THE ENVIRONMENTAL ASSESSMENT

THE URUNG SUBMERGED LAND FILL PROJECT Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

CONTENTS

EXECUTIVE SUMMARY ...... 5 INTRODUCTION ...... 8 Identification Applicant ...... 13 Identification of EA Preparer ...... 22 EA Process & Documentation ...... 22 Environmental Assessment Methodology ...... 24 Project Descriptions ...... 24 Project Objectives ...... 24 Project Site Description ...... 25 Project Location ...... 26 Project Features ...... 30 Infrastructure Considerations ...... 31 Project Implementation Schedule ...... 31 Existing Environmental Conditions ...... 31

Impact Assessment & Mitigation ...... 33 Initial Impact to the Project Site before Filling . . . . . 33 Vegetation Clearing . . . . . 33 Excess Soil from Excavation Activity ...... 34 Waste Water Generation ...... 34 Air Pollution ...... 34 Noise ...... 35 Potential Damage to Urung Road ...... 35 Solid Waste Generation & Disposal ...... 35 Storm Water Management ...... 36 Traffic Hazards ...... 36

Erosion and Sediment Measures (Erosion Sediment Control Plan . . . 37 Other Mitigating Measures ...... 41 Accountability ...... 48

References ...... 71

2 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

LIST OF EXHIBITS Exhibit 1 – Propose Site Map & Characteristics ...... 16 Exhibit 2 – Matrix of Impacts ...... 17 Exhibit 3 – Project Location & GPS Location Points . . . . . 26 Exhibit 4 – Soil Type ...... 29 Exhibit 5 – ESCP Illustration ...... 44 Exhibit 6 – Accountability ...... 48 Exhibit 7 – Historical Clearance ...... 49-51 Exhibit 8 – Unexploded Ordnance . . . . . 52 Exhibit 9 – Request for Proposal No. RFP- 218-02 . . . . . 53 Exhibit 10 – Award Letter NSL 2018-42 ...... 54 Exhibit 11 –Terms of References ...... 55-56 Exhibit 12 – Joint Resolution No. 10-3-1S ...... 57-58 Exhibit 13 – Notice of Violation ...... 59-60 Exhibit 14—Order Imposing Civil Penalty ...... 61-63 Exhibit 15 – Notice of Suspension of Civil Penalty . . . . . 64-67 Exhibit 16a – NSPL No. 7-13 ...... 68-69 Exhibit 17 – Governor’s Letter to EQPB Executive Officer . . . . 70

LIST OF TABLES

Table 1 – Owner/Applicant Information ...... 13 Table 2 –Information of EA Preparer . . . . . 22

LIST OF FIGURES

Figure 1 – List of Plants ...... 18-20 Figure 2 – Bird Survey Form ...... 21 Figure 3 – Project Site Map ...... 25

3 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

LIST OF PHOTOS TAKEN LEADING TO USLP SITE Photo 1 – Crab Holes . . . 8 Photo 2 – Photos 2-5 Taken at Project Site . . . . . 27 Photo 6 – West Side of Project Site ...... 28 Photo 7 – Natural Pit With Water ...... 30 Photo 8 – Yasumba . . . . . 32 Photo 9 – An Example of Silt Curtain ...... 37 Photo 10 – Foliage ...... 43 Photo 11 – Old Truck Parts ...... 43 Photo 12 – Culvert Conveyance ...... 45 Photo 13 – Natural Pit and Conveyance ...... 46 Photo 14 – Old Silt Fence ...... 47 Photo 15 – Bamboos ...... 47

4 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

EXCEUTIVE SUMMARY

NGARAARD - STATE OF LEGENDS CALLS FOR BEAUTY OF LIVES. Beautiful ancient sacred paths link with other lands, and some legends that still thrive in our hearts are from Ngaraard. Stone paths through the forests give one a chance to reflect on path to self-discovery and appreciation of our lives. Once you encounter the beautiful scenery and warm hearted island hospitality, you will be reminded how beautiful life is. The Ngaraard State “Kerradel” is a land of opportunity. Kerradel the Five for One and One for All State has five (5) counties, 1) Elab, 2) Choll, 3) Ngebuked, 4) Ulimang, and 5) Ngkeklau. It is one of the states in Palau that has both east and west coasts with white sandy beaches and six (6) Protected Area Network Conservation Areas. 1) East Coast Ngaraard Conservation, 2) Ungellel Conservation Area, 3) Ngaraard Mangrove Conservation Area, 4) Ngerkall Conservation Area, 5) Diong ra Ngerchokl, and 6) Ongiil Conservation Area. These conservation areas are connected to and have joined the Palau Protected Area Network (PAN) in 2011.

The on-going project that is similar to the Urung Submerged Land Fill Project (USLFP) is the Etoikechang Yasumba Project that was EQPB approved in 2015. Permit is expired and being requested for extension and now awaiting EQPB approval. The new governor, the Honorable Benjamin Iskawa may change the plan for Etoikechang Yasumba Project (EYP) to dredge all the way to Yasumba and to re-dredge back thus creating channel to about halfway and build a pier for boat docking. This process in changing the scope of work for EYP will be requested through the EQPB. The re-dredged materials from this EYP and other projects to take place in Ngaraard could provide fill materials to be used for filling the proposed Urung Submerged Land Fill Project.

The Ngaraard State Government is proposing to build additional structures such as housing residences for the people of Ngaraard and extra buildings and/or structures in support of the forthcoming activities toward the development of Ngaraard State in particular the submerged land at Urung, Ngebuked county of Ngaraard State. This Submerged Land Lot No. is 053 E 16 with an area of 4,266 sq meters on the east of State public works building at the state compound.

Request for Proposal No: RFP 218-02 was solicited for environmental assessment and Bidding Period was from May 23, 2018 to June 17, 2018. Each proposal were submitted in sealed

5 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597 envelopes bearing the name and address of applicant and identified with proper request for proposal number where all proposals were to be submitted or mailed to Ngaraard State office. Sealed proposals from local vendors for an Environmental Assessment (EA) were opened on June 18, 2018. All proposals were to be evaluated based on bidding price and for additional information on specifications to contact the state office. The Freelancing Consultant Company (FCC) submitted a bid for this request for proposal and was accorded with an Award Letter NSL 2018-42 dated June 13, 2018 (Exhibit 10). This award letter served as a basis to undertake the task of environmental assessment for this proposed USLFP pertinent to EQPB Chapter 24 National Code and its Regulations promulgated 26 May 1996. And this EA is prepared as an obligatory process to seek approval from EQPB which will enable Ngaraard State Government to start filling this particular submerged land. It is also a process that FCC is trying to show based on the assessment of this USLFP pertinent to 2401-61-03 Applicability, 2401-61-05 Contents of EA and 2401-61-06 Significance Criteria.

There was no discussion with Governor in relation to alternatives for this proposed project hence The “No Action” Alternative should always be considered an option to the proponent even before the project is conceptualized. Nonetheless alternatives could have been considered if the lands in Ngaraard have all been surveyed for their determination of ownership and with clear certification of titles. Moreover the Certification of Title for this proposed USLFP is very clear in reference to the Article 1 Section 2 of Palau Constitution and Joint Resolution No. 10-3-1S (Exhibit 11). Alternatives discussed in this section are in reference to the Public Notice of Request for Proposal RFP No: 2018-02 proposing to build additional structures such as housing residences and extra buildings or structures to support forthcoming activities toward development of Ngaraard State. Hence the Joint Resolution No. 10-3-18 clearly stated that this proposed USLFP will provide much needed space for the Public Works facility, the PNCC Hub, the warehouse and possible Olbetibel building to resolve the current congestion problem of Ngaraard State Government. This same joint resolution also stated that USLFP may provide access to Ngebuked, Elab, and Ulimang area in the event of the current road becomes unusable due to sea level rise. This USLFP may have two components – enable EQPB process the environmental assessment to fill the submerged land and later to build the aforementioned structures once this proposed filling of submerged land in Urung is completed. Hence building of structures after filling this site may require another EQPB process because of its close proximity across to the eastward healthy mangroves.

An initial terrestrial walk survey was conducted on June 28, 2018 to get an overview of the vegetations, bird and animals associated or found in the site. And on July 3, visited the site again for the second time to observe the high tide at 09:54 A.M. to see how it flows through the culvert and to what extend through the site and to resurvey for vegetations, birds and animals and to observe in-order to absorb the feel of the environment of the site. Visited the site again on July 7, 2018 with plant expert Mr. Naito Soaladaob to resurvey and identify vegetations.

6 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

During the site survey, the site was noted and estimated to be composed of 65% Tebechel- Rhyzophora mucronata. List of other plants identified are in Figure 1 and Birds in Figure 2. Most if not all species of bird seen and heard during the survey are transitional and are just occasionally utilizing the area. Especially the Morning Birds identified in particular place are not transitional or occasionally utilizing the area as during these three visits they seem to have being remained or aggregated in a confined dense Ngesngesil close to the road.

Access road to Urung dock before was going around caressing the base of natural basalt hill. The site for this proposed USLFP is currently unutilized. It became enclosed when Ngaraard State government built the Orredakl cement road in 2007 directly to Urung, Proposed Site Map & Characteristics as Exhibit 1. If this Project is going through as planned by Ngraard State Government, the benefits may outweigh the negative impacts this Project may impose.

The negative impacts of the proposed USLFP will include soil disturbance/erosion and sedimentation, removing of Tebechel and other vegetations, dust emission and noise from heavy equipment. These impacts are typical of any type of development and can be mitigated through proper erosion control measures and construction management. No substantial degradation to adjacent environment is foreseen.

The results of this assessment are that the negative impacts that have been identified in this document shall be adequately minimized by the suggested mitigation measures. Therefore, the proposed action should not result in significant impacts on the nearby environment. It is suggested that an Environmental Impact Statement (EIS) is not required for this proposed project. A Finding of No Significant Impact (FONSI) is anticipated.

Several beneficial actions are anticipated as a result of the proposed action to develop the proposed USLFP site. Several residents may have a place for their residences and that Ngaraard State Government may build several infrastructures in support of the forthcoming activities toward development of Ngaraard state. Moreover this proposed USLFP will provide much needed space for the Public Works facility, the PNCC Hub, the warehouse and possible Olbetibel building to resolve the current congestion problem of Ngaraard State Government. This proposed USLFP site is also an excellent habitat for mangrove crabs and even land crabs are prevalent along the side of the old road (the shoreline) just half exposed above their cubicles and crawled back in when confronted. The site can be properly developed for aquaculture farm to polyculture milkfish, crabs and prawns.

7 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 1 - Crab holes

1. INTRODUCTION

Applicability

Except as otherwise provided, an environmental assessment shall be required for any and all actions which propose: (A) The use of national or state lands; The Certification of Title for this proposed USLFP is very clear in reference to the Article 1 Section 2 of Palau Constitution and the Joint Resolution No. 10-3-18 adopted March 02, 2018 (Exhibit 12).

Urung Orredakl cement road was constructed in 2007 during the Administration of Governor Laurentino Ulechong by Palau Transportation Corporation in conjunction with CIP-Bureau of Public Works and Ngaraard State government. The road was supposed to be constructed following the existed dirt road alignment and prohibiting the diversion of road through the mangrove or wetland areas. Nonetheless the Orredakl road diverted the old existed dirt road which violated the Permit PEA- 179-06 special condition which limited the construction of the road to the existed dirt road alignment. On March 08, 2007 EQPB inspectors conducted a follow-up inspection and found that there was a

8 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597 clear evidence of mangrove cutting and mangrove in the area to allow for the construction of the new road which is a clear violation of Permit PEA-179-06 Special Condition. And the three permittees - the Palau Transportation Corporation, CIP-Bureau of Public Works and Ngaraard State government were served a Notice of Violation EQPB NOV No. 07-14 issued on 13th of March 2007 (Details-Exhibit 13).

On March 20, 2018 the Three Permittees representatives appeared before the EQPB Board meeting and acknowledged the error made on their part, agreed to take responsibility for the negligent actions leading to the construction of the unpermitted road crossing through the mangrove area, and asked the Board’s understanding to allow the new road alignment indicating the irreversible rehabilitation of mangrove area and emphasizing the need for safety and accessibility to the people of Ngaraard State.

On March 21, 2007, EQPB letter was sent to Permittees directing them to proceed with the require work to complete the newly constructed road in accordance to submitted plans on file at EQPB office. It also mentioned that the Board is currently assessing the fines to be imposed on the parties, and urged Ngaraard State Governor Laurentino Ulechong to enact a legislation that would designate as conservation areas wetlands not less than 2,675m² with the presence of similar biodiversity as he alluded to during the Board’s meeting on March 20, 2007.

Moreover the three Permittees and or Respondents received the EQPB Order No. 07-17 (Details Exhibit 14) issued on 18th of April 2007 Imposing Penalties specifically relating to the violation of EQPB’s Earthmoving Violations 2401-1-14 et seq., and failure to adhere to permit conditions set forth in Permit PEA-179-06 relating to the Orredakl Road Improvement Project located in Ngaraard State. All Three Permittees and or Respondents were ordered to pay civil penalty as follows;

CIP-Bureau of Public Works:

• $1,000.00 fine payable to EQPB Mitigation Trust Fund. • In-Kind technical assistance to design a plan to improve the road and help acquire EQPB permit to the water filter plant in Ngetmellasch, Ngaraard State. Submit design plan to EQPB for review and approval. • In-Kind assistance to help the Bureau of Public Works Rural Operator to repair/install functional chlorinator for the public water supply system in Choll, Ngaraard State by the end of June 2007.

Palau Transportation Corporation:

• In-Kind Assistance through labor and materials to improve road to water Ngetmellasch, Ngaraard, and improve the road for vehicle access during water system monitoring/treatment inspections.

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Ngaraard State Government:

• In-Kind assistance through labor and materials to improve road to water filter at Ngetmellasch, Ngaraard State and improve the road for vehicle access during water system/treatment inspections. • Enact legislation to designate as conservation areas wetlands not less than 2,675 square meters (m²) with presence of similar biodiversity.

The Three Respondents/Permittees concurrently received on 16th of May 2007 EQPB Order No. 07-24 – Notice of Suspension of Civil Penalty and Amendment of Fine. This is pursuant to Environmental Quality Protection Act, 24 PNC §et seq., (“EPA”) and 24 PNC §162 to suspends the $1,000.00 fine against CIP-Bureau of Public Works (CIP) and amend the fine for Ngaraard State Government. The suspension of civil penalty and amendment of fines may have been the positive consensus reached during the meetings held between Respondents and the Board’s on March 20, 2007 and May 3, 2007. The entire contents of EQPB Order No. 07-24 can be referred to Exhibit 13.

Applicable Ngaraard State Laws & Plans

• Ngaraard State Public Law (NSPL) No. 4-4 – To provide for the designation and set aside of mangrove area on the West Coast of Ngaraard as a Conservation Area – Section 7-9.

• Ngaraard State Public Law (NSPL) No. 7-13 – An Act – To designate a wetland area at Ungelel as a Conservation area and for other purposes. Legislative Purpose – The State is committed to designate a wetland area as a Conservation area by way of EQPB Order No. 07-17, which was entered to resolve an Environmental Quality Protection Board matter concerning the construction of the Urung Orredakl Road. The wetland area comprising of 2,675 m² at 7° 38’59”N, 134° 38’02”E mangrove area west of land area of Ungelel and Northwest of the adjacent roadway.

• NSPL 7-25 – To designate and declare Ngerkall Lake, the Metmellasech Water Dam, and Diong ra Ngercchokl and the areas surrounding it as conservation areas in Ngaraard State.

• NSPL No. 8-5 – To establish a marine and terrestrial conservation zone in Ngkekelau, Ngaraard to be called the Ongiil Conservation Area.

• Joint Resolution No. 8-3-33-18S- Ratifying further amendments to the Kerradel Conservation Network Management Plan 2011-2016.

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

• NSPL 9-14- To amend the NSPL 4-4 to establish buffer zone for the Mangrove Areas on the West Coast of Ngaraard.

• Joint Resolution No. 10-13-1S – To endorse and support Governor Benjamin Iskawa’s proposed to fill (reclaim) the mangrove area to the east of Ngaraard State Office. The site for proposed Urung Submerged Land Fill Project. (USLFP)

• Ngaraard Final Master Plan

• Kerradel Management Plan 2011-2016

• Kerradel Management Plan 2018-2023

(B) The use of national or state funds, unless the funds are to be used for: (1) Feasibility or planning studies for possible future programs or projects which the applicant has not yet approved, adopted, or funded, provided however, that the applicant shall specifically consider environmental factors and available alternatives in its feasibility or planning studies, or; - Several beneficial actions are anticipated as a result of the proposed action to develop the proposed USLFP site. Several residents may have a place for their residences and that Ngaraard State Government may build several infrastructures in support of the forthcoming activities toward development of Ngaraard state. The Ngaraard residents in

Koror - Sechemus, Ikesiil, Delui, and Ngel are about to be displaced by the encroaching high tide and may have to relocate and it is of essence that Ngaraard leaderships get together to address displacement of its citizens. The concern of encroaching tide will remain an issue even if several residential housings are placed in the USLFP. This is confirmed by residents who frequent Urung that have noticed the tide to be more than four inches (4) above or over the cement road at some times during extreme spring tides in April and or summer in August. This proposed USLFP site can be beneficial to the people of Ngaraard if properly developed for aquaculture farm to polyculture milkfish, crabs and prawns that can generate revenues to the state.

Funding for USLFP and Ngekelau Etoikechang Yasumba Project has not been met hence Ngaraard State Public Law (NSPL) No. 10-3 authorized and appropriated the initial sum of $8,000.00 for the environment assessment of the site. And during telephone interview with Honorable Keizi Shiro, Chairman of Ways & Means Committee is very keen of his support for the project and have asked the Governor to come - up with likely funding outline for both USLFP and Etoikechang Yasumba Project for inclusion to next fiscal year budget.

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(2) The acquisition of unimproved real property; - This property is undeveloped meaning absence of man-made structure however it is still having its natural characteristics of a submerged land (keburs) with 65% Tebechel Rhyzophora mucronata-mangrove plants, 25% brackish & 15% terrestrial plants. Hence the site has lost its distinctive smell of the mangrove the hydrogen sulfide smell of decaying detritus is no longer present. Rekung el Beab and Rekung el daob can be noticed in their cubicles/holes as often found near edge of land before/shoreline the mangrove. The Joint Resolution No. 10-3-1S adopted on March 20, 2018 endorsed and supported Governor Benjamin Iskawa’s proposal to fill in (reclaim) this enclosed mangrove area to the east of the Ngaraard State Office.

(C) Any use within any land which has been or may be classified as conservation district by the Republic or one of its state's land use commissions. In 2010, Ngaraard created the Kerradel Conservation Network consisting of six conservation areas and nominated the sites into the Palau Protected Areas Network (PAN). A five year management plan was developed with implementation of the Plan financed by the PAN. This management plan is a second iteration of a five-year management plan for the Kerradel Conservation Network (KCN). 1) East Coast Ngaraard Conservation Area, 2) Ungellel Conservation Area, 3) Ngaraard Mangrove Conservation Area, 4) Ngerkall Conservation Area, 5) Diong ra Ngerchokl, and 6) Ongiil Conservation Area. These six conservation areas cover an area of 8.892 km² or 23.4% of total land and marine area. These conservation areas are connected to and have joined the Palau Protected Area Network (PAN) in 2011.

(D) Any use directly or indirectly impacting "coastal waters" and "wetlands" as defined in the Republic of Palau Marine and Fresh Water Quality Regulations. The direct and indirect impact to coastal waters is not known as there is no record indicating such hence in 2007 construction of Orredkakl cement road directly to Urung cut the mangrove that is now enclosed and is the subject site for fill in this project process.

(E) Any use within any historic site as designated by the Palau Historic Preservation Office. There is no historical site at the proposed USLFP however the only historical site is the Cheldeklel a Dirrengulbai which is approximately 600 meters away to the north of causeway. (F) Any proposed action which the Board determines may have a significant impact on the environment. The proposed action should not result in significant impacts on the nearby environment. It is suggested that an Environmental Impact Statement (EIS) is not required for this proposed project. A Finding of No Significant Impact (FONSI) is anticipated. Moreover the Erosion & Sediment Control Plan (ESCP) will be strictly adhered to, to ensure that no sediments or pollutants seepage to the mangroves nearby that may impact on its ecosystem.

12 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

G) This USLFP will not be inconsistent or in conflict with provisions of Significance Criteria of 2401- 61-06 and may comply with the 2401-11-05 Section C § 1 & 3 Classification of Coastal Water Use - 1) The uses to be protected in this class of waters are small boat harbors, commercial and industrial shipping, bait fishing, compatible recreation, over-water commercial or residential structures for recreational or domestic use*, the support and propagation of aquatic life, and aesthetic enjoyment. 3) The Class B designation should apply only to a limited area next to boat docking facilities. No coastal areas with a coastal mangrove fringe greater than 50 feet in width shall be classified as Class B waters after the effective date of this amendment.*

1.1 IDENTIFICATION OF THE APPLICANT

Ngaraard State has a new governor, the Honorable Benjamin Iskawa along with new members of the 10th Olbetibel of Ngaraard State Legislature. The leaderships of Ngaraard are working in- concert with each other in regard to the USLFP and a good sign is the supplemental budget through NSPL 10-3 providing the initial budget for the site environmental assessment. Even the Speaker Keizi Shiro who was telephone interviewed is very keen to work with his colleagues to approve this budget. The members of the 10th Olbetibel have also advised the governor to come-up with his budget outline in next fiscal year for USLFP and Etoikechang Yasumba Project so that the budget can be worked-out to finance both projects. Speaker Shiro indicated that there may be large sum of money to be received from the Radar installation in Ngaraard which can be channeled to fund these two projects. Dredging Etoikechang to Yasumba and redregde back to build marina and use materials to fill Urung project site is “Like killing two birds with one stone.” Table 1 – Information about the project owner/applicant, address and contact information.

Name of Project: The Urung Submerged Land Fill

Applicant Name: Ngaraard State Government

Contact Person: Governor Ben Iskawa/John Mengidab

Address: P.O. Box 6026 Republic of Palau 96940

Telephone No: (680) 824-4499/4490/779-9054

Fax No: (680) 824-4855

E-mail: [email protected]

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(B) Identification of agencies and organizations consulted in making assessment;

There were no agencies contacted for reason of redundancy as this Environmental Assessment Report may have to be sent for review by numerous agencies and there maybe comments or questions to be raised and need to be addressed and or clarified by the EA Preparer. However EQPB was requested for Scoping Meeting on 24th June 2018 where the Governor and the EA Preparer were advised of the 2007 EQPB NOV No. 07-17- Notice of Violation and EQPB Order No. 07-17- Order Imposing Civil Penalty with regard to the proposed site to USLFP. During this meeting, the Governor was advised to come up with a formal request processes to EQPB for considerations in respect to the USLFP. Nevertheless both Chairmen of the Ways & Means Committee Mr. Keizi Shiro and Resources & Development Mr. Saburo Remoket were telephone interviewed on July 4 & 5, are very keen to support governor and optimistic that budget for next fiscal year to finance these two projects of USLFP and Etoikechang Yasumba Project will be authorized and appropriated.

(C) General description of the action's technical, economic, social, and environmental characteristics;

Action’s Technical;

1) The State may have all the - Tebechel-Rhyzophora mucronata uprooted as the when stumps rot may create a sink-hole in the soil to compromise the structural foundation of structures that may be built on the site;

2) Once filling is complete, let the site to compact naturally for at least three months and for the soil to be stabilized before construction starts;

Economic;

This proposed site can be developed into aquaculture farm to polyculture mangrove crabs - Scylla serata, Milkfish – Chanos chanos, & Saltwater shrimp – Panaeus monodon to generate revenues to the state. The proposed site can also be leased to Ngaraard aquaculturists so that they can generate money from the sales of their products to support their families and at the same time pay lease rental and taxes to the Ngaraard state government. Approximately $4.5 million is still available at Palau National Development Bank to loan at a minimal interest rate for development of aquaculture, piggery, chicken and agricultural farms.

14 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Social;

Some of the Ngaraard citizens in Koror who reside in Delui, Butilei, Sechemus, and Ikesiil, who are about to be displaced by encroaching high tide can relocate to this proposed site to socially dwell in their own community. Nonetheless the encroaching high tide will remain a national concern and to address this issue particularly for Ngaraard State, its leaderships need to get together and 1) identify public and private lands to allow for housing developments & 2) expeditiously meet with H.E. Tommy E. Remengesau Jr. to get a hold & secure some of the money from ROC Taiwan for Ngaraard housing developments.

Characteristics of the Environment;

The proposed site is a submerged land (mangrove) that ends at the base of the natural basalt hill that runs the length of Urung. It became enclosed when Ngaraard state Government built the Orredakl cement road directly to Urung dock and, now it is sandwiched between the cement road and basalt hill. It shares the boundary with 053 E14 of Mr. Kenneth West property and 053-E15 & 053-E13 Ngaraard State compound. The vegetations consist of 65% Tebechel – Rhyzophora mucronata with the surrounding shrubs and sedges. This site has lost its distinctive smell of hydrogen sulfide of rotting detritus. A substrate sample was even dug for smell testing and result was that this distinctive smell have ceased to exist or not evident.

15 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(D) Exhibit 1 - Propose Site Map and Characteristics

Onetime Fishmarket Urung Junction State Office

State Public-works

2006 Cement Road

USLFP Proposed Site

Old Road

Compact Road to Urung causeway to Ngerchelong

16 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(E) Identification and summary of major impacts and if any

Exhibit 2– Matrix of Impact

Impact Assessment

Mitigating M easures Type Duration Scope Magnitude/Severity Impact

Short Long Loca- Wide- Insig Moderate Severe Positive Negative Term Term lized spread nifca nt Soil erosion is limited to only filling. Silt Soil Erosion X X X X fence and sand bags will be deployed Only in Proposed site. 95% of Tebechel X to be uprooted for Vegetation Clearing X X summer house or X chips & firewood. Shrubs & sedges can be left for use as silt fence to reduce silt flow if any. Excess Soil from Only limited to the Grading Activity fill area. Silt fence X X X X will be deployed around area to be affected. Sand bags deployed in front of culvert to filter sediments runoffs Waste Water Generation Workers use toilet at X X X X outside State office

All heavy Air Pollution X X equipments will be X properly muffled

17 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Figure 1 – List of Plants

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Figure 1a – List of Plants continued

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Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Figure 1b – Signature page.

Mr. Naito Soaladaob is a local plants expert who has been helping FCC in identification of plants in numerous EA Methodology. Scanning the name lists of plants into this EA Report will only authenticate his original work.

20 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Figure 2 Bird Survey

21 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.2 IDENTIFICATION OF EA PREPARER

Mr. Theo Isamu has been a freelance consultant since retiring in 2009. He has been involved in the aquaculture and fisheries development and management for the last 35 years as a technician, chief and a first director of the Bureau of Marine Resources – Ministry of the Natural Resources Environment & Tourism. Start conducting Environmental Assessment in 1989 first for Ngatpang and in 1990 for Melekeok Fishing Port- Marina. Mr. Isamu believes that Palau Environmental Quality Protection Board (EQPB) PNC Title 2401-1 Earth Moving Regulations shall not be taken for granted at all costs as the present generation is only the caretaker of our “Lukel a Klengar” for the future generations.

Table 2. Information of EA Preparer:

Name of Company: Freelancing Consultant Company

Name of Contact Person: Theo Isamu

Address: P.O. Box 1694 Koror, Palau 96940

Contact Numbers: (680) H - 488-5352/CP-778-2597

E-mail: [email protected]

EA Process and Documentation

The environmental process depends on the scope and activities that project will be involved in relation to the business. In respect to the applicability of the environmental process as per 2401-61-03-04 and except as otherwise provided, an environmental assessment shall be required for any proposed action which the Board may determines to have a significant impact to the environment. And this EA applicability is consistent with 2401-61-05 and will not marginalize or compromise Significant Criteria as per 2401-1-06. The environmental assessment process was conducted in reference to past FCC’s EA documents and EQPB Chapter 24 Palau

22 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

National Code and its Regulations promulgated 26 May 1996. Interaction and consultation with applicant was vital to get information as much as possible of the project to prepare this environmental assessment report to EQPB.

The Award Letter which informed that FCC has been selected to undertake this environmental assessment was the basis for collecting information and collating data necessary to write this environmental assessment report. Below is the nomenclature of events in collecting information.

June 13, 2018 – Received Award Letter from Ngaraard State Treasurer Ms. Lotoya Besebes and requested her to make an appointment with governor on June 18, 2018.

June 18, 2018 – Called the Governor Iskawa for a meeting at Longshoremen Restaurant. Governor advised on his overview of the project and signed the Bilateral Terms of Reference that outlined the scope of work for each party.

June 28, 2018 – Met with Ms. Lotoya Besebes at Longshoremen to uplift copies of Ngaraard State Conservation Laws and the NSPL No. 10 -3 for Supplemental Budget.

June 29, 2018 – Visit project site to survey for birds and vegetation. Took vegetation photos and around the site.

July 03, 2018 – Visit the site again to check the tide on how far it goes through the mangrove. Interview Mr. Jerome Temengil to get his view about the project in relation to his mandate as the Kerradel Conservation Network Coordinator. Requested Mr. Temengil to send via email the Kerradel Conservation Management Plan and the Ngaraard State Master Development Plan.

July 04, 2018 – Telephone interview Chairman of Ways & Means Keizi Shiro about his views with respect to the USLF project.

July 05, 2018 – Telephone interview Chairman of Resources & Development Mr. Saburo Remoket on his views about the USLF project.

July 7, 2018 – Accompanied the plant expert Mr. Naito Soaladaob to the site to identify trees, shrubs and sedges. And visit Ngekelau to take photos of Etoikechang Yasumba Project.

July 24, 2018 – Governor Iskawa met with EQPB Executive Director and staff for a scoping meeting to discuss the past project site violation and the way forward for this new USLFP.

23 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.3 EA Methodology

An initial terrestrial walk survey was conducted on June 28, 2018 to get an overview of the vegetations, bird and animals associated or found in the site. And on July 3, visited the site again for the second time to observe the high tide at 09:54 A.M. to see how it flows through the culvert and to what extend through the site and to resurvey for vegetations, birds and animals and to observe in-order to absorb the feel of the environment of the site. Visited the site again on July 7, 2018 with plant expert Mr. Naito Soaladaob to survey and identify vegetations. The FCC visited the project site for three (3) times. Upon these three visits, FCC conducted birds and plant survey, and walked around the site to absorb and feel its surroundings. Since the project site is in close proximity to the state office it was possible to visit the office and interview some of the staffs who were able to exchange their experience about the site.

1.4 PROJECT DESCRIPTION

The Project is to fill the 4266²m submerge land (Keburs) adjacent in boundary with the Ngaraard State office is consistent with the Governor’s plan proposing to meet the Project Objectives. The State public-works will dredge materials from Etoikechang Yasumba project to fill this project site. And this EA is an initial EQPB permitting process to enable Ngaraard state to fill the project site thus meeting its objectives.

1.5 Project Objectives:

The Governor Iskawa’s plan is to use the Etoikechang Yasumba Project dredge materials to fill the propose USLFP site. However the Etoikechang Yasumba Project request for its permit extension is still being reviewed by EQPB but once the permit is approved then dredging will commence to avail materials to fill USLFP site. The second component objective for this project is for Ngaraard State to build additional structures such as housing residences for the people of Ngaraard and extra building and/or structures in support of the forthcoming activities toward the development of Ngaraard State.

24 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.6 Project Site Description

The proposed site is a submerged land (mangrove) that shares the shoreline with the base of the natural basalt hill that runs the length of Urung. It became enclosed when Ngaraard state Government built the cement road directly to Urung dock and now it is sandwiched between the cement road and basalt hill and also sharing boundary with Ngaraard state office. The vegetations consist of 65% Tebechel – Rhyzophora mucronata-mangrove plants, 25% brackish and 15% terrestrial plants of surrounding shrubs and sedges. This site has lost its distinctive smell of hydrogen sulfide of rotting detritus of plants leafs and branches. A peat substrate sample was even dugout for smell testing and result was that the distinctive smell of mangrove peat have ceased to exist or not evident.

Figure 3 – Project Site

25 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.7 Project Location: Exhibit 3

USLFP site is located in close proximity sharing boundary to the Ngaraard State office & it public work facility & PNCC Hub at Urung, Ngebuked, Ngaraard. It is a submerged land (keburs) of more or less than 4,266²m sharing the boundary of Mr. Kenneth West property 053-14.

Exhibit 3 Map Layout & 3 GPS location points of USLFP site in purple, orange & red box. Site indicated by white star, state office and public work facility are also indicated by white arrows.

Ngaraard State Office Five For One, One For All

State Publicworks

GPS N07°38.473 GPS N37°38.467 E134°37.956 E134°38.020

USLFP Proposed Site

GPS N07°38.52 E134°37.977

26 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photos taken at Project Location

Photo 2-Left Culvert at N07°38.494 & E134°37.984

Photo 3&4 taken of same culvert outlet at left at low tide on June 29, 2018 and at right at high tide taken on July 3, 2018 Photo 3 High Tide

Photo 4 Right Culvert inlet at N07°38.496 E134°37.986

Photo 5 24 Coconuts lining up the side of the project site of cement road leading to the Urung Port. USLFP area is 4266²m to the west/left of the Orredakl cement road.The cement road divided the mangrove in 2006 that became enclosed and is now the project site.

Orredakl Cement Road

27 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 6

West side of the project site. The green structure is the Ngaraard State Publicwork building. Bananas, Kisaks, Coconuts, Ngas and Tebechel seem to demarcate the boundary. This site was also a submerged land and was filled up to be used as sites for Ngaraard state office and facilities. Fill materials were dredged at tip of Ururng causeway to the west.

28 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

USLFP site has a map Unit of 617 of Ilachetomel Series resulting from decaying leafs and branches of trees and other decomposed deposits.

Exhibit 4 – Soil Type

Ilachetomel Series Map unit: 617 Depth class: Very deep Drainage class: Very poorly drained Most limiting permeability (Ksat): More than 36 cm/hr (more than 14.17 in/hr); very USLFP Site high Landform: Intertidal zone of mangrove swamps, salt marshes, and tidal marshes Landscape: Shoreline of volcanic islands Geomorphic position: Talf Parent material: Organic deposits derived dominantly from decomposing mangrove roots and litter Elevation: -1 to 4 meters (-3 to 13 feet) Slope: 0 to 1 percent Climatic data Mean annual precipitation: 3,300 to 4,650 millimeters (130 to 183 inches) Mean annual air temperature: 27.0 degrees C (81 degrees F) Taxonomic class: Euic, isohyperthermic Typic Sulfihemists

29 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.8 Project Features – Project site now is 65% mangrove trees, 25% brackish plants and 15% terrestrial plants and is enclosed by a natural basalt hill, the cement road and the land site for Ngraard State Office and its facilities. The vegetations in the site will be completely uprooted to enable filling of the site. Total area of the proposed site is 466²m.

Technical Characteristics – The estimate total volume of materials to fill the proposed site is more or less than 2400³y fill to be dredged from Etoikechang Yasumba Project. The surrounding contour of the site surveyed to arrive in a decision on how to deploy the silt fence and placing of sand bags. It is recommended that part of cement road parallel must be elevated at least 2 feet to keep out the encroaching tide during April spring and August summer high tide. The site must also be filled to be of same level with the new elevation of the cement road. The artificial culvert conveyance must be reconstructed to accommodate the natural conveyance so that the storm surge will not push through to flood the project site. The Photo 7 below shows the natural conveyance facility of the storm water from basalt hill to flow down to the project site. Pit with water naturally formed by the force of storm water.

Photo 7 - Natural Pit with water

30 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

1.9 Infrastructure Considerations – Governor Iskawa is proposing to build additional structures such as housing residences for the people of Ngaraard and extra buildings or structures in support of the forthcoming activities for the development of Ngaraard State. Designs for these proposed infrastructures will be produced when USLF project is completed and to be included in the next EQPB process.

3. Project Implementation Schedule – There is no project definite schedule to start hence soon to start when USLFP is approved and the request for extension to dredge Etoikechang Yasumba project is approved by EQPB. Even the likely schedule for the project to complete is not known.

Financing – Budget for projects is vital for their continuity. The annual budget for Ngarard public works is $36,000 and this is allotted for fuel, repair and parts. Hence the leadership of the 10th Olbetibel concurred that they will support Governor Iskawa on this project and have asked him to provide an outline cost for both Etoikechang and USLFP for use to justify budget for next fiscal year.

3.1 Existing Environmental Conditions - The project site is untouched still retaining its original foot prints of Tebechel and surrounded with shrubs, sedges and kemokem usually found edge of shoreline before the mangrove. These trees will be uprooted because if the stumps are left may rot in the fill and create a sink hole to compromise whatever structures to be built upon the project site. The trees can be used for summerhouse, firewood or can be chipped and use as plant soil supplements. The shrubs and sedges will be cleared with backhoe and to be left as facilities to reduce acceleration of runoff should it rains. The coconuts and bananas and other trees on the side of basalt hill will remain untouched as they are natural facilities to reduce acceleration of runoffs to the site.

31 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 8 - Etoikechang Yasumba Project where materials are to be dredged to fill the Urung Submerged Land Fill Project (USLFP). Length of causeway now is more or less than 554.74 feet. This project is awaiting extension permit approval from EQPB. Yasumba as a small speck in foreground with arrow pointing to it. Distance from Etoikechang to Yasumba is more or less than 3,700 feet.

Yasumba

32 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

4. IMPACT ASSESSMENT & MITIGATIONS

4.1 Initial Impact to the Project Site Before Filling - Soil Erosion

Potential erosion could occur as a consequence of localized alterations and land disturbing, removal and clearing of trees. Bare peat/soils will be exposed during the clearing, once exposed, peat/soils may be subjected to erosion and subsequently deposited into outside the area of works. Loose peat/soils are susceptible to erosion, especially if it rains heavily. Storm water runoff from the site may carry loose soil/peat particles into the adjacent area, hence reclaiming should remain is the area of works.

Mitigating Measures: Erosion and Sedimentation Control Plan (ESCP) required by the EQPB shall be strictly implemented. These erosion control measures include sand bags berm /silt fence of geo-textile lined around the perimeter of works. These silt fences shall be installed in appropriate locations and regularly maintained throughout the duration of construction activity. Earthmoving will not be undertaken during heavy rains. All erosion control structures in place shall be inspected regularly and observed during heavy rainfall to verify efficiency and effectiveness. All damaged erosion control structures shall be repaired. Additional erosion control measures shall be implemented if found necessary.

4.2 Vegetation Clearing

About 65% of mangrove plants will be uprooted with 25% of brackish water plants and 15% of terrestrial plants. Terrestrial plants at the base of basalt hill are not to be removed as they will act as natural facility to reduce acceleration of storm water onto the site. 95% of the area will be disturbed during filling of the project site. Grass, ferns, and small trees to be cleared can be piled parallel to the cement road to reduce acceleration of runoff or storm water from the natural conveyance running down the basalt hill. Hence bananas and coconuts must not be removed to hold the soil together to prevent erosion.

Mitigating Measures: The USLFP site is sandwiched by the basalt hill, state land area and the cement road. With this unique physical characteristics sand bags can be used to completely block the left culvert in-outlet GPS location N 07°38.494 and E 134°37.904 The project site could be divided into four sections where one section is cleared and fill and let it stabilized and hardened to use as a stepping stone for the next clearing area and so forth. In this way the fill area can be stabilized and if there is storm water they can remain in the uncleared area and filtered through naturally and or through the sand bags. As much as possible, clearing of vegetation shall be limited to the areas to be impacted. Clearing of vegetation and project site

33 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597 filling shall be conducted by phasing to minimize the area exposed and susceptible to soil erosion. Cleared vegetation and tree branches shall be stockpiled along the perimeter of the cement road of project area to help filter sediments during heavy rains. Silt fence can also be used in this perimeter as additional facility to reduce possible acceleration of runoffs. Once the area of fill is close to the level of the state land area and the cement road then the silt fence must be installed in the entire perimeter to reduce sediment seepage onto the other side of the mangrove. Sand bags can be piled up alongside the length of cement road to reduce acceleration and filter runoffs.

4.3 Excess Soil from Excavation Activity

Excavation of the building foundation is expected in the next phase of this USLFP. Should there be excess soil materials will be used to fill low-lying areas. Adequate compaction shall be provided to a fill area to prevent and/or reduce possible erosion.

Mitigating Measures:

Excavated materials from Etoikechang Yasumba Project may be temporarily stockpiled close to USLFP site. These material stockpiles if not used will be covered by tarpaulin or plastic sheeting to prevent erosion.

4.4 Wastewater Generation

Wastewater resulting from equipment washing and all types of wastewater shall not be allowed to be discharged directly into the site.

Mitigating Measures: Additional workers if any will be allowed to use the existing toilet facilities outside the state office. Wastewater from equipment washing will be diverted into an undisturbed project area and allowed to settle prior to discharge, if necessary. Otherwise, the water will be left in the undisturbed project site until it seeps out or dries up naturally.

4.5 Air Pollution

Unmanaged air pollution—especially from particulate and gaseous emissions generated by construction machinery—may create nuisance and, in extreme cases, adverse health impacts. Site activities will require breaking up, digging, crushing, transporting, and dumping of large quantities of dry material and will generate dust in and around project areas. The transport of materials from source to site would entail use of heavy trucks, which have the potential to produce polluting gaseous emissions and dust and falling objects, depending on the material being transported. Dust emissions may result from the excavation works while gaseous pollutant concentrations from construction vehicle activities, such as site preparation,

34 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597 earthmoving/grading may increase at the project site, but these impacts are largely unavoidable and temporary (short term). High rainfall in Palau is expected to help minimize fugitive dust emission from the mentioned activities.

Mitigating Measures: Mitigation measures will include (i) operating construction vehicles within agreed time periods, (ii) enclosing construction sites, (iii) spraying dusty roads, (iv) maintaining moisture on construction materials, (v) covering dump trucks and other transportation vehicles, (vi) controlling vehicle speed, (vii) covering exposed soil or storage areas, viii) limiting land filling and leveling works during rainy season.

4.6 Noise

Noise generation is expected in any construction activity. The use of heavy equipment such as grader and excavator is expected to increase the noise level in the area. Birds habituating the area may move elsewhere because of the construction noise and their habitat being destroyed. Construction noise may disturb transitional wildlife and birds in the nearby area. However, the increase in noise level due to the construction activity will only be temporary (short term).

Mitigating Measures: All equipment operating within the construction area will be properly muffled. Work hours will be limited between 7:00 AM and 6:00 PM, Monday through Friday and Sunday. No nighttime activity, that will generate noise, will be performed at the project site. Measures to minimize impacts to human will be implemented, e.g., the Ngkeklau and Urung community will be informed of increase in traffic and the expected noise generation.

4.7 Potential Damage to Urung Road

Due to frequent travel of hauling trucks delivering filling materials and other types of heavy equipment, potential damage may occur to the existing Ngkeklau road, compact road including Urung Road. Mud, dirt and spillage may also result from dirty truck/equipment tires and overfilled trucks entering these roads.

Mitigating Measures: Dump truck shall carry amount of soils and maintain speed such that it will not cause any spillage during travel from the site to its destination; Dump truck carrying soils shall be covered with tarpaulin; All outgoing trucks tires may be washed clean of dirt/soil before entering Ngkeklau community, Compact and Urung road.

4.8 Solid Waste Generation, Collection and Disposal

The project is expected to generate considerable amount of solid waste, especially when clearing to uproot the Tebechel and other trees, shrubs and sedges. There should be an effort

35 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

from the applicant to practice the 3Rs, reduce, recycle & reuse to minimize solid waste generation.

Mitigating Measures: A waste management plan will be prepared and followed. Tebcechel can be used for summerhouse materials, and branches can be put through a wood chipper to prepare soil cover for garden beds, etc. Shrubs and sedges can be used to spread onto the unstabilized fill to reduce acceleration of runoffs until it’s stabilized. Decaying shrubs and sedges can be recycled to fertilize vegetable garden table or flower beds.

4.9 Stormwater Management

Stormwater is expected upon completion of USLFP site as more areas are exposed, in particular the ground cover removal and grading will add up to the amount of stormwater. If not properly addressed, the stormwater may flood the area.

Mitigating Measures: If possible, stormwater management plan will be developed, however water may be easy to percolate through the area of project site that has been filled with porous dredged corals and sand materials from Ngkelau Etoikechang project. The temporary conveyance facility will be excavated to direct stormwater from the natural conveyance facility to the excavated pit before the in-outlet culvert facility until they permeate or dry naturally or filtered through the sand bags.

4.9.1 Traffic Hazards

Increase in traffic volume is expected when the project fill starts. If not properly dealt with, this impact may result to traffic-related accidents. Traffic controllers may be placed particularly at the junction to Urung and before entering project site.

Mitigating Measures: Traffic warning signs, e.g., STOP, YIELD, KEEP RIGHT, etc., shall be installed at appropriate locations along the side of the access road before junction to Urung and project site.

36 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

5. EROSION & SEDIMENTATION CONTROL PLAN (ESCP)

The purpose of a silt fence is to retain the soil on disturbed land (Photo 9), such as a construction site, until the activities disturbing the land are sufficiently completed to allow revegetation and permanent soil stabilization to begin. Keeping the soil on a construction site, rather than letting it be washed off into wetlands, mangroves, natural water bodies (e.g., streams, rivers, ponds, lakes, estuaries) prevents the degradation of aquatic habitats and siltation of harbor channels.

A silt fence is a temporary sediment barrier made of porous fabric. It’s held up by wooden or metal posts driven into the ground, so it’s inexpensive and relatively easy to remove. The unique characteristics of the site sandwiched sediment-laden stormwater runoff, causing sediment to be retained by the settling processes. A single 100 foot (ft) run of silt fence may hold 50 tons of sediment in place. Most construction sites today do have silt fences. In the USLFP site it is good to use the silt fence and sand bags to seal the outlet culvert so that runoffs can be filtered by sand before seeping to the other side. The silt fence may also be used when fill area becomes level with the cement road. More efforts to reduce acceleration of sediments should be done after filling the site. Silt fence should be set from west side around to eastern point of boundary parallel or west to east alongside the cement road.

Photo 9 – An Example of Silt Curtain

37 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

This Project Erosion and Sedimentation Control Plan (ESCP) demonstrates to the Board that alteration of these measures and/or facilities (EQPB 2401-1- 09) or inclusion of other measures will prevent accelerated sedimentation, other water quality degradation, or other environmental degradation. This section will address recommended mitigation measures practically that Ngaraard State will comply and carry-out in order to prevent/reduce erosion and sedimentation during of project site. Ngaraard public work management or Mr. John Mengidab will consult with EQPB personnel to ensure that these measures are implemented and be ready to make changes to ESCP and facilities if required. Other important measure requirements to be complied with are as set forth in EQPB 2401-1-04, 1-08 &2401-1-10& 2401- 1-11. The measures below are amalgamation of measures a as set forth in 2401-1-09 & 2401-1- 10.

(A) Limiting Exposed Areas (B) Containment of Underwater Sedimentation * (C) Velocity Control (D) Stabilizing (E) Interim Stabilizing (F) Containment of Fills and Reclaimed Land Within Bodies of Water or tidal Zones*

(G) Collection of Runoff (H) Restoration

The following sections will address only 5 measures applicable USLFP site hence B, F, are not applicable. Project site was in tidal zone but (F) measure is not addressed because the site is now sandwiched by the basalt hill, state land compound and the cement road. And the tide is confined to the mouth of outlet culvert an artificial conveyance alongside the cement road. Even biological measurements such as pH, temperature and oxygen level were not necessary to be conducted as the site is confined in a small area and its changes in physical parameters may not be able to influence the whole Urung bodies of water or its tidal zones. High tide was observed during 09:54 A.M. high tide in July 3, 2018 which only confined to the mouth of the conveyance culvert and alongside the ditch parallel to the cement road. Each measure is addressed with recommended actions and facilities for effective implementation to prevent/reduce velocity acceleration of erosion and sedimentation.

38 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(A) Limiting Exposed Areas – All earthmoving activities shall be planned and undertaken in such a manner so as to minimize the area of disturbed land, reef or lagoon. Sediment retention booms shall be erected demarcating the project area as the work must remain within the original footprint to reduce further removal of new vegetation and soil.

Mitigating Measures: Sediment retention booms must be used, constructed to restrict accelerated sedimentation around earthmoving or earth disturbing activity on the project site in all cases. Retention boom is a geotextile fabric made of 95% propylene or ester polymer is best used as silt curtain. A temporary security galvanized steel fence can be constructed for the silt boom to be lashed onto it to prevent sagging and permeable sand bags maybe placed if preferable at the base to serve as barriers and additional runoff filters. Sediment booms must be inspected during and after heavy rain for possible sagging or tear. Workers must keep a close watch for possible precipitation and be ready to cease all earth moving activities. State Publicwork personnel management shall ensure that each section of earth moving must be covered with tarp plastic sheeting if not stabilized after working day.

(C) Velocity Control

Natural Conveyance A temporary diversion berm if necessary sand bags to be deployed around the area along with retention boom and shall be constructed demarcating the area of works protect the trees and vegetation that may not be cut or cleared as they will act as barriers to reduce the acceleration velocity of runoffs and to filter sedimentation should there be any.

(D) Stabilizing

Area or site to fill may be divide in to 4 section Each section of bare peat or disturbed earth the project site must be stabilized and covered with plastic sheeting before moving on to the next section. Dried grasses on site shall be retained for moisture absorption and to reduce the velocity of runoffs. As mentioned earlier the workers must keep a close watch for possible precipitation or inclement weather and be ready to cover-up all disturbed soil and cease all activities relating to dredging, transporting and stockpiling.

39 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Interim Stabilizing

Where it is not possible to permanently stabilize a disturbed area immediately after the final earthmoving and filling has been completed or where the activity stops for more than 14 days, interim stabilization measures shall be promptly implemented. No earthmoving activity shall be conducted during times of inclement weather unless directed by the Board to prevent further accelerated erosion or sedimentation. All disturbed soil must be covered with plastic sheeting and maybe planted with appropriate plants and grasses as a long term natural facilities to prevent acceleration of erosion and sediments. Bananas, coconuts, and trees around the boundary are not to be removed. Shrubs, trees and sedges on the inclined wall of the basalt hill must not be removed as they will act naturally as barriers to reduce acceleration of stormwater or runoffs.

(G ) Collection of Runoffs through artificial facility

It is quite impossible to stop the inclement weather or rain pouring onto the site hence practical measures could be applied basically to reduce the velocity of runoffs and divert it to facilities for removal of sediments. In this case diversion terraces or interceptor channel may be constructed as support the existing facilities to prevent & reduce velocity acceleration of flow of surface runoff so as not to cause accelerated erosion. Should basin be required for sediment settlement as an add-on, the Ngaraard publicwork personnel may excavate a pit with enough capacity to hold the sedimentation and facilities such as small tree branches and silt fence to reduce acceleration and filter through the sand bags in front of culvert conveyance before going out to the adjacent mangrove.

(H) Restoration – 2401-1-11

(A) Stabilization. Upon completion of the project, all areas which were disturbed by the project activities shall be stabilized so that velocity of accelerated erosion and/or accelerated sedimentation will be prevented.

(B) Interim Control Measures. Any erosion and sedimentation control facility required or necessary to protect areas from erosion during the stabilization period shall be maintained until stabilization is completed.

40 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

(C) Final Measures. Upon completion of stabilization, all unnecessary or unusable control facilities shall be removed, the areas shall be graded and the soils shall be stabilized.

6. Other Mitigating Measures

The Ngaraard publicwork personnel may design a plan for containment of rain & storm water and erosion & sedimentation control with this Environmental Assessment to EQPB. However the followings are other methods and facilities that could be applied and implemented before any additional earth moving activity is to take place on the site.

• Sandbags will be piled to completely cover the culvert facility. Propylene sediment boom will be deployed in entire periphery of the cement road to the west end of the boundary. Small frond with leafs if cut to be piled before the silt fence to also serve to reduce flow and filter of sedimentations; • All uncovered/unfinished excavated earth after working hours must be covered by plastic sheeting or be cordoned temporarily using sand bags to prevent &reduce velocity acceleration of sediment & erosion flow into surrounding areas, • Important trees and common grass vine like dried Lisel a beab, ngidech, bigger trees outside the area of works should be saved for rain to trickle down on them reducing direct impact to the disturbed peat/soil to prevent/reduce possible erosion and runoffs;

• Establish cooperation for consulting with EQPB technicians for advice in proper placement of retention boom and other technical environmental management issues that may continue to help prevent/reduce sediment flow into the surrounding environment during filling and future construction; • All earthfilling activities should remain in original footprint & be planned and undertaken in such a manner to minimize the area of disturbed land, • First Aid Kits to be made available on-site, • Clearing of vegetation and trenching should only be within the original foot print of area of works,

• Soil stockpiles should not be placed outside the area of works and bare disturbed peat/soil should be covered with plastic sheeting as soon as practicable, • Minimize disturbance to trees should there be nesting birds outside the area of works, • Limit the use of heavy equipment and chainsaws to only allow daytime working hours,

41 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

o Where areas are stripped of vegetation, stabilize them to prevent erosion;

• Storage facilities should be maintained and allow for efficient and safe collection and waste containers should be managed and maintained,

• To be aware and report any UXO and unexpected archaeological finds to the Historical and Cultural Preservation Division,

• Other impacts for consideration include secondary effects relating to changes in the environment.

42 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 10 - The coconut, kemokem, sedge foliages on this side of cement road will not be cleared as they will serve as barrier to reduce acceleration of runoffs and sedimentations. Can be cleared once if the fill area is stabilized.

Photo 11 - This old truck parts at eastern boundary at the side of cement road must be removed, must have broken down during the road construction and never removed.

43 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

ExhibitExhibit 5 - EROSION III SEDIMENTATION CONTROL PLAN ILLUSTRATION

Culvert

Stormwater trickle from natural pit flow to silt fence through sand bags and culvert.

Natural Pit

44 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 12 - This culvert conveyance will be filled with sand bags as filters so that excess storm water can filter out before going to the other side mangrove and when the filled area is stabilized, sand bags can be replaced by boulders for water to permeate through their cracks. The culvert berm is a foot above cement road and the conveyance receives water from the state compound draining into this culvert.

45 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 13 - The pit that receives storm water from the natural conveyance can be enlarged enough to receive stormwater from the basalt hill so that water would not disperse to the area of fill that have not been stabilized. A temporary conveyance will also be directed to this pit so that sediments can settle down before water can trickle out through silt fence & sand bags and culvert conveyance.

46 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Photo 14 – Silt fence left on site that must have been used to reduce acceleration of sediment when filling the state compound. All silt fences must be removed once fill area is stabilized

Photo 15 - Surprised to find Bamboo Bambusa vulgaris in project site shoreline

47 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 6 -- Accountability

July 15, 2018

ACCOUNTABILITY

The information contained herein the Environmental Assessment Report are true based on interviewees comments & consultations with Applicant and investigations & assessment undertaken in the subject project site of Urung Mangrove Area on the east of the State public works building at the State Compound. And my signature has been affixed here below to attest that such information are true & correct and I will be accountable for them.

48 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 7a

49 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 7b

50 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 7c

51 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 8

52 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 9

53 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

54 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 11 Terms of Reference

HONORABLE BEN ISKAWA THEO ISAMU GOVERNOR – NGARAARD STATE FREELANCING CONSULTANT COMPANY P.O. BOX 6026 P.O. BOX 1694 NGARAARD, REPUBLIC OF PALAU 96940 KOROR, REPUBLIC OF PALAU 96940 PHONE : 824 - 4490 PHONE: (H) 488-5352 – MP: 778-2597 EMAIL: [email protected] EMAIL: [email protected]

The Environment Assessment (EA) is prerequisite for all earth moving requirements promulgated by the Palau Environmental Quality Protection Board pursuant to the authority granted by Title 24 Palau National Code. This Bilateral Terms of References (BTOR) is reached between Honorable Ben Iskawa Governor of Ngaraard State and Freelancing Consultant Company (FCC) in regard to environmental assessment of a submerged land at Urung which Lot No. is --- This BTOR outlines the tasks of both parties which both collect and to share information where FCC will collate such information as a coherent Environmental Assessment Package (EAP) report. This EAP report of two hard copies and 12 Compact Discs (CDs) will then be submitted to the Environmental Quality Protection Board (EQPB) to be disseminated to reviewers and report back with comments and or questions.

Upon submission to EQPB, process for approval may take 30– 45 days depending on the number of project on hand to be reviewed compounded with EQPB members meeting on Thursday every other week. If there are any comments or questions asked relating to the EA process or the Project, the FCC will liaise with Governor Iskawa or his representative to provide reply or answer to EQPB. The FCC and Governor Iskawa may also meet with EQPB for a scoping meeting in reference to 2401-1-07 to understand the critical environmental issues and a way forward for ease in the implementation of the reclaiming process of Urung submerged land..

Tasks to be undertaken by the Freelancing Consultant Company (FCC);

Undertake environmental assessment perspective of the site relating to the biological parameters of the submerged land in subject at Urung on, fish, invertebrates, animals, birds, and plants (fauna & flora). Solid- waste management plan, national and state legal perspectives, economic development plan, socio economic survey, attend public hearing, road safety & noise measures, EQPB Erosion & Sedimentation Control Plan, sea level rise and erosion relating to climate change and recommendations with final write up as the Environmental Assessment Package (EAP) which may take at least 30 days to complete.

55 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Information requested by FCC and tasks to be undertaken by Ngaraard Sate Government to be which information requested are and to be incorporated in the EAP report:

1. State Government Profile:

a) Name and Full address, number of personnel, b) Arrange/Conduct Public hearing for Urung Dock, c) Provide copies of laws, resolution, minutes from public hearing, d) Provide copies of Tourism, PAN, & Conservation plans, e) Ngaraard State short, medium and or long-term development plans; f) Apply and pay all fees relating PPUC, Historical, UXO, and EQPB permits; g) Liaise with CIP for Detailed Design of facilities to be built – where & type of materials to be used and volume of dirt or sand needed for fill the project site. The detailed scope of work of the project, anticipated cost & value, schedule or how many days allot to each activity or in phase by phase with likely total days to complete the project;

The FCC fee for the EA is with initial payment of during signing and final payment of upon completion of EA. Nonetheless, FCC will work closely with Ngaraard State Government through open dialogue to expedite approval of EQPB Permit for the implementation of this Project. With all aforementioned information requested to be made available as soon as practical, so that EA Package Report may be completed and submitted on July 31, 2018. This payment is in Reference to RFP – 2018-02 and Approval Award Letter dated June 13, 2018.

Governor Ben Iskawa Date FCC Theo Isamu Date

56 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 12a – Joint Resolution

57 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 12b

58 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 13a

59 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 13b

60 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 14a

61 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 14b

62 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 14c

63 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 15a

64 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 15b

65 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 15c

66 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 15d

67 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 16a

68 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 16b

69 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

Exhibit 17

70 The Urung Submerged Land Fill Project (USLF)

Theo Isamu Freelancing Consultant Company P.O. Box 1694 Koror, Palau 96940 Tel No. H 680 488-5352/MP 778-2597

REFERENCES ......

1981 Republic of Palau, Environmental Quality Protection Act, Republic of Palau Public Law (RPPL) No. 1- 58 Re: Codified Title 24 PNCA

Republic of Palau, EQPB August 2000. Guide to Environmental Impact

Environmental Assessment - December 2006 - Proposed Reclamation and Marina Improvement Project at Malakal of Koror State, Republic of Palau

Environmental Assessment - March 2006 - Proposed Oil and Gas Exploration Project at Velasco Reef in Kayangel State of the Republic of Palau

Environmental Impact Assessment Training – August 12-14 2008

Environmental Assessment – Palau Pacific Resort by Brewer/Brandman Associates May 1990;

Environmental Assessment – Melekeok Fishing Port by Theo Isamu January 1990;

Environmental Assessment – Palau Tuna Fishing Port – Melekeok November 2014

Environmental Assessment-Peleliu State Desalination System –May 08 2013

EQPB Regulations 2401 – May 26, 1996/January 8, 2013

Natural History of Palau (SC249)

Palau Soil Survey 2011 Natural Resources Conservation Service (NRCS) US DOA

Wild Orchid Hotel – Environmental Impact Assessment by NECO Construction Inc, December 23, 2013

Palau Visitors Authority States Brochure – Page 10

Environmental Impact Assessment of Airai Forest Villa – Asia-Pacific International Investment Inc. February 15, 2015

Environmental Assessment - Residence & Office Facility Palau E.U. Investment Inc. August 25, 2017

Environmental Assessment of PNQ Prefab Barracks June 25, 2018 – Being Reviewed.

EQPB Permit PEA 179-06 Conditions

71 The Urung Submerged Land Fill Project (USLF)