Matrix of Comments Received and Responses
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MATRIX OF COMMENTS RECEIVED AND RESPONSES Public Consultation Meeting on the Draft Terms of Reference (TOR) for Regional Environmental Assessment (REA) and Environmental and Social Impact Assessment (ESIA) of Proposed Shuren Hydropower Plant (HPP) and Flow Regulation of Orkhon River and Construction of Reservoir Complex Projects Conference Hall of the Government House of the Republic of Buryatia (by Videoconference with Nizhneangarsk), Ulan-Ude City, Republic of Buryatia, March 30, 2017 MINIS Project Management Unit, expert teams of the Ministry of Environment and Tourism and Ministry of Energy jointly organized a public consultation meeting on March 30, 2017 in the Cultural Center of Nizhneangarsk urban-type settlement to discuss draft TOR for REA and ESIA of proposed Shuren HPP and Flow Regulation of Orkhon River and Construction of Reservoir Complex (Orkhon) as required by World Bank’s Operations Safeguard Policy 4.01 Environmental Assessment. The World Bank representatives participated in the consultations as an observer. Purpose of Consultations: to seek feedback from stakeholders on the draft TOR for REA/ESIA of proposed Shuren HPP and Orkhon projects, respond to their questions and capture their concerns, inputs and recommendations to strengthen TOR. Approach to consideration of feedback in the TORs: the aim of the response matrix is to demonstrate how comments and suggestions received on the TORs are taken into consideration in the ToR drafting process. Not all comments or suggestions are agreed with and acted on, but every comment and suggestion is considered and alternative approaches are explained where the feedback is not accepted. In the absence of agreement with all consultation participants to disclose names and affiliations, all comments are reproduced in the response matrix without attribution in order to preserve anonymity and promote impartial review. Participants: representatives of the government of the Republic of Buryatia, Ministry of Natural Resources of the Republic of Buryatia, local administration, NGOs, residents of Nizhneangarsk urban-type settlement, the MINIS project management team, the Ministry of Environment and Tourism of Mongolia, the Ministry of Energy of Mongolia, developers of TOR for REA and ESIA, and the World Bank representatives. This response matrix includes questions and comments received during the public consultation in Ulan-Ude by videoconference with Nizhneangarsk and written feedback from residents of Nizhneangarsk urban-type settlement. Project Question/Comment MINIS Response Both Due to the fact that as a result of the above projects a certain volume of Within the REA, current and future tendency of water demand, projects water reserves will be retained on the territory of Mongolia, how much abstraction and distribution, water shortages, water quality and the water level in the Selenge River and the Lake Baikal will decrease? water level will be identified and analyzed. All available (Severobaikalsk) relevant information on hydrology, hydrochemistry and water pollution will be collected, compiled, organized, reviewed and 1 Project Question/Comment MINIS Response assessed. The analysis will be complimented by a projection of potential effects of developments in the Selenge River basin and around the Lake Baikal. Generally, the potential projects will include only minor abstractions of water, and the flow rate of Selenge River will likely be affected in an order of magnitude of under 1%. Both Are the risks and consequences of the increase in the level of wild fire Risks of fire and other threats due to decreased water level will projects risks in the forests caused by a decrease in the water level and, as a be included in the scope of REA. The cumulative studies possible consequence, a change in the microclimate, characterized by within the REA will also investigate natural forces, e.g. an increase in the dry season in the summer, are calculated? climate change / global warming, and its effects on the (Severobaikalsk) occurrence of forest fires. The detailed microclimatic effects of the projects would be investigated in detail, if a decision to proceed with the ESIAs is taken. Both What are the compensation measures for the indigenous inhabitants of The REA will provide preliminary estimates of potential projects the Republic of Buryatia, engaged in traditional activities - the impacts on land and livelihoods including identification of the extraction of aquatic biological resources and hunting, in case of type and scale of any required resettlement., both in the changes in the habitat of traditional hunting zoness and certain fish immediate project area and in the wider zone of potential species, including the Baikal cisco? (Kholodnoe Evenkiiskoe) impacts (Selenge Basin and Lake Baikal). A detailed social assessment including household surveys and data collection will be conducted as part of a Resettlement Action Plan during the detailed ESIA stage, if a decision is made to proceed to that stage. At this detailed stage, planning for involuntary resettlement will follow a mitigation hierarchy where such resettlement will be avoided where possible, and minimized and appropriately compensated for where necessary and unavoidable. Where resettlement is deemed to be necessary, the objective of the Resettlement Action Plan will be to ensure that affected stakeholders are actively involved in decision- making about options and alternatives, that all affected assets are compensated for in kind or in cash, at replacement cost; that the resettlement results in livelihood improvement (or restoration); and that vulnerable households are identified and provided with eligible support. If required, the plan will involve site selection (including environmental assessment of proposed sites), site preparation, and relocation; and 2 Project Question/Comment MINIS Response replacement or restoration of public infrastructure and social services. The costs and budget for the resettlement should be identified as part of the plan, including all unit rates for compensation, and including contingencies for price escalation and unanticipated expenses; Identification of parties to finance the cost of implementation of a Resettlement Action Plan is the responsibility of the Government of Mongolia. Both Was there an inventory of places where animals were disposed in the The flooded area will be determined during the REA. The projects flood zones? What measures are envisaged in the project to ensure requirements of the legislation of Mongolia are stringent with sanitary and epidemiological safety in this case? (Baikalskoe respect to disposal of dead carcasses of domestic animals. All Evenkiiskoe) the necessary measures to prevent the threat of sanitary and epidemiological welfare to the population are taken. Over the past 20 years, there have been no cases of an unfavorable sanitary-epidemiological state of the environment in Mongolia. But this issue will need to be more closely studied in the REA. Generally, the reservoir area will be carefully prepared for inundation, including vegetation clearing, removal of any hazardous substances (including animal carcasses), the salvage of archeological and cultural artifacts, and the relocation of cemeteries and graves. Written feedback received in February-April 2017 Project area Both A study of impacts on peatlands and wetlands in delta of Selenga The study area under the REA will extend upstream and projects should be added in the REA. (Nizhneangarsk) downstream over the entire Selenge River basin from the project site including Lake Baikal. The impacts of the potential projects on sensitive receptors such as peatlands and wetlands will be considered in the REA. Lake Baikal Both The project will have a negative impact on ecological state of Lake At this time the studies on the regional and project-specific projects Baikal, and can lead to drying of the lake. HPP is potentially going to impacts are only being designed. This consultation process is 3 Project Question/Comment MINIS Response be for the mining industry, and the risk of inflow waste to lake, and part of the process of finalizing the TOR, which in turn are the other pollutants will harm cisco. (Nizhneangarsk) key document that drives and shapes the course of the studies. It is too early to make conclusions on particular anticipated impacts on Selenge River and Baikal Lake. It is precisely the purpose of the consultations to get the study design right to ensure all necessary data and information are collected and analyzed, and that risks and impacts are properly recognized and addressed, and management, mitigation and monitoring measures defined. The study area under the REA will extend to Lake Baikal. The REA will identify any potential impacts of the proposed projects on the outstanding universal value and integrity of Lake Baikal. The REA will help identify whether there is a threat to biotic communities in Lake Baikal and whether unique ecosystem properties of Lake Baikal could be adversely impacted as a result of existing and planned projects. The water quality and water level will be analyzed as part of the baseline assessment within the REA. The analysis will be complimented by a projection of potential effects of developments in the Selenge river basin and around the Baikal Lake. All available relevant information on hydrology, hydrochemistry and water pollution will be collected, compiled, organized, reviewed and assessed. General concerns about environmental impacts Both Against HPP in