating and to reduce heat loss; - The building layout should be well considered to maximize the utilization of the sunlight and natural ventilation available; - The building design must follow the Mongolian building standard 91.040 (comprehensive package of the standards related to construction) as well as the standards 91.140.99; 91.140.60; 91.140.80, MNS 3838 : 1985 (see also attachment 3).

B. Electricity design

- Install photovoltaic system on rooftop of each facility with a capacity of not less than 5 kW for the Aimag development centers and 10 kW for the DPO building; - Select equipment and devices with low energy consumption and high power coefficient/factors; - Adopt appropriate lighting standards for different functional areas; - Select energy saving lighting devices; and optimize the lighting control.

C. Heating and ventilation design

- Optimize ventilation system by maximizing natural ventilation usage; - Select higher grade material to improve the heat insulation; - Optimize the heating system to improve the heat exchange efficiency and to reduce unnecessary heat loss; - Establish a regular inspection mechanism of the heating and ventilation system.

D. Water and Drainage design

- Adopt appropriate piping material to reduce water leakage and water head loss; - Promote rainwater harvesting through the provision of a rainwater collection system of not less than 50% of the sealed area and an underground tank for the partly supply of the outdoor irrigation system; - Adopt water conservation devices such as water taps and toilets.

By this the project will contribute to target 8 (Preserve ecological balance and to be placed among first 30 countries on the rankings of the countries by the Green economy index in the world) of “Mongolia’s Sustainable Development Vision – 2030”

D. Cumulative, Indirect Impacts

127. Potential negative cumulative impacts could arise from other projects in the vicinities particularly other construction projects near the buildings. At the time of this IEE, no information was available on planned construction works from other projects that could overlap with the construction stage of this project. Should such other construction projects occur during the project implementation, construction related cumulative impacts can be effectively minimized by adopting proper mitigation measures, including:

i) coordination with other projects in the area of influence in terms of construction schedule, possible access road and borrow/disposal sites and spoil sharing; ii) contractors will develop material transport plan with consultation of local road management authority and local community; iii) enforcement of good construction management to minimize dust, noise and waste generation; iv) education of construction workers to minimize social disturbance and cultural conflict; and v) proper management of each construction site and timely restoration/strengthening affected areas upon completion of each construction project.

128. With effective implementation of good construction management measures, these common construction-related cumulative impacts can be adequately mitigated to acceptable levels.

129. Temporary traffic disturbance. When the buildings are constructed, traffic may be temporarily interrupted or disturbed. The interruption will be short term. Contractors will consult with relevant aimag authorities on the timing of the road excavation, including departments responsible for transport and traffic police.

E. Climate risk, adaptation to climate variability and change

130. The project’s vulnerability to climate variability and change is low. Global climate models predict that annual precipitation will generally increase in Mongolia, with winters predicted to become milder and snowier. This could in principle represent an increased risk of snow loading, which could impact on the structural integrity of the centers. However, the relatively low levels of precipitation from November to March mean that snow cover is not significant in winter. Project sites in the Aimags have been selected to ensure that the centers are not located within flood prone areas.

F. Seismic risks

131. Mongolia is a seismically active region and main seismicity is caused by active continental deformation in the India-Asia collision zone. Last century, strong continental seismic events took place in 1905 and 1957. Due to these strong seismic events, Bulnay and Bogd faults were formed. Potential risks for the planned six mainly single-storey buildings in the Aimags can be considered as low. On September 24 in 1998, an earthquake of Mw = 5.3 at 190 km from Ulaanbaatar has been felt in the city. Moreover, some quaternary fault scarps were recognized at a distance of 40 to 200 km from the capital. It is estimated that they could produce magnitude 6.5 to 7 earthquakes and may cause damage in the city. The detailed design engineering firm, who will design the 6-storey Business Incubator Center for DPO in UB, will further assess and address the seismic risks.

VII. INFORMATION DISCLOSURE AND PUBLIC CONSULTATIONS

A. Information Disclosure and Consultation during Project Preparation

132. Consultation with Government Officers and Experts. During preparation of the environmental baseline report for this IEE, individual consultation meetings were held with experts and Government officers during 5 – 9 and 13 – 15 of May, 2016 in order to discuss the project, obtain baseline data, and identify potential environmental impacts and concerns:

(1) Consultation with aimag governor’s office teams: (i) joint field visits to project sites; (ii) provision of data on aspects of wastewater treatment; (iii) current and planned activities; and (iv) environmental supervision and monitoring.

(2) Consultation with aimag environmental protection authorities: (i) provision of information on protected areas, waste management; (ii) siting of proposed buildings.

Example of consultation with local authorities: Joint site vist Example of joint site vist with local authorities: Meeting with with Choibalsan officers, May 2016 officers fromTsetserleg city, May 2016 Figure VII-1: Consultation with local authorities. Source: PPTA Consultant

133. Public consultation and information dissemination (15 – 25 of September, 2016). Consultation took place on environmental safeguard issues in project selected areas to (i) inform the stakeholders on (a) Project aim and design, proposed construction specifics; (b) anticipated impacts arising from the project construction; (c) proposed measures to avoid and mitigate them; (d) grievance redress mechanism (GRM). The public consultation was further used to (ii) solicit stakeholders’ concerns, opinions & comments for the proper consideration in the IEE and EMP and to (iii) document all meeting procedure and conduct questionnaire survey among local people living close to the site. Public meetings for local citizens were conducted to present (a) the project design, (b) the proposed local DPO building, (c) ADB’s safeguard compliance system, (d) related Mongolian legislation on environmental protection and (e) potential environmental impacts and the mitigation plan

134. In total, 227 people participated in the formal meetings. In addition, several informal interviews were conducted with potentially affected people during site visits. Figure VII-2 shows public consultant being undertaken with local residents. The detailed public consultation report is provided in the appendix.

Public consultation meeting with local residents in Arkhangai, Public consultation meeting with local residents in Dornod, September 2016. September 2016.

Stakeholder meeting, discussion of the project, Dundgobi, Public consultation meeting with local residents in Khovd, September 2016. September 2016.

Beneficiary participating in the public consultation meeting with Public consultation meeting with local residents in Ulaanbaatar, local residents in Khuvsgul, September 2016. September 2016.

Figure VII-2: Public consultation meetings. Source: PPTA consultant

135. Findings of the consultation process. The meetings highlighted that most of the residents fully support the construction of the new service centers at the proposed locations (239 local people out of 277 agreed to execute the project and construct the building). Concerns were expressed on the quality of the construction and on the duration of the construction. Where appropriate, the

recommendations provided during the consultation meetings were integrated into the mitigation measures in this IEE. In general the project is supported by residents as it will tackle a number of issues which are a concern to them. All questions and items raised during the consultations were discussed and explained in detail by the consultant. A sample list of raised concerns and the provided answers are provided in the following:

Qustion: Did the project address the request for the set the date for preparing PWD specialists?

Answer: It was explained that the exact timing/schedule will be clear after approval of the project. Moreover, the entity, who will responsible for running the center will need capacity building strategy based on center's need.

Question: Tsetserleg city - request for the construction to start at the beginning of the kindergarten break?

Answer: It was explained that noise level have to be in the limits, which will be required in the procurement document in detail. Because the construction planned to be started in the spring doesn't mean that the time for construction will start after the break of kindergarten.

Question: Mandalgovi city - request to plant trees and grass around the site?

Answer: It was explained that the construction will follow state standards, where green zone required to be no less than 20-25% of the site area.

Question: Khovd city - request to cooperate with state hospitals?

Answer: The issue is under responsibility of the Ministry. However, the project team agreed to need of special regulation in terms of these centers.

B. Future Public Consultation and Information Disclosure

136. During project implementation, affected people will be consulted and informed through formal questionnaire surveys, site visits and informal interviews. Public meetings will be organized prior to midterm mission to present and discuss EMP implementation progress, solicit community opinions and concerns, and agree on required corrective actions..

137. In compliance with the SPS, environmental information related to the project will be disclosed as follows:

(1) the initial environmental examination (IEE) is disclosed on ADB’s project website (www.adb.org), and is available for consultation in the PIU’s office; (2) the generic environmental impact assessments (GEIAs) approved by (MEGDT) is disclosed on the MEGDT website; and (3) annual environment monitoring reports will be disclosed on www.adb.org and at all site offices.

VIII. GRIEVANCE REDRESS MECHANISM

A. Introduction

138. A project grievance can be defined as an actual or perceived project related problem that gives ground for complaint by an affected person (AP). During the preparation stage of the project, APs were encouraged to provide comments on the domestic GEIAs and EMP. As a general policy, the PIU will work proactively toward preventing grievances through the implementation of impact mitigation measures and community liaison activities that anticipate and address potential issues before they become grievances. In addition, as the project has strong public support and will not involve any involuntary land or property acquisition or resettlement, significant grievance are unlikely. Nonetheless, during construction and operation stages it is possible that unanticipated impacts may occur if the mitigation measures are not properly implemented, or unforeseen issues arise. In order to address complaints if or when they arise, a project grievance redress mechanism (GRM) will be established in each city in accordance with ADB requirements and GoM practices.

139. A GRM is a systematic process for receiving, recording, evaluating and addressing AP’s project- related grievances transparently and in a reasonable period of time. The project GRM includes a procedure for receiving grievances, recording/documenting key information, and evaluating and responding to the complainants in a reasonable period of time. Any concerns raised through the GRM will need to be addressed promptly and transparently. The GRM will be accessible to diverse members of the local communities, including more vulnerable groups such as women, youth and elderly. Multiple points of entry, including face-to-face meetings, written complaints, telephone calls, or e-mail, will be available. Opportunities for confidentiality and privacy for complainants will be honored where requested.

B. Proposed Grievance Redress System

140. The proposed GRM follows the existing approach taken for managing complaints about local issues by members of the public in Mongolia. Residents' complaints or concerns are generally taken to bagh or soum representatives for resolution, therefore this system is proposed for the GRM.

141. Each Aimag will assign one staff prior to construction to establish a Project Complaint Unit (PCU) to deal with complaints from affected people (AP) throughout implementation of the project. The PCU will be the key contact point for bagh and soum representatives who may require information about the project or who have an issue they would like to discuss. The PCU’s phone number, fax, address, email address will be disseminated to the people at the bagh and soum levels by the bagh or soum representatives (reverse information distribution system, based on the residents complain system) at the beginning of the project. The PCU will maintain a complaints database and communicate with contractors, supervision engineers, the environmental inspectors of the State Professional Inspection Agency (SFIA), aimag environmental authorities, the PIU, and representatives of affected baghs. Prior the start of the project, a list of the responsible persons and their contact details will be set up for each sector.

C. GRM Steps and Timeframe

142. Procedures and timeframes for the grievance redress process are as follows and shown in Figure VIII-1. The GRMs will remain accessible throughout project implementation stage until a Project Completion Report is issued.

(1) Stage 1: Access to GRM. If a concern arises, the AP may resolve the issue of concern directly with the contractor, or make his/her complaint known to either the PCU directly, or through the bagh or soum, whichever level of authority he/she is most comfortable with;

(2) Stage 2: Official Complaint to PCU. If a complaint is filed at bagh/soum level, the bagh/soum representative will submit an oral or written complaint to the PCU. For an oral complaint the PCU must make a written record. For each complaint, the PCU must assess its eligibility. If the complaint is not eligible, e.g. related to an issue outside the scope of the project, PCU will provide a clear reply within five working days to the AP;

(3) Stage 3: PCU Complaint Resolution. The PCU will register the eligible complaint informing the PIU, the contractor, the PIU and ADB. The PCU, with support of the Environment Specialist (ES), will take steps to investigate and resolve the issue. This may involve instructing the contractor to take corrective actions. Within seven days of the redress solution being agreed upon, the contractor should implement the redress solution and convey the outcome to the PCU;

(4) Stage 4: Stakeholder Meeting. If no solution can be identified by the PCU or if the AP is not satisfied with the suggested solution under Stage 3, within 20 days the PCU will organize a multi-stakeholder meeting under the auspices of the head of the concerned soum, where all relevant stakeholders will be invited. The meeting should result in a solution acceptable to all, and identify responsibilities and an action plan. The contractor should implement the agreed redress solution and convey the outcome to the PCU within seven working days;

143. Stage 5: Aimag Governor Resolution. If the multi-stakeholder meeting cannot resolve the problem, and the AP is unsatisfied, the PCU will set up a meeting with the relevant aimag Governor to identify a solution.Reporting. The PCU will record the complaint, investigation, and subsequent actions and results. The PIU will include this information in the quarterly progress reports to the PSC. In the construction period and the initial operational period until project completion report, the EA will periodically report complaints and their resolution to ADB in the quarterly project progress reports and annual environmental monitoring reports.

144. Responsibilities of the PCU. The responsibilities of the PCU are as follows:

• The PCU will instruct contractors and construction supervisors to refer any complaints that they have received directly to the PCU. Similarly, the PCU will coordinate with local government departments to capture complaints made directly to them; • The PCU will log complaints and date of receipt onto a complaints database and inform the PUSO and the Contractor; • The PCU will investigate the complaint to determine its validity and to assess whether the source of the problem is because of project activities, and identify appropriate corrective measures and responsible persons; • The PCU will inform the AP of investigation results and the action taken; • If a complaint is transferred from local government agencies, the PCU will submit an interim report to local government agencies on status of the complaint investigation and follow-up action within the time frame assigned by the above agencies; • The PCU will review the contractor’s response to the identified corrective measures, and the updated situation; • The PCU will undertake additional monitoring, as necessary, to verify as well as review

that any valid reason for complaint does not reoccur.

145. Multi-stakeholder meetings. The invitees to this meeting will depend on the nature of the complaint. For example if the complaints relate to health, land disputes, or labor issues, the appropriate specialist in this field will be invited to the stakeholder meeting. This may include officers from the Land Administration (land rights issues), Women's Union NGO (gender issues), Health authorities (health issues), aimag environment protection authorities, aimag Professional Inspection Agency (occupational and community safety as well as environmental issues); and the Ministry of Labor & Social Security Officer (labor issues).

Stage 1: GRM Access Point AP contact contractor, PCU directly or via Bagh/ Soum) Day 1 of Complaint

Stage 2: Complaint to PCU Bagh/Soum meets PCU within 3 days of Complaint Date

No PCU Decision: Is the complaint eligible? PCU Explains to AP

Yes

Stage 3: PCU Complaint Resolution PCU Registers Eligible Complaint, informs the PIU, contractor, ES, PSC, ADB Respond to AP & talk to Yes Contactor within 10 days of Can PCU solve the problem? Complaint Date Implement solution within 15 No days of Complaint Date Stage 4: Stakeholder Meeting Within 20 days of ComplaintNo Date

Yes Solution Action Plan. Initiate Can Stakeholder Meeting solve the problem? Implementation of Action Plan within 7 days of Meeting Date No

Stage 5: Aimag Governor Refer to Governor for resolution

Solution Action Plan. Initiate Implementation of Action Plan within 7 days of Governor's Resolution

Figure VIII-1: Proposed Project GRM

IX. ENVIRONMENTAL MANAGEMENT PLAN

146. The environmental management plan (EMP) for the project is presented in Appendix 1. The EMP defines the roles and responsibilities of the institutions involved in EMP implementation. Such institutions will seek to ensure continuous improvement of environmental protection activities during preconstruction, construction, and operation of the project in order to prevent, reduce, or mitigate adverse impacts.

147. The EMP has been prepared in line with ADB’s Safeguards Policy Statement (2009). Specific measures are developed in relation to the design, construction and operation of each project output, and the impacts identified in relation to physical, biological, cultural and socio-economic resources, as discussed in Section VI of this IEE.

X. CONCLUSIONS

148. Benefits. The geographical focus of the project will be on Ulaanbaatar and six aimags (Arkhangai, Darkhan-uul, Dornod, Dundgobi, Khovd, and Khuvsgul). New services will be created in the aimag centers and outreach services will be provided to CWD and PWD in the soums and khoroos. Some project activities focusing on strategic issues will have national reach. The project will directly benefit PWD and their families, a population subgroup whose poverty rates are more than twice as much those of others: 42% versus 18%. Employment to population rate for 15-59 year old PWDs is only 28%, compared with 69% for the rest of the population. In general PWD have significantly lower human development indicators than others: 53% of 6-18 year old CWDs are unable to read, as compared with 4% for other children. Almost 100,000 PWD could benefit from improved employment services and by the end of the project at least 5,000 more PWD are expected to enter the labor market than in 2014. Social welfare reforms should result in better services being provided to all PWDs and their families, covering indirectly more than 400,000 people. Some of the project activities, including early identification and improved services, will focus on target regions that cover more than 50% of PWD living in poverty and have been identified to maximize coverage of PWD especially those living in poverty. It is expected that 17,000 children and 62,000 adults will benefit from these new services in the project target areas.

149. Adverse environmental impacts. Findings of the IEE show that the project does not have any predicted significant, long term or irreversible impacts on the physical, biological or socio-economic environment of the four project cities.

150. During construction, the project will have short-term impacts which can be mitigated to an acceptable level through mitigation measures which seek to reduce the potential for harm to the environment and human health. Dust and noise generated by construction activities are expected to impact local residents and business as they are not within the project area of influence. Waste arising is an inevitable consequence of construction activities. In order to manage this sustainably and with least risk to the environment and human health, a Waste Management Plan will be developed and adhered to by the contractor. Surface water quality and effluent quality will be monitored regularly throughout the construction phase.

151. During operation, no significant adverse environmental impact is anticipated. Comprehensive measures to reduce the environmental impact from the operation of the new buildings will be implemented. All buildings will meet relevant health and safety standards, adhere to universal design principles, and incorporate energy-efficiency measures.46 Water, wastewater and solid waste services will be connected to existing municipal services.

152. Environment management plan (EMP). An EMP has been defined which specifies the roles and responsibilities of key project stakeholders, including MLSP, PIU, the PSC, the aimag Professional Inspection Agencies, the Detailed Design Engineering Firm, contractors, and the Environment Specialist, in overall environmental management. In order to ensure that adequate environmental management capacities are in place during project implementation, the PIU will procure the services of ES to provide support in (i) project preparation including updating the project EMP; (ii) training; (iii) regular environmental quality monitoring in compliance with the monitoring plan; (iv) annual project EMP progress reporting; and (v) identifying environment-related implementation issues and necessary corrective actions.

46 All buildings will be equipped with rooftop photovoltaic systems.

153. Consultation. The stakeholder consultation process conducted during the development of this IEE, particularly with aimag representatives and PUSOs, demonstrated that the AF project has strong local support. In the framework of the DEIAs, more than 400 people were consulted through questionnaire surveys, focus group discussions and public meetings. Citizens are overwhelmingly support the AF project.

154. Information disclosure, GRM. In compliance with ADB’s Safeguard Policy Statement (2009), environmental information related to the AF project will be disclosed as follows: (i) this initial environmental examination (IEE) is disclosed on ADB’s project website (www.adb.org), and will be available in the aimag’s and PIU’s office; (ii) the general environmental impact assessments (GEIAs) approved by the Ministry of Environment, Green Development, and Tourism (MEGDT) are available from the PIU’s office; and (iii) annual reports on project’s compliance with the EMP will be available at www.adb.org. Environment safeguards related complaints or disputes will be handled in accordance with the grievance redress mechanism (GRM) established for the project. verall Conclusion. The IEE concludes that: (i) the inherent features of the proposed project sites do not pose any significant constraints that would require costly special mitigation measures; (ii) the adverse environmental impacts of the project, as a whole, will be minor or moderate; and temporary; (iii) the measures to mitigate the adverse impacts can be provided and instituted without difficulty through proper engineering design and environment-friendly management of construction activities and operation; (iv) the adverse impacts can be further mitigated with efficient environmental management and monitoring, prior to construction, and during construction and operation; and (v) the adverse impacts will be greatly offset by the significant socio-economic benefits that will be derived from the project. Category B for environment is confirmed. The project is feasible from an environment safeguards point of view.

72 Appendix 1

Environmental Management Plan

November 2017

Mongolia: Ensuring Inclusiveness and Service Delivery for Persons with Disabilities Project

Prepared by Ministry of Labor and Social Protection for the Asian Development Bank.

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CURRENCY EQUIVALENTS (as of 17 October 2017)

Currency unit – togrog (MNT) MNT1.00 = $ 0.0004 $1.00 = MNT2,459.50

ABBREVIATIONS

ACM – asbestos containing materials ADB – Asian Development Bank ASI – Agency for Specialized Inspection EEE – External Environmental Expert EIA – Environmental Impact Assessment EMP – Environmental Management Plan DEIA – Detailed Environmental Impact Assessment DPO – Disabled people’s organization GASI – General Agency for Specialized Inspection GEIA – General Environmental Impact Assessment GoM – Government of Mongolia GIC – Grant Implementation Consultant Services LEED – United States Green Building Council’s Leadership in Energy and Environmental Design MECS – Ministry of Education, Culture, Science and Sport MEGD – Ministry of Environment and Green Development MNS – Mongolian national standards MOH – Ministry of Health MLSP – Ministry of Labor and Social Protection NGO – non-governmental organization PIU – project implementation unit SPS – Safeguard Policy Statement VOC – volatile organic compound

NOTES

In this report, "$" refers to US dollars.

This generic environmental management plan 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. Your attention is directed to the “terms of use” section of this website.

74 Appendix 1

ENVIRONMENTAL MANAGEMENT PLAN

A. Introduction

1. This Environmental Management Plan (EMP) has been prepared for the proposed ADB Ensuring Inclusiveness and Service Delivery for Persons with Disabilities Project (Grant 48076- 002-MON) to support the Government of Mongolia in ensuring delivery of services for persons with disabilities (PWD) in Ulaanbaatar and at the aimag (province) level. The overall aim of the project is to ensure access by PWD to employment to increase their autonomy and contribution to the economy and society in general. The EMP is based on the domestic general environmental impact assessments (GEIA), the environmental baseline reports and other relevant project documents. The EMP covers all project implementation phases, including planning, design & pre-construction, construction, and operation of all project components, and the impacts identified in relation to physical, biological, cultural and socio-economic resources, as discussed in Section VI (Anticipated Impacts and Mitigation Measure) of the Initial Environment Examination (IEE).

2. Key project stakeholders and institutions include (i) the project Executing Agency (EA) which is the Ministry of Labor and Social Protection (MLSP)MLSP; (ii) the Implementing Agencies (IAs), including the EA´s Population Development Department on employment of PWDs and the Ministry of Health (MOH) on early identification of CWD ; (iii) the disabled people’s organizations (DPOs); (iv) the detailed design engineering firm (C1) which prepares designs, drawings and specifications of buildings, the construction supervision engineers (C1) and the environment specialist (C13) hired by the PIU; and (v) civil works contractors.

B. Objectives

3. The objectives of the EMP are to ensure implementation of: (i) identified mitigation and management measures to avoid, reduce, mitigate, and compensate for anticipated adverse environment impacts; and (ii) monitoring and reporting against the performance indicators, while ensuring that the project complies with the Mongolian environmental laws, standards and regulations and to ADB Safeguard Policy Statement (SPS 2009). Organizational responsibilities are identified for execution, monitoring and reporting.

4. The EMP defines appropriate mitigation measures for the anticipated project environmental impacts, and the institutional responsibilities and mechanisms to monitor and ensure compliance. The EMP specifies (i) objectives; (ii) implementing organizations and responsibilities; (iii) major environmental impacts and mitigation measures; (iv) environmental monitoring and reporting arrangements; (v) future public consultation; and (vi) the project level GRM including training.

5. The EMP requires the civil works contractors to plan for the construction projects, including issues such as work scheduling, consultation with and notification to potentially affected people. Specific measures are developed in relation to the design, construction and operation of each project output, and the impacts identified in relation to physical, biological, cultural and socio-economic resources. The EMP will be reviewed and updated by the environment specialist (C13) and the PIU at the end of the detailed design in order to be consistent with the final detailed design. The updated EMP will be reviewed and disclosed on ADB’s website.

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C. Implementation Arrangements

6. The Executing Agency (EA) will be the Ministry of Labor and Social Protection (MLSP) which is the lead government ministry on disability policy. The Implementing Agencies (IA) will be the Ministry of Health and Sports (MOHS, for output 1) and the Ministry of Labor (MOL, for output 4), and MLSP for outputs 2, 3 and 5.The EA will be responsible for the overall implementation and compliance with the EMP. The EA will establish a Project Implementation Unit (PIU), which will have the overall responsibility delegated by the EA for supervising the implementation of mitigation measures and the reporting to ADB. The EA will coordinate internal and external professional sectors to make their contribution to environmental management plan and monitoring arrangements and will ensure that the national environmental, health and safety laws, regulations, procedures, and guidelines as well as the design standards and codes will be followed. The structure of the project implementation arrangement is shown in Figure EMP-1.

Executing Agency Ministry of Labor and Project Steering Social Protection (MLSP) Committee

Ministry of Health Working groups Population Development (Implementing Agency) Department of MLSP (Implementing Agency)

Project Implementation Unit

International and national consultants

Advises (for project purposes) Oversees (for project purposes)

Figure EMP-1: Project EMP Implementation Arrangement

7. The EMP implementation arrangements and responsibilities of each organization are summarized in Table EMP-1.

76 Appendix 1

Table EMP-1: EMP Implementation Organizations – Roles and Responsibilities Executing Agency • The MLSP will be the executing agency of the project (EA), Implementing • The implementing agencies will be MLSP and MOH Agencies (IA) • A project steering committee (PSC) will be established to approve annual budgets and plans and guide and support project implementation which will include the EMP Project Implementing • By the EA Unit (PIU) • The PIU will be established by MLSP and located in Ulaanbaatar and will be responsible for day-to-day management of the project. The PIU will be staffed by qualified professionals including an accountant/financial management specialist, a project manager, two disability experts, a part- time media specialist and PIU local coordinators to be based in the aimag, a monitoring and evaluation specialist, a procurement specialist and guided and coached by a project management specialist. For the implementation of the EMP, the PIU will be supported by an environmental specialist (ES), contracted under C13 by the EA. • The PIU will assume the overall responsibility for project coordination on behalf of the MLSP and MOH and will implement the following tasks: (i) coordinate procurement (with the support of the Government Procurement Agency); (ii) coordinate and supervise the implementation of the EMP, with the support the ES; (iii) include EMP in bidding documents; ensure that civil works contracts are responsive to EMP provisions; (iv) conduct site visits to each construction site at least twice (at inception and completion stage); (v) Ensure the provision of the required training (vi) prepare the EMP implementation progress report as input to quarterly and annual project reports. Project steering • A project steering committee (PSC) will be established to approve annual committee (PSC) budgets and plans and guide and support project implementation. • The PSC will be chaired by the MLSP and composed of representatives of MOH, Ministry of Finance, NRC, NCRC, NAC and DPOs that are representative of a range of disabilities and disability issues. • Six project steering sub-committees will also be established in the target aimags to (i) approve annual budgets and plans for each aimag; (ii) guide and support project implementation; and (iii) provide coordination between departments, and other stakeholders involved. The sub-committees will be chaired by aimag governors, and composed of heads of finance, social development, health, education and culture departments, NGOs and DPOs, and parent representatives, and other stakeholders. Detailed Design • A national engineering firm will be recruited to: Engineering Firm (i) prepare design drawings, bill of quantities, ensuring compliance of design (C1) with relevant building codes; (ii) implement duties described in the Table EMP-4: Construction EMP, Construction Readiness (iii) identify all permits to be obtained for construction works; provide support for evaluating bids and preparing bid evaluation reports, if requested; (iv) help develop the bidding documents for civil works contracts; (v) prepare a civil works supervision plan for each construction site; (vi) supervise civil works contractors and inspect sites against the designs, drawings and specifications; (vii) prepare milestone (inception, midterm, draft final, and final) reports in

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English and Mongolian which should be acceptable for ADB, the MLSP, MOH and the PCS; (viii) consult relevant stakeholders in the process of assuming the tasks.

Environment • An individual consultant will be engaged as environment specialist (ES) to Specialist (C13) support the PIU in implementing the project. The Task of the Es will include: (i) confirm that construction works do not cause any involuntary resettlement impacts; (ii) assist the PIU in preparing bidding documents for construction works to ensure that the environment-related specifications provided in the EMP are incorporated in technical specifications; (iii) provide support in evaluating bids for construction works to ensure that compliance with the environment-related specifications is evaluated and documented in bid evaluation reports; (iv) review and clear, on behalf of the PIU, site-EMPs prepared by civil works contractors; (v) Conduct at least two site visits to each construction site (at the beginning of the works and at completion stage), carry out the site inspeciton in coopeation with (C1), ensure that inspection checklist are filled; (vi) Prepare annual progress reports of the EMP implementation (including compliance of the civil works contractors with obligations, inspection activities and findings, problems encountered during rehabilitation and operations, and the relevant corrective actions undertaken); (vii) together with the Detailed Design Engineering Firm (C1) , carry out construction completion inspections to confirm the regularity and safety of each building and to confirm that green building components are implemented, with the involvement of relevant government agencies; (viii) prepare an EMP implementation completion report (in English and Mongolian), no later than three months after completion of all rehabilitation works supported under the project.

Civil Work • The civil work contractors will have main environmental management Contractors responsibility. They will: (i) ensure that their bids respond to environmental management requirements of this EMP; (ii) develop site-EMPs for each project site based on the EMP (appendix 2); (iii) assign or hire a qualified person to coordinate the site-EMP implementation, including workplace safety; (iv) ensure that adequate resources are available to implement the site-EMP throughout the construction period; (v) secure appropriate permits and licenses before undertaking the works; (vi) establish a telephone hotline staffed at all times during working hours; (vii) disseminate information on the construction progress, including anticipated activities that might cause safety risk, is disseminated in a timely manner; (viii) inform the PSC, the PIU, and ADB in case of complaints.

External • Aimag Agency for Specialized Inspections (ASI) inspectors responsible for environment, health environment, health and safety will inspect project interventions in and safety participating facilities; supervision agencies • Given the low-risk and low-impact rating of civil works inspections will be conducted as needed.

78 Appendix 1

D. Environmental responsibilities and Project Readiness Indicators

8. Detailed design. The national detailed design engineering firm (C1) will carry out the seismic risk assessment for the sites and will ensure that all environmental safeguard clauses for civil works contracts will be included in the tender documents (Attachment 3). The company will prepare design drawings for each facility ensuring compliance of design with relevant building codes and with the green building design concept (LEED). This will include:

(i) The building codes as described in the Attachment 2 (ii) The LEEDs requirements to be integrated into the sites as described in the Attachment 7

9. General EIAs (GEIA) for the aimag project sites were issued, screened and accepted. For the DPO building a draft General EIA was prepared. The MLSP will have to send an official letter requesting to conduct GEIA to the Municipal Environment and Green development department. This application should include the project approved design, the environmental baseline report with the supporting aerial and topographic photos, the land certification with the registering map (cadaster) as an attachment and the supporting letter from the District Governor’s office to the Municipal Environmental department. The department will carry out the screening of the GEIA and will report the results within 14 days to the MLSPMLSP.

10. As for the sites located in the aimags, it is unlikely that for the DPO building a detailed EIA will be requested. If a detailed EIA will be requested, the MLSP will draft the TOR for carrying out of an environmental assessment (EA) based on the GEIA scoping report. MLSP will seek ADB’s approval prior to engaging the EA Consultant. The selected consultant will conduct the detailed EIA and MLSP will send this to MEGDT for approval.

11. Preparation of bidding documents, evaluation of bids. Civil works and equipment will be procured in accordance with ADB’s Procurement Guideline (2013, as amended from time to time). The PIU, with the support of the detailed design engineering firm (C1) and the environment specialist (C13), will incorporate the EMP including the clauses defined in Table EMP-4 and design specs into the respective bidding documents.

12. Preparation of site-EMPs. After contract award but before construction commencement, each civil works contractor will develop a site-EMP based on additional site investigations, consultation with the facility management and PIU local project coordinators. The site-EMPs should be generated using the EMP provided in Table EMP-4. The contractor shall also assign a qualified person to coordinate the site-EMP implementation. No construction shall be commenced without cleared site-EMP by the PIU local project coordinator and/or aimag ASI inspector.

13. Confirmation of project readiness. After contract award but before construction commencement, the PIU project sub-coordinators, with the support of the environment specialist, shall confirm the following to the PIU and the EA:

(i) The contractor has developed a site-EMP complying with the EMP (Table EMP- 4) and responding to contract clauses and specifications; (ii) The contractor has secured all required permits; and (iii) The contractor has assigned a qualified person to coordinate site-EMP implementation, established a hotline, and disclosed civil works and site-EMP related information in and around the construction site.

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14. Implementation of the site-EMP. During construction, the contractor has overall responsibility for the site-EMP implementation. The contractor will cover the costs for environmental impact mitigation and protection measures. Each contractor shall submit to the PIU project sub-coordinators monthly progress reports which shall include a section on the site- EMP implementation.

15. Table EMP-2 summarizes and shows the environmental responsibilities by project phase and responsible agencies:

Table EMP-2: Environmental Responsibilities by Project Phase Phase Responsible Environmental Responsibilities Agencies Preparation EA, ADB Reviewing and endorsing of EMP and Design Detailed Design Ensuring that all requirements listed in the Engineering Firm EMP are included in the tender (C1) documents Carrying out of a seismic risk assessment Ensuring that all Mongolian building codes are followed in the design Incorporation of all LEEDs requirements in the final design PIU Reviewing and confirming that detailed design of project facilities incorporates all requirements of EMP Tendering PIU Incorporating EMP clauses into the bidding documents and civil contracts. Construction PIU, IAs Reviewing and clearing site-EMPs prepared by contractors; Advising on, and supervising implementation of mitigation measures, implementing compliance monitoring, developing quarterly progress reports and annual environmental monitoring report.

Contractors Developing site-EMP, implementing mitigation measures and internal monitoring and reporting. Construction Conducting of site visits to each construction Supervision site Consultant of the Preparation of annual progress reports of the Detailed Design EMP implementation Engineering Firm Carrying out construction completion (C1), inspections Environment Preparation of the EMP implementation Specialist (C13) completion report ASI inspectors Supervising implementation of EMP ADB Conduct annual review missions, review progress reports, disclose reports on project website. Operation Facility Operators Maintain facilities, conduct regular internal monitoring on the performance of environmental equipment and

80 Appendix 1

infrastructure PIU, IA Supervising implementation of mitigation measures

16. Table EMP-3 presents the Readiness Indicators which provide a measure of whether environmental commitments are being carried out and environmental management systems are in place before construction.

Table EMP-3: Readiness Indicators Pre-Construction

Indicator Measurement Methods Measurement Environmental Supervision (i) ES contracted. Yes No in place (ii) Site specific GRM established. Yes No (iii) Bidding documents and contracts incorporate the Yes No Bidding documents and environmental safeguards contracts with environmental (iv) Bidding documents and contracts incorporate the EMP safeguards Yes No mitigation and monitoring requirements (v) Environmental requirements of EMP included in contract Yes No documents for civil works construction contractors Contract documents (vi) Contractor SEMP developed and submitted to PIU and ES for Yes No review and approval

E. Potential Impacts and Mitigation Measures

17. Table EMP-4 lists the potential environmental issues and impacts during the pre- construction and construction phases of the project, as identified by the GEIAs and the IEE, as well as corresponding mitigation measures designed to minimize the impacts. The mitigation measures consist of actions, activities, plans and documents that need to be undertaken, observed, obtained, prepared to prevent, mitigate, or compensate for, the salient adverse impacts enumerated in Chapter IV of the IEE. For the developing of the site EMP, the contractors need to refer to the IFC General EHS Guidelines to supplement the environmental, health and safety measures identified within the IEE.

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Table EMP-4: Construction Environment Management Plan Project Description Institutional arrangements Project location: Contractor: (Name, Contact Number) Name of facility: PIU local coordinator: (Name, Contact Number) Planned Environment Specialist (ES), (Name, Contact Number) interventions: Architectural Engineer: Construction period: (mm/yyyy-mm-yyyy) Aimag environment agency (Name, Contact Number)

Will the activities involve the Activity Management and following: Mitigation Measures [ ] Yes [ ] No Construction readiness Section A below [ ] Yes [ ] No Construction or extension of building Section B below [ ] Yes [ ] No Removal of hazardous or toxic materials Section C below [ ] Yes [ ] No Community health and safety Section D below

Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators Pre-construction Phase (A) Construction General conditions • Confirm that facility construction plan responds to Contractor PIU Confirmation letter readiness contract clauses; by Contractor to • Secure all required permits for construction and PIU. rehabilitation; • Assign a qualified person to coordinate the site-EMP implementation, including workplace safety; • Establish a telephone hotline staffed at all times during working hours. Display contact details prominently displayed at the site; • Notify the public of the works through appropriate notification prior to construction. Disseminate information on the construction progress, including anticipated activities that might cause safety risk in a timely manner; • All works undertaken on Ulaanbaatar construction site will be timed to avoid the typical summer rainfall floods; and

82 Appendix 1

Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators • Rainfall forecasts will be monitored and work halted in the event that there is a flood risk; • Set up a monitor and response system in case that physical cultural resource (PCR) are discovered in accordance with the IEE Facility design in • Ensure that the building envelopes (external walls) are Engineering Firm PIU, ADB Detailed Design compliance with built to a good quality standard, using high quality drawings design codes insulating materials. • Confirm that facility extension or rehabilitation complies with relevant GoM’s design standards and codes for energy-efficient, safe buildings, including but not limited to: MNS 3838:2008 and Construction standard package # 91.040, #91.140.99 and other standards listed in Attachment 2. • Ensure that only low or no VOC-emitting materials will be used (including paints, coatings, adhesives, carpet and furniture’s). • Select water-based nontoxic, no allergenic paint for drywall or plaster surfaces (no latex or oil-based paints); • Ensure that seismic design standards are included if necessary; • That the described energy efficiency measures in the IEE and in the conceptual design are included in the final design and are implemented during construction to ensure energy and resource-efficiency of project facilities. Construction Phase (B) Construction or Dust generated • During interior demolition use debris-chutes above the Contractor PIU, aimag ASI Inspection checklist; extension of building during construction, first floor; Progress Report air emissions from • Keep demolition debris in controlled area and spray (PIU) construction vehicles with water mist to reduce debris dust; and machinery • Keep surrounding environment free of debris to minimize dust; • There will be no open burning of construction/waste material at the site

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Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators

• There will be no excessive idling of construction vehicles at sites Regularly (at least once a day) spray water on construction sites where fugitive dust is generated; • Vehicles delivering granular and/or fine materials to the sites must be covered. • Regularly consult with nearby residents to identify concerns, and implement additional measures as necessary. • Ensure good ventilation in buildings being rehabilitated or constructed. • Protect temporary stockpiles to reduce dust emissions • Spay water on construction sites and material handling routes where fugitive dust is generated Seismic risks • If seismic risks exist, build as planned. Contractor PIU, Consultant Inspection checklist; Engineer, aimag Progress Report ASI (PIU) Noise from • Maintain equipment and machinery in good working Contractor Facility, PIU, Inspection checklist; construction activities order; aimag ASI, ES Progress Report • Undertake regular equipment maintenance, ensure (PIU) compliance with relevant standard; • Operate between 8am to 6, prohibit work in night time; • Reach an agreement with nearby residents regarding the timing of works to avoid any unnecessary disturbances and avoid work during weekend; • Conduct noise monitoring during the construction work and follow the IFC EHS standards. Ensure noise levels around the construction sites do not exceed 55dB (daytime) and 45dB (nighttime); • Adjacent to the schools to liaise with the school teachers to ensure disturbance during any sensitive periods such as exams is avoided; • Locate sites for concrete-mixing and similar activities at least 300 m away from noise sensitive areas; • Vehicles transporting construction materials or wastes will comply with posted speed limits at all times and will

84 Appendix 1

Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators be limited to low speeds in construction sites; • Vehicles transporting construction materials or wastes will not use their horn when passing through or nearby sensitive locations, such as residential communities, schools and health care facilities; • Public notification of construction operations will incorporate noise considerations and reference to the grievance redress mechanism; and • Ensure noise monitoring is undertaken at construction site boundaries and near sensitive receptors, in compliance with the monitoring plan. Vegetation, re- • Cutting or removal of trees for any reason outside the Contractor PIU, aimag ASI, Inspection checklist; vegetation of approved construction area is strictly prohibited; ES Progress Report disturbed areas; • Properly re-vegetate disturbed areas after completion (PIU) greening of sites of civil works. Soil erosion, • Strip and stockpile topsoil, divert runoff from sites to Contractor PIU, aimag IA, Visual inspection, damage, excavation, existing drainage or ponds. DNET monitoring report spoil disposal • Surplus soils from soil excavation will be used as refill and landscaping materials on site or transported to a site approved by DNET. • Soil damage emerged during the construction work should be restored • The construction or installation of electricity, heat and water supply networks should be executed in accordance with the preliminarily approved plan and design; soil damage caused by above works should be enhanced, leveled and vegetated. • Develop and implement borrow management plan Construction and • Ensure that construction will be subject to the waste Contractor ES, aimag ASI Inspection checklists domestic wastes and hierarchy to ensure efficient use and management of (ES), wastewater resources Progress report generated on • Discharge construction wastewater and domestic (PIU, ES) construction sites wastewater to sewer systems (if possible), or provide on-site treatment/disposal facilities to ensure compliance with effluent discharge standard; • Collect valuable materials (packing materials, reusable products) and recycle or reuse;

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Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators • Provide appropriate waste storage containers for construction wastes; • Install confined storage points of solid wastes away from sensitive receptors, regularly haul to an approved disposal facility; • Use licensed contractors to remove wastes from the construction sites; • Indiscriminate disposal of rubbish, construction wastes or rubble, and burning of waste, are strictly prohibited. • Provide adequate solid waste collection facilities in all buildings; • Regularly clean and disinfect waste collection facilities. • Provide temporary drainage provision during construction to ensure that any storm water runoff from construction areas will be controlled; • Enclosed drainage around chemical and fuel storage areas on construction sites and storage will be on hard standing; • Monitor groundwater quality at existing boreholes and wells prior to and during project construction. (C) Removal of Toxic and hazardous • Prior to construction, undertake appropriate soil testing Contractor PIU, aimag ASI Inspection checklists hazardous or toxic wastes, products at the Ulaanbaatar site. If contamination is encountered (ES), materials carry out a risk assessment and develop a remediation Progress report strategy in accordance with the IFC EHS Guidelines on (PIU, ES) Contaminated Lands. Take additional precautions to avoid wind blown contaminated soi, ensure any contaminated spoil to be disposed of off-site to suitably licensed landfill. • Prior to construction, search existing facilities for chemicals and any other substances such as asbestos or asbestos containing materials (ACM); • If toxic solid waste is found during construction, construction activities should be suspended and the aimag ASI inspector consulted to define appropriate actions; • Provide appropriate waste storage containers for hazardous wastes and hazardous products;

86 Appendix 1

Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators • Store chemicals/hazardous products and waste on impermeable surfaces in secure, covered areas; • Provide spill cleanup measures and equipment at each construction site. • If Asbestos containing materials (ACM) is found, Develop ACM control plans including handling, transport and disposal and the required PPE for workers (E) Health and Safety Occupational Health • Define safety measures at the construction site to Contractor PIU, aimag ASI Inspection checklists and Safety protect the workers and the public (ES), • Provide safe supply of clean water and an adequate Progress report number of latrines and other sanitary arrangements at (PIU, ES) the site and work areas; • Provide clean area to rest and eat for workers, away from potential exposure to hazardous substances; • Provide garbage receptacles at construction site; • Provide personal protection equipment for workers in accordance with relevant health and safety regulations; • Develop an emergency response plan to take actions on accidents and emergencies; • Document and report occupational accidents, diseases, and incidents; • Ensure that safety, rescue and health matters are given a high degree of publicity to all persons regularly or occasionally at active construction sites. • Emergency contact numbers for local fire, medical and police services shall be kept at prominent place. Community Health • Assess potential disruption to services and identify Contractor PIU, aimag ASI Inspection checklists and Safety risks before starting construction; If temporary (ES), disruption is unavoidable, develop a plan to minimize Progress report the disruption and communicate the dates and duration (PIU, ES) in advance to all affected people, in coordination with the facility management; • Place clear signs at construction sites in view of children and staff as well as the public, warning people of potential dangers such as moving vehicles, hazardous materials, etc., and raising awareness on

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Stage/Activity Potential Impacts Mitigation measures Implem. Agency Superv. Agency Monitoring and/or Issues Indicators safety issues; • Ensure that all construction sites will be made secure, discouraging access through appropriate fencing whenever appropriate. • Prepare traffic and access plan within and around the facility during construction, as needed. Avoid construction traffic especially during sensitive times such as start/close times when children may be running around, • Provide educational session to schools if they are in the neighbourhood to warn the children about dangers of construction site and not to enter them.

Stage/Ac Potential Impacts Mitigation measures Implem. Superv. Monitoring tivity and/or Issues Agency Agency Indicators • Connect the building to the local sewage and water network Operation Effluent from the • Conduct regular checks of receiving sewage systems Operator of Monitoring Aimag ASI phase Centers • Including regular monitoring of soil and water quality by licensed the Center reports laboratory at aimag level. • Include all required civil works and equipment to ensure good indoor air quality, operate the equipment as required • Conect the building with the central heating system; Contractor, EMP Ensure good air • If the building cannot be connected and a boiler is needed must meet the Mongolian emission standards and/or) IFC AQ emission standards for Operator of the Aimag ASI implementation quality >3MW<50MW boiler. Ensure the boiler is energy efficient and uses clean Center completion report fuel instead of coal; • If a boiler is needed, include regular maintenance of the boiler and monitoring of emissions in accordance with local regulations. • Locate noise equipment indoors with building walls with sufficient Contractor, EMP thickness; Noise from Center Operator of the Aimag ASI implementation • Conduct noise monitoring by qualified entity to confirm compliance with Center completion report the national ambient noise standard (MNS 4585:2007) if required. Emergency • Ensure that fire dectors are regularly maintained Operator of Operation Aimag ASI preparedness and • Carry out regular emergency preparedness training for staff and people the Center reports

88 Appendix 1

Stage/Ac Potential Impacts Mitigation measures Implem. Superv. Monitoring tivity and/or Issues Agency Agency Indicators response regular working in the center • Ensure that all safety and hazard signs are maintained • Prepare and implement Operational Risk Mitigation Plan, and Emergency Preparedness and Response Plan • Conduct regular inspection and proper maintenance • Sign a contract with the local waste management company for the regular collection of waste Solid waste from • Collect, store and periodically dispose of generated hazardous waste, if at Operator of Operation Aimag ASI the center all generated the Center reports • Set up a waste recycling system and encourage staff and visitors to recycle • Develop and implement OHS program include job hazard analysis, risk analysis and ranking, safety procedures, training plans, safety incident reporting and record keeping, etc.; • Post safety instructions in each workshop regarding the storage, Health and safety transport, handling or pouring of chemicals; Operator of Operation Aimag ASI exposures of workers • check electrical equipment for safety before use; verify that all electric the Center reports cables are properly insulated; take faulty or suspect electrical equipment to a qualified electricity technician for testing and repair; • all workers will undergo periodic examinations by occupational physician to reveal early symptoms of possible chronic effects or allergies.

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F. Environmental Monitoring

18. The project monitoring program focuses on the environment within the project‘s areas of influence for each of the sites. The monitoring shall comply with the methodology provided in the relevant Mongolian national environmental monitoring standards. Other associated compliance standards to be followed are the national environmental quality standards of air, water and noise, and the effluent discharge standards (see IEE Chapter II). Monitoring will include the following:

19. Internal monitoring/supervision by contractors. Civil works contractors will develop site environment management plans (SEMP) with environmental management and internal supervision systems based on the approved project EMP and the GEIAs, undertake self-check activities and fully cooperate with the environmental inspectors of the aimag environmental authorities and the State Professional Inspection Agency (SFIA).

20. Internal monitoring/supervision and reporting by PIU. During construction, the PIU will be responsible for conducting internal environmental monitoring (consisting mainly of visual site inspection) in accordance with the monitoring plan. The PIU will be supported by the responsible engineers and the ES. Supervision results will be reported to the EA.

21. Site inspections, public consultation. During civil works, the PIU project sub- coordinators, together with the construction supervision consultants (C1), the environment specialist (C13) and the aimag ASI inspectors, will conduct regular site inspections to oversee the contractor’s compliance with the approved site-EMP. Inspections shall be carried out by the environment specialist (C13), conducted at least on a quarterly basis during civil works, and follow the site inspection checklist developed for that purpose (Attachment 4). Public consultation during construction will mainly rely on informal interviews with the DPO staff and nearby residents during site inspections by the PIU, the construction supervision consultants (C1), and the environment specialist (C13). The completed inspection checklists will be submitted to the PIU on a quarterly basis for verification and confirmation. In case of violations, the PIU shall report it to the aimag ASI (for the 6 aimag facilities) or the Ulaanbaatar environment protection authorities (for the DPO building in Ulaanbaatar). The checklists will be incorporated into quarterly and annual reports to ADB, which will be disclosed on the project website.

22. Supervision and reporting by the environment specialist. The environment specialist (C13) will conduct at least two site visits to each facility where civil works are being carried out (at the beginning of civil works, and at completion stage). The environment specialist will synthesize status of civil works and EMP implementation in the quarterly progress report to ADB (including compliance of contractors with obligations, problems encountered during construction and operation, and the relevant corrective actions undertaken). At the end of the rehabilitation works, it will be necessary to confirm the regularity and safety of each building. The completion inspection will be conducted by the environment specialist (C13) together with the construction supervision engineers (C1), and with involvement of aimag environment protection agencies and ASI inspectors. The environment specialist (C13) will compile, on behalf of the MECS, a EMP implementation completion report, no later than 6 months after completion of all civil works related to the project.

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G. Environmental Reporting

23. Environmental monitoring and inspection activities and findings will be documented for purposes of reporting, record keeping, verifying, referring and evaluating the environmental performance of the Project. The documentation shall also be used as basis in correcting and enhancing further environmental mitigation and monitoring. Environmental monitoring reports (EMRs) will be prepared as follows (see also Table EMP-5):

(i) Monthly internal progress reports will be prepared by the onsite construction supervision consultants (C1) of the PIU during construction, submitted to the EA and PSC. These monthly reports will include; (a) physical progress of the component; (b) mitigation measures implemented; (c) grievances received, resolved, closed and/or directed to other mechanisms; (d) emergencies responded to; and (e) corrective actions taken.

(ii) Environmental impact monitoring reports will be prepared by the ES contracted by the PIU to report on the results of environmental quality monitoring as specified in the EMP. Two reports will be prepared during the construction and commissioning stages. The reports will include the analysis results and assessment of compliance/non-compliance with the EMP, Mongolian and international standards.

(iii) Annual EMP progress reports, by the ES (on behalf of PIU) to be submitted to the ADB and the EA to comply with environmental agreement in the loan and Mongolian Law on EIA. Table EMP-6: Project Reporting Requirements

Table EMP-5: Environmental Reporting Plan

Report From Report To Purpose Frequency C1 PIU, IAs Progress on EMP Implementation Monthly Project progress reports (including section PIU ADB Quarterly on EMP implementation progress) Indepependent environment monitoring Twice during construction ES PIU, PSGs results period Annually, until PCR is PIU (ES) ADB EMP progress reports issued Source: ADB PPTA Team

H. Training, Capacity Building and Awareness Raising

24. To ensure effective implementation of the EMP, the capacity of the PIU and the contractors will be strengthened, and all parties involved in implementing mitigation measures and monitoring of environmental performance must have an understanding of the goals, methods, and the best practices of project environmental management. The PIU and the contractor will offer training specific to their roles for aimag cities under the project. The main training emphasis will be to ensure that all involved are well versed in environmentally sound practices and are able to undertake all construction and operation with the appropriate environmental safeguards.

25. Training Needs Assessments will be conducted by the ES to tailor the training for

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maximum impact. The trainer will include in their program a before/after assessment to evaluate the success of the training. An evaluation questionnaire will be used to assess the effectiveness of the training and the training program will be adjusted based on feedbacks. Training will be provided throughout the implementation of the project by and financed from PIU and Construction Supervision and the training program is summarized in Table EMP-6.

Table EMP-6: Training Program

Topic Attendees Sub-topics Provider Frequency

EMP contents, SEMP Twice - PIU, supervision preparation, roles and PIU and Once prior to, and engineers, responsibilities, monitoring, EMP requirements Construction once after contractors supervision and reporting Supervision the first year of procedures, review of first year project construction experience (after 12 months) Use and purpose of GRM; PIU, supervision ADB requirements for GRM; Twice: Once prior engineers, PIU and Grievance redress GRM procedures; to, and once after contractors, aimag Construction mechanism (GRM) Roles and responsibilities; the first year of and bagh Supervision Review of first year experience project construction representatives (after 12 months) Construction safety, Twice: Once prior PMU, supervision PIU and occupational safety during to, and once after Safety Training engineers, Construction operation and maintenance, the first year of contractors Supervision traffic safety project construction

Source: ADB PPTA consultants.

I. Public Consultation

26. The stakeholder consultation process conducted during the development of the IEE, demonstrated that all sub-components under the AF project have strong local support. In compliance with ADB’s Safeguard Policy Statement (2009), environmental information related to the project was and/or will be disclosed to affected people as follows: (i) this IEE is disclosed on ADB’s project website (www.adb.org), and is available for consultation in the PIU’s offices; (ii) the GEIAs will be approved and disclosed by MEGDT; and (iii) annual reports on project’s compliance with the EMP as well as the Project Completion Report will be available at www.adb.org.

27. During project implementation, affected people will be consulted and informed through formal questionnaire surveys, site visits and informal interviews by the ES. The ES will, prior to project completion report (PCR) mission, organize a survey to assess community satisfaction with project implementation, project outputs, and EMP implementation performance.

J. Grievance Redress Mechanism

A grievance redress mechanism (GRM) will be established for each project site in accordance and as defined in the Chapter VIII of the IEE. The GRM will follow the existing approach taken for managing complaints about local issues by members of the public in Mongolia.

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K. Mechanisms for Feedback and Adjustment

28. Based on environmental inspection and monitoring reports, the PIU and PSC with the assistance from the ES will decide whether (i) further mitigation measures are required as corrective actions, or (ii) some improvements are required for environmental management practices.

29. The effectiveness of mitigation measures and monitoring plans will be evaluated by a feedback reporting system. Adjustment to the EMP will be made, if necessary. The PIU will play a critical role in the feedback and adjustment mechanism with the support from the ES.

30. The need to update and adjust the EMP will be reviewed when there are design changes, changes in construction methods and program, negative environmental monitoring results or inappropriate monitoring locations, and ineffective or inadequate mitigation measures. Based on environmental monitoring and reporting systems in place, the PIU and PSC with the support of the ES will assess whether further mitigation measures are required as corrective action, or improvement in environmental management practices are required. The PIU will inform ADB promptly on any changes to the project and needed adjustments to the EMP. The updated EMP will be submitted to ADB for review and approval, and will be disclosed on the ADB project website.

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Attachment 1: List of sites and core environmental information

Figure 3: Location Diagram of the planned development centers

Aimag Location Clean Sewage District Electricity Waste water available heating available Collection available available available Ulan Bator Next to the X X X X X existing DPO building Khovd Jargalant soum, X X X X X Tsmbagarav bag Darkhan Darkhan soum- X X X X X Uul 10, microregion 12 Khovsgold Murun Soum, O O O O X 8th Bag Arkhangai Erdenebulgan X X - X X soum, 5th bag Dornod Kherlen Soum, X X X X X 9th Bag, Dundgovi Between Police X X X X X station and TVET center Legend: X = already available at the site O = not available but in close distance - = not available, onsite solution required

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Google Earth Images of Identified project sites

Ulaanbaatar City, Dund Gol Street, 3rd Khoroo, Bayangol District. Multipurpose building and working places for DPO

Khovd, Jargalant soum, Tsmbagarav bag The site is located in the western part of the center of Khovd city along the main road to the north. Size: 2800 sq.m

Darkhan Uul, Darkhan soum-10, microregion 12 Situated in the western part of constructed area of the city Size: 5000 sq.m

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Khovsgold, Murun Soum, 8th Bag In the right side a new school was constructed and necessary infrastructure can be linked directly from the school building. Size: 4000 sq.m

Arkhangai, Erdenebulgan soum, 5th bag The site is located in the left side of the kindergarten 8. Infrastructure (water supply, waste disposal and electricity) will be connected from the existing system of newly established kindergarten. Size: 3200 sq.m

Dornod, Kherlen Soum, 9th Bag, The site is located close to the main road, next to the LDS Chapel and the Hospital. Size: 3000 sq.m

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Dundgovi, Between Police station and TVET center Selected site locates directly in the north of the newly constructed TVET center and the entrance of the building can be constructed to the main road. Size: 2800 sq.m

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Attachment 2: Environmental Laws, Environmental Quality and Health and Safety Standards Relevant to the Project Name of Law Year Description Regulates relations concerning the use & protection of subsoil in Law on Subsoil 1988 the interests of present and future generations. Regulates the possession & use of land by a citizen, entity & 1994 organization, & other related issues. Articles 42/43 provide guide on Law on Land (2012) removing possessed land & granting of compensation relative to removing. Regulates “relations between the state, citizens, economic entities and organizations in order to guarantee the human right to live in a healthy and safe environment, have ecologically balanced social and economic development, and for the protection of the Law on Environmental 1995 environment for present and future generations, the proper use of Protection (2012) natural resources and the restoration of available resources”. Its Article 7 requires the conduct of natural resource assessment and environmental impact assessment to preserve the natural state of the environment, and Article 10, the conduct of environmental monitoring on the state and changes of the environment. Regulates the protection of the atmosphere to provide environmental balance & for the sake of present & future generations. Allows government to set standard limits to emissions Law on Air (2012) from all sources. Provides for the regular monitoring of air pollution, hazardous impacts & changes in small air components such as ozone and hydrogen. Regulates the protection, proper use, & restoration of natural plants Law on Natural Plants (2012) other than forest & cultivated plants. Regulates relations pertaining to the effective use, protection & restoration of water resources. Specifies regular monitoring of the Law on Water (2012) levels of water resources, quality & pollution. Provides safeguards against water pollution. 1996 Regulates the inhibition, protection, inspection of pasturelands & Law on Plant Protection (2007) plants. Regulates “relations concerning protection of the environment, prevention of ecological imbalance, the use of natural resources, Law on Environmental 1998 assessment of the environmental impact and decision-making on Impact Assessment (2012) the start of a project”. It sets out the general requirements and procedures for project screening and conduct of environmental assessment and review. Governs relationships concerning maintenance of sanitary conditions, defining the general requirements for sanitation in order to ensure the right of an individual to healthy & safe working & living Law on Sanitation 1998 conditions, ensuring normal sanitary conditions, & defining the rights & duties of individuals, economic entities & organizations with this respect. Regulates the collection, registration, research, classification, Law on Protection of evaluation, preservation, protection, promotion, restoration, Cultural Heritage 2001 possession and usage of cultural heritage including tangible and

intangible heritage. Governs the collection, transportation, storage, & depositing in landfills of household & industrial waste, & re-using waste as a

Law on Wastes source of raw materials to eliminate hazardous impacts of 2012 household and industrial waste on public health & the environment. Undertakings that generate significant amount of wastes must

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Name of Law Year Description dispose of the wastes in designated landfills that meet prescribed standards. Regulates matters relating to the principles & full powers of disaster Law on Disaster 2003 protection organizations & agencies, their organization & activities, Protection (2012) as well as the rights & duties of the State, local authorities, enterprises, entities & individuals in relation to disaster protection. Regulates all the construction phases from design to completion of Law on Buildings 2008 construction. It also regulates civil works. Ministerial order # 196 The Design Authors Supervision during Construction works (БНбД 1999 Ministry of Infrastructure 11.04.99) Source: Mongolia: Ulaanbaatar Urban Services and Ger Areas Development Investment Program (MFF), ADB, 2013

Air Quality MNS 4585:2007 National air quality standards and parameters, applies to urban areas Noise MNS 0012-1-009:1985 Standard for noise level in residential areas and civil construction Water Quality (surface & groundwater) MNS 3342:1982 General requirements for protection groundwater from pollution/contamination MNS 0899:1992 Requirements/rules for selecting water supply source & hygienic requirements MNS 4586:1998 Indicator of water environment quality and general requirements MNS 6148:2010 Permissible level for ground water polluting substances. Drinking Water Quality MNS 900:2005 Hygienic requirements and quality control for drinking water Wastewater MNS 4943:2000 Effluent/wastewater standard. Occupational Health/Safety MNS 12.1.06:1988 General requirements for safety against extreme high noise MNS 4990:2000 Hygienic requirements in workplace environment Dormitory MNS 5869 - 2008 Dormitory service. General Requirement MNS 5682 - 2006 Road and access for vehicles, pedestrian and disabled people Fire safety MNS 0640 : 1989 Fire safety requirement Construction work 91.040 The comprehensive package of the standards related to construction 91.140.99 The package of the standards that regulates inside construction and civil works for all buildings 91.140.60 The package regulates water supply system 91.140.80 The package regulates all the sewage water removal system MNS 3838 : 1985 Construction design developing and fire safety Heating MNS 3238 : 2001 Design for heating system MNS 3240 : 2003 Heating and air conditioning system design MNS 5041 : 2001 Technical requirements for Heat-only Boilers MNS 5043 : 2001 MNS 5457 : 2005 Permissible level of pollutants in emission from heating and gera chimneys and testing method a National dwelling: A ger is a portable, bent dwelling structure traditionally used by nomads in the steppes of Central Asia.

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Attachment 3: Environmental Safeguard Clauses for Civil Works Contracts The general environment, health and safety obligations of the Contractor within this Contract, without prejudice to other official provisions in force, include the following: • The Contractor shall ensure that the construction and decommissioning of project facilities comply with (a) all applicable laws and regulations of Mongolia relating to environment, health and safety; (b) the Environmental Safeguards stipulated in ADB’s Safeguards Policy Statement (2009); and (c) all measures and requirements set forth in the environmental management plan (EMP). • The Contractor shall establish a telephone hotline staffed at all times during working hours. Contact details shall be prominently displayed at the sites. The Contractor shall disseminate in a timely manner information on the construction progress, including anticipated activities that might cause safety risk. • The Contractor shall secure all necessary permits and licenses before undertaking the works. • The Contractor shall assign sufficient qualified staff to manage site-EMP implementation, and ensure adequate financial resources are available to implement the site-EMP throughout the construction period. • The Contractor shall provide equal pay for equal work, regardless of gender or ethnicity; provide those they employ with a written contract; provide the timely payment of wages; use local unskilled labor, as applicable, comply with core labor standards and the applicable labor laws and regulations, including stipulations related to employment, e.g. health, safety, welfare and the workers’ rights, and anti-trafficking laws; and not employ child labor. The Contractor shall maintain records of labor employment, including the name, ethnicity, age, gender, domicile, working time, and the payment of wages. • All buildings shall be designed in compliance with relevant the Government of Mongolia’s design standards and codes for energy-efficient, safe buildings, including but not limited to: Mongolian national standards (MNS) 3838: 2008 and Construction standard package # 91.040. Only low or no volatile organic compound (VOC)-emitting materials shall be used (including paints, coatings, adhesives, carpet and furniture’s) to ensure high indoor air quality. Water-based nontoxic, no allergenic paint for drywall or plaster surfaces shall be preferred to latex or oil-based paints. All facilities shall be properly sited to minimize the risk of scouring that may result from increase intensity of precipitation as a result of climate change. • The Contractor shall take necessary precautions to avoid interruptions to water supply, wastewater collection, heating and other utility services during the civil works. • The Contractor shall prepare a construction site-EMP based on the construction EMP, and share it with the project implementation unit (PIU) prior to construction. • The Contractor shall take appropriate sanctions against personnel violating the applicable specifications and provisions on environment, health and safety. • The Contractor shall document, and systematically report to the the project implementation unit (PIU), of each incident or accident, damage or degradation caused to the environment, workers or residents or their assets, in the course of the works. • The Contractor shall provide all relevant information about the EMP and the Site-EMP to subcontractor/s and be responsible for their actions. • The Contractor shall provide the PIU with a written notice of any unanticipated environmental, health and safety risks or impacts that arise during implementation of the contract that were not considered in the EMP.

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Attachment 4: Environmental Site Inspection Checklist Note: This form is designed for use by the project implementation unit (PIU) local project coordinator during site inspections and may not be exhaustive. Modifications and additions may be necessary to suit individual projects and to address specific environmental issues and mitigation measures.

Name of facility: ______Location: ______Inspection Date: ______Inspection Time: ______Inspector(s): ______

Inspection Item Yes No N.A. Remarks (i.e. problem observed, possible cause of nonconformity and/or proposed corrective/ preventative actions) 1. Has contractor appointed a construction supervisor and is the supervisor on-site? 2. Is information pertaining to construction disclosed at construction site (including construction period, contractor information, etc)? 3. Are chemicals/hazardous products and waste stored on impermeable surfaces in secure, covered areas? 4. Is there evidence of oil spillage? 5. Are chemicals stored and labeled properly? 6. Is construction equipment well maintained (any black smoke observed)? 7. Is there evidence of excessive dust generation? 8. Are there enclosures around the main dust-generating activities? 9. Does contractor regularly consult with facility management as well as nearby residents to identify concerns? 10. Is there evidence of excessive noise? 11. Any noise mitigation measures adopted (e.g. use noise barrier / enclosure)? 12. Is construction wastewater and domestic wastewater discharged to sewer systems (if possible), or are on-site treatment facilities (septic tank) provided? 13. Is there any wastewater discharged to soil or surface water? 14. Is the site kept clean and tidy (e.g. litter free, good housekeeping)? 15. Are separated labeled containers/areas provided for facilitating recycling and waste segregation? 16. Are construction wastes/recyclable wastes and general refuse removed off site regularly (any fireplaces observed)?

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Inspection Item Yes No N.A. Remarks (i.e. problem observed, possible cause of nonconformity and/or proposed corrective/ preventative actions) 17. Is safe supply of clean water and an adequate number of latrines provided for workers? 18. Is personal protection equipment provided for workers? 19. Are clear information and warning signs placed at construction sites in view of the students and staff as well as the public? 20. Are all construction sites made secure, discouraging access through appropriate fencing? 21. Are disturbed areas properly re-vegetate after completion of works? 22. Consultation: Were any complaints filed with the contractor, and have staff and nearby residents raised any concerns related to the performance of contractor? 23. Are universal design features are properly constructed? 24. Are the green building and energy- efficient building design principles implemented? 25. Any other problems identified or observations made?

______Date, Name and Signature of PIU staff/ consultant

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Attachment 5: Management Principles For Handling And Removal Of Asbestos If a likelihood of disturbing hazardous materials such as asbestos, lead paint and PCBs in electrical fixtures becomes apparent during construction, a hazardous waste management plan shall be developed. This management plan will especially be cognizant of the environmental risks associated with asbestos and follow these management principles. Asbestos is the name applied to a group of six naturally occurring silicate mineral chains, of which the long fiver chrysotile is the most common. The material was appreciated because of its properties. Asbestos fibers are virtually indestructible, resistant to chemicals and heat, and they are very stable in the environment. They do not evaporate into air or dissolve in water, and they are not broken down over time. However, because it is so hard to destroy asbestos fibers, the body cannot break them down or remove them once they are lodged in lung or body tissues. They remain in place where they can cause disease. Particular attention is therefore required during works which will potentially disturb asbestos containing materials (ACM). Based on International Labor Organization recommendations, the following minimal requirements will be adhered to in the management of asbestos during project works. i. conduct careful inspection and documentation of the premises and testing of materials to assess the presence of asbestos containing materials (ACM).

ii. for small quantities of ACM in a particular building, and if the level of friable ACM is very low and unlikely to increase during demolition, the buildings may be removed without prior removal of asbestos. Workers may be provided with a suitable face mask and instructed to wash body, clothes and shoes after work before going home.

iii. for larger quantities of ACMs, or if the level of friable ACM is significant or may become significant during demolition, special arrangements need to be made for the removal of ACM before the demolition of the building. ➢ Where available, a national or regional company will be contracted which is specialized or at least has substantial expert experience with removing asbestos. ➢ The firm will follow standard's general requirements covering subjects such as notification and reporting and monitoring. ➢ The workers will be trained, provided with appropriate PPE, work in shifts to ensure proper use of PPE, wash after work, and are properly supervised. Laundry will be done on site to minimize exposure of children. ➢ The authorities will ensure that the buildings surrounding the demolition site are vacated during removal of asbestos and following clean-up. If friable materials are expected, the building will be covered in a protective tent of plastic. ➢ The firm will in any case use wet methods or wetting agents except where this is infeasible. ➢ The asbestos-containing waste produced from the demolition operation must be kept wet at all times until it has been loaded for transport away from the demolition site. ➢ Asbestos waste must be placed in sealed, labeled, impermeable bags or other closed, labeled, impermeable containers. Trucks with water-tight, dust-tight cargo haulers will take the containers to a proper storage place.

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Attachment 6: Detailed Requirements of ADB SPS 2009 Environmental safeguards requirements, including environmental impact assessment requirements, are defined in ADB‘s Safeguard Policy Statement (2009). All projects funded by ADB must comply with SPS 2009 to ensure that projects undertaken as part of programs funded under ADB loans are environmentally sound, are designed to operate in compliance with applicable regulatory requirements, and are not likely to cause significant environmental, health, or safety hazards. With respect to the environment, the SPS 2009 is underpinned by the ADB Operations Manual, Bank Policy (OM Section F1/OP, 2010). The policy promotes international good practice as reflected in internationally recognized standards such as the World Bank Group‘s Environmental, Health and Safety Guidelines. ADB‘s Environmental Safeguards policy principle are defined in SPS (2009), Safeguard Requirements 1, as follows: (ix) Use a screening process for each proposed project, as early as possible, to determine the appropriate extent and type of environmental assessment so that appropriate studies are undertaken commensurate with the significance of potential impacts and risks. (x) Conduct an environmental assessment for each proposed project to identify potential direct, indirect, cumulative, and induced impacts and risks to physical, biological, socioeconomic (including impacts on livelihood through environmental media, health and safety, vulnerable groups, and gender issues), and physical cultural resources in the context of the project‘s area of influence. Assess potential transboundary and global impacts, including climate change. Use strategic environmental assessment where appropriate. (xi) Examine alternatives to the project‘s location, design, technology, and components and their potential environmental and social impacts and document the rationale for selecting the particular alternative proposed. Also consider the no project alternative. (xii) Avoid, and where avoidance is not possible, minimize, mitigate, and/or offset adverse impacts and enhance positive impacts by means of environmental planning and management. Prepare an environmental management plan (EMP) that includes the proposed mitigation measures, environmental monitoring and reporting requirements, related institutional or organizational arrangements, capacity development and training measures, implementation schedule, cost estimates, and performance indicators. Key considerations for EMP preparation include mitigation of potential adverse impacts to the level of no significant harm to third parties, and the polluter pays principle. (xiii) Carry out meaningful consultation with affected people and facilitate their informed participation. Ensure women‘s participation in consultation. Involve stakeholders, including affected people and concerned nongovernment organizations, early in the project preparation process and ensure that their views and concerns are made known to and understood by decision makers and taken into account. Continue consultations with stakeholders throughout project implementation as necessary to address issues related to environmental assessment. Establish a grievance redress mechanism to receive and facilitate resolution of the affected people‘s concerns and grievances regarding the project‘s environmental performance. (xiv) Disclose a draft environmental assessment (including the EMP) in a timely manner, before project appraisal, in an accessible place and in a form and language(s) understandable to affected people and other stakeholders. Disclose the final environmental assessment, and its updates if any, to affected people and other stakeholders. (xv) Implement the EMP and monitor its effectiveness. Document monitoring results, including the development and implementation of corrective actions, and disclose monitoring reports. (xvi) Do not implement project activities in areas of critical habitats, unless (i) there are no measurable adverse impacts on the critical habitat that could impair its ability to function, (ii) there is no reduction in the population of any recognized endangered or critically endangered species, and (iii) any lesser impacts are mitigated. If a project is located within a legally protected area, implement additional programs to promote and enhance the conservation aims of the protected area. In an area of natural habitats, there must be no significant conversion or degradation, unless (i) alternatives are not available, (ii) the overall benefits from the project substantially outweigh the environmental costs, and (iii) any conversion or degradation is

104 Appendix 1

appropriately mitigated. Use a precautionary approach to the use, development, and management of renewable natural resources. (xvii) Apply pollution prevention and control technologies and practices consistent with international good practices as reflected in internationally recognized standards such as the World Bank Group‘s Environmental, Health and Safety Guidelines. Adopt cleaner production processes and good energy efficiency practices. Avoid pollution, or, when avoidance is not possible, minimize or control the intensity or load of pollutant emissions and discharges, including direct and indirect greenhouse gases emissions, waste generation, and release of hazardous materials from their production, transportation, handling, and storage. Avoid the use of hazardous materials subject to international bans or phase-out. Purchase, use, and manage pesticides based on integrated pest management approaches and reduce reliance on synthetic chemical pesticides. (xviii) Provide workers with safe and healthy working conditions and prevent accidents, injuries, and disease. Establish preventive and emergency preparedness and response measures to avoid, and where avoidance is not possible, to minimize, adverse impacts and risks to the health and safety of local communities. (xix) Conserve physical cultural resources and avoid destroying or damaging them by using field-based surveys that employ qualified and experienced experts during environmental assessment. Provide for the use of ―chance find‖ procedures that include a pre-approved management and conservation approach for materials that may be discovered during project implementation.

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Attachment 7: Overview LEEDs requirements integrated into the sites

- Encouraging regionally appropriate landscaping using local material such as gabion wall. - Maintain native vegetation cover on site - Open space that encourages interaction with the environment, social interaction Sustainable Site - Each site proportion is variable but outdoor space is greater than 30 % - No fence to our site is necessary for a larger interaction to the city - public facilities - Rainwater management using ecoblock for the pavement of the parking

- Program of the building is entering into the social equity and public health priorities

Regional Priority

- encouraging the usage of a ramp instead of a lift for the vertical circulation - Adult and Children care = Civic and community Innovation and Design facilities

- Natural day light maximize inside all rooms - Access to views - surrounding and into the courtyard - Usage of Low emissivity material - Environnemental Tabacco smoke control Indoor Environmental - Increase ventilation (Ashrae will be a minimum) Quality - Usage of material/fitting helping to achieve effective acoustic - Thermal confort of the building insuring the perfect detail design and construction of the building (thermal bridge free building)

- Energy-use monitoring with on Building Management System installation - Usage of LED light appliances Energy and - Natural light into all corridor and ramps ( sky light and Atmosphere space planning arrangement) - Usage of the renewable energy for the solar panel installed on the sloped roof -Usage of double windows min U-value: 0.30)

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- Water consumption reduction using the double flush system - Water consumption reduction using infrared tap Water efficiency command - Collection of the rain water coming from the roof (Rainwater harvesting)

- Usage of regional materials (local stone, Light block, bricks) Material and - Storage and collection of the recyclable into the Resources waste storage (near the garage)

- Work with the local authorities to create on bus stop at less than 400m - Access to quality transit Location and - Storage area for pram and bicycle Linkages - Building location into the Aimags networks

- Early analysis of the interrelationships among system

Integrative process