China - Gansu and Xinjiang Pastoral Development Project : environmental impact assessment (Vol. 7 of 7) : Gansu environmental management and monitoring plan

E614 Rev. V. 7 July 17, 2003 Gansu and Xinjiang Pastoral Development Project Environmental Management and Monitoring Plan Gansu Province July 17, 2003 HLtE COPY  Table of Contents Introduction. 1. Implementation Organizations and Responsibilities 1.1 Implementation Organizations 1.2 Role of PMOs and Environmental Monitors 1.3 Responsible Supervision Organizations 1.4 Environmental Management Plan 2. Gansu Environmental Monitoring Plan 2.1 Monitoring Items 2.2 Monitoring Implementer 2.3 Monitoring Report System 2.4 Pre-Implementation Monitoring (Baseline Data) 2.5 Monitoring during Implementation/Construction 2.6 Monitoring during Operation 2.7 Monitoring Budget 3. Environmental Training/Institutional Strengthening 3.1 Training Objectives 3.2 Combined Training Courses, Gansu and XAR 3.3 Specific Training Courses for Gansu 4 Gansu EMMP Budgets 5. Conclusions and Recommendations 5.1 Major Conclusions 5.1.1 Selection of Project Areas 5.1.2 Environmental Impact Analysis and Mitigation Measures 5.2 Recommendations 5.2.1 Follow-up Program 5.2.2 Public Participation 5.2.3 Further Suggestions and Environmental Requirements  List of Tables Table I Environment Monitoring Plan, GXPDP, China Table 2 Environmlental Management Plan, GXPDP, China Table 3 Construction Air Quality Monitoring Program Table 4 Noise Monitoring Program During Construction Table 5 Cost Estimation of Environment Monitoring of Gansu Table 6 Salary Cost of Environment Protection Staff of PMOs, Gansu Table 7 Cost for Environment Training in Gansu Table 8 Cost Estimate for Agrochemical Management Plan for Gansu Table 9 Total Cost Estimate for EMMP, Environmental and Agrochemical Management Planning Training for Gansu List of Figures Figure 1 Environmental Management Organization during Construction Stage Figure 2 Environmental Management Organization during Operation Stage Figure 3 Monitoring Report Chart  Introduction 1. This Environmental Management and Monitoring Plan (EMMP) forms an integral part of the Environmental Impact Analysis (EIA) of the World Bank-financed Gansu and Xinjiang Pastoral Development Project prepared by the Chinese Research Academy of Environmental Sciences, and is referenced to in the World Bank's project legal agreements. 2. The experiences on EIA around the world has shown that even if mitigation and monitoring plans proposed in the EIA are clearly described, the mitigation and monitoring plans may be ignored without effective and competent monitoring and enforcement procedures to supervise and ensure the implementation. Therefore, the EMMP is developed as a monitorable and enforceable plan, prior to commencement of the project activities as part of the overall project management operation. The EMMP identifies the responsibilities of each organization involved in the implementation of EMMP and the proposed mitigation and monitoring activities during design, construction/implementation, and operation. For projects where International Finance Agencies (IFAs) participate in project funding, the Loan Agreement guarantees that the monies needed for establishing and operating the EMMP would be made available as an integral part of the project budget (not as a kind of "add on"). 3. The project's influence on environment will occur during not only the construction/implementation phase, but also during the operation periods. In Chapter 7 of the EIA, all the perceived issues affecting the environment were identified and analyzed. Corresponding mitigation measures were proposed. In this document the environmental monitoring plan, the implementing agency and the corresponding legally responsible agencies/institutions are identified. This orderly identification, assessment, and presentation of mitigation measures ensures that no important issues are overlooked and that negative impacts are prevented or reduced to minimum. 4. The project is complex, covers a vast area, and involves many environmental issues. However, the impact of the project to local environment can be effectively controlled if the following major environmental issues are monitored and controlled. 1. Implementation Organizations and Responsibilities 5. In China, project environmental management within each concerned ministry and commission is organized and carried out by their respective environmental protection department under the supervision of SEPA and local EPBs. 6. The Ministry of Agriculture (MOA), one of the concerned ministries, is one of the organizations that have responsibilities for protection and management of environment within the areas of influence of the project. The institution that has direct responsibility is the Ecological Environment Division of the Department of Science, Technology and Education of the Ministry of Agriculture. Its main responsibilities are: (1) to ensure that the project adhere with the relevant environmental protection laws, regulations and standard of China, and (2) to supervise environment protection in the agricultural sector of the country. SEPA provides supervision and monitoring to the work of MOA. Other organizations such as the Livestock Bureaus and Animal Husbandry Bureaus in Gansu and XAR have similar departments and personnel for environmental protection who are also responsible for supervision and monitoring of the project impact under the overall supervision of the relevant EPBs.  7. Both Gansu and XAR have provincial environment monitoring stations (EMS) responsible for monitoring the environmental impact of various development activities within their respective jurisdictional boundaries, and for compiling the annual environmental quality reports. The responsibility of these organizations include: (1) reporting to SEPA any changes in the quality of natural environment, (2) environmental pollution control; (3) progress achieved in environmental protection; and (4) handling application for discharge of important pollution source. Environment monitoring stations (EMS) at city and county levels are responsible for monitoring changes of environmental quality of atmosphere, water, noise and natural environment and for reporting to the provincial environmental monitoring station. 8. However, the EPB and the EMS staffs are not responsible for daily inspection and monitoring of the environmental performance of the project. Therefore, the respective PPMO should provide necessary organization and manpower to ensure effective and smooth implementation of the environmental requirements of the project. The following chapter discusses the details of implementing institutions and the proposed EMMP, its manpower and institutional requirements. 1.1 Implementation Organizations 9. During project implementation/construction and operation phases of the project, implementation of the EMMP is the responsibly of the respective PMOs. Gansu and XAR EPBs should be requested to: * Collect the required data as is outlined in this document; and * Monitor the implementation of the EMMP and check whether the mitigation measures of each subcomponent of the project are successfully undertaken. 10. The respective county EPBs should be requested by the respective PMOs to supervise and inspect subcomponents of the project that could have potential environmental impact following the proposed EMMP procedure outlined in this section and the relevant environment protection laws of China. 11. The project areas will include 19 counties, two farms and one corporation (Hovill) in Gansu and 24 counties and three farms in XAR. In order to ensure smooth implementation of the project with minimum negative impact on environment, the following EMMP is formulated and must be followed by the project proponents in its entirety. The EMMP must be considered as a part and parcel of the project and must be budgeted as a project item in the financial feasibility report and the project implementation plan. 12. In order to ensure successful implementation of the proposed EMMP and in line with relevant national environmental regulations, each PMO should appoint an officer, on a part-time basis, who will have full responsibility for the successful implementation of the activities defined in mitigation and monitoring sections of the EIA report (Chapter 7) and the EMMP described in this document during each phase of the project implementation and at least the first five years of project implementation. The county PMOs (CPMOs) should also designate one of their staff to be trained by the project to take the responsibility of ensuring the adoption of all EMMP activities by the project at the county/farm level. He/she should convey the environmental issues within the project to 2  the project implementation agencies of the PPMO and the county EPBs, responsible for data collection and providing technical assistance to the environmental officer. The environmental officers identified at PMOs at every level (province/region, prefecture, county) are responsible for the preparation of the environment protection materials and documents related to project implementation for review by SEPA, the World Bank supervision mission staffs and respective EPBs at various levels During operation phase, each CPMO will assist the PPMO with implementing the environmental monitoring program and other work included in the EMMP. However, the ultimate responsibility for ensuring that all activities identified in the EMMP are implemented rest on shoulders of the respective provincial PMOs and they must ensure smooth flow of required environmental reports/data from the counties to the provincial/regional offices. The environmental management and organizations during implementation and operation phases are diagrammed in Figure. I and Figure. 2, respectively. PLG |- PPMO | Environmental Officer (PPMO) Design Unit County PMOs designated Local governmental institutions environmental Supervisors including EMS, EPBs, Forestry Bureaus, GMS, etc. Fig. 1 Environmental Management Organization during Construction Stage PLG PPMO PPMOs, CPMOs (1 person, each) Local governmental institutions including EMS, GMS, Provincial and County EPBs, etc. Fig. 2 Environmental Management Organization during Operation Stage 3  1.2 Role of PMO and Environmental Monitors 13. As was discussed in 1.1, implementation of EMMP will be the responsibility of PMOs at various levels. They are responsible for ensuring the smooth implementation of the mitigation measures and the monitoring plan as is detailed in the environmental assessment report. Their major tasks include: a. Review and implementation of mitigation and monitoring activities with comments on the activities as needed to obtain minimum acceptable environmental performance level in the overall project; b. Regularly check implementation of pollution control measures in project sub- components that might have pollution problems such as beef and dairy cattle development sub-component and large feedlots. Report those facilities that are not operating properly or are discharging above SEPA's environmental standard discharge regulation and report such violations to local EPBs; c. Recommending, gaining approval for and carrying out any special studies, which are either recommended by the implementing agencies or are believed necessary for reaching the minimum acceptable environmental performance; d. In close cooperation with the project design and implementation teams, make sure that the relevant mitigation measures contained in the EMMP are reflected in the final project plans and that necessary conditions for project monitoring are in place; e. Provision of necessary training of staff of PMOs and implementers of project subcomponent on environmental issues and environmental inspection to improve the institutional capacity of county and township personnel in implementation of EMMP activities; f. Supervise the implementation of the environmental protection measures as specified in the environmental mitigation plan; g. Provide written guidelines whenever gaps in environmental performance are found, seek assistance from appropriate specialists and to take corrective measures; h. Perform emergency response plans during environmental emergency conditions and report any environmental accident/mishaps to the PPMO and local EPBs in a timely manner; i. Make sure that appropriate environmental reviews and project specific ElAs are prepared and approval is obtained for any newly proposed financially and economically feasible enterprise/marketing activities. Approval from the appropriate line agencies (county, prefecture, or provincial EPB and/or SEPA) as national environmental regulations dictates should be sought and permits should be obtained. Results of the environmental studies should be presented to the WB with English translation of environmental permits for approval before release of funds for such new activities. j. Implement the EMMP including engaging and supervising monitoring institutions and ensure that all sampling activities as defined in the monitoring plan are completed on a timely manner; 4  k. Prepare periodic reports on environmental performance of the project's activities related to implementation and operation to be availed to relevant environmental administrative departments/Bureaus and the World Bank Supervision mission members; 1. Deal with the complaints concerning the environmental aspects and accept the supervision of the environmental protection departments; m Arrange for the visits of the Bank Mission staff, if necessary and regulatory staff of EPB or EMS; n. Supervise environmental issues during project implementation/construction and urge construction/implementation teams to follow relevant regulations; and o. Be responsible for other actions needed for implementing the EMMP. 1.3 Responsible Supervision Organizations 14. The XAR EPBs, and Gansu EPBs under the guidance of SEPA are the administrative departments for environmental protection. They are responsible for the environmental management and supervision within the jurisdiction of the respective autonomous region and province. The local EPBs at prefecture and county levels are the administrative departments of the corresponding local governments' environmental protection under respective regional and provincial governments and are responsible for the environmental management and supervision within the jurisdiction of the local government. They will be responsible for environmental monitoring and supervision of project sub-components within their respective local government jurisdiction. EPBs and EMS offices at county, prefecture, and provincial levels should cooperate closely with clearly defined responsibilities to accomplish monitoring work of the project. Under the jurisdiction of each Provincial/regional EPB, a Provincial/regional Central EMS should be established that is responsible for the monitoring of environmental quality within the jurisdiction of the province/region. The Prefecture/county level EMS established under prefecture and/or county EPBs are responsible for the environmental monitoring within the jurisdiction of prefectures. The environmental protection work of this project will be carried out under the supervision of SEPA, provincial/regional EPBs and local EPBs within the project areas. The environmental supervision plan is summarized in Table 1. 1.4 Environmental Management Plan 15. In order to ensure the effective implementation of the proposed environmental mitigation measures for the project, an environment management plan has been formulated and listed in Table 2. 5  Table 1 Environment Monitoring Plan, GXPDP, China Stage Organization Monitoring items Monitoring Objectives Feasibility Study SEPA, WB 1. Review EIA 1. Guarantee a complete environmental assessment, and appropriate subject identification, emphasize the key points. 2. Review EMMP draft 2. Make sure it reflects the possible, significant potential problems which might be produced by this project 3.Guarantee a concrete and practical action plan of mitigation measures Design & Gansu EPB, 1. Review the preliminary 1. Strictly execute EMMP Implementation XAR EPB, design for environmental SEPA, WB protection and EMMP 2. Ensure that all national environmental laws and regulations with regards to .project construction/implementation are considered. SEPA, WB 2. Check whether 3. Secure that sufficient environmental protection investment is in place investment for environment protection is in place. Gansu EPB, 3. Check selection of project 4. Check whether there are sufficient water resources in the project areas for the XAR EPB areas. development of artificial pastures, dairy farms, feedlots, breeding farms. 5. Ensure that the project areas are far away from the nature reserves buffer and core areas, and make sure that the project will not block the migration route of wild animals. 4. Supervise dust and noise 6. Take recommended measures in EMMP to dust and noise pollution. pollution, if found to be an issue. 7. Ensure that construction teams follow EMMP, and relevant state and local laws and regulations. 8. If noise is found as an environmental nuisance, enforce proposed construction times according to EMMP. 6  Stage Organization Monitoring items Monitoring Objectives 5. Inspect whether there are 9. Protect cultural relics underground cultural relics. 6. Inspect the discharge and 10. Ensure that solid waste and raw sewage are disposed according to relevant treatment of daily sewage national and local regulations. Ensure that surface and groundwater are not and waste from larger contaminated. construction site such as dairy farms 7. Check whether 11. Ensure erosion control measures according to EMMP, national and local laws construction will cause are in place. accelerated soil erosion. Operation Gansu EPB, .Inspect the implementation 1. Protect the environment; minimize the environmental impact during operation XAR EPB, of EMMP in operation stage phase. Local EPBs, GMS 2.Check the implementation 2. If necessary, review and amend the EMMP to overcome unforeseen impacts. of monitoring plan 3. Guarantee the sewage disposal meet the standard. 3. Verify whether it is necessary to take further 4. Ensure that project impacts on natural resources are minimized, especially on environmental protection natural grasslands and water resources. measures for unforeseen environmental problem. 5. Make sure national laws and regulations with regards to animal numbers are enforced. 4. Ensure that grassland management/improvement measures are implemented. 5. Ensure that number of animals is not increased above carrying capacity. 7  Stage Organization Monitoring items Monitoring Objectives Gansu EPB, 1. Check whether the 6. Enforce the national regulations with regards to discharge of pollutants, XAR EPB, discharge of pollutants especially sewage discharge of dairy farms and runoff from large feedlots. Local EPBs meets the national standards. 7. Ensure that project will not cause any additional degradation of natural grassland. Report any wrong doing to appropriate regulatory agencies. 2. Check if project is causing unforeseen pressure 8. Ensure that project will not cause negative impact on water resources and their on natural grassland, and the availability for downstream users. Report any wrong doings to the appropriate water balance in the region. regulatory agencies. 3. Check whether the 9. Prevent any potential project impact on nature reserves, rare flora and fauna by project has any impact on enforcing the EMMP. nature reserves, rare flora or fauna. 10. Supervise and check agricultural chemicals used in rodent control, grasshopper/locust control, and eradication of poisonous grasses in natural 4. Check if project is grassland, ensure that no Category I pesticide is used and other pesticides will not causing accelerated soil cause pollution of surface and groundwater resources. erosion. 5. Review the use of agricultural chemicals in project areas. 8  Table 2 Environmental Management Plan for GXPDP, China Issues | Mitigation Policies and Control Measures Implementer Responsible A. Design Phase 1. Optimize project design and plan to minimize its potential negative environmental impacts. 2. Project subcomponents should be planned and designed to avoid environmental sensitive areas like core and buffer zones of nature reserves and wildlife habitats, to avoid natural and cultural relics, and to reasonably arrange construction schedule to minimize land occupancy and reduce land occupancy time. 3. Review and ensure that there is a balance between livestock number and feed in the project areas. Make certain through monitoring that project's grassland management plans Gansu PPMO, ensure that this project will not put additional pressure on natural grassland, and worsen XAR PPMO, degradation of natural grassland. EMS, Water Gansu PPMO, I.The Project Resources XAR PPMO 4. Review water balance studies in the project areas where irrigation water are used for Bureaus, Design artificial pasture development through coordinate with water resource management teams agencies. 5. Ensure that there will not be any significant impact on water resources of the region, the minimum flow requirements, and the water requirements of downstream users. Promote the adaptation of more efficient irrigation systems in the project areas. 6. Formulate appropriate feeding models, strengthen management on grazing. In semi- pastoral areas, the number of livestock should be determined by grass availability. Ensure that the number of animals do not increase above the available feed in natural grasslands (grassland carrying capacity). 9  Issues Mitigation Policies and Control Measures Implementer Agency 7. Strengthen GMS to enforce monitoring and regulating the number of animals within natural grasslands due to implementation of this project. 8. Ensure that the migration routes of wild animals and their feed sources will not be blocked by fencing, especially in the summer pastures, and ensure adequate feed supply for wild animals. 9. Respective PPMOs should provide the project plans for such project subcomponents that are close to nature reserves and/or habitats of wild animals for approval of relevant departments. 10. Prepare a separate EA report for development of the dairy subcomponent of the project in Gansu. 1. If construction of limited access roads is required, they should be designed to minimize land occupancy and avoid/minimize damage to vegetation. 2. Land Use 2. Construction of wool packing, feed plant and laboratories should use as little land as Design Units Gansu PPMO, possible. XAR PPMO 3. Artificial grassland development should not claim any new, natural grassland or forest area. 1. Review all agrochemicals that are proposed for use in the project areas and prevent use of any pesticide in WHO Category la that might be proposed for use. 3. Agricultural ~~~~~~~~~~EMO, County Gansu PPMO, ChmAgricultural 2. Promote the use of low residue agrochemicals (pesticides, insecticides, herbicides, Agricultural XAR PPMO Chemicals rodenticides, and solutions used for disinfections). Extension Station 3. Alternative control measures should be selected to replace highly poisonous pesticides. 10  Environmental Mitigation Policies and Control Measures Implementer Responsible Issues Agency 4. Number 1. Project county GMS monitors variation of the numbers of sheep grazing on natural Variation of Sheep pasture and selection of migration route within the project areas. Provincial and Gansu PPMO, Stock in the county GMS XAR PPMO Project Areas 5. Water Resource 1. Organize relevant agencies to undertake water balance studies in the project areas. Water Resources Gansu PPMO, Utilization Bureaus or XAR PPMO ___________________________________________________________________Stations_________ B. Implementation / construction phase 1. Construction machineries should be kept far away from nature reserves and wildlife habitats. If construction activities are located in proximity of buffer areas, effort should be made to reduce noise as low as possible 2. It is not allowed by national laws to convert forest or natural grasslands to any other use Construction 1. Nature reserves including artificial grasslands. Artificial grassland development should be implemented in truction Gansu PPMO, and wildlife present agricultural land or previously converted agricultural land with irrigation facilities. Bureaus, EMS, XAR PPMO, habitats EBuras EM,County PMOs 3. Proper disposal of wastes resulted from construction activities. Waste disposal sites should be located far from nature reserves and wildlife habitats. 4. Construction workers should be directed not to enter core and buffer areas of nature reserves. Hunting and damage to wild plants should be strictly prohibited. 1. After the canal construction is finished, on such canals that the canals is designed in fill material, vegetation planting should be arranged to cover the exposed side slope. To get the Gansu PPMO, 2. Soil Erosion best effect, the side slope plantation should be completed one month in advance to the Construction XAR PPMO, rainy season. Teams, EMO County PMOs 2. Avoid digging irrigation ditches on mountain slopes greater than 250 or on sloping land II  Environmental Responsible Issues MiiainPlce n oto esrsIpeetr Agency during rainy season. Sand bags, hay bales or straw matt should be used on the down slope side of any cut areas to reduce soil erosion and increase in sediment load of the water bodies. 3. After completion of construction work or development of artificial pastures, vegetative cover should be planted as soon as possible to prevent wind and water erosion, as well as runoff. 4. The construction of large-scale dairy farm in Gansu should employ restrict soil erosion control measures during construction to prevent soil erosion and increased sediment load in nearby river/water bodies. As much as possible, the excavated material should be used in construction and any surplus should be disposed off properly according to national and provincial environmental pollution laws. 5. The waste earth and stone chips produced during construction activities at dairy farms, feedlots, irrigation infrastructure rehabilitation and other construction activities, if cannot be used in construction, should be piled in designated areas and be removed to dump sites. If no assigned dumpsites are available they can be compacted layer-by-layer and protected by surrounding retaining walls, and then be covered with vegetation on a timely manner. I. If there are residential areas within 300m of the construction site, construction activities are forbidden at 22:00 to 6:00 at night, 12:00 to 14:00 in daytime. In XAR, the schedule should be postponed by two hours to reflect the local environmental conditions. 3. Noise 2. The access roads should be selected away from such sensitive locations as schools, Teams, EMO County PMO residences and hospitals. If access roads are within 50 meters of sensitive areas, transportation should be banned _________________ during night hours. 12  Environmental Mitigation Policies and Control Measures Implementer Responsible Issues Agency 3. When the construction site is close to school, no construction work with heavy noise machines should be arranged at school time; when the construction site is close to densely populated residences, construction work with machinery that produce high noise levels should not be arranged at nighttime. In case that the above construction work has to be proceeded, consultation must be made with the residents who may be impacted or proper compensation must be paid. To reduce the noise pollution of construction machineries, mobile noise isolation can be used. 4. The construction operator's work time should be arranged in accordance with the labor hygiene standard, and personal protection measures such as wearing earplugs and helmets, etc. should be provided to the operators. i. Mixing equipment should be placed at least 300 meters from residential areas, hospitals and schools. Sealing, vibration reducing and dust absorbing measures should be adopted. 2. According to national labor laws, labor protection measures should be provided to the operators of the construction machineries, such as protective glasses and masks. Construction 4. Air quality Team, County County PMO 3. Water should be sprayed during dry, dusty days on the construction sites and related PMO roads to prevent dust. 4. Large-scale dairy farms in Gansu should be located at least 1,000 meters away from environmentally sensitive areas such as residential areas. 1. Inform contractors and construction workers on recognition of cultural relics and importance of protecting them. County Cultural 5. Natural and Relics Bureau Gansu PPMO, cultural relics 2. During construction, if cultural relics are found, construction should stop, the County PMO XAR PPMO construction supervisor should protect the site, and concerned department should be immediately notified to handle the find. 13  Environmental Mitigation Policies and Control Measures I mplementerResponsible Issues ____________________________________________________________________________________ .1. ___________Agency 6. Minority 1. Respect the living style and traditional customs of minority nationalities. Construction Gansu PPMO, Nationalities ________________________________ Tearn, EMO XAR PPMO C. Operation phase 1. Ensure that the project formulated grassland management plans are followed and the numbers of sheep are kept below the grassland carrying capacity to ensure sustainable use of grasslands. 2. Enhance the capability of county grassland stations that are responsible for supervision County, 1. Grassland and enforcement of grassland laws. Provincial and Gansu PPMO, Resources 3. In line with the principle of balancing grass and livestock, artificial grassland and other regional GMS, XAR PPMO feed sources should be developed to reduce pressure on natural grasslands. EMO 4. Ensure that project financed fencing activities will not produce any impediment for non- domesticated animals that also require utilizing the same natural resources. The fencing activities should not block 1. For those project areas where water resource is scarce, study on water balance should be conducted; water use quote for the project should be coordinated with water resources management department. 2. Advanced water saving irrigation technologies such as sprinkler irrigation should be County PMOs, Gansu PPMO 2. Water resources considered, especially in areas where perennial alfalfa is to be planted to reduce impact on Water Resources and EPB,XAR water resources and availability of water resources in the lower reaches and surrounding Bureaus PPMO, and EPB areas. 3. Alternative plants to alfalfa with lower irrigation water requirement should also be considered in areas with potential irrigation water shortage such as sorghum, oat and vetch. 14  Environmental Mitigation Policies and Control Measures Implementer Responsible Issues Agency 4. Rainfed artificial grassland development should mainly use abandoned agricultural land and sloping land (as long as rainfall distribution is adequate for rainfed cropping) to reduce the pressure on irrigated grassland.- 1. Project financed fencing, as much as possible, should be restricted to winter pastures. Prior to finalization of any project financed fencing plan, respective environment protection agencies that are responsible for wildlife and nature reserves (forestry bureaus, EPBs) should be consulted and their approval should be obtained. 2. If there are wild herbivore animals in the project areas, either no project financed fencing should be allowed in areas that are shared by both domestic and wild animals, or an area of adequate size, determined by responsible lined agencies should be allocated as County PMO, Gansu PPMO nature reserves exclusion zone for the use of wild animals. EMO, Forestry and EPB, XAR Bureau, EMS PPMO, and EPB 3. Local wild grass species should be selected for supplementary sowing in natural grassland; the grassland stations of the project areas must supervise the selection of seeds and supplementary sowing methods. 4. No chemical fertilizer should be used on natural grassland unless recommended by the AHB or research centers. If fertilizer application is recommended, use of organic manure should be preferred. 1. Supervise and enforce grassland carrying capacity to prevent overgrazing. EMO, Local 4. Soil Erosion 2. Only flat agricultural land (less than 2% slopes) should be selected for development of PMOs, Agric. Gansu PPMO, irrigated artificial grassland, to prevent aggravated soil erosion and non-point source Extension Officer pollution, caused by irrigation of sloping land. 5. Use of 1. PMOs and agricultural extension stations should formulate appropriate pest management Local PMOs, Gansu PPMO, agrochemicals plans to improve efficiency of agro-chemical application and to minimize negative, long- Local EPBs, XAR PPMO term impacts of pesticides on natural environment. Agricultural 15  Environme ntal Mitigation Policies and Control Measures Implementer Agency extension Stations 2. Select pesticides and herbicides with short-term residual effect and low toxicity 3. Improve watershed management and agricultural practices based on research conducted by the national and local institutions and include them in the extension programs, especially in grassland management and artificial pasture development. 4. Promote timely and well-balanced application of farmyard manure and chemical fertilizers. 5. Prior to pesticide application for large-scale rodent control, it must be approved by the province/county EPB, and relevant regulations should be strictly followed. In no circumstances, any category la and preferably Category lb pesticides, as defined by WHO, should be used within the project areas. 1. Artificial grassland development should not claim any new land. Only previously converted agricultural land with available and allocated water resources should be used for Gansu PPMO, 6. Land use change development of artificial pastures. According to the national laws and decrees, no natural County PMO XAR PPMO grasslands or forestland can be converted for any other use including development of artificial grasslands. .- 1. The manure and other waste, developed by dairy and beef cattle farm operations (Gansu), and large feedlots (Gansu, XAR) should be disposed off properly. Animal waste 7. Solid and liquid should be collected and composted before application to agricultural fields as farmyard 7. Sohd anmanure. sewage of large manure. Gansu PPMO, dairy farms, cattle County PMO XAR PPMO farms and feedlots 2. Solid and liquid waste should be treated, and detailed manure management plans must be formulated based on recommendation provided in Chapter 7, to ensure that surface and groundwater will not be polluted. 16  Environmental I Mitigation Policies and Control Measures Implementer Responsible Issues _____________________________________________________________Agency 3. Sewage of the dairy farm in Gansu must be treated and satisfy the national standards for discharge before their release or use for irrigation. _ D. Environment Monitoring 1. Monitoring the ecological environment of grassland: status of grassland degradation, status and rate of desertification, ecological environment quality change and trend analysis. Gansu/XAR 1. Natural 2. Disaster monitoring and disaster relief forecast for grassland-based livestock industry. GMS, agricultural Gansu PPMO, grassland Monitoring trends in pest and diseases within natural and artificial grasslands. extension, and XAR PPMO EMS. 3. Monitoring annual fluctuation of grassland productivity. Pre-implementation phase (baseline data collection): a. Monitoring items: pH, total P, total N, N03-N, NH3-N, COD, BOD5, fecal and total coliforms, and suspended solids b. Monitoring frequency: once Gansu PPMO, 2. Surface Water Local EMS XAR PPMO c. Monitoring periods: 1-2 days. d. Location to be monitored: medium and large-scale dairy farms, large-scale feedlots and any other areas deemed necessary upstream and downstream of potential non-point pollution sources by the environmental protection agencies. 17  Environmental Mitigation Policies and Control Measures Implementer Responsible Issues Agency Implementation/operation phase: a. Monitoring items: pH, total P, total N, N03-N, NH3-N, COD, BOD5, fecal and total coliforms, and suspended solids. b. Monitoring frequency: Once every year during the implementation period of each sub- project, followed by once every year for 5 years during operation). c. Monitoring periods: 1-2 days. d. Location to be monitored: medium and large-scale dairy farms, large-scale feedlots and any other areas deemed necessary by the environmental protection agencies upstream and downstream of potential non-point pollution sources, and based on observable pollution indicators (eutrophication, foul smell, etc.). 18  Environmental Mitigation Policies and Control Measures Implementer Responsible Issues ______ ___ Agency Pre-implementation phase (baseline data collection): a. Monitoring items: pH, total P, total N, N03-N, NH4-N, COD, BOD5, fecal and total coliforms. b. Monitoring frequency: once c. Monitoring periods: I day d. Location to be monitored: Wells with 100 m diameter of medium and large-scale dairy farms, large-scale feedlots and areas deemed necessary by the environmental protection agencies. Implementation/operation phase: 3. Groundwater Implementation/operation phase: Local EMS Gansu PPMO, a. Monitoring items: pH, total P, total N, N03-N, NH4-N, COD, BOD5, fecal and total coliforms. b. Monitoring frequency: Once every year during the implementation period of each sub- project, followed by once every year for 5 years during operation. c. Monitoring periods: I day d. Location to be monitored: Wells with 100 m diameter of medium and large-scale dairy farms, large-scale feedlots and areas deemed necessary by the environmental protection agencies. 19  2. Gansu Environmental Monitoring Plan 16. The main purpose of this section is to summarize the needs of monitoring and to prepare a sound environmental monitoring program. The main objectives of the plan are: * To ensure that all the mitigation measures specified in the ETA will actually be carried out; * To evaluate the monitoring data to determine whether the environmental protection measures as proposed (including design, implementation, and operational procedures) are actually furnishing adequate environmental protections and if not, to indicate the correction measures that is needed, and * To ensure sustainable use of natural resources (such as water, grassland and soil) by the project. 17. The proposed monitoring plan follows not only follows the Bank requirement, but is also responsive to SEPA's monitoring requirements as are outlined in Technical Guidelines for Environmental Impact Assessment, General Principles, HJ/T 2.1-93, and Technical Guidelines for Environmental Impact Assessment, Surface Water Environment, HJ/T 2.3-93. 2.1 Monitoring Items 18. The monitoring program includes monitoring for each of the individual environmental issues as identified in Chapter 7 of the EIA. 2.2 Monitoring Implementer 19. The implementers of the monitoring plan are Gansu PPMO and respective county PMOs. According to the jurisdictional zoning, respective PMOs at various levels will undertake their monitoring responsibilities. The Prefecture, City or county EMS will carry out monitoring the quality of surface and groundwater, while Gansu Provincial GMS will undertake monitoring overall grassland ecology conditions and related issues. Gansu PPMO should reach a contractual agreement with respective monitoring stations before project implementation. The county PMO environmental officers are responsible for requesting for monitoring activities by the respective monitoring stations, according to the requirement of EMMP and whenever emergency situation arises. 2.3 Monitoring Report System 20. The reporting system for environment monitoring is shown in Figure 1. After completion of each environmental monitoring task, the prefecture or county EMS should submit the monitoring report to the PPMO and to the higher administrative department of environmental protection. During implementation/construction, and the first five years of operation phases, Gansu provincial PMO should prepare environmental quality report for the first year every six months, and annually from Year 2 and submitted for review by the Bank supervision mission staffs. All submitted reports should also be available to Gansu EPB and to SEPA, upon their request. 2.4 Pre-implementation Monitoring (Baseline data) 21. The pre-implementation/construction monitoring program is designed to achieve two main objectives. The first one is to check whether the mitigation measures contained in  the environment assessment report have been incorporated in the final design document and in the construction contracts. The second is to assess the existing conditions, including seasonal variability of the various parameters. The proposed monitoring plan for each component is as outlined in Figure 3. The monitoring items and related issues can be found in table 2. SEA MOA ||World Bank| E Prefecture/County EMS Fig. 3 Monitoring Report Chart, Gansu 2.5 Monitoring during implementation/construction 22. The monitoring of implementation programs is designed to evaluate the construction activities and to ensure that they meet the established criteria. The construction of project should be monitored by the EMS, especially activities related to the construction and/or rehabilitation of irrigation infrastructure to develop the artificial pastures, construction of medium and large-scale dairy and beef fattening farms, milking stations, milk collection facilities, markets, and presently proposed and future enterprises such as slaughterhouses, wool processing, skin tannery, and to a lesser extent development of large feedlots or breeding farm facilities and warm sheds. The cost of environmental monitoring will increase if new enterprises or other market related sub-component with potential environmental impact that are not yet proposed are included in the future as sub- component of the marketing component. Such potential livestock related enterprises include, but are not limited to slaughterhouses, wool processing plants, and skin tannery plants. 23. The construction of the project could bring about some potentially adverse impacts on environmental parameters including air quality, vegetation, soil erosion, acoustic environment, public health, biological resources, etc. Air Quality: Dust control methods implemented to reduce construction generated dust levels will be spot checked throughout the construction period to evaluate their effectiveness and provide the basis for additional measures (as required). Table 8-3 presents air quality monitoring program for the project areas, if found necessary. Table 3 Construction Air Quality Monitoring Program 21  Monitoring Site Item Frequency Sampling Timing Implementer Construction sites TSP Twice a Once in the Ihe PPMO is responsible for the where large year, I to 2 morning and once implementation of this program, residential area days in the afternoon. and will entrust the corresponding within 100m. municipal EMS to undertake the monitoring tasks, as needed. Noise: The construction noise-monitoring program is designed (see Table 8-4) to monitor the impact of construction noise on the near residents. For noise-producing construction activities far away (more than 200 m) from residential areas, this monitoring is unnecessary. Table 4 Noise Monitoring Program During Construction Site Monitored Frequency Monitoring Monitoring Implementer period timing Environmentally-sensitive sites At random, 1d Once/day, CPMO/ EMS within 200 m of construction site if required ay Once/ night Soil Erosion and Surface Water Sediment Loading: Soil erosion could occur at construction sites, along areas of cut and fill such as irrigation canals and during construction of medium and large-scale dairy farm activities around water conveyance means (weirs, rivers, waterways, etc.). Such erosion could cause increase in river sediment load that could negatively impact aquatic flora and fauna. Respective CPMOs will be responsible to identify areas that could cause such impacts and should direct the contractor to provide adequate soil conservation measures along the slope such as hay- bale, silt fence and/or fiber mats to prevent increase in the sediment load of rivers and lakes within the project area. 2.6 Monitoring during Operation 24. The environmental impacts during project operation phase will be mainly the potential pollution to surface and groundwater by sewage discharge from medium-scale dairy farms and related facilities (milking centers, DHI, milking collection station, etc), large- scale feedlots (beef and sheep), and the impacts to natural grassland as a result of improper use of resources such as overgrazing. The main parameters that should be monitored include: * Surface and groundwater quality especially where dairy farms, large or concentrated beef fattening farm operations, and/or large-scale feedlots are established; * Groundwater draw down where groundwater or consumptive use of surface and groundwater is used for irrigation of artificial pastures; and * Number of grazing animals, and grassland degradation status. 25. More detailed and relevant information on environment monitoring parameters, implementing agencies and responsible institutions are presented in Table 2. 2.7 Monitoring Budget 22  26. An estimated budget for the implementation of the monitoring programs for Gansu is listed in Table 5. The cost of baseline surveys during pre-implementation monitoring is estimated at 60,00OYuans (RMB), 90,000 RMB during implementation phase and 240,000Y during operation phase. The total cost of environmental monitoring is estimated as 390,000 RMB. This budget does not include the cost of reviewing the project implementation plan document during pre-implementation phase or any additional monitoring requirement that might be needed if new enterprises are included in the project. The additional cost of EMMP for such projects should be estimated and upon approval of such projects, should be included as a part of the project implementation cost. Table 5 Cost Estimation of Environmental Monitoring of Gansu Monitoring Phase Monitoring Contents Cost, Yuan Pre- Surface Water quality (only on major rivers within project 40,000 implementation influence) (once) Groundwater Quality within areas with signs of groundwater 18,000 shortage Quality of natural grassland and variation of grazing capacity 20,000' Sub-total 78,000 Implementation Surface Water quality (only on major rivers within project 80,000 period (once every influence) year for 2 years) Groundwater quality (only within project areas with signs of 28,000 water deficiency) Air and Acoustic Environment (if needed) 10,000 Sub-total 118,000 Operation (once Quality of surface water 200,000 every year for 5 Quality of groundwater 70,000 years after Quality of natural grassland and variation of grazing capacity 40,000 completion of Sub-total 310,000 implementation phase of each sub- project) Total 506,000 The cost of each activity during implementation and/or operation might change, depending on whether new enterprises are included in the future phases of the project that might require additional air and water resources monitoring. Should be collected from GMS. 3. Environmental Training/Institutional Strengthening Plan 3.1 Training Objectives 27. The objectives of the environmental training program is to enable provincial and county PMO officials responsible for implementation of EMMP to further strengthen their capabilities and to enable them to ensure successful implementation of the mitigation and monitoring plans specified in the EIA report during final project design, implementation and operation of the project. The trainees could also include environmental officers from Hovill Dairy Company in Gansu and breeding farms in both Gansu and XAR, but the respective groups should adsorb the transportation, food and lodging costs. 28. In order to ensure the success of the intensive training courses and the implementation of EMMP, it is required that the employees who will be assigned as the environmental officers to have university degrees from accredited universities in one of the relevant 23  natural resource areas (grassland management, water resources, agronomy, etc.) and should have a minimum of four and two years of experience to be assigned as environmental officers for the PPMO and county PMO, respectively. 3.2 Combined Training Courses, Gansu and XAR 29. The following courses will be included in the environmental training pogrom in both Gansu and XAR: * Understanding and applying of laws, regulations, standards and norms of the Chinese government concerning environmental protection; and * Environmental management criteria utilized by the World Bank; 30. Environmental technology and environmental monitoring techniques including: * Status of surface waters, principles of hydrogeology, and groundwater distribution; * Basic knowledge of environmental monitoring; * Basic understanding of identifying degree of grassland degradation and different types of grasslands; * Pollution control technologies; * Basics of water sampling and sample treatment for analysis of different elements identified in EMMP; and * Preparation of reports on environmental monitoring. 31. The officers of provincial EPBs will provide training on these subjects in Lanzhou and/or Urumqi, being assisted by the scientist of the respective Grassland Management Institutes, Animal Husbandry Bureaus and the Lanzhou and Xinjiang Agricultural Universities. In order to reduce the training cost, XAR and Gansu PMOs have the option and could decide to arrange for combined training courses for the senior environmental staffs of respective PMOs, State and breeding farms and Hovill Dairy Company, using the capabilities of both XAR and Gansu universities and scientific institutions. If the second option (combined option) is selected, the training program will be somewhat modified and will take the "training of the trainers" format. 32. In addition, it is proposed to include a training course for extension and GMS officers who will be involved in dissemination of information to the local farmers and herders on principles of pest management and proper use of agrochemicals including information on: * Best management practices in agrochemical use and application; * Proper methods for use and application of agrochemicals, and use of protective gears; * Proper storage of agrochemicals and review of their toxicity levels; 24  * Use of alternative methods to highly toxic agrochemicals for pest, weed and rodent control in artificial and improved pasture areas; * Principles of integrated pest management and introduction to idea of appropriate pest management planning; and * Health issues with respect to use and handling of agrochemicals. 33. This course should be provided by appropriate university (Gansu Agricultural University and Xinjiang Agricultural University), and should have a mixture of classroom and in the field format. 3.3 Specific Training Courses for XAR and Gansu 34. The main training requirements of XAR are almost the same as Gansu. The major differences in training activities include additional training requirement for XAR due to presence of more diverse ecoregions in XAR and more emphasis on semi-pastoral livestock development model. Gansu would require specific training on environmental issues related to dairy and beef cattle operations, and proposed enterprises. 35. In all the proposed training courses, trainers should prepare a comprehensive training material as a part of their responsibilities and the material should be distributed between the training participants so that they could use the information in their future presentation to the project beneficiaries and other officers within their respective institutions (training of the trainer alternative). 4. Gansu EMMP Budgets 36. Table 5 presents cost estimates for implementation of EMMP in Gansu at Y 506,000. Table 6 presents estimated budget for salaries of part time environmental protection staff of PMOs at various levels in Gansu, which is 931,500 RMB (Y). Tables 7 and 8 present provide the estimated budgets of Y 95,300 and Y 69,800 for training programs in environmental management and agrochemical management plan training in Gansu, respectively. Table 9 presents the overall environmental management cost estimate for Gansu amounting to Y 1, 680,030. If the incremental salary costs of the PMO employees are not included in the total cost, the actual additional EMMP cost is Y 655,380. Table 6 Salary Cost of Environment Protection Staff of PMOs, Gansu Preparation Implementation Operation Personnel (6 years) (5 years) Total Total Cost Total Total Cost Total Total Cost m/m Yuan m/m Yuan m/m Yuan PPMO 3 7,500 24 60,000 15 37,500 County PMOs 396* 594,000 220* 330,000 Sub total 7,500 594,000 330,000 Grand total 931,500 Notes: 1. This an opportunity cost. The employee is fully employed by the respective PMOs for other technical activities and will be assigned to EMMP for 25% of his/her time per year during implementation and 17% (2 months per year) for monitoring periods. 2. Estimated cost of PPMO officer is 2,500 Rmb per month and county PMO officer is 1,500 Rmb per month. 25  Table 7. Cost for Environment Training in Gansu Training Plan No. of Training Contents Time Daily Total Personnel cost cost 1. Classroom training Days Yuan Yuan 1.1 Trainers 4 As per Environmental 6 600 14,400 1.2 PMO Personnel 1 9 Training Program 6 300 34,200 1.3 Facilities & management 10,000 Subtotal 56,800 2. Field/practical training 2.1 Trainer 2 5 600 6,000 2.2 PMO Personnel 19 Field Trips 5 300 28,500 2.3 Transportation 5 800 4,000 Subtotal 38,500 Total . 95,300 Table 8 Cost Estimate for Agrochemical Management Plan for Gansu Training Plan No. of Training Contents Time Daily Total IPersonnel cost cost 1. Classroom training Days Yuan Yuan 1.1 Trainer (University Professor) 1 As per Environmental 4 1,000 3,000 1.2 Extension and GMS Personnel 38 Training Program 4 300 45,600 1.3 Facilities & management . 8,000 Subtotal _ 56,600 2. Field/practical training . 2.1 Trainer (University Professor) I 1 . 1,000 1,000 2.2 Extension and GMS Personnel 38 Field Trps 1 300 11,400 2.3 Transportation . 1 800 800 Subtotal 13,200 Total 69,800 Table 9 Total Cost Estimate for EMMP, and Environmental and Agrochemical Management Plannin Training in Gansu Item Reference Preparation Implementation Operation Subtotal* Yuan Incremental staff cost Table 8-9 7,500* 594,000* 330,000* 931,500* Training Table 8-10 89,800 165,100 .__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ and 8-11 . EMMP Table 8-5 78,000 118,000 310;000 506,000 Sub-Total 175,300 712,000 640,000 1,527,300 Contingency, 10% 17,530 71,200 64,000 152,730 Total 192,830 783,200 704,000 1,680,030 * The figures presented-are the assumed salaries of full-time employees (opportunity cost) of respcctive PMOs for the period that they should work on environmental issues, and not an additional cost to the respective PMO. The actual cost of EMMP, with 10% contingency is Y655,380. 26  5 Conclusions and Recommendations 5.1 Major Conclusions 37. The environmental and social analysis of the GXPDP indicated that while the project would have no major direct negative impact on the natural environment, its overall social and environmental impact would be positive. The project, if successfully implemented, should improve natural grassland conditions within the project counties, should increase food supply for livestock, and should increase farmers income and livestock production, not by increasing the number of animals, but through breed improvement and improved marketing systems. Hence, the economic and social well being of the farmers of the project areas should improve in the forms of available, reliable, and fair market system for sale of higher quality livestock produce such as mutton sheep and fine-wool. The proposed project, in general, will have a positive impact on the socio-economic conditions of the farming communities by improving their livelihood through increased purchasing power. 5.1.1 Selection of Project Areas 38. Project areas in Gansu include 19 counties (cities) in ten prefectures, one corporation and two farms managed by Gansu Provincial Agriculture and Animal Husbandry Bureau. The development of fine wool sheep will dominate Sunan and Huangcheng. Development of mutton sheep will be the main project activity in other project counties. Dingxi, Jiuquan, and Lintao Counties and Hovill Dairy Company will also focus on dairy cattle and milk production. 5.1.2 Environmental Impact Analysis and Mitigation Measures 39. The potential environmental impacts of the project during implementation/construction phase of the project in both Gansu and XAR are temporal and limited in magnitude. There are, however, a number of unavoidable aspects of project implementation, which, if not well handled, may have potential adverse impacts on both natural environment and social environment in some localities. The magnitude of such impacts will depend on the success of and the manner in which proposed project specific environmental mitigation plans and programs are implemented. The temporary negative impacts of theses impacts are believed to be minor and include potential vegetation damage during rehabilitation of irrigation infrastructure for the development of artificial pastures and due to temporary land occupation at the construction sites, minor soil erosion and corresponding increase in sediment load during construction, and minor potential noise, air, and water pollution. However, if the mitigation measures proposed in the Report are successfully implemented, the degree of environmental impacts during this phase of the project will be insignificant. 40. During operational phase, potential environmental issues that are identified in the report include: (l) potential impact on water resources (surface and groundwater), (2) potential soil pollution through application of agrochemicals for control of poisonous grass, rodents, and grasshoppers, (3) potential cumulative impact of large dairy farms and large feedlots on both soil and water resources (eutrophication, increase in COD, coliforms, etc.), and (4) potential impact on plant biodiversity of natural grasslands in project areas, if chemical fertilizer application to natural grasslands practice is adopted by the project proponents. 41. Regarding each possible adverse impact, corresponding mitigation measure is proposed for the purpose of preventing or reducing it to insignificant levels. The use of 27  better watershed management and best management practices based on the latest findings of research and extension component of the project should guide herders, livestock farmers, and large dairy farms and feedlot managers in use of rational and environmentally balanced methods to reduce point and non-point source pollution within the project areas. Since the project schemes are scattered and involve a large area of Gansu and XAR, effective implementation of the proposed mitigation measures would be a challenge to the project proponent. In order to cope with the complex environmental issues, an EMMP including institutional strengthening, environmental training and environmental monitoring plan is developed. The EMMP should be strictly implemented to ensure that the proposed project would have neither significant nor irreversible adverse impact on the natural environment of the project area. 5.2 Recommendations 42. In order to prevent potential. negative impacts of the proposed project and to improve the likelihood of having a successful project, it is suggested to adopt a dynamic approach to the environmental monitoring and management by further incorporating measures to include additional measures to reassess the EMMP if unforeseen environmental impacts are identified during project development and operation phases. 5.2.1 Follow-up Program 43. A follow-up program is recommended to analyze the overall impacts of the project implementation and operation. Such program will be served to verify that predictions of impact put forward in the planning stages are as expected, and if not, adequate and timely corrective measures would be developed and implemented. Hence, corrective measures can be undertaken before irrevocable impacts have occurred. Information gathered from these programs is also used as input to refine future design. 44. The proposed program should incorporate the monitoring plan as presented in Chapter 9 of the EIA. 45. A number of interim reports should be prepared by the PPMO environmental officers of both Gansu and XAR, as outlined below, to ensure that findings of the EMMP are incorporated in the project design of future sub-projects and a dynamic approach to EMMP is followed by the project; (1) An interim report at the end of the pre-construction program, to provide input to the implementation phase; (2) Interims semi-annual reports (first two years) on the completion of implementation and construction activities; (3) Annual interim reports during the monitoring of project operation; and (4) A final report, summarizing impacts and successes of mitigation measures. 46. If significant unforeseen negative impact is discerned at any stage, the schedule will allow for a re-evaluation of the situation and provide sufficient time to implement further measures. Reports should be submitted to senior PPMO management, the World Bank supervision mission staffs, and various regional lined agencies, if requested, for review and comments. 5.2.2 Public Participation 47. The community and public involvement process was initiated during the environmental and socio-economic surveys when herders, livestock farmers and village communities were contacted to obtain baseline information. It is imperative that these 28  processes should continue so that the project participants feel that they are involved in the project and that their views and concerns are being adequately considered in the project planning process. In order for the beneficiaries to participate in the project design more actively, it was suggested to develop detailed BPP for the projects and have been prepared by the PPMOs in Gansu and XAR. These plans detail participating activities in each stage of project implementation and participants including herders, livestock farmers, breeding stations, large county operated farms, government organizations, NGOs and particularly the disadvantaged groups including women and minority nationalities in the project area. Since no specific sites and dates of participating activities are specified in these plans, it is suggested that the PPMOs develop a concrete schedule based on the prepared plan to guarantee a smooth implementation of the plan during project implementation. 48. In general, the majority of livestock farmers and herders support the implementation of the project. In addition, all the cadres at grassroots units, staff of the provincial and city project offices, staff of the livestock bureaus at provincial, city and county levels and officers of the Ministry of Agriculture who were interviewed strongly support the implementation of the project. 5.2.3 Further Suggestions and Environmental Requirements 49. Project beneficiaries should strictly follow the grassland management plans and county grassland management stations should effectively supervise the implementation of the grassland management plans to control/prevent overgrazing. Grazing of natural grasslands should follow grassland laws and animal numbers should be controlled based on nutritional carrying capacity of available grasslands to protect the condition of natural grasslands and promote sustainable development of livestock industry. 50. Prior to selection of project location, detailed water balance studies must be carried out, to ensure that the incremental water use will not damage water balance of the project areas, and project development and consumptive water use will not cause any significant negative impact to downstream water users and minimum flow requirements is observed. 51. Prior to finalization of the dairy sub-component in Gansu, individual environmental assessment of medium size 100-cattle dairy farms should be completed to determine whether the location of the dairy farms are environmentally acceptable, and whether proposed corresponding pollution control measures are adequate for the size of the proposed operations. In the individual feasibility and design reports of these projects, the sizing and type of sewerage (mainly milk residues and washing water) treatment facilities and details and sizing of manure management facilities (settling ponds, manure storage areas, etc.) must be presented before final environmental approval of such plans could be granted. The same process should be followed for any newly added enterprises in both CThnmii n,nd XAR 29