Initial Environmental Examination

Project Number: 44321-013 November 2019

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

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

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

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

KINGDOM OF CAMBODIA Nation Religion King

Ministry of Economy and Finance

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

Initial Environmental Examination for Establishment of Paddy Drying and Storage Facility at Phou Poy Rice Mill in Chumnik Village, Commune, , Province

November 2019

CURRENCY EQUIVALENTS (November 2019)

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

ABBREVIATIONS

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

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

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... vi I. INTRODUCTION ...... 1 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 1 A. Government Environment Policy and Regulation ...... 1 1. Law on Environmental Protection and Natural Resource Management ...... 1 2. Environmental Impact Assessment Process Sub-Decree ...... 2 B. Evaluation Standards ...... 3 C. ADB Environment Requirement ...... 5 D. Environmental, Health, and Safety Guidelines ...... 7 III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN ...... 7 A. Subproject Provinces ...... 7 B. Subproject Scope...... 8 C. Subproject Context...... 9 IV. DESCRIPTION OF THE ENVIRONMENT ...... 10 A. Physical Resources ...... 10 1. Topography, Geology and Soils ...... 10 2. Climate ...... 10 3. Water Resources ...... 12 B. Biological / Ecological Resources ...... 12 C. Socio-economic Resources ...... 13 1. Items of Historical and Archaeological Significance ...... 13 2. Human and Economic Development ...... 13 1) Livelihoods ...... 13 2) Poverty Levels ...... 14 3) Health ...... 15 4) Unexploded Ordinance ...... 15 V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ...... 15 A. Method of Assessment ...... 15 B. Environmental Impacts Related to Location ...... 15 C. Environmental Impacts Related to Construction ...... 16 D. Environmental Impacts Related to Operation ...... 17 E. Global, Trans-boundary and Cumulative Impacts ...... 18 VI. ANALYSIS OF ALTERNATIVES ...... 18 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...... 19 A. Consultations and Information Disclosure during design ...... 19 B. Further Information Disclosure ...... 21 VIII. GRIEVANCE REDRESS MECHANISM ...... 21 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 23 A. Responsibilities for Environmental Management ...... 23 B. Environmental Monitoring ...... 24 1. Monitoring for Compliance with EMPs ...... 24 2. Testing for Noise and Dust Control ...... 24 C. Environmental Monitoring Reports ...... 25 D. Institutional Arrangement and Responsibilities ...... 25 X. CONCLUSION AND RECOMMENDATIONS ...... 25 XI. REFERENCES ...... 26 XII. ANNEXES ...... 27 Annex 1: Agreement of Phou Poy Rice Mill with PDOE, Battambang ...... 27 Annex 2: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation ..... 29 Annex 3: Land Title of Phou Poy Rice Mill Issued by PDLMUPC ...... 30

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Annex 4: Existing Location of Phou Poy Rice Mill ...... 33 Annex 5: Detail Design of PDS facility for Phou Poy Rice Mill ...... 34 Annex 6: Calculation of Capacity Including Raw Materials for PDS facility at Phou Poy Rice Mill ...... 35 Annex 7: Total Annual and Average Monthly Rainfall from 2011-2018 in Battambang ...... 36 Annex 8: Rapid Environmental Assessment (REA) Checklist...... 37 Annex 9: Environmental Management Plan Summary) ...... 42 Annex 10: Environmental Monitoring Plan ...... 49 Annex 11: List of participants in the consultation meeting ...... 59

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LIST OF TABLES

Table 1: Annex of Sub-Decree No 72 ANRK. BK. (SA II-A7) (Dated: 11 August 199) ...... 2 Table 2: Drinking Water Standards (2004) ...... 4 Table 3: Ambient Air Quality Standard ...... 5 Table 4: Maximum Permitted Noise Level at Workshop, Factory and Industry Area (dB) ...... 5 Table 5: Rice Crop Production by Season ...... 13 Table 6: Poverty levels (2010-2017) by district in Battambang ...... 14

LIST OF FIGURES Figure 1: Location of Project Provinces ...... 7 Figure 2: Location of Phou Poy Rice Mill ...... 8 Figure 3: Annual Rainfall from 2011-2018 at Battambang ...... 11 Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang ...... 11 Figure 5: Photo of consultations meeting with relevant stakeholder ...... 20 Figure 6: Grievance redress mechanism ...... 22

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EXECUTIVE SUMMARY

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

2. The Rice Millers eligible to avail the concessional loans from Rice-SDP to establish the PDS Facilities are selected following a cumbersome process. Upon receipt of the expression of interest (EOIs) from the Rice Millers, the PMO conducted a feasibility study through engaging an independent firm, assessed the Rice Millers’ PDS business proposals, and came up with a Final Ranking of the Rice Millers before employing a detailed design and construction supervision (DD & CS) consulting firm (IRE) to support the Rice Millers. The final ranking of the Rice Millers was endorsed by the PDS Selection Committee. The Phou Poy Development Import Export Co., Ltd (Phou Poy Rice Mill) is ranked first in and therefore got selected to avail the concessional loan for establishment of PDS Facility. After the ranking, both the PMO and the DD & CS consultants worked with the Phou Poy Rice Mill and completed the initial survey for detailed design, verification of the proposed location, site layout for construction, system and process design, machine layout drawings, detailed design and specifications of equipment, and budget estimates for the Facility. Following the detailed design of the Facility, a Public Consultation Meeting on environmental and social safeguards impact assessment for the proposed PDS Facility was conducted by a Rice-SDP technical team comprising of MEF/PMO officials and consultants, MAFF/NIO officials and consultants, and DD&CS consultants together with the provincial officials. The main focus of the assessment was to avoid risks and support the Rice Miller to strengthen his/her safeguard systems and develop the capacity to manage environmental and social risks.

3. The feasibility study and subsequently the detailed design present a proposal for establishment of a PDS Facility within the existing business compound of the Phou Poy Rice Mill located in Chumnik village, Anlong Vil commune, Sangkae district, Battambang province. The Phou Poy Rice Mill owns about 60 hectares of a single piece of land including rice mill compound and adjoining farm land in the location, and the proposal proposes establishment of a PDS Facility on an area of 2,880m2 (around 0.29ha) within the existing rice mill compound of the Phou Poy Rice Mill. The proposed Facility will have a drying capacity of 300-800 tons per day (TPD) of wet paddy.

4. The proposed Facility is not environmentally critical and not within or adjacent to environmentally sensitive areas and regarded as Category B for environmental impact (according to ADB project framework criteria). The proposed works will mainly involve construction of a PDS facility with the dryer size being 24 m x 60 m x 21 m (Width x Length x Height) and storage building size being 24 m x 60 m x 17 m (Width x Length x Height). The activities will not be critically harmful to the environment. The few adverse direct impacts during construction are expected to be local, temporary and short-term and most likely to occur during working hour of

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the construction period. These will not be sufficient to threaten or weaken the surrounding natural resources. The Rice Miller has applied and received the Environmental Protection Agreement from Provincial Department of Environment (PDOE) as part of establishing the PDS Facility and improving the business operation performance to fulfill the Government’s requirements. The specific environmental management plan (EMP) addressing adequate mitigation measures to be implemented by the contractor especially during the construction of the PDS Facility is in place.

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

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I. INTRODUCTION

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

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

8. The proposed PDS facility for Phou Poy Rice Mill includes social and environmental safeguards assessment and management plan. The purpose of the Facility is to increase paddy drying capacity by 300-800 tons per day (TPD), disseminate new technology, and reduce the flow of wet paddy to neighboring countries. The Phou Poy Rice Mill owns about 60 hectares of a single piece of land including rice mill compound and adjoining farm land in the location (land title issued by Provincial Department of Land Management and Urban Planning-“PDLMUPC”, Battambang, on 31 July 2006), and the proposed Facility will be established on an area of 2,880m2 (around 0.29ha) within the existing rice mill compound of the Phou Poy Rice Mill.

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

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. Government Environment Policy and Regulation

1. Law on Environmental Protection and Natural Resource Management

10. The Law on Environmental Protection and Natural Resources Management was enacted by the National Assembly and launched by the Preah Reach Kram/NS-RKM-1296/36 on December 24th, 1996. This law has the following objectives: (i) To protect and promote environment quality and public health through prevention, reduction and control of pollution;

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(ii) To assess the environmental impacts of all proposed projects prior to the issuance of a decision by the Government; (iii) To ensure the rational and sustainable conservation, development, management and use of the natural resources of the Kingdom of Cambodia; (iv) To encourage and provide possibilities for the public to participate in the protection of environment and the management of the natural resources; and (v) To suppress any acts that cause harm to the environment.

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

2. Environmental Impact Assessment Process Sub-Decree

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

13. The sub-decree includes an annex which provides information on development projects requiring EIA or IEIA. An excerpt for relevant projects is provide in Table 1 below.

Table 1: Annex of Sub-Decree No 72 ANRK. BK. (Dated: 11 August 1999)

List of Projects Requiring an IEIA or EIA No. Type and activities of the projects Size /Capacity

A. INDUSTRIAL I. Foods, Drinks, Tobacco 1 Food processing and caned ≥ 500 Tones/year

2 All fruit drinks manufacturing ≥ 1,500 Litres / day

3 Fruit manufacturing ≥ 500 ones/year

4 Orange Juice manufacturing All sizes

5 Wine manufacturing All sizes

6 Alcohol and Beer brewery All sizes

7 Water supply ≥ 10,000 Users

8 Tobacco manufacturing ≥ 10,000 Boxes/day

9 Tobacco leave processing ≥ 350 Tones/ year

10 Sugar refinery ≥ 3,000 Tones / year

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11 Rice mill and cereal grains ≥ 3,000 Tones / year

12 Fish, soy bean, chili, tomato sources ≥ 500,000 Litres/ year

B. AGRICULTURE

1 Concession forest ≥ 10,000 Hectares

2 Logging ≥ 500 Hectares

3 Land covered by forest ≥ 500 Hectares

4 Agriculture and agro-industrial land ≥ 10,000 Hectares

5 Flooded and coastal forest All sizes

6 Irrigation systems ≥ 5,000 Hectares

7 Drainage systems ≥ 5,000 Hectares

8 Fishing ports All sizes

14. Since this PDS Facility involves agriculture and agro-industrial land much less than that prescribed above (Table 1), it is not required to do the environmental impact assessment based on sub-decree No 72 ANRK.BK. However, as the Facility comes under the rice mill and cereal grains industrial activities, the Phou Poy Rice Mill has applied and received the Environmental Protection Agreement from Provincial Department of Environment (PDOE) as part of establishing the PDS Facility and improving the business operation performance to fulfill the Government’s requirements (see Annex 1). The proposed Facility will be constructed within the existing rice mill compound owned by the Phou Poy Rice Mill and will be monitored by PDOE as mentioned in the Environmental Protection Agreement.

B. Evaluation Standards

1) Law on Water Resources Management

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

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

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

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2) Water pollution control sub-decree

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

3) Drinking Water Quality Standards

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

Table 2: Drinking Water Standards (2004)

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

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

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

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Table 3: Ambient Air Quality Standard1

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

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

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

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

C. ADB Environment Requirement

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

(i) Avoid adverse impacts of projects on the environment and affected people, where possible; (ii) Minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and (iii) Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks.

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

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

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

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

26. The main purpose of the Rapid Environmental Checklist is to screen the potential environmental impacts of the proposed PDS Facility for Phou Poy Rice Mill that may occur during project design, construction, and operation phase. The environmental study is undertaken through field investigations and screening of potential impacts both negative and positive and developing of mitigation measures for each negative impact are made. Based on the results of the environmental and social field investigations and recommendation from relevant stakeholders and local communities in the project area, the potential environmental impacts that are expected to occur due to the project activities during pre-construction, construction, and operation phases are noted and their mitigation measures established. The results of Rapid Environmental Assessment are described in Annex 8.

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D. Environmental, Health, and Safety Guidelines

27. ADB’s Safeguard Policy Statement applies pollution prevention and control technologies and practices consistent with international good practices as reflected in internationally recognized standards such as the World Bank Group’s Environmental, Health and Safety Guidelines. The Guidelines provide the context of international best practice and contribute to establishing targets for environmental performance. The air and noise standards in the EHS guidelines will be used to complement the Government standards in this document where needed. Occupational and community health and safety, as laid out in the EHS Guidelines, will be a cross-cutting assessment for the Facility.

III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN

A. Subproject Provinces

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

Figure 1: Location of Project Provinces

29. Battambang is located in the Northwest of Cambodia and borders Banteay Meanchey to the north, to the south-east and south, to the northeast,

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

B. Subproject Scope

30. The proposed PDS Facility for Phou Poy Rice Mill will be constructed within the existing Rice Mill compound situated on the National Road No. 5, Chumnik Village, Anlong Vil commune, Sangkae District in Battambang province. The existing Rice Mill started its operation since 1990 and running for the last 29 years. Thus, the Rice Miller has vast experience in rice milling industry. The Rice Mill is located on a single piece of 60 ha of land owned by the Rice Miller of which around 10 ha has been fenced (land title issued by PDLMUPC, Battambang, on 31 July 2006 is attached as Annex 3). The Rice Mill front boundary borders National Road No.5 and across the road there are residential area and behind the settlements are private rice lands. In the back of the Rice Mill, adjacent to the backyard boundary are rice farms belonging to the Rice Mill. In the left, adjacent to the left side boundary, there is Department of Transportation and to the right, adjacent to the right side boundary, there is one small abandoned rice mill. (see Figure 2 below and Annex 4). The current milling capacity of the Rice Mill is 5-6 tons per hour (i.e. 43,000 tons paddy per year). Existing drying type is Batch columnar recirculation type for a volume of 180 TPD. The Rice Miller has currently engaged 25 workers of which 13 are women.

Figure 2: Location of Phou Poy Rice Mill

31. The proposed PDS Facility will be built on a plot of about 2,880 m² inside the existing Rice Mill compound. The proposed works will mainly involve construction of a PDS facility with

Page | 8 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill the dryer size being 24 m x 60 m x 21 m (Width x Length x Height) and storage building size being 24 m x 60 m x 17 m (Width x Length x Height). The proposed Facility will have a drying capacity of 300-800 TPD of wet paddy. Some of the salient features of the Facility to be established are:

. Drying system: Modern drying plant will be installed which will start from Paddy intake – Precleaning – Weighing – 1st Stage Fluidized Bed Drying (Fast drying) – Conditioning – 2nd Stage Louisiana State University (LSU) Drying – Weighing and Storing. All immature grains and dust will be sent to storage room. . Bulk handling system: During drying process, wet paddy will be conveyed by bucket elevators and dried paddy will be conveyed by overhead belt conveyor to storage room. . Biomass furnace: This direct heat furnace will be a Cyclonic type which will use mainly husk as biomass fuel. The amount of husk used will be 25 TPD (≥ 1,500- 2,000 tons per year) which will be collected from the rice mill. Currently the Rice Miller also uses husk as biomass fuel for their furnace/burner.

. The amount of ash generated per day will be 1 TPD (≥ 60 ton per year) but no ash/smoke will be released to the environment as the Cyclonic type furnace has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income.

. Storage system: Warehouse type with aeration system including some bag storage for different varieties of paddy.

. Construction: Construction work will use a small amount of water only as readymade mixed concrete from supplier will mainly be used. Contractor will install onsite WC for their workers. Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. Noise from hammering (for temporary period only) initially during construction period will be monitored and managed through use of new motor or good maintenance.

. Operation: No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance.

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

C. Subproject Context

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

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34. The Phou Poy Rice Mill is located about 7 km from Battambang town along road No. 5 to . The establishment of PDS facilities at Phou Poy Rice Mill will expand the current capacity of drying wet paddy by 300-800 TPD thereby improve the quality and quantity of domestically milled rice, increase the capacity for paddy storage in Battambang, accommodate paddy supplies at peak periods after harvest, reduce the movement of unprocessed paddy across the border to Thailand and Viet Nam immediately after harvest, ensure better quality for processing and retained added value in Cambodia. The improvement in the Facilities will also help the Rice Miller achieve a fully satisfactory performance of the rice mill by ensuring its durability and economic efficiency. In the immediate setting, the surrounding villages will benefit greatly from establishment of the Facility as most of the villagers cultivate paddy and the Rice Miller can buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport far, and their sons/daughters could work as labor at the Facility to earn income. After the completion of the facilities, the Rice Mill may employ double the number of villagers it is employing currently to work in the mill.

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

IV. DESCRIPTION OF THE ENVIRONMENT A. Physical Resources

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

2. Climate 37. Cambodia has a moist tropical climate, classified as equatorial monsoonal5, consistent with its location 10-13 degrees latitude north of the equator. The climate features warm to hot temperatures throughout the year and an annual monsoon cycle of alternating wet and dry seasons. The main wet season, the Southwest monsoon, occurs between June and October, when reduced air pressures over Central Asia cause air to be drawn landward from the Indian Ocean. Project Management and Contractors need to be aware that there has been considerable change in the incidence of drought and late arrival of wet season rains

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

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

Page | 10 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill across Cambodia. Approximately 80% of all rainfall occurs during this season. Conversely, during the cooler months between November and January, air flows over Cambodia originate from Central Asia and are drier, resulting in cooler and less rainy weather. It is projected that as a result of Climate Change, the amount of rain fall in the wet season will increase, the duration of the wet season will be shorter and periods of dry spell will occur within the wet season. The dry season is expected to be longer.

38. Flooding data has been recorded in every Sangkat (commune) of during the rainy season from June to December. In 2013, serious floods affected the whole province (flooding occurred mostly in October to December). The highest level of flooding occurred in Svay Por and Preak Sdach Sangkats with water depth ranging from one to two meters

39. The Battambang weather station managed by the PDWRAM, Battambang is situated near the proposed PDS Facility for Phou Poy Rice Mill. The detailed design for the proposed Facility considered the last 8 years rainfall data i.e. from the year 2011 to 2018. The annual rainfall during 2011 to 2018 at Battambang weather station varied from 885 mm to 1,657 mm with the average being 1230 mm. (Annex 7 & Figure 3 below).

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

1,500.0

1,000.0

Rainfall, mm 500.0

- 2011 2012 2013 2014 2015 2016 2017 2018 Year

Source: Provincial Department of Water Resources and Meteorology

40. The wet-season in Cambodia starts from May to October. Peak levels of rainfall are up to 96.8 mm in a day found in March 2017 and 191 mm in one day in July 2014 may be return storm period. The average monthly rainfall recorded during 2011 to 2018 at Battambang weather station varied from 8.5 mm in January to 226.4 mm in September. (see Annex 7.1 & Figure 4 below). Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang Average Monthly rainfall (Year 2011-2018) 250.0 200.0 150.0 100.0 50.0 0.0 Ma Ma Rainfall, mm Jan Feb Apr Jun Jul Aug Sep Oct Nov Dec r y Rainfall(mm) 8.5 8.7 40.4 60.0 109. 138. 157. 116. 226. 220. 71.2 11.9 Month

Source: Provincial Department of Water Resources and Meteorology

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3. Water Resources

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

42. Groundwater occurs in aquifers in the Pleistocene deposits and is used in the proposed PDS Facility area for domestic purposes. Deeper, more substantial aquifers may occur in rock layers but extensive geophysical and drilling exploration is needed to assess the potential of groundwater for use. Along with ground water, water supplied by district water supply in the Facility area is mainly used for domestic purposes. The Toul Sangke River is about 7km from the Phou Poy Rice Mill. The Rice Mill has 2 private water ponds (30m x 50m) which harvests rain water and used for cultivation purposes.

B. Biological / Ecological Resources

43. Based on Royal Decree (Preah Reach Kret) on the Establishment and Designation of Protected Areas of November 01, 1993, there are 23 Protected Areas, of which 4 natural protection areas are located in Battambang province: (i) 59,000 ha of Phnom Samkos Wildlife Sanctuary situated in Samlot and Koskralor district. (ii) 400 ha of Dounsam wildlife protection area in small forest of Kamreang, Phnomprek, Sampovloun and Barvil district. (iii) 20,000 ha of Samlot Multiple Use Area (forest protection area) situated in Samlot district (iv) 20,000 ha of Prektorl flooded forest protection area situated in Aekphnom and Sangkae district 44. The proposed PDS Facility for Phou Poy Rice Mill is located far away from these protected areas. It’s about 7km from . The flooded forest and forest surrounding Battambang province are reportedly have been destroyed for commercial and family rice farming affecting the habitats of fisheries and birds (source: Battambang Development Plan, 2016-2018).

45. The aquatic ecosystems that occur in the Battambang include seasonally flooded fields and small streams and are important habitats to fish, aquatic reptiles and amphibians. At least 500 fish species recorded in the Cambodia’s Mekong River (the Lower Mekong basin encompasses at least 1,200 fish species). Within the above figure, 296 fish

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

Page | 12 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill species are from Tonle Sap Lake. So both Mekong River and Tonle Sap Lake have great diversity of fish species in Cambodia (Source: So Nam, 2010).

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

C. Socio-economic Resources

1. Items of Historical and Archaeological Significance

47. Ancient structures, mainly temples and shrines but sometimes bridges and water storage or control structures are common over the Cambodian landscape, with the major cluster in the Angkor temple complex within Siem Reap. However, no ancient structures, no temples or shrines are located around the proposed PDS Facility.

2. Human and Economic Development 1) Livelihoods

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

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

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

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

50. Aquatic ecosystems are vulnerable to the effects of agrochemical use, particularly pesticides. The pesticides in use in the area included products that are known to contain

Page | 13 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill compounds that are classified as persistent, such as 2 4-Dichlorophenoxyacetic acid (2 4-D), or methyl parathion, the active ingredient in the product Folidol.7 While these compounds progressively break down on release, fish and other aquatic organisms can be harmed, particularly as a result of improper, uninformed or irresponsible use or methods of container disposal. The proposed PDS Facility does not deal with the pesticides and hence will have no negative effect on aquatic ecosystem. However, the project through associated activities (as mentioned in para 35), will strengthen the technical extension services directed at farmers and ACs on the use of pesticides.

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

2) Poverty Levels

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

53. Based on the Battambang Development Plan, the poverty level in Sangkae district of Battambang province has reduced from 22.98% in 2010 to 18.99% in 2017(see Table 6 below). In the Anlong Vil Commune of Sangkae District, where the proposed PDS Facility is located, the poverty rate has decreased from 32.50% in 2004 to 17.30% in 2012 (Ministry of Planning, 2012). The proposed PDS Facility will significantly contribute to a qualitative improvement in the villagers living standards as they will get opportunity to expand their rice business as the Rice Miller will buy more paddy from them than earlier times, farmers will be able to save on transportation cost as they do not have to transport the paddy very far, and also they can work as labor at the Facility to earn income.

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

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

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3) Health

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

55. Battambang province has 6 referral hospitals, 77 health centers, 365 private clinics, 13 laboratories and 213 pharmacies (Source: Battambang Development Plan 2016-2018). In the Sangkae district where the proposed PDS Facility is located there is one district referral hospital and nine health centers including one in Anlong Vil commune.

4) Unexploded Ordinance

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

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

A. Method of Assessment

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

B. Environmental Impacts Related to Location and Pre-construction

58. The proposed PDS Facility is located barely 7km from Battambang town that is expanding following improvements to the national road network. The site has good road access for both the construction and operation phases. The Facility will be constructed on a plot of about 2,880 m² inside the existing Rice Mill compound which is elevated from the ground level. However, if needed, the surface level of the ground may further be raised. A Land Acquisition and Resettlement Plan for the Facility is not relevant as the land is privately owned.

59. The area is on a floodplain, susceptible to floods. Flooding causes risks of release of

Page | 15 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill waste from the grain handling process and from toilets within the facility. These can be mitigated by the construction of building and treatment ponds on raised platforms and inclusion of provisions for drainage of a specification sufficient for safe draining of flood water.

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

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

C. Environmental Impacts Related to Construction

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

63. The preparation of foundations for the building will involve excavation/drilling (albeit upon a filled area). Excavation operations may result in the release of silt and dust. Some or all of the material produced by the excavations will be used on site to create a raised platform for treatment ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to surrounding location.

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

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

66. Much of the labor and some of the skilled labor required for the work will be obtained locally, however contractors are likely to bring staff from other parts of Cambodia, who will be accommodated locally during construction, either in rented accommodation or in temporary housing. Interactions with local residents can potentially lead to the spread of communicable diseases, social disturbance and the release of raw sewage from temporary toilets. Potential effects will be mitigated by (i) maximizing employment form local residents, to the extent

Page | 16 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill practicable, (ii) construction of suitable toilets such as pit latrines on sites identified by local communities, and arrangements for grey water treatment and discharge, such as soakage pits, to minimize the release of pollutants into waterways, (iii) arrangements for collection of solid waste, (iv) briefing of workers and awareness raising of the local population on potential risks of infection and communicable diseases, including advice on avoidance of such problems, and (v) allocation of responsibility to an on-site member of the contractor’s staff to ensure that these measures are observed continuously.

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

D. Environmental Impacts Related to Operation

68. The facility will be housed in a large industrial scale building constructed for the purpose and will contain storage and transfer bays and specially designed high capacity machinery for processing functions. Potential health and safety hazards to workers include accidental contact with moving parts, noise nuisance and respiratory problems from dusty conditions. These risks are mitigated by the inclusion of safety railings, and by training and instruction to workers.

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

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

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

72. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the

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Rice Miller or provided to farmers as a slurry. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels.

73. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary.

74. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. An assessment of the adequacy of the water supply will be made to test the water quality and quantity. If water from the supply is not potable or available in adequate quantity, alternative sources of water shall be investigated, which may include the collection and storage of rain water (as a partial supply), or use of groundwater. Provision shall be made for treatment for use to render it safe for washing purposes, while potable water shall be obtained from a supply approved by the Ministry of Industry, Mines and Energy.

75. The site will be prone to periods of intense rainfall during storm events and may be subject to occasional flooding. The design of the building will therefore include provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water when this occurs. The drainage system will be sufficient to prevent the formation of ponds and muddy patches within the facility compound. Adequate fill is proposed to raise the ground level to a height that poses little risk from flooding.

E. Global, Trans-boundary and Cumulative Impacts

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

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

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

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

VI. ANALYSIS OF ALTERNATIVES

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

Page | 18 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill verges, where the crop is subject to contamination by vehicle fumes and pathogens on the ground, as well as uneven drying and the potential for fungal infestation to develop.

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

VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultations and Information Disclosure during design

82. Consultations were conducted from early subproject preparation stage relating to preliminary engineering designs prepared by the consultants and other items concerning to the subproject implementation through visits to the subproject site, commune and PIO during February-March 2019. The subproject was discussed with the Governor’s office, and with the director and staff of the provincial department of agriculture (PDA) in the province.

83. A public consultation meeting was conducted on 24 May 2019 at the subproject site to undertake subproject screening and design tasks through discussions with relevant stakeholders including Rice Miller, villagers including those who have land boundaries with the proposed subproject site, village chief, commune chief, district governor, PIO director, PDOE director, PDAFF staff, PDLMUPC staff, provincial gender focal point, etc. and with the participation of MAFF officials, PMO officials & consultants, and DD& CS consultant for PDS Facilities. A total of 22 participants including 5 women participated in the consultation meeting. (See Annex 11).

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

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Figure 5: Consultation meeting with relevant stakeholders and visit to proposed PDS Facility location

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B. Further Information Disclosure

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

VIII. GRIEVANCE REDRESS MECHANISM 86. People living close to a development site may experience some adverse impact during the subproject implementation period. People who may be affected by the subproject or concerned about its environmental impacts are entitled to lodge complaints regarding any aspect of the preparation and implementation of the subproject.

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

88. A well-defined grievance redress and resolution mechanism is established to resolve grievances and complaints in a timely and satisfactory manner. The PMO has informed and discussed about it with the villagers during the public consultation meeting. All affected persons will be made fully aware of their rights, and the detailed grievance redress procedures will be publicized through an effective public information campaign. The grievance redress process applies to potential environmental issues and includes four steps of which three are followed before complaints may be elevated to a court of law as a last resort, as follows (see Figure 6 below):

(i) 1st step: Complaints and grievances will be provided verbally or in writing to the village chief and/or commune chief. The receiving agent will provide immediate written confirmation of receiving the complaint. If after 15 days the complainant does not hear from the village chief and/or commune chief or if he/she is not satisfied with the decision taken in the first stage, the complaint may be brought to the District Office. (ii) 2nd step: The District Office in cooperation with the Provincial Implementation Office (PIO) representative and PDAFF officials has 15 days within which to resolve the complaint to the satisfaction of all concerned. If the complaint cannot be solved at this stage, the District Office will bring the case to the Provincial Governor Office (PIO) and/or Provincial Grievance Redress Committee (PGRC) and has to inform the

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complainant.

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

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

Figure 6: Grievance Redress Mechanism

Next Higher Court

Provincial court

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

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

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

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

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

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

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

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

IX. ENVIRONMENTAL MANAGEMENT PLAN

A. Responsibilities for Environmental Management

93. The environmental management plan (EMP) covers all phases of core subproject implementation from preparation through commissioning and operation, and it aims to ensure the monitoring of environmental impacts and activation of environmental mitigation measures. Relevant parts of the EMP will be incorporated into the construction, operation, and management of subproject. Environmental protection measures will (i) avoid, and (ii) where avoidance is not possible, mitigate environmental impacts, and (iii) achieve compliance with national environmental regulations and ADB safeguard Policy statement 2009.

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

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

96. During PDS facility operation, responsibility for mitigation rests primarily with the Rice Miller supported by relevant provincial departments. The summary of environmental management plan is in Annex 9.

B. Environmental Monitoring

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

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

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

1. Monitoring for Compliance with EMPs

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

2. Testing for Noise and Dust Levels

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

102. Noise levels will be determined with an integrating noise meter. The maximum noise level in a workshop, factory and industry as specified in Annex 7 of the Sub-decree on Air Pollution and Noise Disturbance (2000) is 85 dB(A). This should be taken as the continuous noise equivalent level of 85 dB(A) Leq, and determined by using an integrating noise meter.

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Readings and analysis will be undertaken once per year during operation, at each plant.

C. Environmental Monitoring Reports

103. To ensure proper and timely implementation of the EMP and adherence to the agreed environmental covenants, the PMO will submit semi-annual environmental monitoring report to the ADB including environmental performance based on the monitoring and inspections data and the report will be disclosed on the ADB website.

D. Institutional Arrangement and Responsibilities

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

105. The PMO will shoulder all administrative costs incurred in the resolution of grievances and complaints within the project-level grievance redress mechanism and is responsible for implementing the EMPs. During the design and construction phases, the PMO will be supported by the PIOs. The winning contractor shall prepare the CEMP and upon endorsement by the Program Manager will be fully responsible for its implementation. The PMO will be supported by the DD&CS consultants on safeguard implementation, monitoring and reporting activities. The environmental specialist and other cross sectorial implementation consultants of the program will provide necessary backstopping in review and finalization of reports and recommendation of mitigation measures based on EMP. During PDS facility operation, responsibility for mitigation will rest primarily with the Rice Miller supported by relevant provincial departments (PDOE/PDOLVT).

X. CONCLUSION AND RECOMMENDATIONS

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

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

108. During consultation meeting and field observation all relevant stakeholders confirmed

Page | 25 Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill that the proposed PDS Facility site and its surrounding area have been actively cultivated since the years of conflict, and they did not come across with any UXO in the proposed area. The safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in subproject area.

109. It is recommended that the EMP is included in contract document for works contracts.

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

XI. REFERENCES

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

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XII. ANNEXES

Annex 1: Agreement of Phou Poy Rice Mill with PDOE, Battambang

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Kingdom of Cambodia Un-official Translation Nation Religion King

Environmental Protection Agreement

I am Ith Michael, age 36 years old, Cambodia Nationality, ID Card: 170565814 dated 26 January 2011; Expire date: 26 January 2021, Permanent Address: 20 Uksaphea Village, Sangkat Prek Preah Sdach, Krong Battambang, Battambang Province, Representative of Phou Poy Rice Mill.

To: Director of Battambang Provincial Department of Environment

To contribute to environmental protection in the process of social development, I do the following environmental commitments to Battambang Provincial Department of Environment for Phou Poy Rice Mill business operation that is located in Chumnik Village, Anlong Vil Commune, Sangkae District, Battambang Province, as below:

Provision1. Ensure management of liquid waste storage tanks, and properly manage sediment discharge from the storage tank before releasing it to authorized areas or the public sewer system. Provision2. Ensure the management of garbage, do not dispose off the garbage in public places or areas near the source of water thereby affecting the public order, aesthetic and also people who have residences nearby. Provision3. Ensure minimization of noise, vibration, dust, and odor release due to rice mill operation and avoid health hazards to workers and people living nearby due to the release. Provision4. Allow Environmental Officer from Battambang Provincial Department of Environment who has valid mission letter to inspect the rice mill site every 30 days to advise on pollution control in the environment. Provision5. In case the department or the Ministry of Environment requires me to modify any environmental techniques to comply with the new guidelines and standards, I would completely agree to the guidelines. Provision6. Volunteer to contribute some funds as environment fee to Battambang Provincial Department of Environment every year.

Provision7. This agreement is valid for one year from the date of this agreement. 30 days prior to the expiry of this agreement, I will submit a request for renewing the agreement to Battambang Provincial Department of Environment for the new term. Provision8. In the case that I failed to comply with any provision or contrary to this agreement, I shall be fully responsible under the relevant Cambodian Laws, especially Environmental Protection and Natural Resources Law.

BTB Date: 29.04.2019 No. 162/Bor.Sor.khor.Bor Seen and Verified Thumb Print Seen and Approved To Director of PDOE BTB Date: 29.04.2019 BTB Date: 29.04.2019 Director of PDOE Chief of Environmental

Protection Office Ith Michael

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

No Parameter Unit Standard Value A. River 1 pH mg 6.5 – 8.5 2 BOD5 mg 1 – 3 Suspended Solid mg 25 – 100 4 Dissolved Oxygen mg 2.0 - 7.5 5 Coli-form MPN/100ml < B. Lakes and Reservoirs 1 pH mg 6.5 – 8.5 2 COD mg 1 3 Suspended Solid mg 1 – 4 Dissolved Oxygen mg 2.0 - 7.5 5 Coliform MPN/100ml < 6 Total Nitrogen mg 0.1 – 0.6 7 Total Phosphorus mg 0.005 – 0.05 C. Coastal water 1 pH mg 7.0 – 8.3 2 COD mg 2 3 Dissolved Oxygen mg 2 – 4 Coliform MPN/100ml < 5 Oil content mg 0 6 Total Nitrogen mg 0.2 – 1.0 7 Total Phosphorus mg 0.02 – 0.09 Note: l = liter; mg = milligram; ml = milliliter Source: Annex 4 of Sub-decree on Water Pollution Control, 1999

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Annex 3: Land Title of Phou Poy Rice Mill Issued by PDLMUPC

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Annex 4: Existing Location of Phou Poy Rice Mill

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Annex 5: Detail Design of PDS facility for Phou Poy Rice Mill

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Annex 6: Calculation of Capacity Including Raw Materials for PDS facility at Phou Poy Rice Mill

PHOU POY DEVELOPMENT BATTAMBANG RAW MATERI AL CALCULATI ON Wet Paddy ( avg. 30% M.C. ) : 10,000 T Harvest duration in 1 season : 30 Days Drying Capacity : 10000 ÷ 30 = 333 TPD DRYI NG PLANT Wet Paddy ( avg. 30% M.C. ) : 333 TPD Loss 4% Impurities : -13 TPD Loss 16% M.C. : -53 TPD Dried Paddy ( avg. 14% M.C. ) : 266 TPD PADDY STORAGE Dried Paddy ( avg. 14% M.C. ) : 266 TPD Harvest duration in 1 season : 30 Days Dried Paddy storage per season :266 30 = 7,992 T MI LLI NG PLANT � Milling capacity : 6TPH / 144 TPD Capacity of paddy storage per season : 56 Days

10,000T Paddy per season (30% M.C.)

Burner ASH 1 TPD Water + Immature Grain DRYING PLANT 25 TPD 66 TPD 16% + 4% CAPACITY 333 TPD

266 TPD

DRIED PADDY STORAGE ~8000 T

RICE MILL HUSK CAPACITY 96 TPD

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

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

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

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

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

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

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

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

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

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

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

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

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

. Mangrove x

. Estuarine x

. Buffer zone of protected x area

. Special area for x protecting biodiversity

. Bay x

B. Potential Environmental Impacts Will the Project cause…

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

. Eventual degradation of x The design of the Facility includes sewage treatment ponds to be water bodies due to constructed on a raised platform. Water from the dust removal discharge of wastes and plant will be combined with condensate from the dryer and will be other effluents from plant treated in settling ponds, to enable organic matter to be extracted, or facility complex? and used by the Rice Miller or provided to farmers as a slurry for re-use as a soil conditioner. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. The silt produced by the excavations will be used on site to create a raised platform for treatment ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to surrounding location. . Serious contamination of x Not expected as construction work will use a small amount of soil and groundwater? water only as readymade mixed concrete from supplier will mainly be used. There are also no salinity issues expected at any sites as ground water will not be used. Provision shall be made for safe storage and use of hazardous materials such as fuels and lubricants. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan.

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Screening Questions Yes No Remarks . Aggravation of solid waste x Solid wastes from the Facility will be treated in the treatment problems in the area? ponds and organic matter will be extracted, and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. . Public health risks from x The proposed Facility will be far from local residents and discharge of wastes and nuisance and health effects of exhaust emissions and noise poor air quality; noise and will not be significant. The proposed Facility will be constructed foul odor from plant on a small plot of land inside the existing Rice Mill compound emissions? which is constructed on a 60 ha of single parcel of land owned by the Rice Miller. Responded did not express any concern on the discharge of wastes, noise and foul odor from the current Rice Mill. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. . Short-term construction x Construction work will use a small amount of water only and no impacts (e.g. soil erosion, ground water will be used for construction. Contractor will install deterioration of water and onsite WC for their workers. Noise and vibration from hammering air quality, noise and (for temporary period and short duration only) during construction vibration from period will be monitored and managed through use of new motor construction equipment? or good maintenance. When excavation takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The silt produced by the excavations will be used on site to create a raised platform for treatment ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to surrounding location. Good construction practices to mitigate noise, soil erosion, dust to be specified in the EMP and specifications. In addition, most construction activities will be far from local residents and nuisance and health effects of exhaust emissions will not be significant. For the same reasons, noise nuisance is not expected to be significant. . Dislocation or involuntary x Not Applicable as the proposed Facility will be constructed on a resettlement of people? small plot of land (about 2,880 m²) inside the existing Rice Mill compound which is constructed on a 60 ha of single parcel of land owned by the Rice Miller of which around 10 ha has been fenced. (land title issued by PDLMUPC, Battambang, on 31 July 2006 is attached as Annex 3 to the IEE). . Disproportionate impacts x The Facility will not impact poor, women and children, or other on the poor, women and vulnerable groups negatively. Currently, the Rice Mill employs 25 children, Indigenous villagers including 13 women and after the completion of the Peoples or other Facility, the Rice Mill may employ double number of villagers to vulnerable groups? work in the mill. The Rice Miller has good reputation of treating

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

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

. Water pollution from x No waste water from this type of drying process is generated as discharge of liquid moisture from wet paddy will evaporate. The design of the Facility effluents? includes sewage treatment ponds to be constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry. . Air pollution from all plant x When excavation takes place during dry conditions, excavated operations? surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. . Gaseous and odor x Power generation by means of a gasifier fed with rice husk will emissions to the produce exhaust gas. The gas is a clean fuel which will be used atmosphere from to produce electrical power. No ash/smoke will be released to the processing operations? environment as the Cyclonic type furnace will be utilized which has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income. . Accidental release of x Provision shall be made for careful loading and unloading, safe potentially hazardous storage and use of hazardous materials such as fuels and solvents, acidic and lubricants. Each contractor shall prepare a site safety plan and alkaline materials? obtain approval for it from the supervising agency prior to the start of works. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan. The drivers or users of excavators and vehicles shall be trained operators and where appropriate shall have license for operating them. . Uncontrolled in-migration x Not Applicable as the proposed Facility is located next to the with opening of roads to National Highway no. 5 and will be constructed on a small plot of forest area and land inside the existing Rice Mill compound which is constructed overloading of social on a 60 ha of single parcel of private land owned by the Rice infrastructure? Miller.

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Screening Questions Yes No Remarks . Occupational health x Protective clothing shall be issued to workers wherever hazards due to fugitive appropriate when working on excavations, and dust masks when dust, materials handling, working in dusty conditions. Noise proof materials for housing will noise, or other process be used to reduce noise from ash room, dust room and operations? machinery. Noise from blower and its drivers will be monitored and managed through good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Risks due to material handlings will be mitigated by the inclusion of safety railings, and by training and instruction to workers. . Disruption of transit x The proposed Facility is located next to the National Highway no. patterns, creation of noise 5. The Facility will be constructed on a small plot of land inside and congestion, and the existing Rice Mill compound which is constructed on a 60 ha pedestrian hazards of single parcel of private land owned by the Rice Miller. However, aggravated by heavy safety precautions such as flagman to regulate traffic will be trucks? provided as specified in the EMP.

. Disease transmission x The Contractor will install onsite WC for their workers. To ensure from inadequate waste sanitary conditions in and around the facility, an on-site system of disposal? treatment of sewerage from workers’ toilets will be provided. The Rice Miller has and will continue to carry out regular fumigation around the compound to destroy temporary breeding places for diseases such as those transmitted by mosquitoes and rodents. . Risks and vulnerabilities x No chemical, biological and radiological hazards are expected related to occupational during construction and operation. For physical safety, PPE and health and safety due to pit latrines will be provided to all workers. Contractor will physical, chemical, and provide orientation to all workers about using PPE, first aids kit, biological hazards during etc. To prevent pollution of soil and water surface/ groundwater: project construction and (i) storage facilities for fuels, oil, cement, and chemicals will be operation? within secured areas on impermeable surfaces, provided with bunds and cleanup installations. (ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that affects the soil and water sources. (iii) fuel storage and refilling areas will be located at least 50 m from the construction sites and will be protected by temporary drainage bunds to contain spills. (iv) During construction, care will be taken while loading and unloading of fuel stored at the campsite. During operation, the Rice miller will continue to provide PPE, first Aids kit, etc. and training courses to workers on safety standard; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE. . Large population increase x The number of non-local workers will be small in number. If during project necessary, construction contractors will be required to provide a construction and worker’s camp with independent basic facilities. The Rice Miller operation that cause has currently employed 25 workers including 13 women which is increased burden on expected to double after the new Facility becomes operational. social infrastructure and Currently, the Rice Miller has accommodation facilities/bedrooms services (such as water and 16 bathrooms including toilets, carries out monthly fumigation supply and sanitation around the compound, provides sanitation orientation to the systems)? workers, assured pipe water from district water supply agency ensuring enough water supply to all people working in the rice mill, and provides filter water for drinking and cooking purposes. During the public consultation meeting, the Rice Miller mentioned that he is willing to construct more basic facilities if the need arises.

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Screening Questions Yes No Remarks . Social conflicts if workers x Priority in labor employment will be given to local residents from other regions or and non-local workers will be small in number. countries are hired?

. Community health and x Construction area will be clearly demarcated and access safety risks due to the controlled. Safety warnings and diversion signboards will be transport, storage, and employed. Borrow pits will be filled back and first aids kit will be use and/or disposal of provided for the workers, project staff and stakeholders. materials likely to create physical, chemical and biological hazards during construction, operation and decommissioning?

A Checklist for Preliminary Climate Risk Screening

Screening Questions Score Remarks

Location Is siting and/or routing of the project (or its 0 The Facility will be constructed inside the and components) likely to be affected by climate existing Rice Mill compound which is Design of conditions including extreme weather related elevated from the ground level. The project events such as floods, droughts, storms, proposed location has never been landslides? flooded even during the big flood in 2013. The level of water was about 0.3m lower than the ground level. However, the design of the Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water if this occurs. The drainage system will be sufficient to prevent the formation of ponds and muddy patches within the facility compound. Adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. Would the project design (e.g. the clearance for 0 Not applicable. bridges) need to consider any hydro- meteorological parameters (e.g., sea-level, peak river flow, reliable water level, peak wind speed etc.)? Materials Would weather, current and likely future climate 0 Not applicable. and conditions (e.g. prevailing humidity level, Maintena temperature contrast between hot summer days nce and cold winter days, exposure to wind and humidity hydro-meteorological parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)? Would weather, current and likely future climate 0 Not applicable. conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s)? Performa Would weather/climate conditions and related 1 Climate extreme events may affect the nce of extreme events likely affect the performance (e.g. supply of paddy to the Facility thereby project annual power production) of project output(s) (e.g. affecting the performance of the Facility. outputs hydro-power generation facilities) throughout their design life time?

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Annex 9: Environmental Management Plan Summary Potential Mitigation measure(s) Cost Responsibility for Supervising Environmental Impact Allocation Implementation Agency

Design and Preconstruction

Risk of flooding The Facility will be constructed inside the existing Rice Mill compound which is elevated Include in DDCS Firm (IRE) MEF/PMO from the ground level. The proposed location has never been flooded even during the big construction flood in 2013. The level of water was about 0.3m lower than the ground level. However, budget adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels.

Lack of mechanism to Establish and function a grievance redress mechanism (GRM), as described in the IEE PMO budget PMO /PIO MEF/PMO address environmental (Section 8). complaints Make public the existence of the GRM through public awareness campaigns and display PMO budget DDCS firm (IRE)/ MEF/PMO poster of GRM at the subproject site. PIO/PMO

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

Prepare a logbook and put at a place accessible to all relevant stakeholders to record Include in Contractor/DDCS MEF/PMO complaints and action taken properly during the subproject implementation. construction firm (IRE)/ Budget PIO/PMO Effects on homes A Land Acquisition and Resettlement Plan for the Facility is not relevant as the land is Rice Miller Rice Miller MEF/PMO/PIO and Property. privately owned. The Facility will be built well within the privately owned land and there will be no need for any compensation.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

Environmental, Measures to ensure occupational health and safety will include: Include in Contractor DDCS firm (IRE)/ Health and Safety construction MEF/PMO - Contractor shall be required by the PMO to ensure that their workers and other staff (EHS) budget engaged in the proposed constructions are in a safe environment. - Contractor shall ensure that (i) all reasonable steps are taken to protect any person on the site from health and safety risks; (ii) the construction site is a safe and healthy workplace; (iii) machineries and equipment are safe; (iv) adequate training or instruction for occupational health and safety is provided; (v) adequate supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety. - Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE) - Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites. - Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings)

Community health and safety will be safeguarded by: - Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated to its original condition after construction. - Implementing safety measures around the construction sites to protect the public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites. - Maximizing employment of local residents to the extent practicable.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

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

Construction Phase

Effects associated with (i) Re-use excavated material to the extent practicable, Include in Contractor DDCS firm (IRE)/ the use of excavated soil (ii) Obtain materials from licensed quarries, construction MEF/PMO and/or laterite for PDS (iii) Enter in to appropriate agreements with landowners for borrow sites, and landscaping budge Facilities construction. works to use borrow sites, in accordance with the agreements made with landowners,

(iv) Not be allowed to dispose the excavated soil into water body or other free land without local authority permit.

Release of silt from the (i) Adequate supervision of the works, (ii) Discretionary use of silt traps where Include in Contractor DDCS firm (IRE)/ site excavated due to warranted, (iii) Careful placing of excavated material, and (iv) Clean the silt after daily construction MEF/PMO the subproject work. budget implementation

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

Water / Pollution from (i) Wastewater from the camp sites discharged by building latrine with good septic tank, Include in Contractor DDCS firm (IRE)/ construction waste water. (ii) Transporting waste residue to dispose at approved dumpsites by authority to avoid construction MEF/PMO contamination of the people household, agricultural land and waterways surrounding budget the location, and (iii) Provide regular truck maintenance to improve the condition and store the oil properly

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

Health risks to worker When excavation takes place during dry conditions, excavated surfaces and stockpiled Include in Contractor DDCS firm (IRE)/ from dust pollution material shall be sprayed with water to prevent the release of dust. The proposed Facility construction MEF/PMO will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will budget be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions.

Risks of unsanitary The Facility will be constructed inside the existing Rice Mill compound which is elevated Include in Contractor DDCS firm (IRE)/ working and grain from the ground level. The proposed location has never been flooded even during the big construction MEF/PMO storage conditions flood in 2013. However, adequate fill is proposed to raise the ground level to a height that budget during flood events poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

Hazardous materials To prevent pollution of soil and water surface/groundwater: Include in Contractor DDCS firm (IRE)/ during subproject (i) Storage facilities for fuels, oil, cement, and chemicals will be within secured areas construction MEF/PMO implementation on impermeable surfaces, provided with bunds and cleanup installations. budget (ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that is going to affect soil and water sources. (iii) Fuel storage and refilling areas will be located at least 50m from construction sites and will be protected by temporary drainage bunds to contain spills. (iv) Be careful in loading and unloading fuel during the construction activities.

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

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

Noise and Vibration/ Construction during night time within 280m of residences shall be strictly prohibited. During Include in Contractor DDCS firm (IRE)/ Noise impacts on daytime construction, contractor will ensure that: construction MEF/PMO sensitive receivers (i) Sites for concrete- mixing plants and similar activities will be located at least 1 km away budget from residences and schools; and (ii) Temporary anti-noise barriers will be installed to shield any schools or residences within 100m of the construction site. Borrow pit /quarry for Contractor have to include orientation to all workers on borrow pit protection to avoid the danger Include in Contractor DDCS firm (IRE)/ getting soil for (i.e. prevent cattle and people – specifically children falling into the borrow pit during and after construction MEF/PMO subproject construction construction activities). Contractor will ensure to: budget • Install fence around the pit and put up warning signboard during the construction activities, and • Back fill with soil after construction activities are completed.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

Use of land for storage (i) Contractor will provide compensation to landowners by early in a month. Include in Contractor DDCS firm (IRE)/ and campsite (ii) In cases where landowners temporarily provide their land to the contractor to construction MEF/PMO build camp site, it will be based on a contract agreement (details will be stated budget in contract agreement) (iii) After completing works, contractor will carry out restoration of land to former condition or better, according to agreements formed with landowners. Effects of vehicle Although the construction will take place inside privately owned land but the contractor has to Include in Contractor DDCS firm (IRE)/ access related to daily carry out: (i) careful supervision of vehicle movements to ensure minimal damage to construction MEF/PMO operational farmland and vegetation, etc. if any and (ii) minimal disturbances to human beings, budget management children going to school and animal. Effects of the (i) Assigning the responsibility of the contractor’s staff, workers and local people’s Include in Contractor DDCS firm (IRE)/ temporary worker welfare to a senior member of the contractor’s staff construction MEF/PMO populations staying in (ii) Maximizing employment of local residents to the extent practicable. budget a camp site (iii) Construction of suitable toilets such as pit latrines on sites. (iv) Providing electricity to all workers staying overnight. (v) Providing primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such as soakage pits, to minimize release of pollutants into waterways. (vii) Orientation to the workers on dangers of communicable diseases.

Safety hazards to Contractor work plan have to include allocation of responsibility for site safety to the Include in Contractor DDCS firm (IRE)/ workers and local people contractor’s site supervisors staff to ensure all reasonable safety measures, have been construction MEF/PMO during construction taken up. budget (i) Prepare and provide enough safety protection clothing and equipment, flagman, sign boards, etc. and place hazard warnings. (ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and contractor’s site supervisors staff. Occurrence of water Contractor work plan during construction have to include raising awareness to the workers Include in Contractor DDCS firm related diseases on hazards posed by poor sanitation and use of untreated water for drinking and bathing. construction (IRE)/ budget MEF/PMO

Operation phase

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

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

Water pollution from No waste water from this type of drying process is generated as moisture from wet paddy Rice Miller Rice Miller PDOE, MEF/ discharge of liquid will evaporate. The design of the Facility includes sewage treatment ponds to be PMO/PIO effluents constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry.

Dust control The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence Rice Miller Rice Miller PDOE, MEF/ no ash/smoke will be released to the environment. Dust produced by the drying process will PMO/PIO be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions. Noise and Vibration/ Noise proof materials for housing will be used to reduce noise from ash room, dust room Rice Miller Rice Miller PDOE, MEF/ Noise impacts on and machinery. Noise from blower and its drivers will be monitored and managed through PMO/PIO sensitive receivers good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Risks and Rice miller will continue to provide PPE, first aids kit, etc. and training courses to workers Rice Miller Rice Miller PDOLVT/PDO vulnerabilities related on safety standard; include safety railings to mitigate risks due to material handlings and E/MEF/PMO/ to occupational health provide training and instruction to workers; carry out proper fumigation around the PIO and safety during compound; follow the laid out regulations by the PDOLVT related to health and labor operation policy; and follow the EMP and agreement with PDOE.

Residue of husk Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Rice Miller Rice Miller PDOE/MEF/ (Ash)/Waste i. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself PMO/PIO or may sell to farmers to generate extra income ii. Husk will be used as biomass fuel by the Rice Miller for their furnace/burner. iii. Ash will not be allowed to dispose into water bodies Garbage/Waste i. Provide specific basket or bucket for kitchen garbage disposal Rice Miller Rice Miller PDOE/MEF/ generation by workers ii. Make arrangements for collection of solid waste PMO/PIO iii. Make arrangements for grey water treatment and discharge, such as soakage pits iv. Assign specific role and responsibility and clear schedule for maintenance and collection of all waste

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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

Design and Preconstruction Phase Risk of flooding The Facility will be constructed inside the existing Rice Mill compound Phou Poy Rice Mill Detailed design Quarterly - Resident Include in which is elevated from the ground level. The proposed location has located in Chumnik and follow up Engineer construction never been flooded even during the big flood in 2013. The level of Village, Anlong Vil construction record and Budget water was about 0.3m lower than the ground level. However, commune, Sangkae supervision. report adequate fill is proposed to raise the ground level to a height that district, poses little risk from flooding. The settling ponds shall be on a raised Battambang. platform, at least 0.5 m above the height of 10-year flood levels.

Lack of Establish and function a grievance redress mechanism (GRM), as Phou Poy Rice Mill Public Quarterly Environment PMO budget mechanism to described in the IEE (Section 8). located in Chumnik information follow up Specialist, address Village, Anlong Vil booklet. record and Resident environmental commune, Sangkae Make public the existence of the GRM through public awareness report Engineer and Complaints campaigns and display poster of GRM at the subproject site. district, Battambang. Site Manager Ensure that names and contact numbers of representatives List of contact of the (Contractor site Manager, Village -Commune Chief, PIO and person and contractor MEF/PMO representative) are placed on the notice boards outside participant list the construction site and at local government offices (e.g., provincial and commune levels).

Build capacity of the contractor on implementation and monitoring of Training EMP document and Training program Prepare a logbook and put at a place accessible to all relevant Logbook Include in stakeholders to record complaints and action taken properly during construction the subproject implementation. Budget A Land Acquisition and Resettlement Plan for the Facility is not Phou Poy Rice Mill Land title and Quarterly – Site Manager Include in Effects on relevant as the land is privately owned. The Facility will be built well located in Chumnik observation follow up of the construction homes and within the privately owned land and there will be no need for any Village, Anlong Vil record and contractor and Budget Property. compensation. commune, Sangkae district, Battambang. report Resident

Engineer.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

EHS Measures to ensure occupational health and safety will include: Phou Poy Rice Mill List of skilled Monthly and Site Manager of Include in located in Chumnik labor and quarterly – the contractor construction - Contractor shall be required by the PMO to ensure that their Village, Anlong Vil worker, list of follow up and Resident Budget workers and other staff engaged in the proposed constructions are commune, Sangkae equipment for report Engineer. in a safe environment. district, Battambang. - Contractor shall ensure that (i) all reasonable steps are taken to contract protect any person on the site from health and safety risks; (ii) the implementation, construction site is a safe and healthy workplace; (iii) machineries water basin or and equipment are safe; (iv) adequate training or instruction for bucket, occupational health and safety is provided; (v) adequate first aid kit supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety. - Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE) - Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites. - Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings)

Community health and safety will be safeguarded by: - Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated to its original condition after construction. - Implementing safety measures around the construction sites to protect the public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites. - Maximizing employment of local residents to the extent practicable.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

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

Construction Phase

Effects (i) Re-use excavated material to the extent practicable, - Phou Poy Rice Mill Construction Daily and Site Manager of Bill of associated (ii) Obtain materials from licensed quarries, area or within 5km schedule and Monthly the contractor and quantity in with the use of (iii) Enter in to appropriate agreements with landowners for borrow of site earth work. bill of records Resident the contract excavated soil sites, and landscaping works to use borrow sites, in accordance -List of construction quantity Engineer award with the agreements made with landowners, and/or laterite material for PDS (iv) Not be allowed to dispose the excavated soil into water body or other Facilities free land without local authority permit. construction.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

Release of silt Phou Poy Rice Mill, Observation, Daily and Site Manager Bill of quantity from the site (i) Adequate supervision of the works, Chumnik Village, cross Monthly of the in the contract excavated due (ii) Discretionary use of silt traps where warranted, Anlong Vil checking with records based contractor and award to the (iii) Careful placing of excavated material, and Rice Miller and on the specific Resident Engineer subproject (iv) Clean the silt after daily work. commune, Sangkae implementation district, Battambang. stakeholders construction schedule

Water / Pollution i. Wastewater from the camp sites discharged by building latrine Phou Poy Rice Mill, Observation, Monthly Site Manager of Bill of quantity from with good septic tank. Chumnik Village, cross records based the contractor, in the contract ii. Transporting waste residue to dispose at approved dump sites Anlong Vil on the specific construction checking with Resident award by authority to avoid contamination of the people household, commune, Sangkae work wastewater Rice Miller and agricultural land and waterways district, Battambang. Engineer, Rice iii. Provide regular truck maintenance to improve the condition and stakeholders Miller and Village store the oil properly Chief

Risk of The Contractor will install onsite WC for their workers. To ensure Phou Poy Rice Mill, Observation, Monthly Site Manager of Bill of quantity contamination sanitary conditions in and around the facility, an on-site system of Chumnik Village, cross checking records based the contractor, in the of nearby treatment of sewerage from workers’ toilets will be provided. The Anlong Vil with Rice Miller on the specific Resident contract design of the Facility includes provision for drainage of a specification commune, Sangkae and work waterways Engineer, Rice award sufficient to handle storm-water flows, and safe draining of storm district, Battambang stakeholders water if this occurs. Miller and Village Chief

Health risks to When excavation takes place during dry conditions, excavated Phou Poy Rice Mill, Observation, Monthly Site Manager of Bill of quantity worker from surfaces and stockpiled material shall be sprayed with water to prevent Chumnik Village, cross checking records based the contractor, in the dust pollution the release of dust. The proposed Facility will use Cyclonic type Anlong Vil with Rice Miller on the specific Resident contract furnace which has no exhaust stack and hence no ash/smoke will be commune, Sangkae and work Engineer, Rice award released to the environment. Dust produced by the drying process district, Battambang stakeholders will be collected by passing dust laden air from the dryer into a Miller and Village chamber where water is introduced by a series of sprayers. The water Chief spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing such as dust masks shall be issued to workers when working in dusty conditions.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

Risks of The Facility will be constructed inside the existing Rice Mill compound Phou Poy Rice Mill, Observation, Monthly Site Manager of Bill of quantity unsanitary which is elevated from the ground level. The proposed location has Chumnik Village, cross checking records based the contractor, in the working and never been flooded even during the big flood in 2013. However, Anlong Vil commune, with Rice Miller on the specific Resident contract adequate fill is proposed to raise the ground level to a height that Sangkae district, and work grain storage Engineer, Rice award poses little risk from flooding. The settling ponds shall be on a raised Battambang stakeholders conditions platform, at least 0.5 m above the height of 10-year flood levels. The Miller and Village during flood Contractor will install onsite WC for their workers. To ensure sanitary Chief events conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.

Hazardous To prevent pollution of soil and water surface/groundwater: Phou Poy Rice Mill or Observation, Monthly Site Manager of Bill of materials during (i) Storage facilities for fuels, oil, cement, and chemicals will be surrounding location cross records based the contractor, quantity in subproject within secured areas on impermeable surfaces, provided with of the subproject, checking on the specific Resident the contract bunds and cleanup installations. Chumnik Village, work implementation with Rice Engineer, Rice award Anlong Vil (ii) The contractor will not use the spilled materials related to Miller and the vehicle, machinery, and equipment that is going to affect commune, Sangkae Miller and Village to soil and water sources. district, Battambang. stakeholders Chief (iii) Fuel storage and refilling areas will be located at least 50m from construction sites that will be protected by temporary drainage bunds to contain spills. (iv) Be careful in loading and unloading fuel during the construction activities.

(i) Equipment will be maintained to a high standard to ensure Phou Poy Rice Mill or Observation, Monthly Site Manager of Bill of Air quality efficient running and fuel-burning. surrounding location cross records based the contractor, quantity in (ii) High- horsepower equipment will be provided with tail gas of the subproject, checking with on the specific Resident the contract purifiers. work Chumnik Village, Rice Miller and Engineer, Rice award (iii) All vehicle emissions will be in compliance of with relevant stakeholders Cambodian emission standards. Anlong Vil Miller and Village commune, Sangkae Chief district, Battambang.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

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

Noise and Construction during night time within 280m of residences shall be strictly Phou Poy Rice Mill or Observation, Daily and Site Manager of Bill of quantity Vibration/ prohibited. During daytime construction, contractor will ensure that: surrounding location record, cross Monthly the contractor, in the Noise impacts on (i) Sites for concrete- mixing plants and similar activities will be of the subproject, checking with records based Resident contract sensitive located at least 1 km away from residences and schools; and Chumnik Village, Rice Miller and on the specific Engineer, Rice award receivers (ii) Temporary anti-noise barriers will be installed to shield any Anlong Vil commune, stakeholders work Miller and Village schools or residences within 100m of the construction site. Sangkae district, Chief Battambang.

Borrow pit /quarry Contractor have to include orientation to all workers on borrow pit Location of soil Observation, Monthly and Site Manager of Bill of quantity for getting soil for protection to avoid the danger (i.e. prevent cattle and people – specifically collections. record, cross quarter records the contractor, in the subproject children falling into the borrow pit during and after construction activities). checking with Resident contract construction Contractor will ensure to: Rice Miller/ Land Engineer, Rice award • Install fence around the pit and put up warning signboard during owner and Miller/ Land owner the construction activities, and stakeholders and Village Chief • Back fill with soil after construction activities are completed.

Use of land for (i) Contractor will provide compensation to landowners by early in Phou Poy Rice Mill or Contract Monthly Site Manager of Bill of quantity storage a month. surrounding location agreement payment report the Contractor in the contract and campsite (ii) In cases where landowners temporarily provide their land to of the subproject, between award the contractor to build camp site, it will be based on a contractor and contract agreement (details will be stated in contract Chumnik Village, agreement) Anlong Vil landowner (iii) After completing works, contractor will carry out restoration of commune, Sangkae land to former condition or better, according to agreements district, Battambang. formed with landowners.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

Effects of Although the construction will take place inside privately owned land but Phou Poy Rice Mill or Check to verify Monthly and Site Manager of Bill of quantity vehicle access the contractor has to carry out: (i) careful supervision of vehicle surrounding location The Quarterly the contractor and in the contract related to daily movements to ensure minimal damage to farmland and vegetation, of the subproject, contractor report Resident award operational etc. if any and (ii) minimal disturbances to human beings, children Engineer, Rice Chumnik Village, rule book management going to school and animal. Miller and Village Anlong Vil and license Chief commune, Sangkae of driving district, Battambang. Effects of the (i) Assigning the responsibility of the contractor’s staff, workers Existing workers Observation on Quarterly and Site Manager of Bill of quantity temporary and local people’s welfare to a senior member of the campsite and the site operation based on the the contractor and in the contract worker contractor’s staff worker from the including list operation Resident award populations (ii) Maximizing employment of local residents to the extent and CV of the status Engineer, Rice villages. staying in a practicable. worker Miller and Village camp site (iii) Construction of suitable toilets such as pit latrines on sites Chief . (iv) Providing electricity to all workers staying overnight. (v) Providing primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such as soakage pits, to minimize release of pollutants into waterways. (vii) Orientation to the workers on dangers of communicable diseases. Safety Contractor work plan have to include allocation of responsibility for Existing workers Labor Law in Quarterly and Site Manager of Bill of quantity Hazards to site safety to the contractor’s site supervisors staff to ensure all campsite and the 1999 of Royal based on the the contractor and in the contract workers and reasonable safety measures, have been taken up. Resident Engineer worker from the Government operation award local people (i) Prepare and provide enough safety protection clothing and Rice Miller and Cambodia status during equipment, flagman, sign boards, etc. and place hazard villages. Village Chief construction warnings. (ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and contractor’s site supervisors staff.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

Occurrence of Contractor work plan during construction have to include raising Phou Poy Rice Mill or Specific water Based on the Contractor, Include in water related awareness to the workers on hazards posed by poor sanitation surrounding location company or diseases Commune construction diseases and use of untreated water for drinking and bathing. of the subproject, shop address occurred Chief, health Budget Chumnik Village, and list of centers, village Anlong Vil patient. chief, Rice Miller, commune, Sangkae PIO and other Collection of district, Battambang. stakeholders sample and laboratory analysis. Operation phase

Maintenance of Contractor work plan have to include orientation to all stakeholders Phou Poy Rice Mill, Operation and Quarterly Site Manager of Include in equipment and involved on work routine and periodic maintenance, quality of Chumnik Village, maintenance report the contractor, construction avoiding damage equipment, and raw material to be used based on contract Anlong Vil commune, schedule Resident Budget to the assets document. Sangkae district, Engineer, Rice Battambang. Miller, and other stakeholder

Water pollution No waste water from this type of drying process is generated as Phou Poy Rice Mill or Operation and Quarterly Rice Miller, PDOE/ Rice Miller from discharge moisture from wet paddy will evaporate. The design of the Facility surrounding location maintenance report MEF/PMO/PIO of liquid effluents includes sewage treatment ponds to be constructed on a raised of the subproject, schedule platform. Water from the dust removal plant will be combined with Chumnik Village, condensate from the dryer and will be treated in settling ponds, to Anlong Vil commune, enable organic matter to be extracted, and used by the Rice Miller or Sangkae district, provided to farmers as a slurry. Battambang. Dust control The proposed Facility will use Cyclonic type furnace which has no Phou Poy Rice Mill or Operation and Quarterly Rice Miller, PDOE/ Rice Miller exhaust stack and hence no ash/smoke will be released to the surrounding location maintenance report MEF/PMO/PIO environment. Dust produced by the drying process will be collected by of the subproject, schedule passing dust laden air from the dryer into a chamber where water is Chumnik Village, introduced by a series of sprayers. The water spray causes the dust to Anlong Vil commune, collect and form a slurry which is non-toxic and can be provided to Sangkae district, famers for re-use as a soil conditioner. Protective clothing such as Battambang. dust masks shall be issued to workers when working in dusty conditions.

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Impact to be Parameters Location Means of Frequency Responsibilities Cost Monitored Monitoring Estimate

Noise and Noise proof materials for housing will be used to reduce noise from Phou Poy Rice Mill or Operation and Quarterly Rice Miller, PDOE/ Rice Miller Vibration/ ash room, dust room and machinery. Noise from blower and its surrounding location maintenance report MEF/PMO/PIO Noise impacts drivers will be monitored and managed through good maintenance. of the subproject, schedule on sensitive Noise within the facility will be reduced by the inclusion of noise Chumnik Village, receivers baffles on machinery and ear protection is provided where Anlong Vil commune, necessary. Sangkae district, Battambang. Risks and Rice miller will continue to provide PPE, first aids kit, etc. and training Phou Poy Rice Mill, Operation and Quarterly Rice Miller, Rice Miller vulnerabilities courses to workers on safety standard; include safety railings to Chumnik Village, maintenance report PDOLVT/PDOE/ related to mitigate risks due to material handlings and provide training and Anlong Vil commune, schedule MEF/PMO/PIO occupational instruction to workers; carry out proper fumigation around the Sangkae district, health and safety compound; follow the laid out regulations by the PDOLVT related to Battambang. during operation health and labor policy; and follow the EMP and agreement with PDOE. Residue of husk Cyclonic furnace collects ash at the bottom and then conveys to the Phou Poy Rice Mill, Operation and Quarterly Rice Miller, PDOE/ Rice Miller (Ash)/Waste ash room. Chumnik Village, maintenance report MEF/PMO/PIO i. Ash will be collected at the ash room and use as fertilizer by Anlong Vil commune, schedule the Rice Miller himself or may sell to farmers to generate extra Sangkae district, income Battambang. ii. Husk will be used as biomass fuel by the Rice Miller for their furnace/burner. iii. Ash will not be allowed to dispose into water bodies

Garbage/Waste i. Provide specific basket or bucket for kitchen garbage Phou Poy Rice Mill, Operation and Quarterly Rice Miller, PDOE/ Rice Miller generation by disposal Chumnik Village, maintenance report MEF/PMO/PIO workers ii. Make arrangements for collection of solid waste Anlong Vil commune, schedule iii. Make arrangements for grey water treatment and discharge, Sangkae district, such as soakage pits Battambang. iv. Assign specific role and responsibility and clear schedule for maintenance and collection of all waste

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Training program:

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

Capacity Building and Training Requirements

Subject/Content Participants Trainer Frequency

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

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

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

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

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Annex 11: List of participants of the public consultation meeting

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

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