Initial Environmental Examination

Project Number: 44321-013

July 2020

Cambodia: Climate Resilient Rice Commercialization Sector Development Program (National Road No. 5, Pou Pir village, Kear commune, Moung Ruessei district, Battambang province)

Prepared by Ministry of Economy and Finance for the Royal Government of Cambodia 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.

CURRENCY EQUIVALENTS (July 2020)

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 ...... 11 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 ...... 16 V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ...... 16 A. Method of Assessment ...... 16 B. Environmental Impacts Related to Location ...... 16 C. Environmental Impacts Related to Construction ...... 17 D. Environmental Impacts Related to Operation ...... 18 E. Global, Trans-boundary and Cumulative Impacts ...... 19 VI. ANALYSIS OF ALTERNATIVES ...... 19 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...... 20 A. Consultations and Information Disclosure during design ...... 20 B. Further Information Disclosure ...... 21 VIII. GRIEVANCE REDRESS MECHANISM ...... 22 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 24 A. Responsibilities for Environmental Management ...... 24 B. Environmental Monitoring ...... 25 1. Monitoring for Compliance with EMPs ...... 25 2. Testing for Noise and Dust Control ...... 25 C. Environmental Monitoring Reports ...... 25 D. Institutional Arrangement and Responsibilities ...... 26 X. CONCLUSION AND RECOMMENDATIONS ...... 26 XI. REFERENCES ...... 27 XII. ANNEXES ...... 28 Annex 1: Request Letter from Phou Poy Rice Mill for Relocation of PDS Facility ...... 28 Annex 2: Agreement of Phou Poy Rice Mill with PDOE, Battambang ...... 33 Annex 3: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation ..... 37

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Annex 4: Land Title of Phou Poy Rice Mill Issued by PDLMUPC ...... 38 Annex 5: Location of Proposed PDS Facility for Phou Poy Rice Mill ...... 40 Annex 6: Detail Design of PDS facility for Phou Poy Rice Mill ...... 42 Annex 7: Calculation of Capacity Including Raw Materials for PDS facility for Phou Poy Rice Mill ...... 45 Annex 8: Total Annual and Average Monthly Rainfall from 2011-2018 in Battambang ...... 46 Annex 9: Rapid Environmental Assessment (REA) Checklist...... 47 Annex 10: Environmental Management Plan Summary) ...... 53 Annex 11: Environmental Monitoring Plan ...... 61 Annex 12: Minutes of public consultation meeting...... 72

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LIST OF TABLES

Table 1: Annex of Prakas No. 021 PRK.BST dated 03 February 2020 ...... 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 ...... 14 Table 6a: Poverty levels (2010-2017) by district in Battambang ...... 15 Table 6b: Poverty levels (2004-2012) by communes/sangkats in Moung Ruessei ...... 15

LIST OF FIGURES Figure 1: Location of Project Provinces ...... 7 Figure 2: Location of Proposed PDS Facility for 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 ...... 12 Figure 5: Photo of consultations meeting with relevant stakeholder ...... 21 Figure 6: Grievance redress mechanism ...... 23

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EXECUTIVE SUMMARY

1. This report is a new initial environmental examination (IEE) for establishment of paddy drying, and storage (PDS) Facility for Phou Poy Rice Mill. The IEE for the proposed PDS Facility within Phou Poy Rice Mill, located at Chumnik Village, Anlong Vil Commune, Sangkae District, Battambang Province was approved by ADB on 24 January 2020. However, before the actual construction of the Facility can start at the proposed site, the Rice Miller received complaint from the villagers on possible dust nuisance from expansion of his existing rice mill business facilities. The Rice Miller requested the Program Management Office (PMO) to move the PDS Facility to another site owned by the Miller, located at Pou Pir Village, Kear Commune, Moung Ruessei District, Battambang Province and informed that the villagers and local authorities at the new location welcome the establishment of the PDS Facility and that the Miller would get more business and marketing opportunities at the new location. The PMO agreed to the Rice Miller’s request and initiated review of the design of the Facility and prepared safeguard documents (IEE & due diligence report for social safeguards) for the new location. The detailed design and construction supervision (DD & CS) firm has confirmed that there will not be any changes to the design of the Facility. The letter of the Rice Miller requesting relocation of proposed PDS Facility is attached as Annex 1.

2. The establishment of PDS facilities is 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 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 Prey Veng, 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.

3. 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 DD & CS consulting firm (IRE Co. Ltd) 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 Battambang province 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, 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.

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4. The feasibility study and subsequently the detailed design present a proposal for establishment of a PDS Facility on the private land owned by Mr. Phou Poy, owner of the Phou Poy Rice Mill. The proposed site is located at Pou Pir village, Kear commune, Moung Ruessei district, Battambang province. The Phou Poy Rice Mill owns about 4.28 hectares of a single piece of land at the location and the proposal proposes establishment of a PDS Facility on an area of 2,880m2 (around 0.29ha) of the private land of the Phou Poy Rice Mill. The proposed Facility will have a drying capacity of 300-800 tons per day (TPD) of wet paddy.

5. 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 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.

6. 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, 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 stage.

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I. INTRODUCTION

7. 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.

8. 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.

9. 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 4.28 hectares of a single piece of land at the proposed location, Pou Pir village, Kear commune, Moung Ruessei district, Battambang province (land title issued by Provincial Department of Land Management and Urban Planning-“PDLMUPC”, Battambang, on 21 September 2016). The proposed Facility will be established on an area of 2,880m2 (around 0.29ha) of this private land of the Phou Poy Rice Mill.

10. 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 (EIA) (1999) and the Prakas on EIA Classification for Development Projects (2020).

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. Government Environment Policy and Regulation

1. Law on Environmental Protection and Natural Resource Management

11. 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

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prevention, reduction and control of pollution; (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.

12. 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

13. 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.

14. The sub-decree includes an annex which provides information on development projects requiring EIA or IEIA. The annex was further updated through the Prakas No. 021 PRK.BST dated 03 February 2020 on EIA Classification for Development Projects. An excerpt for relevant projects is provide in Table 1 below.

Table 1: Annex of Prakas No. 021 PRK.BST (Dated 03 February 2020)

Environmental Impact Assessment Classification based on the scales of

Sl. Types of Projects development projects No. Contract on (as in EIA IEIA Environment Prakas) Protection

1. Mining, Energy and Industrial Sectors

68 All types of soft drink and juice (All factories types)

69 Fruit jam factories (≥ 500 tons/year) (< 500 tons/year)

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Rice and grain (processing) millers (≥ 3.000 70 or factories tons/year) Fish sauce, soy sauce, soy paste, (≥ 500.000 71 chili sauce, tomato sauce factories liters/year)

75 Cotton processing factories All sizes

79 Rice flour factories All sizes

2. Agricultural Sector

145 Dense forest business (≥ 500 ha) (< 500 ha)

146 Forest land (≥ 500 ha) (< 500 ha)

147 Agro-industrial farmland (≥ 500 ha) (< 500 ha)

Agro-industrial rehabilitation and 155 (< 500 ha) development (≥ 500 ha)

15. Since this PDS Facility comes under the “Rice and grain (processing) millers or factories”, as per Table 1 above, the Phou Poy Rice Mill has applied and received the Environmental Protection Contract Agreement from the 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 2). The proposed Facility will be constructed well within the private land 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

16. 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.

17. 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.

18. 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

19. 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 3).

3) Drinking Water Quality Standards

20. 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 21. 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 22. 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

23. 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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24. 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.

25. 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.

26. 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.

27. 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 9.

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D. Environmental, Health, and Safety Guidelines

28. 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. Additionally, the risks faced by workers and the public due to COVID 19 pandemic will be included in the health and safety management plan following recommendation from ADB Cambodia Resident Mission (letter dated 21 May 2020).

III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN

A. Subproject Provinces

29. 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 Thailand, 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

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

31. The proposed PDS Facility for Phou Poy Rice Mill shall be constructed on the private land owned by Mr. Phou Poy, owner of Phou Poy Rice Mill, situated along the National Road No. 5, Pou Pir Village, Kear Commune, Moung Ruessei District in Battambang province. The Rice Miller owns a single piece of 4.28 hectares of fully fenced land at the proposed site (land title issued by PDLMUPC, Battambang, on 21 September 2016 is attached as Annex 4). The Rice Miller has vast experience in rice milling industry as he started his business in 1990 and continuing it for the last 30 years. The proposed PDS Facility shall be constructed on a small plot of land well within the private land of the Rice Miller. The front boundary of the proposed site borders National Road No.5 and across the road there are private rice fields. The proposed site is surrounded by private rice fields from all the other sides. On the left side, adjacent to the rice fields there is one house which is about 800 meters away from the proposed site. (see Figure 2 below and Annex 5). The current milling capacity of the Rice Mill located at Chumnik village Anlong Vil commune Sangkae District, Battambang Province is 5-6 tons per hour (i.e. 43,000 tons paddy per year or 27,950 tons milled rice 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 Proposed PDS Facility for Phou Poy Rice Mill

Home

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32. The proposed PDS Facility will be built on a plot of about 2,880 m² inside the fully fenced private land owned by the Rice Miller. 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).3 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.

33. The detailed design of the PDS Facility for Phou Poy Rice Mill in brief can be found in Annex 6 while the complete sets of drawings along with full description of the detailed design can be found in the bidding and contract 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 7.

C. Subproject Context

34. 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

3 The Rice Miller will ensure that necessary construction permissions for PDS Facility are obtained from Provincial Department of Land Management, Urban Planning and Construction (PDLMUPC) prior to the start of the civil work. Such permissions will be attached as annexes to the semiannual environmental monitoring report to be submitted to ADB.

Page | 9 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy development of drying and storage facilities accessible to cooperatives are given priority by the RGC for the implementation of the rice policy.

35. The proposed site for PDS Facility for Phou Poy Rice Mill is located about 40 km from Battambang town and about 5 km from Moung Ruessei district office along national road No. 5 to Phnom Penh. The establishment of proposed PDS facilities 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, 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 Facility.

36. 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

37. 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)4, causing a layer of deposits in the order of 100 m deep, over the largely sandstone parent rock beneath.5 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

38. Cambodia has a moist tropical climate, classified as equatorial monsoonal6, consistent with its location 10-13 degrees latitude north of the equator. The climate features

4Rice-SDP Supplementary Appendix IV - Initial Environmental Examination, Svay Antor Paddy Drying and Storage Subproject. 5 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.

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

Page | 10 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy 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 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.

39. Flooding data has been recorded in every Sangkat (commune) of Battambang 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 Kear and Moung communes with water depth ranging from one to two meters.

40. 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 8 & 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

41. 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 8.1 & Figure 4 below).

Page | 11 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

3. Water Resources

42. 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.7 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.

43. 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 Moung Ruessei River is about 6km from the proposed site and the Rice Miller has 01 private pumping well (about 60m depth) and 01 private water pond (90m x 90mx 5m) on the site. The water pond harvests rain water and the Miller will use it for rice mill operation purposes.

B. Biological / Ecological Resources

44. 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

7 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.

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(iv) 20,000 ha of Prektorl flooded forest protection area situated in Aekphnom and Sangkae district 45. The proposed PDS Facility for Phou Poy Rice Mill is located far away from these protected areas. It’s about 6km from Moung Ruessei river, 20km-25km from Tonle Sap Lake and 40km from Sangkae River. 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).

46. 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 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).

47. 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

48. 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

49. 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.

50. 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).

Page | 13 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

51. 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 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.8 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 36), will strengthen the technical extension services directed at farmers and ACs on the use of pesticides.

52. 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

53. 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.

54. Based on the Battambang Development Plan, the poverty level in Moung Ruessei district of Battambang province has reduced from 28.52% in 2010 to 22.10% in 2017 (see Table 6a below). In the Kear Commune of Moung Ruessei District, where the proposed PDS Facility is located, the poverty rate has decreased from 34.00% in 2004 to 23.50% in 2012 (Ministry of Planning, 2012. See Table 6b below). 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, 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.

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

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Table 6a: Poverty rates by districts of Battambang province (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 Krong 3 Battambang 8.76 8.20 17.08 17.14 16.51 16.39 16.47 16.61 4 Bavel 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 Moung 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 Samlout 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 Kamrieng 27.57 25.19 24.06 24.16 22.01 22.00 21.10 20.60 13 Koas Krala 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

Table 6b: Poverty rates by communes-sangkats, Moung Ruessei (2004-2012)

District/Cummune 2004 2005 2006 2007 2008 2009 2010 2011 2012 206.Moung Ruessei 40.2 39.0 37.7 36.2 35.4 32.6 31.3 28.5 26.6 Kear 34.0 32.3 31.0 30.4 29.2 27.5 27.7 25.5 23.5 Prey Touch 40.0 36.2 35.6 32.2 31.3 29.7 25.3 27.4 23.9 Ta Loas 36.7 33.5 32.5 32.2 31.8 29.6 27.1 25.0 24.8 Chrey 40.9 40.0 39.1 37.4 37.0 35.6 30.0 26.2 25.0 Moung 35.8 35.7 33.5 32.7 32.5 30.5 28.6 28.2 25.1 Ruessei Krang 44.7 43.1 42.4 39.2 38.1 35.4 32.6 32.1 28.8 Prey Svay 39.8 39.8 38.7 36.8 36.1 34.6 31.0 30.4 28.9 Robas Mongkol 40.6 39.7 38.6 36.8 35.9 32.5 30.1 28.3 28.9 Kakaoh 43.0 42.7 41.8 40.9 39.5 37.6 35.0 34.3 31.9 Source: Ministry of Planning, 2012

3) Health

55. 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. Additionally, pandemics such as the COVID 19 put workers and the public in great risks and the advisory on health and safety has been issued by the Government.

56. 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 Moung Ruessei district where the proposed PDS Facility is located there is one district referral hospital and nine health centers including one in Kear commune.

Page | 15 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

4) Unexploded Ordinance

57. 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. Moung Ruessei district was also cleared by CMAC. If required, the safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in subproject area and such certification will be included in the semiannual environmental monitoring reports to be submitted to ADB.

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

A. Method of Assessment

58. Following the sub-decree No. 72 ANRK.BK on Environmental Impact Assessment and Prakas No. 021 PRK.BST on EIA classification for development projects. (see para 13 & 14 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

59. The proposed PDS Facility is located about 40 km from Battambang town and about 5 km from Moung Ruessei district office. 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 well within the private land owned Phou Poy Rice Mill which is already elevated from the ground level by 1.5m (about 0.5m higher than the big flood in 2013). 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.

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

61. 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.

62. Environmental Health and Safety (EHS) Manual including plan for COVID 19 pandemic 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

Page | 16 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy 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

63. 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.

64. 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.

65. 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

66. 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. Noise from hammering (for temporary period only) initially during construction period will be monitored and managed through use of new motor or good maintenance.

67. 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 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.

68. 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

Page | 17 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy 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.

69. Covid-19 health and safety plan: In view of the COVID 19 pandemic, Contractor shall come up with a COVID 19 health and safety risk management plan to ensure social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

D. Environmental Impacts Related to Operation

70. 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. The mill owner will provide sufficient PPEs to all workers including hard hat (helmet), booth, mask and glove.

71. 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.

72. 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.

73. 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 operators, 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.

74. 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. The rice miller has already refilled the land up to

Page | 18 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

1.5m (in March 2018) which is about 0.5m higher than the big flood in 2013 and considered to be good enough for construction of PDS Facility and the settling ponds.

75. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance.

76. 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.

77. 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.

E. Global, Trans-boundary and Cumulative Impacts

78. 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.

79. 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.

80. 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.

81. 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

82. 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

Page | 19 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy insufficient land to use for drying surfaces and are nonagricultural flat areas such as road 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.

83. 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

84. 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- May 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.

85. A public consultation meeting was conducted on 11 June 2020 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 PMO officials & consultants, and DD& CS consultant for PDS Facilities. A total of 36 participants including 09 women participated in the consultation meeting. (See Annex 12).

86. 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 proposed site 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 Kear 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, 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 (dated 11 June 2020)

B. Further Information Disclosure

87. 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

Page | 21 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy 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

88. 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.

89. 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.

90. 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 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.

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Figure 6: Grievance Redress Mechanism

Next Higher Court

Provincial court

Provincial Governor Office (PIO), PDAFF and/or YES Grievanc 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, Grievanc 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 Grievanc 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)

91. 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.

92. The 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.

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93. 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.

94. 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

95. 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.

96. The mitigation measures required for the design and preconstruction, construction and operation phases of the improved infrastructure are described in Annex 10, 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 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.

97. The EMP should form part of the bidding and 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.

98. During PDS facility operation, responsibility for mitigation rests primarily with the Rice Miller supported by relevant provincial departments.

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99. The budget for implementation of EMP is included in the cost estimates. For details, please refer to summary of environmental management plan as attached in Annex 10.

B. Environmental Monitoring

100. 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 11.

101. 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.

102. 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

103. 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

104. 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.

105. 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. Readings and analysis will be undertaken once per year during operation, at each plant.9

C. Environmental Monitoring Reports

106. 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. The semi-annual report will be prepared based on primary and secondary sources of information collected through monitoring and inspections (see the detail in Annex 11: Environmental Monitoring Plan) and the report will be disclosed on the ADB website.

9 The results of testing for noise and dust levels during operation will be reflected in the semiannual environmental monitoring reports to be submitted to ADB.

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D. Institutional Arrangement and Responsibilities

107. 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.

108. 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 w i l l rest primarily with the Rice Miller supported by relevant provincial departments (PDOE/PDOLVT).

X. CONCLUSION AND RECOMMENDATIONS

109. 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 2.

110. 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 10 and environmental monitoring plan as attached in Annex 11 will be implemented to mitigate negative impacts during or after subproject implementation.

111. During consultation meeting and field observation all relevant stakeholders confirmed 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. If required, the safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in subproject area and such certification will be included in the semiannual environmental monitoring reports to be submitted to ADB.

112. It is recommended that the EMP is included in the bidding and contract document for works contracts.

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113. 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, CEMP 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). ▪ Prakas No. 021 PRK.BST dated 03 February 2020 on EIA Classification for Development Projects. ▪ 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. D a t e d 2 7 April 1999. ▪ Law on Environmental Protection and Natural Resources Management. The Preah Reach Kram/NS-RKM-1296/36. Dated 24 December 1996. ▪ 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: Request Letter from Phou Poy Rice Mill for Relocation of PDS Facility

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Unofficial Translation

Kingdom of Cambodia

Nation Religion King

______

I, Ith Michael, representing the owner of Phou Poy Rice Mill, located in Chumnik Village, Anlong Vil Commune, Sangkae District, Battambang Province.

TO: H.E Ros Seilava, Secretary of State, Ministry of Economy and Finance, Program Director of Climate Resilient Rice Commercialization Sector Development (Rice-SDP)

Subject: Request for relocation of PDS Facility establishment from Chumnik Village, Anlong Vil Commune, Sangkae District to Pou Pir Village, Kear Commune, Moung Ruessei District, Battambang Province (about 30km from previous PDS location)

Attachment: (i) Hard Land Title No 02060205-0081 (ii) People’s Complaint Letter

As stated above, I would like to inform his excellency, the Secretary of State and Program Director of Rice-SDP that on May 25, 2020, I received notification from Chumnik village chief and Anlong Vil commune chief (as attached) that 7 families from the village registered their complaint opposing the construction of new PDS Facility (under the Rice-SDP) inside the Phou Poy Rice Mill business compound due to possible dust nuisances from expansion of rice mill operation that may affect their daily life. The village chief and the commune chief requested us to relocate the Facility. Therefore, to honor the request of the village chief and the commune chief and to avoid conflict with the people living in the area, I would like to request honorable Program Director in granting permission to Phou Poy Rice Mill to relocate the PDS Facility to the new place accordingly.

Date: 30 May 2020

Ith Micheal

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Annex 2: 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 38 years old, Cambodia Nationality, ID Card: 170565814 dated 26 January 2011; Expiry 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 located in Pou Pir Village, Kear Commune, Moung Ruessei District, Battambang Province, as below:

Provision 1. Ensure management of dust and debris (rice, maize ash, rice husk) from the production line by installing appropriate technology and equipment to filter dust and reduce the health effects on neighboring residents. Provision 2. Ensure management of temporary ash stockpile and regularly spray water or make surrounding wall to protect the area from becoming dusty. Provision 3. 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. Provision 4. Ensure the management of garbage (ash and sacks), 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. Provision 5. Ensure management of oil wastes and accessories from repairs, do not dispose off in public places or areas near the sources of water thereby causing leakage or damage to water sources. Provision 6. Ensure management of the wastes from guests, workers and kitchen wastes wby properly employing trash bins and set up storage tanks for other solid wastes within the rice mill compound. Provision 7. Ensure traffic management at the entrance and exit gates to avoid traffic jam and traffic accidents. Provision 8. Ensure management of temporary parking lots (proper parking of trucks and truck waiting area) to avoid disorder or harming to neighbors. Provision 9. 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. Provision 10. In case the department or the Ministry of Environment requires me to modify any environmental techniques to comply with the new guidelines and standards,

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I would completely agree to the guidelines. Provision 11. Volunteer to contribute 400,000 Riels per year as environmental fee to Battambang Provincial Department of Environment.

Provision 12. 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. Provision 13. 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: 30.06.2020 No. 291/Bor.Sthor.khor.Bor Seen and Verified Thumb Print Seen and Approved To Director of PDOE BTB Date: 30.06.2020 BTB Date: 30.06.2020 Director of PDOE Chief of Environmental Protection Office Ith Michael

Kort Boran Kong Vannak

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Annex 3: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation

No Parameter Unit Standard Value A. River 1 pH mg/l 6.5 – 8.5 2 BOD5 mg/l 1 3 Suspended Solid mg/l 25– – 100 4 Dissolved Oxygen mg/l 2.0 - 7.5 5 Coli-form MPN/100ml < B. Lakes and Reservoirs 1 pH mg/l 6.5 – 8.5 2 COD mg/l 1 3 Suspended Solid mg/l 1– 4 Dissolved Oxygen mg/l 2–.0 - 7.5 5 Coliform MPN/100ml < 6 Total Nitrogen mg/l 0.1 – 0.6 7 Total Phosphorus mg/l 0.005 – 0.05 C. Coastal water 1 pH mg/l 7.0 – 8.3 2 COD mg/l 2 3 Dissolved Oxygen mg/l 2– 4 Coliform MPN/100ml <– 5 Oil content mg/l 0 6 Total Nitrogen mg/l 0..2 – 1.0 7 Total Phosphorus mg/l 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 4: Land Title of Phou Poy Rice Mill Issued by PDLMUPC

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Annex 5: Location of Proposed PDS Facility for Phou Poy Rice Mill

1. View of Phou Poy Rice Mill location

2. Surrounding View of PDS location

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3. Site vicinity picture

4. Truck Parking area

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Annex 6. Detail Design of PDS Facility for Phou Poy Rice Mill

1. Paddy Drying Plant Building

2. Layout of Dryer

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3. Drying Plant Flow Chart

4. Paddy Storage Building

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5. Aeration warehouse storage system

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Annex 7: Calculation of Capacity Including Raw Materials for PDS Facility for Phou Poy Rice Mill

PHOU POY DEVELOPMENT BATTAMBANG RAW MATERIAL CALCULATION Wet Paddy ( avg. 30% M.C. ) :10,000 T Harvest duration in 1 season : 30 Days Drying Capacity : 333 TPD DRYING 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 :7,992 T

MILLING PLANT Milling capacity : 6 TPH / 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 8: 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 8.1: 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 9: 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 the existing ground level as the level has already been raised about 1.5m by the Rice Miller which is about 0.5m higher than the big flood in 2013. 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 well within the private land owned by the emissions? 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) well within a 4.28 ha of single parcel of fully fenced land owned by the Rice Miller. (land title issued by PDLMUPC, Battambang, on 21 September 2016 is attached as Annex 4 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 60-70 workers including about vulnerable groups? 50-60% women to work in the Facility. 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. The intensification of Facility will neither alter agricultural land use nor modify natural agricultural land use to 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 well within a 4.28 ha of single parcel of fully fenced private overloading of social land owned by the Rice Miller. infrastructure?

Page | 49 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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 well and congestion, and within a 4.28 ha of single parcel of fully fenced private land owned pedestrian hazards by the Rice Miller. However, safety precautions such as flagman aggravated by heavy to regulate traffic will be provided as specified in the EMP. trucks?

▪ 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. Additionally, for COVID-19 pandemic, social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, additional hand wash facilities (e.g. pop ups), provision of a welfare attendant for smooth operation, etc. will be ensured. In particular, facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes will be ensured. The Rice Miller will 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.

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Screening Questions Yes No Remarks ▪ 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. After the operation that cause completion of the PDS Facility, the Rice Miller will employ 60-70 increased burden on workers including about 50-60% women to work in the Facility. social infrastructure and The Rice Miller plans to construct 10 accommodation services (such as water facilities/bedrooms and 11 bathrooms including toilets (8 toilets to supply and sanitation be constructed outside and 3 inside the building), carry out systems)? monthly fumigation around the compound, provide sanitation orientation to the workers, provide assured pipe water from district water supply agency ensuring enough water supply to all people working in the rice mill, and provide 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. ▪ 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. First aids kit, use and/or disposal of additional hand washing facilities (e.g. pop ups) to the usual materials likely to create welfare, particularly facilities such as hand sanitizer -minimum physical, chemical and 60% alcohol based, adequate supplies of soap and fresh water biological hazards during and suitable and sufficient rubbish bin for hand towels with construction, operation proper and regular removal and disposal of waste will be and decommissioning? provided to the workers, project staff and stakeholders.

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 compound which is elevated from Design of conditions including extreme weather related the ground level. During the big flood in project events such as floods, droughts, storms, 2013, the level of water was about 1m landslides? above the ground level, but rice miller has already raised the land about 1.5m higher than the ground level which is considered good enough for construction of PDS facilities. The drainage system will be sufficient to prevent the formation of ponds and muddy patches within the facility compound. If necessary, adequate fill is also proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform 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

Page | 51 Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy 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 – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

Annex 10: 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 compound which is elevated from the Include in DDCS Firm (IRE) MEF/PMO ground level by 1.5m by the Rice Miller in 2018. The proposed land is 0.5 m above the big construction flood level in 2013. The proposed land has never been flooded and is considered good budget enough for construction of PDS facilities. However, if needed 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 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 and PIO 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 – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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. COVID-19 Pandemic - Contractor shall ensure that social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. are provided or followed. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hands in Khmer Version at campsite.

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Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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 safe campsite, (viii) provision of primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health including safety from COVID 19, (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 (ii) Obtain materials from licensed quarries, construction MEF/PMO soil and/or laterite for (iii) Enter in to appropriate agreements with landowners for borrow sites, and landscaping budge PDS Facilities works to use borrow sites, in accordance with the agreements made with landowners, construction. (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

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 a t 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

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Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

Risk of contamination of The Contractor will install onsite WC for their workers. To ensure sanitary conditions in Include in Contractor DDCS firm (IRE)/ nearby waterways and around the facility, an on-site system of treatment of sewerage from workers’ toilets construction MEF/PMO will be provided. The design of the Facility includes provision for drainage of a budget specification 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 s u c h a s dust masks shall be issued to workers when working in dusty conditions. Risks of unsanitaryThe Facility will be constructed inside the existing compound which is elevated from the Include in Contractor DDCS firm (IRE)/ working and grain ground level. The proposed location has never been flooded after the big flood in 2013. construction MEF/PMO storage conditions The level of water was about 1m above the ground level in 2013 flood and the Rice Miller budget during flood events raised the land by about 1.5m above the ground level which is considered good enough for construction of PDS facilities. However, if needed 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 above the height of 10-year flood levels. The Contractor will install onsite WC for their workers and stakeholders. To ensure sanitary conditions in and around the Facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. 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 construction MEF/PMO implementation areas 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.

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Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

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 Include in Contractor DDCS firm (IRE)/ getting soil for danger (i.e. prevent cattle and people – specifically children falling into the borrow pit during construction MEF/PMO subproject construction and after 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.

Use of land for (i) Contractor will provide compensation to landowners by early in a month. Include in Contractor DDCS firm (IRE)/ storage (ii) In cases where landowners temporarily provide their land to the contractor to construction MEF/PMO and campsite 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 Include in Contractor DDCS firm (IRE)/ access related to daily to 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.

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Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

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 and COVID -19 pandemic such as social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hand for Covid-19 health and safety plan (in Khmer Version) at campsite.

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 to ensure all reasonable safety measures, have been taken construction MEF/PMO during construction 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 – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

Maintenance of Contractor work plan have to include technical training/orientation to all stakeholders Include in Contractor DDCS firm equipment and (operators, workers, managers etc.) involved on work routine and periodic maintenance, construction (IRE)/ avoiding damage to the quality of equipment, and raw material to be used based on contract document budget MEF/PMO assets 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. To ensure sanitary conditions in and around the facility, an on-site system PMO/PIO effluents of treatment of waste water from workers’ toilets will be provided. The design of the Facility 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 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 PMO/PIO 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 s u c h a s 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, additional hand washing facilities Rice Miller Rice Miller PDOLVT/PDOE vulnerabilities related (e.g. pop ups) to the usual welfare, particularly facilities such as hand sanitizer -minimum /MEF/PMO/ PIO to occupational health 60% alcohol based, adequate supplies of soap and fresh water and suitable and sufficient and safety during rubbish bin for hand towels with proper and regular removal and disposal of waste, etc. operation and training courses to workers on safety standard; include safety railings to mitigate risks due to material handlings and provide training and instruction to workers; 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.

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

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Rice-SDP – Revised Initial Environmental Examination- PDS Facility_ Phou Poy

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

Garbage/Waste i. Provide specific basket or bucket for kitchen garbage disposal (suitable and Rice Miller Rice Miller PDOE/MEF/ generation by workers sufficient rubbish bin for hand towels with proper and regular removal and disposal PMO/PIO of waste) ii. Make arrangements for collection of solid waste 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 – Revised Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Annex 11: 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 compound which is Site of proposed Detailed design Quarterly - Resident Include in elevated from the ground level by 1.5m by the Rice Miller in 2018. PDS Facility for Phou and follow up Engineer construction The proposed land is 0.5 m above the big flood level in 2013. The Poy Rice Mill located construction record and Budget proposed land has never been flooded and is considered good in Pou Pir Village, supervision. report enough for construction of PDS facilities. However, if needed Kear Commune, adequate fill is proposed to raise the ground level to a height that Moung Ruessei poses little risk from flooding. The settling ponds shall be on a raised District, Battambang platform above the height of 10-year flood levels.

Lack of Establish and function a grievance redress mechanism (GRM), as Site of proposed Public Quarterly Environment PMO budget mechanism to described in the IEE (Section 8). PDS Facility for information follow up Specialist, address Phou Poy Rice Mill booklet. record and Resident environmental located in Pou Pir Make public the existence of the GRM through public awareness report Engineer and Complaints campaigns and display poster of GRM at the subproject site. Village, Kear Commune, Moung Site Manager Ensure that names and contact numbers of representatives Ruessei District, List of contact of the (Contractor site Manager, Village -Commune Chief, PIO and Battambang 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 and PIO on implementation and Training monitoring of 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 Site of proposed Land title and Quarterly – Site Manager Include in Effects on relevant as the land is privately owned. The Facility will be built well PDS Facility for observation follow up of the construction homes and within the privately owned land and there will be no need for any Phou Poy Rice Mill record and contractor and Budget Property. compensation. located in Pou Pir Village, Kear report Resident

Commune, Moung Engineer. Ruessei District,

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

EHS Measures to ensure occupational health and safety will include: Site of proposed List of skilled Monthly and Site Manager of Include in - Contractor shall be required by the PMO to ensure that their PDS Facility for labor and quarterly – the contractor construction workers and other staff engaged in the proposed constructions are Phou Poy Rice Mill worker, list of follow up and Resident Budget in a safe environment. located in Pou Pir equipment for report Engineer. - Contractor shall ensure that (i) all reasonable steps are taken to Village, Kear protect any person on the site from health and safety risks; (ii) the Commune, Moung contract construction site is a safe and healthy workplace; (iii) machineries Ruessei District, implementation, and equipment are safe; (iv) adequate training or instruction for Battambang water basin or

occupational health and safety is provided; (v) adequate bucket,

supervision of safe work systems is implemented; and (vi) means first aid kit 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.

COVID-19 Pandemic

- Contractor shall ensure that social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of mask, provision of a welfare attendant for smooth operation, etc. are provided or followed. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing Page | 62

Rice-SDP – Revised 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 Site of proposed Construction Daily and Site Manager Include in Construction Project Manager the CEMP to include any additional or varied PDS Facility for schedule and Monthly of the construction Environmental environmental management or mitigation measures such as (i) safety Phou Poy Rice Mill bill of quantity records contractor and Management of workers and local population at construction site and campsite; (ii) or within 5km of site Resident Budget Plan provision of adequate PPE and orientation on safety to workers, (iii) safe earth work. Engineer storage and use of hazardous materials such as fuels and lubricants, (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 safe campsite, (viii) provision of primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health including safety from COVID 19, (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, - Site of proposed Construction Daily and Site Manager of Bill of associated PDS Facility for schedule and Monthly the contractor and quantity in with the use of (ii) Obtain materials from licensed quarries, Phou Poy Rice Mill bill of records Resident the contract excavated soil (iii) Enter in to appropriate agreements with landowners for borrow or within 5km of site quantity Engineer award sites, and landscaping works to use borrow sites, in accordance and/or laterite earth work. with the agreements made with landowners, for PDS -List of construction Facilities (iv) Not be allowed to dispose the excavated soil into water body or other material construction. free land without local authority permit.

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Rice-SDP – Revised 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 Site of proposed Observation, Daily and Site Manager Bill of quantity from the site ( i ) Adequate supervision of the works, PDS Facility for Phou cross Monthly of the in the contract excavated due ( ii) Discretionary use of silt traps where warranted, Poy Rice Mill located 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. in Pou Pir Village, implementation Kear Commune, stakeholders construction Moung Ruessei schedule District, Battambang Water / Pollution i. Wastewater from the camp sites discharged by building latrine Site of proposed Observation, Monthly Site Manager of Bill of quantity from with good septic tank. PDS Facility for Phou cross records based the contractor, in the contract ii. Transporting waste residue to dispose at approved dump sites Poy Rice Mill located on the specific construction checking with Resident award by authority to avoid contamination of the people household, in Pou Pir Village, work wastewater Rice Miller and agricultural land and waterways Kear Commune, Engineer, Rice iii. Provide regular truck maintenance to improve the condition and Moung Ruessei stakeholders Miller and Village store the oil properly District, Battambang Chief

Risk of The Contractor will install onsite WC for their workers. To ensure Site of proposed Observation, Monthly Site Manager of Bill of quantity contamination sanitary conditions in and around the facility, an on-site system of PDS Facility for Phou cross checking records based the contractor, in the of nearby treatment of sewerage from workers’ toilets will be provided. The Poy Rice Mill located with Rice Miller on the specific Resident contract design of the Facility includes provision for drainage of a specification in Pou Pir Village, and work waterways Engineer, Rice award sufficient to handle storm-water flows, and safe draining of storm Kear Commune, stakeholders water if this occurs. Moung Ruessei Miller and Village District, Battambang Chief Health risks to When excavation takes place during dry conditions, excavated Site of proposed Observation, Monthly Site Manager of Bill of quantity worker from surfaces and stockpiled material shall be sprayed with water to prevent PDS Facility for Phou cross checking records based the contractor, in the dust pollution the release of dust. The proposed Facility will use Cyclonic type Poy Rice Mill located with Rice Miller on the specific Resident contract furnace which has no exhaust stack and hence no ash/smoke will be in Pou Pir Village, and work Engineer, Rice award released to the environment. Dust produced by the drying process will Kear Commune, stakeholders be collected by passing dust laden air from the dryer into a chamber Moung Ruessei Miller and Village where water is introduced by a series of sprayers. The water spray District, Battambang Chief 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 s u c h a s dust masks shall be issued to workers when working in dusty conditions.

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Rice-SDP – Revised 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 Site of proposed PDS Observation, Monthly Site Manager of Bill of unsanitary which is elevated from the ground level. The proposed location has Facility for Phou Poy cross checking records based the contractor, quantity working and never been flooded after the big flood in 2013. The level of water Rice Mill located in with Rice Miller on the specific Resident in the was about 1m above the ground level in 2013 flood and the Rice Pou Pir Village, Kear and work grain storage Engineer, Rice contract Miller raised the land by about 1.5m above the ground level which is Commune, Moung stakeholders award conditions considered good enough for construction of PDS facilities. However, Ruessei District, Miller and Village during flood if needed adequate fill is proposed to raise the ground level to a height Battambang Chief events that poses little risk from flooding. The settling ponds shall be on a raised platform 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.

Hazardous To prevent pollution of soil and water surface/groundwater: Site of proposed Observation, Monthly Site Manager of Bill of materials during (i) Storage facilities for fuels, oil, cement, and chemicals will be PDS Facility for Phou cross records based the contractor, quantity in subproject within secured areas on impermeable surfaces, provided with Poy Rice Mill or checking on the specific Resident the contract bunds and cleanup installations. surrounding location work implementation with Rice Engineer, Rice award (ii) The contractor will not use the spilled materials related to the of the subproject, in Miller and vehicle, machinery, and equipment that is going to affect to Pou Pir Village, Kear Miller and Village soil and water sources. Commune, Moung stakeholders Chief (iii) Fuel storage and refilling areas will be located at least 50m from Ruessei District, construction sites that will be protected by temporary drainage Battambang 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 Site of proposed PDS Observation, Monthly Site Manager of Bill of Air quality efficient running and fuel-burning. Facility for Phou Poy cross records based the contractor, quantity in (ii) High- horsepower equipment will be provided with tail gas Rice Mill or checking with on the specific Resident the contract purifiers. work surrounding location of Rice Miller and Engineer, Rice award (iii) All vehicle emissions will be in compliance of with relevant stakeholders Cambodian emission standards. the subproject, in Pou Miller and Village Pir Village, Kear Chief Commune, Moung Ruessei District, Battambang

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Rice-SDP – Revised 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 Site of proposed PDS Observation, Daily and Site Manager of Bill of quantity as material stockpiles, concrete mixing equipment will be equipped Facility for Phou Poy record, cross Monthly the contractor, in the with dust shrouds. Rice Mill or surrounding checking with records based Resident contract (ii) Water spraying, at least 2 times per day, for suppression soil dust location of the Rice Miller and on the specific Engineer, Rice award or any other particulates and maintenance of driving surfaces will be subproject, in Pou Pir stakeholders work Miller and Village standard site management practices. Village, Kear Chief (iii) Vehicles carrying soil, sand or other fine materials to and from the Commune, Moung construction sites will be covered. Ruessei District, Battambang Noise and Construction during night time within 280m of residences shall be strictly Site of proposed PDS Observation, Daily and Site Manager of Bill of Vibration/ prohibited. During daytime construction, contractor will ensure that: Facility for Phou Poy record, cross Monthly the contractor, quantity Noise impacts on (i) Sites for concrete- mixing plants and similar activities will be Rice Mill or surrounding checking with records based Resident in the sensitive located at least 1 km away from residences and schools; and location of the Rice Miller and on the specific Engineer, Rice contract receivers (ii) Temporary anti-noise barriers will be installed to shield any schools subproject, in Pou Pir stakeholders work Miller and Village award or residences within 100m of the construction site. Village, Kear Chief Commune, Moung Ruessei District, 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 a Site of proposed PDS Contract Monthly Site Manager of Bill of quantity storage month. Facility for Phou Poy agreement payment report the Contractor in the contract and campsite (ii) In cases where landowners temporarily provide their land to Rice Mill or between award the contractor to build camp site, it will be based on a contractor and contract agreement (details will be stated in contract surrounding location of agreement) the subproject, in Pou landowner (iii) After completing works, contractor will carry out restoration of Pir Village, Kear land to former condition or better, according to agreements Commune, Moung formed with landowners. Ruessei District, Battambang

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Rice-SDP – Revised 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 Site of proposed PDS Check to verify Monthly and Site Manager of Bill of quantity vehicle access the contractor has to carry out: (i) careful supervision of vehicle Facility for Phou Poy The Quarterly the contractor and in the contract related to daily movements to ensure minimal damage to farmland and vegetation, Rice Mill or contractor report Resident award operational etc. if any and (ii) minimal disturbances to human beings, children Engineer, Rice surrounding location of rule book management going to school and animal. Miller and Village the subproject, and license Chief located in Pou Pir of driving Village, Kear Commune, Moung Ruessei 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 and COVID -19 pandemic such as social distancing, maintenance of proper sanitary conditions through regular breaks to wash hands, regulating the use of toilet, provision of additional hand wash facilities (e.g. pop ups), provision of a welfare attendant for smooth operation, etc. In particular, Contractor will ensure that facilities such as hand sanitizer - minimum 60% alcohol based, adequate supplies of soap and fresh water, hand towels, suitable and sufficient rubbish bin for disposal of wastes, and facility for proper and regular removal of the wastes are carried out or provided. Contractor will post the MoH’s guidance on washing hand for Covid-19 health and safety plan (in Khmer Version) at campsite.

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

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

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 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. Occurrence of Contractor work plan during construction have to include raising Site of proposed Specific water Based on the Contractor, Include in water related awareness to the workers on hazards posed by poor sanitation PDS Facility for Phou company or diseases Commune construction diseases and use of untreated water for drinking and bathing. Poy Rice Mill or shop address occurred Chief, health Budget surrounding location and list of centers, village of the subproject, in patients. chief, Rice Miller, Pou Pir Village, Kear PIO and other Collection of Commune, Moung stakeholders Ruessei District, sample and Battambang laboratory . analysis. Operation phase

Maintenance of Contractor work plan have to include technical training/orientation to all Site of proposed PDS Operation and Quarterly Site Manager of Include in equipment and stakeholders (operators, workers, managers etc.) involved on work Facility for Phou Poy maintenance report the contractor, construction avoiding damage routine and periodic maintenance, quality of equipment, and raw Rice Mill located in Pou schedule Resident Budget to the assets material to be used based on contract document. Pir Village, Kear Engineer, Rice Commune, Moung Miller, and other Ruessei District, stakeholder Battambang Water pollution No waste water from this type of drying process is generated as Site of proposed PDS Operation and Quarterly Rice Miller, PDOE/ Rice Miller from discharge moisture from wet paddy will evaporate. To ensure sanitary Facility for Phou Poy maintenance report MEF/PMO/PIO of liquid effluents conditions in and around the facility, an on-site system of treatment Rice Mill or surrounding schedule of waste water from workers’ toilets will be provided. The design of location of the the Facility includes sewage treatment ponds to be constructed on a subproject, in Pou Pir raised platform. Water from the dust removal plant will be combined Village, Kear with condensate from the dryer and will be treated in settling ponds, Commune, Moung to enable organic matter to be extracted, and used by the Rice Miller Ruessei District,

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

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

Dust control The proposed Facility will use Cyclonic type furnace which has no Site of proposed PDS Operation and Quarterly Rice Miller, PDOE/ Rice Miller exhaust stack and hence no ash/smoke will be released to the Facility for Phou Poy maintenance report MEF/PMO/PIO environment. Dust produced by the drying process will be collected by Rice Mill or surrounding schedule passing dust laden air from the dryer into a chamber where water is location of the introduced by a series of sprayers. The water spray causes the dust to subproject, in Pou Pir collect and form a slurry which is non-toxic and can be provided to Village, Kear famers for re-use as a soil conditioner. Protective clothing s u c h a s Commune, Moung dust masks shall be issued to workers when working in dusty Ruessei District, conditions. Battambang

Noise and Noise proof materials for housing will be used to reduce noise from Site of proposed PDS Operation and Quarterly Rice Miller, PDOE/ Rice Miller Vibration/ ash room, dust room and machinery. Noise from blower and its Facility for Phou Poy maintenance report MEF/PMO/PIO Noise impacts drivers will be monitored and managed through good maintenance. Rice Mill or surrounding schedule on sensitive Noise within the facility will be reduced by the inclusion of noise location of the receivers baffles on machinery and ear protection is provided where necessary. subproject, in Pou Pir Village, Kear Commune, Moung Ruessei District, Battambang

Risks and Rice miller will continue to provide PPE, first aids kit, additional hand Site of proposed PDS Operation and Quarterly Rice Miller, Rice Miller vulnerabilities washing facilities (e.g. pop ups) to the usual welfare, particularly Facility for Phou Poy maintenance report PDOLVT/PDOE/ related to facilities such as hand sanitizer -minimum 60% alcohol based, Rice Mill located in Pou schedule MEF/PMO/PIO occupational adequate supplies of soap and fresh water and suitable and sufficient Pir Village, Kear health and safety rubbish bin for hand towels with proper and regular removal and Commune, Moung during operation disposal of waste, etc. and training courses to workers on safety Ruessei District, standard; include safety railings to mitigate risks due to material Battambang handlings and provide training and instruction to workers; 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.

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

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

Residue of husk Cyclonic furnace collects ash at the bottom and then conveys to the Site of proposed PDS Operation and Quarterly Rice Miller, PDOE/ Rice Miller (Ash)/Waste ash room. Facility for Phou Poy maintenance report MEF/PMO/PIO i. Ash will be collected at the ash room and use as fertilizer by Rice Mill located in schedule the Rice Miller himself or may sell to farmers to generate extra Pou Pir Village, Kear income Commune, Moung ii. Husk will be used as biomass fuel by the Rice Miller for their Ruessei District, furnace/burner. Battambang iii. Ash will not be allowed to dispose into water bodies

Garbage/Waste i. Provide specific basket or bucket for kitchen garbage disposal Site of proposed PDS Operation and Quarterly Rice Miller, PDOE/ Rice Miller generation by (suitable and sufficient rubbish bin for hand towels with proper Facility for Phou Poy maintenance report MEF/PMO/PIO workers and regular removal and disposal of waste) Rice Mill located in schedule ii. Make arrangements for collection of solid waste Pou Pir Village, Kear iii. Make arrangements for grey water treatment and discharge, Commune, Moung such as soakage pits Ruessei District, iv. Assign specific role and responsibility and clear schedule for Battambang maintenance and collection of all waste

Training program:

A training program is set out in table below to 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

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

Subject/Content Participants Trainer Frequency

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 – Revised Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill

Annex 12: Minutes of public consultation meeting

MINISTRY OF ECONOMY AND FINANCE

Program Management Office (PMO) Climate Resilient Rice Commercialization Sector Development Program (Rice-SDP)

Minutes of Public Consultation Meeting on Social Safeguard Impact Assessment for Establishment of Paddy Drying and Storage (PDS) Facility within Private Land of Phou Poy Rice Mill

Thursday (08:00-11:30AM), 11 June 2020 Pou Pir Village, Kear Commune, Moung Ruessei District, Battambang Province

Chair: H.E Chhim Sabonn, Provincial Program Director, PIO/Battambang

Participants: Villagers (people having rice farms around the Phou Poy Land), Village Chief, Commune Chief, PIO/BTB Program Director and Officers, BTB/PDAFF Officer, BTB/PDoE Officer, BTB/PDLMUPC Officer, MEF/PMO Officers and Consultants, IRE (DD&CS Consultant for establishment of PDS Facility) and Rice Miller.10 A total of 36 Participants including 09 females participated in the Public Consultation Meeting (see participants list as at the end of the Minutes). Agenda 1.0 Objective of the Public Consultation Meeting 2.0 Opening Remark by Provincial Program Director, PIO/BTB 3.0 Presentation of Detail Design of proposed Phou Poy PDS Facility 4.0 Open Discussion on Social Safeguard for the proposed Phou Poy PDS Facility 5.0 Closing of the Meeting

Presentations, discussions, decisions, assignments and conclusion

1.0 Objective of the Meeting The purpose was to disseminate information on the proposed establishment of Paddy Drying and Storage (PDS) Facility for the participants to understand, raise issues/challenges that might arise due to the Facility, and contribute to the discussions/solutions for mitigating any possible negative effects due to the Facility. The meeting had the following objectives:

• Inform the participants on the establishment of PDS Facility • Present the detail design of the PDS Facility for Phou Poy Rice Mill • Discuss on the social safeguards requirements for the PDS Facility and conflict resolution, if any.

2.0 Opening Remark by Provincial Program Director, PIO/BTB

H.E Chhim Sabonn, Provincial Program Director, PIO/BTB, welcomed the MEF/PMO team (officials and consultants) and thanked the villagers, Village Chief, Commune Chief, Provincial officials, and Mr. Phou Poy (Rice Mill owner) and his colleagues for participating in this important

10 BTB= Battambang Province, DD&CS= detailed design and construction supervision firm, MEF= Ministry of Economy and Finance, PDAFF= Provincial Department of Agriculture, Forestry and Fisheries, PDoE= Provincial Department of Environment, PDLMUPC= Provincial Department of Land Management, Urban Planning and Construction, PDS= Paddy Drying and Storage, PIO= Provincial Implementation Office, PMO= Program Management Office. Page | 72

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

meeting. He informed the participants about the Rice-SDP project and its objectives that is to boost rice production, improve quality of milled rice, increase export to the international market as well as to help solve problems of farmers due to lack of post-harvest facilities. He informed that Rice-SDP is going to provide loans to the private rice millers, who aim to invest in PDS Facilities and this meeting is related to that activity. He said that Battambang Province is able to dry paddy rice in between 4,000 to 5,000 tons per day but that also could not able to meet the demand of the province.

He informed the participants that Rice-SDP is going to provide loans to rice millers at different locations in Battambang, Kampong Thom and Prey Veng provinces to establish PDS Facilities. One of them is Phou Poy Rice Mill. Thus, this meeting is very important to study the impact of the social and environmental safeguards requirements to mitigate issues that might affect the people and avoid/resolve conflicts if any because development must go hand in hand with the welfare of the people. He then requested the Rice-SDP team to give presentation on the design of the Facility and asked participants to provide their comments and raise concerns on the effects of the Facility on their living and businesses if any. He requested all the participants to fully participate in the discussions to make the Facility a successful one.

3.0 Presentation of Detail Design of proposed Phou Poy PDS Facility Please see Annex III.

4.0 Open Discussion on Social Safeguard for proposed Phou Poy PDS Facility After the presentation on detail design, the Rice-SDP team presented the location/land proposed by Mr. Phou Poy for the construction of the PDS Facility. The team then raised the following points and/or queries for discussion with the participants:

4.1 Land Title: Does the land title submitted by Mr. Phou Poy as the proposed location of the PDS Facility belong to him? Does the proposed land have any conflict with neighbors? Is the accreditation issued by Authorities genuine?

In response to the queries, the participants replied as below:

(1)- Mr. Phou Poy, owner of Phou Poy Rice Mill, informed the meeting that he owns about 4.28 hectares of land at the proposed PDS site. He has bought the land from villagers and got the hard land title in 2016. The proposed PDS Facility will be established on 0.29 hectares of these land.

(2)- Mr. Yem Ry, Village Chief, said that the proposed land legitimately and rightfully belongs to Mr. Phou Poy, owner of Phou Poy Rice Mill. He had bought the land from the villagers at the market price and did not have any dispute with his neighbors and/or villagers regarding his land boundary.

(3)- Mr. Meas Seum, Kear Commune Chief, said that Kear Commune announced registration of lands and started handing over of hard land title to people since 2016. The activity was completed in 2019 and now all the commune people have hard land title. He added that from the start to the end, he did not get any complaint regarding any land conflict.

(See Annex II: Phou Poy Land Title).

4.2 Establishment of PDS Facility: To explore the benefits and/or concerns that the participants might have for establishing a PDS Facility in their locality that might affect their living and/or daily life, especially for the people who live nearby the Facility, the Rice-SDP team raised the following queries:

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

• Do you have any concern on working hours for construction works at the site especially at night time? • Do you have any concern on safety due to construction and/or do you need any protection or signs to avoid any possible accidents/danger?

In response to the queries, the participants replied as below: 1. Mr. Ma Sareun, a villager from Pou Pir Village, mentioned that working hours should not be a concern because nobody lives nearby the proposed site and if PDS Facility is established in the area, it will make people very happy.

2. Mr. Brounh Sareum, Pou Pir Village Chief said that Cambodian people are clever and know the working hours and they would charge extra for any overtime work and they would not work for free of charge. So, he is not concerned about working hours during the construction. As for safety sign and safe materials, he said that even though the construction will be well within the private land of the rice mill, protection for workers and visitors who visits the construction site should be taken care of.

3. Mr. Pan Yaov, a villager who has rice farm nearby Phou Poy Land, said that on behalf of villagers he would request Mr. Phou Poy to keep some space to be used by villagers who have rice farms behind Mr. Phou Poy Land for transporting their paddy rice products to the national road No 5.

4. Mr. Phou Poy, owner of Phou Poy Rice Mill, said that he will take necessary precautions related to the safety sign and ensure use of safe materials for workers and visitors during the construction period. He added that he did not want to take any chance with his Rice Mill Business. He further promised that he will keep some space at the left side of his land so that people can use it for transporting their paddy rice products to the national road No 5.

5. Mr. Heang Sophary, Administration Chief of Moung Ruessei District Office said that at the moment nobody is living nearby the proposed Facility but once the Facility is operational people may move and start to live nearby it. He advised Mr. Phou Poy to come up with a future plan and start discussing about it with relevant stakeholders.

Continuing the discussions, the Rice-SDP team proposed the participants to discuss the benefits of establishing a new PDS Facility in the locality and how to resolve conflicts if any in the future. To kick start the discussion, the team proposed following queries:

o Do you prefer to have a PDS Facility on the site proposed by Phou Poy Rice Mill? o Do you think PDS Facility will benefit farmers or villagers in general? o If you have any conflict with Phou Poy Rice Mill, whom do you report to for resolution? o Do you have any idea on solving any of the concerns?

Both authorities and people expressed their happiness and were enthusiastic about the upcoming PDS Facility inside the land owned by Phou Poy Rice Mill. They mentioned that the PDS Facility would benefit most of the villagers as they cultivate rice and the rice miller could buy more paddy from them, farmers would be able to save on transportation cost as they did not have to transport far, and also their sons/daughters could work as labor at the Facility to earn income. The participants added that they are not concerned about the perceived negative points on establishment of PDS Facility on the private land owned by Mr. Phou Poy, Owner of Phou Poy Rice Mill as they will get opportunities to expand their rice business. The participants said that if they have any concerns in the future, they would directly talk to Mr. Phou Poy or report to Village/Commune Chief or District Governor for solutions. Page | 74

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

Participating in the discussion Mr. Phou Poy said that he has upgraded his business from family Mr. Meas Seum, Kear Commune Chief scale to commercial scale and he is taking care of said “I support the Paddy Drying and peoples’ welfare and environment. He also Storage Facility on the private land confirmed that he would be happy to discuss with owned by Mr. Phou Poy, owner of Phou people and authority to solve any problem arising Poy Rice Mill because if the Phou Poy due to the PDS Facility. He informed the meeting Rice Mill has new PDS Facility in our that the Rice Mill currently employs 25 commune then he will increase buying poor/vulnerable villagers including 13 women and more quantity of paddy rice to operate they are from different areas of Battambang such his Facility and villagers will get more as Ek Phnom, Banann and Sangkae districts but a profit from their production. Also, it will big majority is from the same village where the Rice create employment opportunity for local Mill is located (Chumnik village, Anlong Vil labors and reduce migration of people commune, Sangkae district). He mentioned that more, on after completion of the proposed PDS facilities at to outside the village’. What’s behalf of Kear Commune, it is proud to Pou Pir Village, Kear Commune, Moung Ruessei have investors investing in the District, he will engage workers two times than the development of large-scale rice mills in current level i.e. around 60-70 villagers of which he our territory. expects women to be around 50-60% of the work ’’ force.

5.0 Closing of the Meeting

H.E Chhim Sabonn, Provincial Program Director, PIO/BTB, congratulated all the participants for sharing ideas related to Social and Environmental Safeguards for the establishment of PDS Facility on private land owned by Mr. Phou Poy, Owner of Phou Poy Rice Mill. He suggested that if participants have any issue with Phou Poy Rice Mill, they should report to the village or commune chief or directly talk with the owner or his management staffs for resolutions. He agreed with the commune chief and the owner of the rice mill that for safety during construction, there need to be safety signs and also barricade to allow only people who are related to work. At the end, he thanked all the participants, local authorities, Rice-SDP team, provincial team and Mr. Phou Poy for participating in this important meeting and for a fruitful outcome.

List of Participants

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

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