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Panel of Experts’ Monitoring Report
Project Number: 26194 Project Number: 36352-013 May 2016
Viet Nam: Song Bung 4 Hydropower Project (Financed by the Ordinary Capital Resources)
Prepared by Greg Weary
For the Asian Development Bank
This consultant’s report does not necessarily reflect the views of ADB or the Government
concerned, and ADB and the Government cannot be held liable for its contents.
SONG BUNG 4 HYDRO POWER PROJECT
ADB PANEL OF EXPERTS (Environment) REPORT
2016 05 2016
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TABLE OF CONTENTS
LIST OF ABBREVIATIONS .……………………………………………………………………. 3 EXECUTIVE SUMMARY .…………………………………………………………….…............ 4 1.0 - INTRODUCTION ....……..…………………………………………....…….………….….. 14 1.1 - THE SONG BUNG 4 HYDROPOWER PROJECT….....…………….……………….. 14 1.2 - ADB PANEL OF EXPERTS (environment) .………………………………………….. 15 2.0 - MANDATE and TERMS OF REFERENCE of the POE (environment)................. 15 3.0 - MISSION OVERVIEW...………………………………………………………................ 16 4.0 - MISSION TASKS, FINDINGS and RECOMMENDATIONS ………………………… 17 4.1 - TASK 1: Environmental Document Review ………………………………… 18 4.2 - TASK 2: Site Visit …………………………………………………………….…. 20 4.3 - TASK 3: Review SB4 Reforestation Plans and Implementation……..…. 20 4.4 - TASK 4: Determine if EMP is implemented properly during Ops………. 22 4.5 - TASK 5: Recommend Corrective Actions ………………………………….. 28 4.6 - TASK 6: Assess Adequacy of Baseline Surveys ……………………….... 28 4.7 - TASK 7: Examine Monitoring Program for Operations……….....…...….. 29 4.8 - TASK 8: Examine Current Institutional Capacities …………...………….. 31 4.9 - TASK 9: Conduct training workshop ………………................................... 32 4.10 - TASK 10: Consult relevant stakeholders ………………………………….. 33 4.11 - TASK 11: Assess impact on fish and fishery ………….…………………. 33 4.12 - TASK 12: Develop an Exit Strategy report ………………………………... 36 APPENDIX 1 - TOR and TASKS for the POE (environment) Mission….…………..….. 37 APPENDIX 2a - Mission Schedule and Activities …………………………………………. 41 APPENDIX 2b - Workshop Participants ………………………………………………. 43 APPENDIX 3 - Documents Requested Prior and During the Mission ……………….. 45 APPENDIX 4a - Conservation offset (COS) "284"on the Song Bung ………….…..... 48 APPENDIX 4b - Conservation offset (COS) "304" on the Song Thanh …………...… 50 APPENDIX 5a - List of Existing Native Trees in the COS ……………………………….. 52 APPENDIX 5b - Draft outline of a simplified RFP to recruit a new IMA ……….......... 55 APPENDIX 5c - Framework for Integrated Watershed Management of Sb4 & Sb2 ... 59 APPENDIX 6 - Photos …………………………………………………………………………. 70
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LIST OF ABBREVIATIONS
ADB - Asian Development Bank AIP - Annual Implementation Plan BCCI - Biodiversity Conservation Corridors Initiative COS - Conservation Off-Set DONRE - Department of Natural Resources and Environment EA - Executing Agency EIA - Environmental Impact Assessment EMP - Environmental Management Plan ERD - Environment and Resettlement Department, SB4HPPMB EVN - Electricity of Vietnam GOV - Government of Vietnam HPP - Hydro Power Project HPC - Hydro Power Company MONRE - Ministry of Natural Resources and Environment NCR - Non Conformance Report PAP - Project Affected Persons PMB - SB4 Hydro Power Management Board PECC 4 - Power Engineering Consulting Joint Stock Co. #4 PIC - Project Implementation Consultant POE - Panel of Experts RE - Resident Engineer SB4 - Song Bung 4 SCL - Sino-Hydro Corporation Ltd. STNR - Song Thanh Nature Reserve TOR - Terms of Reference
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EXECUTIVE SUMMARY
ES 1 – INTRODUCTION
1.1 - THE SONG BUNG 4 HYDROPOWER PROJECT 1.1.1 - The 156 MW Song Bung 4 (SB4) Hydropower Project was approved by the Vietnam Ministry of
Industry in 2003 and is partially funded from within Vietnam and partially by a loan from the Asian Development Bank (ADB).
1.1.2 - The project, scheduled to begin operation in 2014, is intended to meet Viet Nam’s increasing power
demand in an environmentally sustainable and socially inclusive manner. Along with other planned hydropower projects in the region, the project will improve flood control, water availability, aquaculture production, tourism development and contribute to the economic development of central Vietnam and the country in general.
Figure 1: Location of Song Bung 4 hydropower project
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1.1.3 - The project’s 110 meter high dam will capture the flow of water from 1477 km ² of the Bung river watershed creating a reservoir with an area of 15.7 km2 at a full supply level of 222.5 meters above sea level. The main project infrastructures include a Roller Compacted Concrete (RCC) dam and related infrastructures including access roads, three resettlement sites and a 35 kilometer 220-kV transmission line, which is not included in the scope of the ADB loan.
1.1.4 - Construction of the project began in June 2010. The closure of the river and diversion of flows began in January 2012. Impoundment of the reservoir began on August 01 2014 and was completed in October 2014. The commissioning of generating units no. 1 and no. 2 took place September 26 and October 17, 2014 respectively.
1.2 - THE ADB PANEL OF EXPERTS (POE)
1.2.1 - A Panel of Experts (POE), composed of two well qualified, senior, Environmental and Social Safeguards Specialists was formed by the ADB with a mandate to advise ADB and Viet Nam Electricity (EVN) on the environmental and social aspects of the implementation of the project. Five missions by the POE (environment) took place in July 2009, July 1012, November 2013, March 2015 and 2016. ES 2 – POE (environment) MANDATE and TERMS OF REFERENCE 2.1 - The mandate for the fifth mission by the POE (environment) was to: "review the status of the EMP implementation of Song Bung 4 Hydropower Project after impoundment, specifically on the biodiversity and natural resource management of the environmental safeguards preparation and compliance. ES 3 – MISSION OVERVIEW 3.1 - The mission began on March 07 2016 at a meeting with SB4 PMB to discuss mission objectives, strategy, activities and schedule, confirm the availability of the required information, identify key support staff and make arrangements for the field-work. Following the meeting and on the next day the POE (environment) worked with PMB and ERD staff to review the relevant project documents available, identify additional documentation required and finalize the work plan and logistics for the field reconnaissance. 3.2 - The field reconnaissance of potentially affected project areas was conducted Between March 09 and 13. The reconnaissance focused on: 1) restored key construction sites & roads, 2) sites of flooded villages, 3) resettlement sites 4) perimeter of reservoir, 5) important affected tributaries, 6) reforested, protected & special use, compensation, & biodiversity offset areas, 7) flooded area of STNR, Interviews with STNR and DARD staff in the field, and interviews with past and present fishers. Wednesday March 09 the POE travelled to the project area, confirmed arrangements with local authorities & stakeholders, visited the affected part of STNR by road, met STNR guards and fishers in vicinity of the bridge and interviewed miners travelling to placer mining up stream of bridge, The following day the POE conducted the reconnaissance of project infrastructures, roads, transmission lines and some of the watershed areas being degraded by illegal and unsustainable land use. The POE inspected all rehabilitated construction sites. In the afternoon the POE visited and evaluated the condition of the river reach between the dam and A Vuong tributary which is receiving basic compensation flow. The POE then met with the Party Secretary of Vinh Village & resettled villagers to discuss forest protection activities and the advent of unsustainable electro-fishing in the reservoir.
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Friday March 11 the POE Met Mrs. Niu, Vice chair of the peoples committee and Mr. Chuong, director of DARD to discuss the condition and maintenance of the COS, the failure of construction site rehabilitation / reforestation done by contractors, and the significant issue of unsustainable electro fishing in the reservoir. Saturday March 12 the POE conducted a reconnaissance of the reservoir and flooded area of STNR by boat. Conditions of reservoir perimeter and water quality in the main channel of the flooded area and the small tributaries of the channel in STNR were noted. COS 284 was inspected and conditions in the vicinity of each of the flooded village sites. Intercepted five fishing boats on the reservoir to interview the fishers and inspect their catch. Four boats were using traditional methods and one was electro-fishing. Sunday March 13 the POE interviewed several fishers along the Bung River below the dam and met with South Bung River Rangers at their field station. Discussions centered on the changes in fishing practices and success, the extent and need to eliminate electro-fishing on the reservoir. An inspection and interview was also conducted at an aqua culture project in Dai Loc District downstream of Song Bung HPP. A meeting with the STNR officer in charge of planting and maintenance of COS 304 focused on the condition of the COS and the extent to which it constitutes a useful Biodiversity offset. On March 14, 15, 16 & 17 activities included: a Post-field / pre-workshop debriefing with SB4-HPC staff and management to highlight key findings of the field reconnaissance. Additional information acquired by SB4-HPC during the week of the reconnaissance was reviewed and several meetings were held with SB4-HPC staff to discuss the relevance, scope and content of the information provided. Work continued on drafting the briefing presentation and POE mission report and completion of the content, materials, logistics and arrangements for the workshop. March 18 the POE conducted the Workshop on Sustainable Hydro Power & Watershed Management. The 18 participants included representatives from SB4 HPC, SB2 HPC, STNR and DARD.
Saturday and Sunday March 19 & 20 work continued on reviewing analysis and evaluation of information and data made available by SB4-HPC and the drafting of SB4-HBC Debriefing and POE reports. March 21 the mission concluded with the SB4-HPC debriefing and wrap up meetings with Key SB4 staff. ES 4 - MISSION TASKS, FINDINGS AND RECOMMENDATIONS The scope of work and twelve principal tasks assigned to the POE are identified below. A summary of the principal recommendations resulting from the mission and a suggested time frame for their implementation are provided In Table ES 1. 4.1 - Scope of Work The assignment included a review of the status of Environmental Mitigation and Monitoring for the Song Bung 4 Hydropower Project 18 months after impoundment. More specifically the review focused "on the biodiversity and natural resource management of the environmental safeguards preparation and compliance:" (i) mitigation measures for environmental impacts especially on reforestation and vegetation/biomass clearance (ii) capacity of the implementing agencies for environmental management; and (iii) other aspects relevant to compliance with ADB and GOV environmental safeguard policies. 4.2 - Principal Tasks The principal tasks set out in the TOR for the fifth POE mission are highlighted below:
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(i) Review relevant environmental documents of the Song Bung 4 Hydropower Project such as EIA report with EMP, reforestation impacts and offset measures, reservoir clearance plan and monitoring reports; (ii) Conduct site visits around the dam site, reservoir, watershed areas upstream and downstream including the identified reforestation areas (protected forest areas and special use forest areas) within the Song Thanh Nature Reserve (STNR) to assess the adequacy and performance of SB4 HPMB and the contractors in terms of EMP implementation post-construction and operations; (iii) Review the SB4HPMB reforestation plans and its contractors on the biodiversity offset areas including planting the proper native plant species, the number and density of species, budget, staff, and monitoring measures to ensure growth and maintenance; (iv) Determine if the EMP provisions for mitigation and monitoring during operations are being implemented properly by all concerned such as environmental flow; (v) Recommend corrective actions in case mitigation measures are not sufficient and/or considered to deviate from requirements of ADB’s safeguard policies; (vi) Assess the adequacy of baseline surveys and analysis, and determine if there is a need to collect additional baseline data during operations; (vii) Examine the monitoring program and recommend revisions and / or additional components as necessary; (viii) Examine current institutional capacities of environmental management unit (EMU) of the executing agency and other responsible agencies; and recommend capacity building measures; (ix) Conduct a training-workshop on environmental management and monitoring during operation of hydropower project; (x) Consult with relevant stakeholders during field visits and record their concerns; (xi) Assess how fishery has been affected post-inundation and how this is impacting income generation and food security and together with the POE on social, recommend any activities to improve current situation; and (xii) Finalize the Exit Strategy report as an addendum of the POE report delineating steps "to ensure SB4HPMB and ADB’s cessation of their direct involvement under the EMP yet ensuring sustainability of the achieved EMP outcomes". NB: In view of the scope content and level of detail of the POE (environmental) report
this task has been waived by the ADB.
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TABLE ES - 1: OVERVIEW and SCHEDULE FOR IMPLEMENTATION OF RECOMMENDATIONS
POE TASK SUMMARY OF KEY PRIORITY RECOMMENDATIONS BY THE
POE
TIME FRAME TO IMPLEMENT
RECOMMENDATION
1: Review relevant
environmental documents of
the Song Bung 4
Hydropower Project such as
the EIA report with EMP,
reforestation impacts and
offset measures, reservoir
clearance plan, and
monitoring reports
KEY PRIORITY RECOMMENDATIONS RESULTING FROM THE REVIEW OF
AVAILABLE DOCUMENTATION ARE IDENTIFIED IN THE FOLLOWING
SECTIONS OF THIS TABLE
NA
2: Conduct site visits around
the dam site, reservoir,
watershed areas upstream
and downstream including
the identified reforestation
areas (protected forest
areas and special use forest
areas) within the Song
Thanh Nature Reserve
(STNR) to assess the
adequacy and performance
of SB4 HPMB and the
contractors in terms of EMP
implementation post-
construction and operations
IN FUTURE, ADB SPONSORED PROJECTS INVOLVING SIGNIFICANT
RESETTLEMENT SHOULD INCLUDE AN IEE FOR THE PROPOSED SITES.
NB - DETAILS ON SPECIFIC RECOMMENDATIONS RELATED TO
CONDITION OF THE RESERVOIR, WATERSHED, REHABILITATED AND
REFORESTED AREAS (PROTECTED FOREST AREAS AND SPECIAL USE
FOREST AREAS) AND THE ASSESSMENT OF THE ADEQUACY AND
PERFORMANCE OF SB4-HPC AND CONTRACTORS IN TERMS OF EMP
IMPLEMENTATION POST-CONSTRUCTION AND OPERATIONS ARE
PRESENTED IN THE FOLLOWING SECTIONS OF THIS TABLE
ADB SHOULD CONSIDER
INCLUDING E IN FUTURE HPP
PROJECT PREPARATION
3: Review the SB4 HPMB
reforestation plans and its
contractors on the
biodiversity offset areas
including planting the
proper native plant species,
the number and density of
species, budget, staff, and
monitoring measures to
ensure growth and
maintenance.
THE METHODS AND EXTENDED MAINTENANCE PROGRAM FOR THE COS
AS RECOMMENDED AND MANAGED BY DARD AND AS IMPLEMENTED BY
LOCAL VILLAGERS SHOULD BE CONTINUED AND SERVE AS A MODEL FOR
THE MAINTENANCE OF ALL REFORESTATION PROGRAMS WITHIN THE
SB4 WATERSHED.
SB4-HPC SHOULD IMPLEMENT
DURING EVERY PLANTING AND /
OR MAINTENANCE ACTIVITY
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4: Determine if the EMP
provisions for mitigation
during operations are being
implemented properly by all
concerned such as
environmental flow.
A) RE: EFFECTIVE SOLID WASTE MANAGEMENT / MITIGATION:
NONE
B) RE: EFFECTIVE LIQUID & HAZARDOUS WASTE MANAGEMENT / MITIGATION -
NONE
C) RE: WATER QUALITY PARAMETERS TO BE MONITORED.
The POE recommends that the TOR for the IMA be revised to include all
the operational monitoring requirements specified in the approved EIA / EMP,
before the new IMA begins work. This is best done by requesting a new proposal
from the IMA which; specifically confirms their commitment to do the monitoring
as specified in the EIA/EMP and provides the details as to: What, Where, When
and How the monitoring will be done.
THE EIA and EMP provide a comprehensive and approved basis for the
preparation of the Operational Monitoring program. Any deviation must be
justified / approved by the Utility and ADB.
The process implemented by SB4-HPC to recruit and manage the IMA
must ensure that the Monitoring during operations, complies fully with the
specifications in the approved EIA / EMP.
The responsibility for carrying out the operational monitoring
requirements of the IEE and EMP must be imposed upon the IMA; not the Utility
or the ADB / POE.
The most effective approach recruiting and managing the IMA is for
SB4 HPC to issue a new, non- technical Request for Proposals (RFP) to potential
IMAs simply requiring them to submit a detailed proposal for an Operational
Monitoring Program that clearly and specifically confirms their commitment to
carry out the monitoring as specified in the EIA / EMP and provides the details as
to: What, Where, When, and How the monitoring will be done.
More specifically the new RFP should describe SB4-HPC administrative
requirements and indicate that proposals must: identify all required elements of
the Operational Monitoring outlined in the EIA and EMP and describe
the activities, scope, content, level of detail, schedule, methodology, reporting
and cost of their Operational Monitoring program.
D) RE: EFFECTIVE NOISE MITIGATION AND MONITORING:
NONE
E) RE: PROVIDING & MAINTAINING ENVIRONMENTAL / COMPENSATION FLOW:
At the very minimum the compensation flow should be monitored
regularly by SB4-HPC to ensure that, at least the arbitrary and minimal
compensation flow of 2.6 m3/s specified in the design is released at all times.
Monitoring Environmental / Compensation flow downstream of the
SB4 dam should be added to the IMA TOR.
F) RE: MITIGATING LOSS OF DOWNSTREAM FISH AND FISHERY:
Monitoring the Environmental / Compensation flow should be added
to the IMA mandate.
Since there is evidence that productive fish habitat continues to exist
below the dam, the mandate of fishery specialists involved in evaluating the
potential for a reservoir fishery should be expanded to assess the value of
increasing the compensation flow from SB4 to improve the potential for fishing in
the 5.5 km reach between the dam and power house without a significant impact
on dam operations during dry season.
In any event, given the improved water quality downstream and to
demonstrate SB4s commitment to environmental off setting it is suggested that
SB4-HPC develop a small number of simple, community based, demonstration
s ale, Fish Ha itat Offset pools do strea of the da a d a o e the A Voung.
G) RE: THE RECOMMENDED STUDY TO DETERMINE FEASIBILITY OF FISHERY BASED
ALTERNATIVE LIVELIHOOD FOR AFFECTED FISHERS:
Given the improved water quality in the reservoir and downstream, the
NA
NA
SB4-HPC SHOULD IMPLEMENT
BEFORE THE IMA BEGINS WORK
OR AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
NA
EVERY TIME HPC AND IMA
MONITORS ARE IN THE FIELD
SB4-HPC SHOULD IMPLEMENT
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
SB4-HPC SHOULD IMPLEMENT
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
SB4-HPC SHOULD IMPLEMENT
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
SB4-HPC SHOULD IMPLEMENT
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study of the feasibility, costs, and benefits of a reservoir based fishery or aqua
culture recommended in the 2007 EMP should be conducted by qualified and
experienced Social and Fishery specialists before implementing any fish stocking
or aquaculture program.
The feasibility study should include an assessment of the value of
increasing the compensation flow from SB4 to improve the potential for fishing in
the 5 km reach of the river between the dam and power house.
H) RE: MITIGATING THE RESIDUAL IMPACTS OF RESERVOIR CLEARING:
Identify, develop and provide a written commitment to implementing
specific environmental mitigation measures during clearing. As a minimum these
should include measures to: control fires, avoid erosion and siltation, prevent
spills, reduce greenhouse gasses, prevent deforestation beyond reservoir limits
and respond to emergencies.
Describe where and how these measures will be implemented and the
budget and staffing required.
Develop fund and implement an effective monitoring plan, and tools
such as checklists and reporting templates, and monitor the clearing work to
ensure the specifications are followed and impacts are minimized.
I) RE: PLANTING & MAINTAINING VEGETATION ON REHABILITATED
CONSTRUCTION SITES:
SB4-HPC should move quickly to ensure the decommissioned
construction areas are replanted and the trees maintained to maturity
in order to improve the aesthetics and permanently stabilize the
affected areas and abandoned construction sites.
The methods and extended maintenance program recommended and
managed by DARD and implemented by local villagers should serve as
a model for the maintenance of all reforestation programs within the
SB4 watershed.
Wire or bamboo cattle exclusion fences must be installed and
maintained around all areas which have been re-habilitated and re-
vegetated.
J) RE: PLANTING & MAINTAINING THE CONSERVATION OFFSETS:
The methods and extended maintenance program recommended and
managed by DARD and implemented by local villagers should serve as
a model for the maintenance of all reforestation programs within the
SB4 watershed.
K) RE: IMPLEMENTING WATERSHED PROTECTION MEASURES:
If SB4 is to provide long term sustainable power, ADB AND SB4-HPC
must encourage and assist DONRE and MONRE to play an increasingly
effective role in ensuring the SB4 watershed is managed sustainably
during the operations phase.
All HPP projects in Vietnam, including SB4, should include effective and
sustainable Integrated Watershed Management as a priority from
project inception.
SB4-HPC should review Decree no.112 (2008) on integrated watershed
management, and work with concerned parties including but not
li ited to the Co u al People’s Co ittee, Distri t People’s Committee, MONRE and Provincial DONRE to ensure enhanced
compliance.
In the best interest of Viet Nam, sustainable Hydro Power should be
decreed a National Priority.
All relevant stakeholders: National and Local Government Agencies,
Utilities, Community groups and NGOs, should be encouraged and
supported to implement an Integrated Watershed Management
program covering SB4 and SB2 watersheds. (See Appendix 5c)
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
SB4-HPC SHOULD IMPLEMENT THIS
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
SB4-HPC SHOULD IMPLEMENT
DURING THE PLANNING /
CONTRACTING FOR ANY CLEARING
ACTIVITIES
SB4-HPC SHOULD IMPLEMENT
DURING THE PLANNING /
CONTRACTING FOR ANY CLEARING
ACTIVITIES
SB4-HPC SHOULD IMPLEMENT
DURING THE PLANNING /
CONTRACTING FOR ANY CLEARING
ACTIVITIES
AT THE EARLIEST OPPORTUNITY
SB4-HPC SHOULD IMPLEMENT
DURING THE MAINTENANCE OF ALL
PLANTATIONS
SB4-HPC SHOULD IMPLEMENT
IMMEDIATELY FOLLOWING ALL
REFORESTATION WORK
SB4-HPC SHOULD IMPLEMENT
DURING ALL REFORESTATION AND
MAINTENANCE ACTIVITIES
ADB AND SB4-HPC SHOULD BEGIN
IN JULY 2016 AND CONTINUE
THROUGHOUT PROJECT
OPERATIONS
ADB AND GOV SHOULD BEGIN IN
2016
GOV SHOULD CONSIDER THIS
BEGINNING IN 2016
GOV SHOULD CONSIDER THIS
BEGINNING IN 2016
ADB AND GOV SHOULD INITIATE
THIS IN 2016
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5: Recommend corrective actions in case mitigation measures are not sufficient and/or considered to deviate from requirements of ADB’s safeguard policies.
See row 4 (above) for priority recommendations for corrective actions
necessary to meet the mitigation requirements of the EIA, the updated
EMP a d ADB’s safeguard poli ies.
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
6: Assess the adequacy of baseline surveys and analysis, and determine if there is a need to collect additional baseline data during operations.
As soon as possible SB4-HPC should prepare a new Request for
Proposals (RFP) requiring prospective IMA(s) to submit a proposed,
work plan and schedule to develop an appropriate baseline and
implement a comprehensive monitoring program to identify, describe
and evaluate the impacts of project operations on: all physical and
biological parameters identified in the EIA / EMP including but not
limited to reservoir and downstream water quality, GHG,
compensation flow, aquatic invertebrates, fish yield and Mercury
content, and on the watershed during operations.
Since operations have already begun, appropriate baselines should be
established and regular monitoring should be carried out in the
pote tially affe ted rea hes a d i o trol area s oth upstrea and downstream of the dam. Controls could also be established in a
comparable river.
Also see ROW 7 below.
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
7: Examine the monitoring program and recommend revisions and / or additional components as necessary.
RE: IMA'S TOR, WORKPLAN & SCHEDULE for MONITORING DURING OPERATIONS
The responsibility for carrying out the operational monitoring
requirements of the IEE and EMP must be imposed upon the IMA, not
the Utility or the ADB / POE.
As soon as possible SB4-HPC should prepare a new, non-technical
Request for Proposals (RFP) requiring prospective IMA(s) to submit a
proposal that clearly and specifically confirms their commitment to carry
out the monitoring as specified in the EIA / EMP and provides a work
plan schedule and details as to: What, Where, When, and How the
monitoring will be done.
Any deviation from the requirements in the EIA /EMP must be justified /
approved by the Utility and ADB.
The process implemented by SB4-HPC to recruit and manage the IMA
must ensure that the Monitoring during operations, complies fully with
the specifications in the approved EIA / EMP.
More specifically the new RFP should describe SB4-HPC administrative
requirements and indicate that proposals must: identify all required
elements of the Operational Monitoring outlined in the EIA and EMP
and describe the activities, scope, content, level of detail, schedule,
methodology, reporting and cost of their proposed operational
monitoring program.
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
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RE: MONITORING BY ERD (SB4-HPC) DURING TRANSITION FROM CONSTRUCTION
AND BEGINNING OF OPERATIONS PHASES
As soon as possible SB4-HPC needs to: 1) review the environmental
mitigation and monitoring, specifications identified in the EIA and EMP
for the operational period and their approach to environmental and
information management during the construction phase, and 2)
consider and evaluate the shortcomings identified in the transition and
early operations phases and 3) make the necessary adjustments /
improvement and changes necessary to ensure that the
implementation and documentation of mitigation and monitoring
during operations becomes as efficient and effective as during the
construction period.
During operations monitoring SB4-HPC should adapt, adopt and
implement the Non Conformance Reporting (NCR) system used by the
Project Implementation Consultant.
During the operational phase of SB4-HPC should prepare and issue
NCRs automatically for all environmental issues considered important
and urgent by any monitoring agency. ERD should follow up and
ensure these urgent NCRs are resolved within one week or as
otherwise agreed by the stakeholders. Failing this the PMB should
issue a letter indicating the financial penalty for continued non-
compliance.
SB4-HPC specialists should systematically review and follow up on
outstanding issues of non-conformance raised by the new IMA and
other monitoring agencies.
BEFORE THE IMA BEGINS WORK OR
AT THE EARLIEST OPPORTUNITY
THERE-AFTER
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
8: Examine current institutional capacities of environmental management unit (EMU) of the executing agency and other responsible agencies; and recommend capacity building measures.
SB4-HPC should facilitate and support enhanced training related to
enforcement of regulations, patrolling and reporting, boat handling,
and provision of an appropriate number of boats and guard posts in
remote areas of the watershed.
SB4-HPC should enhance their internal management review process to
provide staff with constructive feedback to improve the structure,
content, and level of detail in their internal documentation.
SB4-HPC should provide training to assist their managers and
specialists in preparing constructively critical reviews of all proposals
and monitoring reports. This will improve the deliverables and
documentation related to the environmental management of SB4 HPP.
SB4-HPC specialists should prepare a detailed and comprehensive
written review of all plans, proposals and reports received from
outside agencies and keep these on file.
SB4-HPC specialists should prepare and file written minutes of all
meetings, field activities, and important communications regarding
environmental mitigation and monitoring. These should, as a
minimum, record the names and contact details for personnel
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
13
involved, the purpose, details, required follow up, and target
completion dates.
SB4-HPC should build on the comments and concepts from capacity
building activities and continue to facilitate and optimize teamwork,
build the capacity of the HPC management and specialists. This should
involve simple and cost effective activities such as informal in-house
training sessions, Vietnamese multiple agency workshops, and on the
job mentoring by experienced National and International consultants
already working on SB4.
During the operational phase of SB4 STNR forest officers and guards
should be provided enhanced training related to enforcement of
regulations, patrolling and reporting, as well as boats and guard posts.
During operations monitoring SB4-HPC should adapt, adopt and
implement the Non Conformance Reporting (NCR) system used by the
Project Implementation Consultant.
During the operational phase of SB4-HPC should prepare and issue
NCRs automatically for all environmental issues considered important
and urgent by any monitoring agency. ERD should follow up and
ensure these urgent NCRs are resolved within one week or as
otherwise agreed by the stakeholders. Failing this the PMB should
issue a letter indicating the financial penalty for continued non-
compliance.
SB4-HPC specialists should systematically review and follow up on
outstanding issues of non-conformance raised by the new IMA and
other monitoring agencies.
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
9: Conduct a training-workshop on environmental management and monitoring during operation of hydropower project.
Since effective Watershed Management is critical to sustain the power
output of SB4 over the medium and long term training and
implementation of integrated watershed management must be a
priority component of all future capacity building for ADB sponsored
HPP, including of course SB4.
Integrated Watershed Management (IWM) requires involvement and
commitment from political, project management, technical and
grassroots stakeholders. Specific training is required for all participants
and specific materials and approaches must be provided as
appropriate.
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
10: Consult with relevant stakeholders during field visits and record their concerns.
All recommendations related to the concerns and expectations raised
during discussions with the above mentioned stakeholders have been
refle ted i the appropriate Re o e datio s se tio s of this report.
NA
11: Assess how fishery has been affected post-inundation and how this is impacting income generation and food security and together with the POE on social, recommend any activities to improve current situation.
GENERAL RECOMMENDATIONS: RELATED TO THE FISHERY UPSTREAM OF THE
DAM.
The study of the feasibility, costs, and livelihood benefits of a reservoir
based fishery recommended in the 2007 EMP should be conducted by
qualified and experienced Social and Fishery specialists before
implementing any fish stocking or aquaculture program.
SPECIFIC RECOMMENDATIONS: RELATED TO ELECTRO FISHING IN THE RESERVOIR:
The practice of electro-fishing must be stopped at all costs.
As soon as possible SB4-HPC write a letter of support to the relevant
local authorities pledging the financial and moral support required to
condemn and stop this unfair, unacceptable and unsustainable
practice.
Fishing restrictions / limits should be considered
All boats using the reservoir must be registered
All fishers operating on the reservoir must be licensed
SB4-HPC SHOULD IMPLEMENT THIS
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
BEGIN IN JULY 2016 AND
CONTINUE THROUGHOUT
OPERATIONS
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RECOMMENDATIONS: RELATED TO THE FISHERY IN SONG BUNG REACHES
DOWNSTREAM OF THE DAM
The fisheries feasibility study recommended in the EIA and EMP should
include an assessment of the net value of increasing the compensation
flow from SB4 to improve the potential for fishing between the dam
and power house.
Given the improved water quality downstream of the dam it is
recommended that the SB4 PMB develop a small number of, simple
o u ity ased, de o stratio s ale Fish Ha itat Offset pools downstream of the dam and above the A Vuong.
HPC SHOULD IMPLEMENT THIS
PRIOR TO DESIGNING OR
IMPLEMENTING AN AQUA-
CULTURE PROGRAM
12: Develop an Exit Strategy report as an addendum of the POE report delineating steps to ensure SB4-HPMB and ADB’s cessation of their direct involvement under the EMP yet ensuring sustainability of the achieved EMP outcomes.
NB: In view of the scope content and level of detail of the POE
(environmental) report this task has been waived by the ADB
NA
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1.0 – INTRODUCTION
1.1 - THE SONG BUNG PROJECT 1.1.1 - As described in the 2012 Environmental Mitigation and Monitoring Implementation Plan, the Song Bung 4 (SB4) Hydropower Project is part of the Vu Gia – Thu Bon hydropower cascade approved by the Vietnam Ministry of Industry in 2003. The project is partially funded from within Vietnam and partially by a loan from the Asian Development Bank (ADB).
- The 156 MW project in Nam Giang District, Quang Nam Province in central Viet Nam is intended to meet Viet Nam’s increasing power demand in an environmentally sustainable and socially inclusive manner. The Project is scheduled to begin operation in 2014
1.1.2 - Implementation of the SB4 Hydropower Project on the Song Bung, a tributary of the Vu-Gia River (Figure1), will contribute to the socio-economic development of Nam Giang district, Quang Nam province. During construction the project will create jobs and develop skills for local inhabitants. During operation the project will supply 586.25 million kWh in average annual energy to the national power grid. Along with other planned hydropower projects in the region, the project will improve flood control, water availability, aquaculture production, tourism development and contributes significantly to the economic development of central Vietnam and the country in general.
Figure 2: Location of Song Bung 4 Hydropower Project
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1.1.3 - The SB4 project is one of a cascade of hydro projects that will include the proposed Song Bung 2 hydropower project (located upstream of the Project) and Song Bung 5 hydropower project (located downstream of the Project). A 110 meter high dam will capture the flow of water from 1,477 km ² of the Bung river watershed, above the dam, creating a reservoir with an area of 15.7 km2 at a full supply level of 222.5 meters above sea level (masl). Water from the reservoir will be conveyed through a 3.1 kilometer tunnel to an above ground power house. The discharge from the power house will be conveyed through a short tailrace canal and returned to the Song Bung, 5 km downstream of the dam. 1.1.4 - The main project infrastructures include a Roller Compacted Concrete (RCC) dam with integral, gated spillway; intake structure, headrace tunnel, surge shaft, pressure shaft, and pressure tunnel in the underground works; a power house with two 78 MW Francis generating units, tailrace channel, switchyard; and workers’ camps. A 35 kilometer, double-circuit 220-kV transmission line, which is not included in the scope of the ADB loan, will run from the power house to Thanh My in Nam Giang district. There are also access roads to the project site and the three resettlement sites.
1.1.5 - Construction of the project began in June 2010. The closure of the river and diversion of flows began in January 2012. Impoundment of the reservoir began on August 01 2014 and was completed in October 2014. The commissioning of generating units no. 1 and no. 2 took place September 26 and October 17, 2014 respectively.
THE ADB PANEL OF EXPERTS (POE) 1.2.1 - A Panel of Experts (POE), composed of two well qualified, senior, Environmental and Social Safeguards Specialists has been formed by the ADB with a mandate to advise ADB and Viet Nam Electricity (EVN) on the environmental and social aspects of the implementation of the project. 1.2.2 - The POE is an advisory body reporting directly to both ADB (Director, Energy Division, Southeast Asia Department) and Vice President of EVN (Investment and Development). 1.2.3 The first mission of the POE (environment) was conducted in July 2009, the second in July 2012, the third, in November 2013, the fourth in March 2015 and the fifth, which is the subject of this report, was carried out in March 2016. 2.0 - MANDATE and TERMS OF REFERENCE of the POE (environment) 2.1 - The mandate and Terms of Reference for the fifth mission by the POE (environment) included the: "review the status of the EMP implementation of Song Bung 4 Hydropower Project specifically on "the biodiversity and natural resource management of the environmental safeguards preparation and compliance: (i) mitigation measures for environmental impacts especially on reforestation and vegetation / biomass clearance ; (ii) capacity of the implementing agencies for environmental management and (iii) other aspects relevant to compliance with ADB and GOV environmental safeguard policies." 2.2 - The full Terms of Reference for the POE (environment) are provided in Appendix 1.
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3.0 - MISSION OVERVIEW 3.1 - The fifth mission by the environmental member of the POE began in Danang on March 07 2016 at a meeting with SB4 PMB to discuss mission objectives, strategy, activities and schedule, confirm the availability of the required information, identify key support staff and make arrangements for the field-work. Following the meeting and on the next day the POE (environment) worked with PMB and ERD staff to review the relevant project documents available, identify additional documentation required and finalize the work plan and logistics for the field reconnaissance. 3.2 - The field reconnaissance of potentially affected project areas was conducted between March 09 and 13. The reconnaissance focused on: 1) restored key construction sites & roads, 2) sites of flooded villages, 3) resettlement sites 4) perimeter of reservoir, 5) important affected tributaries, 6) reforested protected & special use, compensation, & biodiversity offset areas, 7) flooded area of STNR, Interviews with STNR and DARD staff in the field, and interviews with past and present fishers.
Wednesday March 09 the POE travelled to the project area, confirm arrangements with local authorities & stakeholders, visited the affected part of STNR by road, met STNR guards and fishers in vicinity of the bridge and interviewed miners travelling to placer mining up stream of bridge, The following day the POE conducted the reconnaissance of project infrastructures, roads, transmission lines and some of the watershed areas being degraded by illegal and unsustainable land use. The POE inspected all rehabilitated construction sites including in the crushing area, camp #13, batch plant, oil depot, work camps on left and right bank, and auxiliary, spoil areas. In the afternoon the POE visited and evaluated the condition of the river reach between the dam and A Vuong tributary which is receiving basic compensation flow. The same afternoon the POE met with the Party Secretary of Vinh Village & resettled villagers to discuss forest protection activities and the advent of unsustainable electro-fishing in the reservoir. Friday March 11 the POE Met with Mrs. Niu, Vice chair of the peoples committee and Mr. Chuong, director of DARD to discuss the condition and maintenance of the COS, the failure of construction site rehabilitation / reforestation done by contractors, and the significant issue of unsustainable electro fishing in the reservoir. Saturday March 12 the POE conducted a reconnaissance of the reservoir and flooded area of STNR by boat. Conditions of reservoir perimeter and water quality in the main channel of the flooded area and the small tributaries of the channel in STNR were noted. Inspected COS 284 in the company of the DARD official responsible for planting and management of the COS. Conditions in the vicinity of each of the flooded village sites were noted. Observed numerous areas in the vicinity of the Padhi resettlement site where gas, presumably methane, was bubbling to the surface of the reservoir. Intercepted five fishing boats on the reservoir to interview the fishers and inspect their catch. Four boats were using traditional methods and one was electro-fishing. Sunday March 13 the POE interviewed several fishers along the Bung river below the dam and met with South Bung River Rangers in their field station. Discussions centered on the changes in fishing practices and success, the extent and need to eliminate electro-fishing on the reservoir. An inspection and interview was also conducted at an aqua culture project in Dai Loc District downstream of Song Bung HPP. A meeting was held with STNR officer in charge of the planting and maintenance of COS 304. Discussion centered on the condition of the planting and the extent to which is constituted a useful Biodiversity offset. On March 14, 15, 17 & 17 the POE held a Post-field / pre-workshop debriefing with SB4-HPC staff and management to highlight key findings of the field reconnaissance. Additional information acquired by SB4-HPC during the week of the reconnaissance was reviewed and several meetings were held with SB4-HPC staff to discuss the relevance, scope and content of the information provided. Work continued on drafting the final briefing presentation and POE mission report and completion of the content, materials, logistics and arrangements for the workshop.
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March 18 the POE conducted the Workshop on Sustainable Hydro Power & Watershed Management. Participants included representatives from SB4 HPC, SB2 HPC, STNR and DARD. Saturday and Sunday March 19 & 20 work continued on the review, analysis and evaluation of information and data made available by SB4-HPC and drafting of the Debriefing and POE report. March 21 the mission concluded with the final SB4-HPC debriefing and wrap up meetings with Key SB4 staff.
The schedule and list of principal activities conducted during the mission is presented in Appendix 2a of this report. 4.0 - MISSION TASKS, FINDINGS AND RECOMMENDATIONS This section and subsections 4.1 through 4.12 identify the twelve tasks in the TOR for the POE (environment) and present the activities, findings and recommendations related to each. 4.1 - TASK 1) "Review relevant environmental documents of the Song Bung 4 Hydropower Project
such as the EIA report with EMP, reforestation impacts and offset measures, reservoir clearance plan, and monitoring reports."
4.1.1 - ACTIVITIES: a) A request for key documents required for the POE (environment) mission was submitted prior to the
mission. (Appendix 3). b) Prior to going to the field the initial review of available documents focused on information relevant to the planned and actual implementation of environmental mitigation and monitoring during the operations phase of SB4. c) More specifically the initial document review focused on the final EIA and EMP, and the TOR and work plan for the new Independent Monitoring Agency (MA) to be engaged in March 2016, and potential environmental management issues related to: Song Thanh Nature Reserve, compensation flow, rehabilitation of construction sites, conservation offsets, adequacy of baseline for environmental monitoring during operations, impacts on fish and fishery, and institutional capacity for environmental protection and monitoring during operations. d) While the clearing plan was reviewed and the need for additional mitigation and monitoring during the clearing process was first identified in the 2013 POE report, and followed up during the POE mission in 2015, it was reviewed once again in 2016 to provide context and background for the identification of residual impacts from clearing activities carried out before flooding more than one year ago. e) Following the initial review of available documentation during the first two days of the mission and again after the field reconnaissance the POE requested SB4-HPC to provide the remaining information on the initial list, plus a number of additional documents available in English, and English summaries of KEY documents available only in Vietnamese. f) A detailed review of all available documents was carried out during preparation of this POE mission report. 4.1.2 - FINDINGS:
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a) Having two days in Danang, prior to beginning the field work, was valuable to review existing documentation and to identify and assess the environmental management, mitigation, and monitoring work implemented since the last POE mission in 2015. In addition this allowed for the setting of priorities and finalizing the schedule for the field reconnaissance and meetings with key stakeholders. b) The POE confirmed that; as noted in previous missions the initial EIA and EMP are good examples of comprehensive, detailed focussed and well written Safeguard documents which provide an excellent framework for the implementation of environmental management and monitoring during the operational phase of the SB4 HPP. NB) - Findings related specifically to the 2016 review and adequacy of the planning and implementation of reforestation in the Conservation Offset Areas (COS) are presented in Section 4.3 of this document. NB) - Findings related specifically to the 2016 review of the clearing plan and the findings and recommendations related to the implementation of clearing are presented in Section 4.4.2.1 (h) of this document. NB) - Findings related specifically to the baseline for Environmental Monitoring during Operations are presented in section 4.6 and 4.7 of this document. NB) - Findings related specifically to Environmental Monitoring during Operations are presented in section 4.7 of this document. 4.1.3 - RECOMMENDATIONS a) As for this mission, the first two days of all POE missions should be spent working in the offices of the IA to review existing documentation, establish the status of ongoing environmental management, mitigation, and monitoring, set priorities and finalize a schedule for the field work and meetings with key stakeholders. NB) - Recommendations related specifically to the review and adequacy of the planning and implementation of reforestation in the Conservation Offset Areas (COS) are presented in Section 4.3 of this document. NB) - Recommendations related specifically to the review and adequacy of the planning and implementation of clearing the reservoir are presented in Section 4.4.2.1 (h) of this document. NB) - Recommendations related specifically to the review and adequacy of the existing baseline for monitoring during the operational period of SB4 are presented in sections 4.6 and 4.7 of this document. NB) - Recommendations related specifically to monitoring during operations are presented in section 4.7 of this document. 4.2 - TASK 2) "Conduct site visits around the dam site, reservoir, watershed areas upstream and
downstream including the identified reforestation areas (protected forest areas and special use forest areas) within the Song Thanh Nature Reserve (STNR) to assess the adequacy and performance of SB4 HPMB and the contractors in terms of EMP implementation post-construction and operations".
4.2.1 - GENERAL ACTIVITIES RELATED TO SITE VISIT:
20
a) Prior to the site visit and field reconnaissance the POE reviewed the EIA and EMP to identify the key mitigation and monitoring requirements for the operations phase spelled out in these documents. The areas where these mitigation and monitoring measures were to be implemented were identified on a large scale map of the project area, A Checklist of the recommended mitigation and monitoring requirements for the operations phase was also prepared and used during the site visit and reconnaissance of the reservoir and selected watershed areas both up and downstream from the dam. b) During the site visit and reconnaissance the POE (environment) was accompanied and assisted by the Project Community mobilizer whose assistance contributed significantly to the positive outcome of the mission. DARD officers and a representative of SB4-HPC accompanied also participated in the reservoir reconnaissance. c) The site visit focused on key potential issues identified in the EIA and EMP. These included but were not limited to: i) Compensation / Environmental flows, ii) reforestation of conservation offsets (COS), iii) clean- up and rehabilitation planting of sites where temporary infrastructures have been dismantled and / or where construction activities have been completed, iv) protection and management of watershed and reservoir resources and v) monitoring during operations. d) More specifically the land based survey included: the affected part of STNR, project infrastructures, roads, transmission lines and some of the watershed areas being degraded by illegal and unsustainable land use, all rehabilitated construction sites and the river reach between the dam and A Vuong tributary which is receiving basic compensation flow.
e) In addition to the land based survey an extensive reconnaissance of the reservoir and adjacent riparian and watershed areas was conducted by boat.
4.2.2 – GENERAL FINDINGS RELATED TO SITE VISIT: a) Sufficient time was available during the mission to visit / view all key areas including: the dam site, access roads, representative sites along the transmission lines and reservoir perimeter, as well as selected affected watershed areas upstream / downstream and the Conservation Off Set area designated COS "284" bordering the Song Bung within the Song Thanh Nature Reserve (STNR). A map showing the location, topography and extent of COS "284" is provided in Appendix 4a. b) Information, reports and observations provided by SB4-HPC on rehabilitation and monitoring activities undertaken since the last POE mission were extremely valuable to the POE. Field support by the Community Mobilizer facilitated logistics and meetings with stakeholders which would otherwise not have been possible. c) The 2016 mandate for the POE (environment) did not include visits to the resettlement areas and consequently it was not possible to follow up on the following two findings of the 2013 and 2015 POE reports. c1) in 2013 a rapid reconnaissance in the vicinity of the resettlement sites suggested that
deforestation for fuel and agriculture appeared excessive. c2) in 2013 the water supply and Septic systems had not been inspected post construction. NB) - Findings related specifically to the condition of the reservoir, watershed, rehabilitated and reforested areas (protected forest areas and special use forest areas) and the assessment of the adequacy and performance of SB4-HPC and contractors in terms of EMP implementation post-construction and operations are presented in following sections 4.3, 4.4 and 4.5 below . 4.2.3 - GENERAL RECOMMENDATIONS RELATED TO SITE VISIT:
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a) In future, ADB sponsored projects involving significant resettlement should include an identification of
potentially significant environmental impacts of resettlement and specific environmental mitigation for them.
NB) - Recommendations related specifically to the condition of the reservoir, watershed, rehabilitated and reforested areas (protected forest areas and special use forest areas) and the assessment of the adequacy and performance of SB4-HPC and contractors in terms of EMP implementation post-construction and operations are presented in sections 4.3, 4.4 and 4.5 below. 4.3 - TASK 3: "Review the SB4 HPMB reforestation plans and (those of) its contractors on the
biodiversity / conservation offset areas (COS), including planting the proper native plant species, the number and density of species, budget, staff, and monitoring measures to ensure growth and maintenance."
NB: This section (4.3) includes the review of planning for and the inspection of the plantings in Conservation Off Set areas. (Appendix 4a & 4b). 4.3.1 - ACTIVITIES: 4.3.1.1: Review of Reforestation Plans (for Conservation Off Set (COS) plantings) a) In 2013 the POE reviewed the Reforestation plans for the COS and assessed the proposed approach to: determining the appropriate (native) plant species, the number of species to be planted, planting density, budget and staff requirements, maintenance and monitoring measures, the source of seedlings and their suitability for reforestation in the COS areas. b) During POE missions in 2015 and 2016 the reforestation plans were reviewed again and the implementation, maintenance and monitoring of the COS were discussed with representatives of STNR and DARD. c) In 2016 updated information related to the implementation and monitoring of the COS reforestation plans, planting and maintenance activities was obtained during interviews with representatives of STNR and DARD responsible for implementation of the actual reforestation and maintenance by subcontractors. d) A meeting was held with STNR officer in charge of the planting and maintenance of COS 304. Discussion centered on the condition of the planting and the extent to which is constituted a useful Biodiversity offset. 4.3.1.2: Field Inspection of the Conservation Off Set (COS) Plantings The 2016 reconnaissance of the reservoir and its immediate surroundings, including COS #284 in STNR and bordering the reservoir (Appendix 4a), was carried out by the POE along with a representative of SB4-HPC, the Community Mobilizer and the DARD officer responsible for planting and management of the COS. 4.3.2 - FINDINGS:
4.3.2.1 Findings from the Review of the Reforestation Plans and Discussions with STNR and DARD The 2016 desk top review of the reforestation plans and discussions with authorities indicated that:
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a) Reforestation plans for the Conservation Off Sets COS "284" and COS "304" were based on detailed and comprehensive data on the areas identified for the COS in the designated production, protection and special use forest areas. (Appendices 4a and 4b). b) The plans included careful site selection, appropriate species and planting techniques, rigorous monitoring and effective follow-up maintenance to ensure the success of the "plantations" in production and protection forest areas designated as COS. c) Discussions with STNR and DARD representatives in March 2016 confirmed that the COS plantings were completed as of March 2015, post-planting inspections were carried out in April 2015 (after the POE mission) and maintenance / replacement planting is/was underway (March 2016). Unfortunately inspection and monitoring reports were not available for review during the POE mission of 2016. d) Based only on the desk top review of the reforestation plans the decision to plant only two species, Hopea odorata (Sao den) and Chukrasia tabularis (Lat Hoa) seemed less than ideal for the creation of an effective Biodiversity Off Set. e) Generally the biodiversity of areas replanted with only 2 or 3 species will be inferior to the biodiversity of a natural “forest” in terms of vegetation, birds and wildlife and, the ecological functions of such areas including maintenance of water quality, runoff control, soil stabilization, fertility improvement and total productivity are likely to less effective than those of a natural "forest". 4.3.2.2 Findings from the 2015 and 2016 Inspection of COS "284" and Discussions with STNR and DARD officials. a) The March 2015 reconnaissance of COS 284 within STNR and bordering the SB4 reservoir had revealed that tree seedlings planted in late 2013 and early 2014 were overgrown and choked by weeds (Appendix 6), photo 1. The few seedlings that were found and uncovered were approximately 10 to 20 cm in height and 3 to 4 mm in diameter and had few leaves. b) Consequently the 2015 POE report had recommended and described the urgent intervention required to save the plantation. c) In March 2016 the POE inspection of COS 284 revealed a vastly improved situation. (Appendix 6, photo 2). This was due to the timely and effective maintenance work by DARD and villagers in April 2015 to clear the weeds from around the seedlings and replace those that had perished. . d) This intervention saved the majority of the seedlings planted in late 2013 / early 2014 and which, by March 2016, had attained an average height of from 0.75 t0 1.5 meters. (Appendix 6, photo 3). e) Based on this experience in 2015 DARD recommended that inspection and maintenance be carried out 3 times each year rather than twice as originally planned. SB4-HPC has agreed to fund this additional annual maintenance work to ensure the success of the plantations. d) The POE reconnaissance of 2016 found that concerns regarding the planting COS 284 and 304 with only two or three species respectively may be less significant than originally thought. This is because, with the maintenance and clearing done, it has become more evident that numerous seedlings of a number of other native tree species have naturally reseeded within and around the COS 284 area there-by improving the potential for the area to become the effective biodiversity Off Set intended by planners. The list of planted and naturally reseeded species in COS 284 is provided in Appendix 5a. e) During the 2016 inspection of the COS "284" site the POE was informed that there was insufficient time to visit the second COS area (# 304) located on the Song Thanh 7 km east of the reservoir. Nevertheless
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secondary information provided by STNR and DARD relevant to the planting and maintenance of COS "304" has been provided in previous sections 4.3.2.1 and 4.3.2.2 of this report 4.3.3 RECOMMENDATIONS 4.3.3.1 Recommendations from the Review of Reforestation Plans for the COS a) None required. 4.3.3.2 - Recommendations from the 2015 Inspection of COS "284" in STNR a) The methods and extended maintenance program for the COS recommended and managed by DARD and implemented by local villagers should be continued and serve as a model for the maintenance of all reforestation programs within the SB4 watershed.
4.4 – TASK 4: "Determine if the EMP provisions for mitigation during operations are being
implemented properly by all concerned such as environmental flow". 4.4.1 - ACTIVITIES: a) The determination of the extent to which EMP provisions for mitigation during operations are being implemented properly was made on the basis of: the document review (Task 1), the site visit, field reconnaissance, interviews with ERD staff affected people and other stakeholders regarding the effectiveness of mitigation (Task 2). 4.4.2 - FINDINGS and RECOMMENDATIONS 4.4.2.1 - Findings and Recommendations RE: Compliance with EMP Provisions for Mitigation during Operations. The EMP identified the requirements for mitigation during HPP operation. The following subsections, "a" through "k": 1) Describe the extent to which the key mitigation requirements outlined in the EMP are being met during HPP operational period and 2) Make recommendations to improve the mitigation during operations to meet the requirements of the EMP and ADB Safeguards. a) RE: Effective Solid Waste Management / Mitigation FINDINGS:
SB4-HPC has followed through on the relevant NCRs and 20 letters sent by the resident engineer to contractors requiring site clean-up of the contractors' offices, camp 13, quarry camp, and several waste rock disposal areas that had not been finished in March 2015.
RECOMMENDATIONS:
None required b) RE: Effective Liquid and Hazardous Waste Management / Mitigation
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FINDINGS:
There is virtually no evidence of this type of waste remaining from the construction period.
The procedures, equipment and facilities for the management of liquid and hazardous wastes at the powerhouse and the dam are in place and adequate for the handling storage and treatment of the small quantities of liquid and hazardous waste generated during operations.
RECOMMENDATIONS:
None required c) RE: Water Quality Parameters to be Monitored. FINDINGS:
Monitoring by an Independent Monitoring Agency during operations of SB4 HPP is critical to the sustainability of the project.
In March 2015 the POE noted that while the TOR for monitoring by the IMA, and their initial monitoring and reporting for 2015 include most of the water quality parameters specified in the EIA / EMP a number of others were not included.
The most important gaps were the lack of monitoring for: change in fish species diversity, fish yield and mercury content, rehabilitation of construction areas, COS, compensation flow, GHG, and unsustainable watershed activities.
The March 2016 POE mission noted that a new IMA is about to be engaged and begin monitoring with the same TOR that was used in 2015.
If not remedied quickly the environmental monitoring will be inadequate for the second year of operations.
RECOMMENDATIONS:
The POE recommends that the TOR for the IMA be revised to include all the operational monitoring requirements specified in the approved EIA / EMP, before the new IMA begins work. This is best done by requesting a new proposal from the IMA which; specifically confirms their commitment to do the monitoring as specified in the EIA/EMP and provides the details as to: What, Where, When and How the monitoring will be done.
THE EIA and EMP provide a comprehensive and approved basis for the preparation of the Operational Monitoring program. Any deviation must be justified / approved by the Utility and ADB.
The process implemented by SB4-HPC to recruit and manage the IMA must ensure that the Monitoring during operations, complies fully with the specifications in the approved EIA / EMP.
The responsibility for carrying out the operational monitoring requirements of the IEE and EMP must be imposed upon the IMA; not the Utility or the ADB / POE.
The most effective approach recruiting and managing the IMA is for SB4 HPC to issue a new, non- technical Request for Proposals (RFP) to potential IMAs simply requiring them to submit a detailed proposal for an Operational Monitoring Program that clearly and specifically confirms their commitment to carry out the monitoring as specified in the EIA / EMP and provides the details as to: What, Where, When, and How the monitoring will be done.
More specifically the new RFP should describe SB4-HPC administrative requirements and indicate that proposals must: identify all required elements of the Operational Monitoring outlined in the EIA and EMP and describe the activities, scope, and content, level of detail, schedule, methodology, reporting and cost of their Operational Monitoring program.
A draft outline for a simplified RFP to recruit a new IMA was sent to ADB and forwarded to SB4-HPC for their consideration / implementation. (Appendix 5b)
d) RE: Effective Noise Mitigation and Monitoring
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FINDINGS:
During the 2016 site visit operating personnel were using hearing protection and other occupational health and safety equipment as required by the EMP.
RECOMMENDATIONS:
None required
e) RE: Providing and Maintaining Environmental / Compensation Flow FINDINGS:
The EIA of 2000 recommended and provided the TOR for a study to determine an appropriate environmental / compensation flow release from the SB4 dam. This study was not done and instead, the dam was designed to release an arbitrary, small and constant environmental / compensation flow of approximately 2.6 m3/s.
In 2015 several field estimates were made of the compensation flow being released below the dam. These (admittedly) rough estimates varied between 2.5 and 3.6 m³/sec. (during a period of intermittent light to heavy rain) and there was not sufficient evidence that the environmental / compensation flow specified in the design of the dam was being maintained by the operations staff.
While a single observation by the POE on March 10 2016 suggested the compensation flow was marginally greater than at the same time last year there is no evidence that SB4-HPC or the IMA have been monitoring the compensation flow since dam closure as required by the EIA and EMP
RECOMMENDATIONS:
At the very minimum the compensation flow should be monitored regularly by SB4-HPC to ensure that, at least the arbitrary and minimal compensation flow of 2.6 m3/s specified in the design is released at all times.
Monitoring Environmental / Compensation flow downstream of the SB4 dam should be added to the IMA TOR.
See also section 4.11 for further information on the importance of environmental / compensation flow.
f) RE: Mitigating Loss of Downstream Fish and Fishery FINDINGS:
In spite of the arbitrary, minor and apparently variable environmental / compensation flow being released from SB4 reservoir, inspection of the reach between the dam and the A Vuong tributary revealed that some aquatic vegetation, macro-invertebrates and small fish do survive in shallow pools. (Appendix 6, photo 4).
While the water quality in the reservoir and immediately downstream is much improved from the pre-project condition and some fishing does occur in the reach, there is not sufficient environmental / compensation flow (Appendix 6, photo 5) to make fishing a productive endeavour between the dam and the A Vuong tributary where, prior to the year 2000 local villagers had traditionally fished for many decades.
RECOMMENDATIONS:
Monitoring the Environmental / Compensation flow should be added to the IMA mandate.
Since there is evidence that productive fish habitat continues to exist below the dam, the mandate of fishery specialists involved in evaluating the potential for a reservoir fishery should be expanded to assess the value of increasing the compensation flow from SB4 to improve the potential for fishing in the 5.5 km reach between the dam and power house without a significant impact on dam operations during dry season.
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In any event, given the improved water quality downstream and to demonstrate SB4s commitment to environmental off setting it is suggested that PMB develop a small number of simple, community based, demonstration scale, “Fish Habitat Offset” pools downstream of the dam and above the A Voung.
NB: These small pools can be simply and quickly excavated by enlarging naturally existing pools. The final pools should be shallow around the perimeter and measure from 5 to 10 meters in length, 3 to 6 meters in width and from 1 to 4 meters in depth. Based on previous experience with fish habitat restoration each demonstration "Fishery Off Set Pool" could be designed by an ecologist in a few hours and completely excavated in five hours with a mechanical excavator.
See also section 4.11 - RE: "assessment of how fish and the fishery have been affected by the project".
g) RE: The Recommended Study to Determine Feasibility of Fishery Based Alternative Livelihood for Affected Fishers FINDINGS:
The technical and ecological feasibility study for a reservoir fishery based on stocking or cage culture, recommended in the EIA and EMP, has not been implemented. Instead it appears that a pilot cage culture project will be introduced in 2016.
Prior to 2000 several hundred families fished in the Song Bung both, up and downstream from the present location of the dam.
The SB4 project now regulates water flows and volumes between the upstream end of the reservoir and the power house.
While water quality in these reaches is excellent the aquatic ecology and the fish species have changed dramatically and many of the people that fished the river before dam closure don't have the skills or equipment to fish the reservoir.
Several local fishers told the POE that they prefer river fish for their personal consumption over reservoir fish which they will sell to outsiders in the market.
RECOMMENDATIONS:
Given the improved water quality in the reservoir and downstream, the study of the feasibility, costs, and benefits of a reservoir based fishery or aqua culture recommended in the 2007 EMP should be conducted by qualified and experienced Social and Fishery specialists before implementing any fish stocking or aquaculture program.
The feasibility study should include an assessment of the value of increasing the compensation flow from SB4 to improve the potential for fishing in the 5 km reach of the river between the dam and power house.
h) RE: Mitigating the Residual Impacts of Reservoir Clearing Although the project had progressed into the operational phase by early 2015, residual impacts of reservoir clearing activities prior to flooding were observed during the POE mission of March 2016. FINDINGS: from 2013, 2015 and 2016 Reviews of the Clearing Plan:
There was no specific EMP included in the clearing plan.
The clearing plan provided only a very brief outline of what activities are included in the clearing work, what the mitigation goals were, and simply states that clearing activities will be monitored.
There did not appear to be a staff position or budget for environmental mitigation or monitoring by the clearing contractors.
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The overview of proposed clearing activities and environmental protection goals did not provide sufficient detail on the activities or mitigation and monitoring to assess the contractors methods and capacity to effectively minimize the environmental impacts of clearing the reservoir.
Without effective mitigation and monitoring during clearing it is likely that there will be unnecessary and otherwise avoidable impacts on: water quality, fish, reservoir and power plant operations, aesthetics, and potentially on the sustained multiple use of the reservoir. Only one example of such a possibility is that “digging” to remove large stumps may cause more impacts than if the stumps are left in place.
FINDINGS: from the 2016 Reservoir Reconnaissance:
During the reconnaissance of the reservoir perimeter it was noted that in most areas the extent of the clearing corresponded well with the high water level.
However in a few areas within STNR there is residual evidence of both; excessive and insufficient clearing which has resulted either from inaccurate mapping of the FSL or deviation from the clearing plan.
Excessive clearing has left a few disturbed, erosion prone and unstable areas on the reservoir shore line. (Appendix 6, photo 6).
In a few areas insufficient clearing has resulted in the flooding of standing timber. While this has resulted in a few accidents involving small boats, the flooded trees provide habitat and shelter for fish. (Appendix 6, photo 7).
During the reconnaissance of the reservoir within the flooded area of STNR it was noted that while the water flowing into the reservoir from the small undisturbed tributaries in STNR is crystal clear the water in the flooded area of STNR carries a significant amount of sediment.
This is due to the erosion of the few disturbed slopes within in the STNR and from gold mining along the river upstream of STNR.
While reconnaissance of the reservoir and shore line in the vicinity of each of the flooded village sites revealed no significant issues, numerous examples of gas bubbling from the bottom of the reservoir were noted in the vicinity of Padhi resettlement site. This is undoubtedly Methane an important Green House Gas.
RECOMMENDATIONS: The following recommendations related to mitigation of impacts from clearing should apply to all future clearing activities. Developers and contractors must be required to:
Identify, develop and provide a written commitment to implementing specific environmental mitigation measures during clearing. As a minimum these should include measures to: control fires, avoid erosion and siltation, prevent spills, reduce greenhouse gasses, prevent deforestation beyond reservoir limits and respond to emergencies.
Describe where and how these measures will be implemented and the budget and staffing required.
Develop fund and implement an effective monitoring plan, and tools such as checklists and reporting templates, and monitor the clearing work to ensure the specifications are followed and impacts are minimized.
To minimize impacts due to erosion and landslide on water quality and long term power output of SB4 HPP, SB4- HPC should encourage and support the replanting / maintenance of a 50 meter wide vegetated strip above the high-water line around the reservoir perimeter.
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i) RE: Planting Monitoring and Maintaining Vegetation on Rehabilitated Construction Sites
FINDINGS:
In 2015 and 2016 the POE observed that a significant number of the rehabilitation plantings done by the contractors in the decommissioned construction areas were poorly done and / or were destroyed by cattle (Appendix 6, photo 8).
The rehabilitation planting of sites, roads and slopes does not meet the requirements of the EMP or contractors terms of reference and will neither stabilize the affected areas nor improve the aesthetics of the abandoned construction sites.
While these areas have been “handed over to others” creation and maintenance of tree cover is essential to rehabilitate these areas aesthetically and ensure their long term stability.
This short coming has not been highlighted in the IMA quarterly reports but it remains a potentially significant issue.
The areas in question include but are not limited to: camp #13, the fuel and oil depot, auxiliary area #6, camp #45, and multiple areas of the "Vietnamese workers camp".
In one area on the left bank a local villager has successfully undertaken the replanting and maintenance of a small area with a view to harvesting the trees for pulp in 3 or 4 years.
While this is commendable and demonstrates the feasibility of reforesting the decommissioned construction sites these sites must remain forested permanently.
During the POE debriefing SB4-HPC committed to having these areas replanted. RECOMMENDATIONS:
SB4-HPC should move quickly to ensure the decommissioned construction areas are replanted and the trees maintained to maturity in order to improve the aesthetics and permanently stabilize the affected areas and abandoned construction sites.
The methods and extended maintenance program recommended and managed by DARD and implemented by local villagers should serve as a model for the maintenance of all reforestation programs within the SB4 watershed.
Wire or bamboo cattle exclusion fences must be installed and maintained around all areas which have been re-habilitated and re-vegetated.
j) RE: Planting Monitoring and Maintaining the Conservation Offsets FINDINGS:
See earlier section 4.3.2 RECOMMENDATIONS:
See earlier section 4.3.3
k) RE: Implementing Watershed Protection Measures FINDINGS:
Uncontrolled access to the watershed by hunters, loggers and farmers via the project’s road network continues to accelerate (Appendix 6, photo 9). Past efforts by the PIC during construction to protect the watershed from uncontrolled exploitation and fire including requests for intervention by local police and authorities have failed.
This is a well-documented problem in many other reservoirs around the world and, wherever it occurs, the result has been changes in the predicted timing, volume and reliability of water flows from the watershed to the reservoir.
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As elsewhere, continued uncontrolled and unsustainable exploitation of the SB4 watershed will have increasingly significant impacts on the sustainability of the project and local populations. (Appendix 6, photo 10).
The loss of forest cover due to unsustainable land use practices will inevitably increase the amount runoff and soil erosion. These in turn will reduce the capacity of SB4 to provide power and the capacity of the watershed to sustainably support local livelihoods.
RECOMMENDATIONS:
If SB4 is to provide long term sustainable power, SB4-HPC should encourage and assist DONRE and MONRE to play an increasingly effective role in ensuring the SB4 watershed is managed sustainably during the operations phase.
All HPP projects in Vietnam, including SB4, should include effective and sustainable Integrated Watershed Management as a priority from project inception.
In the best interest of Viet Nam, sustainable Hydro Power should be decreed a National Priority.
SB4-HPC should review Decree no.112 (2008) on integrated watershed management, and work with concerned parties including but not limited to the Communal People’s Committee, District People’s Committee, MONRE and Provincial DONRE to ensure enhanced compliance.
All relevant stakeholders: National and Local Government Agencies, Utilities, Community groups and NGOs, should be encouraged and supported to implement an Integrated Watershed Management program covering SB4 and SB2 watersheds. (See Appendix 5c)).
4.5 – TASK 5: Recommend corrective actions in case mitigation measures are not sufficient and/or
considered to deviate from requirements of ADB’s safeguard policies. All corrective actions recommended to meet the requirements of the EIA, the updated EMP and ADB’s safeguard policies are provided in section 4.4.2 "a" through "k" (immediately above). The most important and urgent of these actions are highlighted in Table ES 1. 4.6 - TASK 6: Assess the adequacy of baseline surveys and analysis, and determine if there is a need
to collect additional baseline data during operations. 4.6.1 - ACTIVITIES:
In 2015 and 2016 there was no detailed work plan for the preparation of a baseline for the operational phase of SB4. Consequently the adequacy of existing baseline information for the operational phase was assessed based on a review of project documents including the EIA, EMP, and an "outline" TOR for the new IMA. 4.6.2 - FINDINGS: a) The TOR for the IMA in 2015 and 2016 was/is silent on the baseline to be used for environmental monitoring during the operational phase. While the environmental baseline developed during the EIA was adequate for assessing impacts and for monitoring during construction, there is insufficient up to date baseline information in the EIA or from the monitoring during construction to quantitatively assess the impact of project operations on physical and biological parameters such as reservoir and downstream water quality, compensation flow, GHG, Mercury levels in water and fish, species diversity and productivity of aquatic invertebrate and fish populations. b) Furthermore there is no up to date baseline against which the impacts of continued uncontrolled watershed exploitation can be measured.
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4.6.3 - RECOMMENDATIONS: a) As soon as possible SB4-HPC should prepare a new Request for Proposals (RFP) requiring prospective IMA(s) to submit a proposed, work plan and schedule to develop an appropriate baseline and implement a comprehensive monitoring program to identify, describe and evaluate the impacts of project operations on: all physical and biological parameters identified in the EIA / EMP including but not limited to reservoir and downstream water quality, GHG, compensation flow, aquatic invertebrates, fish yield and Mercury content, and on the watershed during operations. (See the 2007 EIA, section 5.1.7.3, chapter 7, Annexes 5 & 10). b) Since operations have already begun, appropriate baselines should be established and regular monitoring should be carried out in the potentially affected reaches and in “control” area(s) both upstream and downstream of the dam. Controls could also be established in a comparable river. c) Also see section 4. 7 below. 4.7 - TASK 7: Examine the monitoring program and recommend revisions and / or additional
components as necessary. 4.7.1 - ACTIVITIES: The adequacy of the monitoring program for the operations period was assessed based on a review of documents including the EIA, EMP, monitoring reports prepared by the IMA in 2015 and the "new" TOR for the IMA being engaged for 2016, and discussions with HPC staff. 4.7.2 - FINDINGS and RECOMMENDATIONS: The EMP identified the requirements for monitoring during SB4 operations. The following subsections, "a" through "c": 1) Describe the extent to which the key monitoring requirements have been met during operations to date and 2) Make recommendations to improve the planning and implementation of monitoring during operations in order to meet the requirements of the EMP and ADB Safeguards. a) RE: IMA's TOR, Work Plan and Schedule for Monitoring During Operations. FINDINGS:
The March 2016 POE mission noted that a new IMA is about to be engaged and begin monitoring with the same TOR that was used in 2015.
THE EIA and EMP provide a comprehensive and approved basis for the preparation of the Operational Monitoring program.
In 2015 the POE noted that while the TOR prepared by SB4 management for the IMA included most of the water quality parameters specified in the EIA / EMP, a number of very important parameters also mentioned in the EIA / EMP were not included. (See the 2007 EIA, section 5.1.7.3, chapter 7, Annexes 5 & 10).
The missing parameters / processes included: change in fish species diversity, fish yield and mercury content, rehabilitation of construction areas, compensation flow, overall seasonal change of flows below the power house, GHG, and unsustainable watershed activities.
Furthermore the IMA monitoring reports to date do not include an analysis and interpretation of the data, or recommendations to improve the monitoring and enhance environmental protection.
Consequently the monitoring during operations to date is not adequate.
Since a new IMA is about to be engaged, if this is not remedied quickly the environmental monitoring for 2016 will also be inadequate during the second year of operations.
RECOMMENDATIONS:
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The responsibility for carrying out the operational monitoring requirements of the IEE and EMP must be imposed upon the IMA, not the Utility or the ADB / POE.
As soon as possible SB4-HPC should prepare a new, non-technical Request for Proposals (RFP) requiring prospective IMA(s) to submit a proposal that clearly and specifically confirms their commitment to carry out the monitoring as specified in the EIA / EMP and provides a work plan schedule and details as to: What, Where, When, and How the monitoring will be done.
Any deviation from the requirements in the EIA /EMP must be justified / approved by the Utility and ADB.
The process implemented by SB4-HPC to recruit and manage the IMA must ensure that the Monitoring during operations, complies fully with the specifications in the approved EIA / EMP.
More specifically the new RFP should describe SB4-HPC administrative requirements and indicate that proposals must: identify all required elements of the Operational Monitoring outlined in the EIA and EMP and describe the activities, scope, content, level of detail, schedule, methodology, reporting and cost of their proposed operational monitoring program.
A draft outline for such a simplified RFP (Appendix 5b) was sent to ADB and forwarded to SB4-HPC for their consideration / implementation.
b) RE: Monitoring by ERD (SB4-HPC) during Transition from Construction and beginning of
Operations Phases FINDINGS:
Overall since the POE mission in 2009 the capacity, performance and effectiveness of PMB and ERD has shown continuous improvement in terms of the implementation of environmental mitigation and monitoring measures specified in the EIA and EMP.
During the construction period the PMB's environmental management system (EMS) had become systematic and effective. The PIC, IMA, ERD and contractor developed good working relationships, procedures were well established and information essential for the effective implementation and documentation of the required environmental management mitigation and monitoring was adequately documented and readily available via the PMB's Information Management System (EMS).
However as indicated in section 4.7.2 "a" above it appears that during the transition and early operation periods the ERD has been less proficient in; monitoring and expediting the clean-up and rehabilitation of abandoned construction sites, monitoring the implementation of the conservation offsets, identifying evaluating and selecting the new IMA and validating and managing the design and implementation of the monitoring program for the operational phase of the project.
RECOMMENDATIONS:
As soon as possible SB4-HPC needs to: 1) review the environmental mitigation and monitoring, specifications identified in the EIA and EMP for the operational period and their approach to environmental and information management during the construction phase, and 2) consider and evaluate the shortcomings identified in the transition and early operations phases and 3) make the necessary adjustments / improvement and changes necessary to ensure that the implementation and documentation of mitigation and monitoring during operations becomes as efficient and effective as during the construction period.
During operations monitoring SB4-HPC should adapt, adopt and implement the Non Conformance Reporting (NCR) system used by the Project Implementation Consultant.
During the operational phase of SB4-HPC should prepare and issue NCRs automatically for all environmental issues considered important and urgent by any monitoring agency. ERD should follow up and ensure these urgent NCRs are resolved within one week or as otherwise agreed by the
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stakeholders. Failing this the PMB should issue a letter indicating the financial penalty for continued non-compliance.
SB4-HPC specialists should systematically review and follow up on outstanding issues of non-conformance raised by the new IMA and other monitoring agencies.
4.8 - TASK 8: Examine current institutional capacities of environmental management unit (EMU) of
the executing agency and other responsible agencies; and recommend capacity building measures.
ACTIVITIES: a) Throughout the mission the POE (environment) worked closely with the SB4-HPC management and specialists as well as representatives of outside agencies and consultants involved in implementation of studies and activities related to the SB4 HPP. The availability and capabilities of these individuals and groups were noted and frequent discussions were held with them regarding their performance and challenges; including the need for tools and capacity building to improve environmental management skills related to implementation of the EMP, mitigation and monitoring to comply with safeguards conformance issues. FINDINGS: a) Since 2009 the Senior PMB, EMU / ERD managers and staff have continued to develop the skills and expertise relevant to the management and implementation of the mitigation measures and monitoring programs outlined in the EIA and EMP. b) While the capacity of the SB4-HPC specialists to implement the provisions of the EIA and EMP improved during the construction period, continued improvement in their focus, flexibility and adaptation is required to meet the new challenges of the operations period. c) As in 2015 the POE finds that the environmental managers and specialists could be more effective in their role if they adopted a more rigorous and constructively critical approach in reviewing plans and proposals from outside agencies.
d) Improvement in the effectiveness of Environmental protection officials and guards is essential to protect the reservoir and watershed and ensure the long term sustainability of the power output from SB4. RECOMMENDATIONS: a) SB4-HPC should facilitate and support enhanced training related to enforcement of regulations, patrolling and reporting, boat handling, and provision of an appropriate number of boats and guard posts in remote areas of the watershed. b) SB4-HPC should enhance their internal management review process to provide staff with constructive feedback to improve the structure, content, and level of detail in their internal documentation. c) SB4-HPC should provide training to assist their managers and specialists in preparing constructively critical reviews of all proposals and monitoring reports. This will improve the deliverables and documentation related to the environmental management of SB4 HPP. d) SB4-HPC specialists should prepare a detailed and comprehensive written review of all plans, proposals and reports received from outside agencies and keep these on file.
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e) SB4-HPC specialists should prepare and file written minutes of all meetings, field activities, and important communications regarding environmental mitigation and monitoring. These should, as a minimum, record the names and contact details for personnel involved, the purpose, details, required follow up, and target completion dates. f) SB4-HPC should build on the comments and concepts from capacity building activities and continue to facilitate and optimize teamwork, build the capacity of the HPC management and specialists. This should involve simple and cost effective activities such as informal in-house training sessions, Vietnamese multiple agency workshops, and on the job mentoring by experienced National and International consultants already working on SB4. g) During the operational phase of SB4 STNR forest officers and guards should be provided enhanced training related to enforcement of regulations, patrolling and reporting, as well as boats and guard posts.
h) During operations monitoring SB4-HPC should adapt, adopt and implement the Non Conformance Reporting (NCR) system used by the Project Implementation Consultant. i) During the operational phase of SB4-HPC should prepare and issue NCRs automatically for all environmental issues considered important and urgent by any monitoring agency. ERD should follow up and ensure these urgent NCRs are resolved within one week or as otherwise agreed by the stakeholders. Failing this the PMB should issue a letter indicating the financial penalty for continued non-compliance. j) SB4-HPC specialists should systematically review and follow up on outstanding issues of non-conformance raised by the new IMA and other monitoring agencies. k) See also section 4.9 below: "Conduct training-workshop on environmental management and monitoring during operation of hydropower project".
4.9 - TASK 9: Conduct a training-workshop on environmental management and monitoring during
operation of hydropower projects. ACTIVITIES: a) The Training / Workshop entitled "Sustainable Hydro Power & Watershed Management" was held on the 18 of March 2016. The welcome and opening remarks delivered by the POE highlighted the value of the capacity building provided by the ADB and stressed the need for the participants to make the most of this, the fourth environmental training workshop provided by the ADB POE. Appendix 2b provides a list of the participants in the workshop. b) The POE facilitating and leading the workshop asked the participants to introduce themselves, provided an overview of the three day workshop and discussed the anticipated outcome of the Workshop which was that "Participants (would come to) understand the global and project specific importance of reservoir and watershed management for sustainable power production during HPP operations". c) The workshop comprised a series of presentations by the POE and discussions related specifically to Sustainable Hydro Power and was capped off with a team building exercise that required participants to apply information knowledge and skills acquired during the workshop to the development of a framework for Integrated Watershed Management for the SB4 HPP. d) The framework for the planning and implementation of an Integrated Watershed Management program including SB4 and the upstream project SB2 is provided in Appendix 5c of the present document.
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FINDINGS: a) The enthusiastic participation of the teams and their professional, knowledgeable presentations at the end of each exercise clearly demonstrated that they did indeed "understand the key aspects and the critical importance of Integrated Watershed Management during HPP operations". b) Discussions with individuals, from the PMB, ERD, STNR, and IMA during and following the capacity building workshop indicated that the information presented and the knowledge gained from the workshop was relevant and would be directly applicable in their day to day work on the SB4 project and in the context of future projects. RECOMMENDATIONS: a) Since effective Integrated Watershed Management is critical to sustain the power output of SB4 over the medium and long term (see section 4.4.2.1 of this document) training and implementation of Integrated Watershed Management must be a priority component of all capacity building for ADB sponsored HPP, including SB4. b) Integrated Watershed Management (IWM) requires involvement and commitment from political, project management, technical and grassroots stakeholders. Specific training is required for all participants and specific materials and approaches must be provided as appropriate. c) All relevant stakeholders: National and Local Government Agencies, Utilities, Community groups and NGOs, should be encouraged and supported to implement an Integrated Watershed Management program covering SB4 and SB2 watersheds. d) See also Section 4.4.2.1 k and Appendix 5c of this report. 4.10 - TASK 10: Consult with relevant stakeholders during field visits and record their concerns. 4.10.1 - ACTIVITIES: a) Consultations were held with SB4-HPC engineering and environmental personnel responsible for implementation of the EMP during operations. Interviews were held with fishers in Vinh Village and environmental protection officers in the field. Meetings with officials from STNR and DARD were conducted in their headquarters. 4.10.2 - FINDINGS: a) All concerns, expectations and suggestions voiced during discussions with fishers, environmental protection officers, and officials from STNR and DARD are reflected in the “Findings” sections of this report. 4.10.3 - RECOMMENDATIONS: a) All recommendations related to the concerns and expectations raised during discussions with the above mentioned stakeholders have been reflected in the “Recommendations” sections of this report and highlighted in Table ES 1 in the executive summary.
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4.11 - TASK 11: Assess how fishery has been affected post-inundation and how this is impacting income generation and food security and together with the POE on social, recommend any activities to improve current situation. ACTIVITIES: This assessment of the project's impact on the fishery in the river reaches above and below the SB4 dam is based on information from: the initial EIA, IMA monitoring reports prior to inundation of the reservoir, previous POE missions, and interviews during the 2016 POE mission with fishers on the reservoir and in Vinh village who had traditionally fished these reaches prior to construction of SB4. FINDINGS: Related to the Fishery in the Reservoir Area. a) Prior to the year 2000 when gold dredging began, water quality in the river was good and a productive, sustainable traditional fishery existed in the Song Bung. Every night fishers from Vinh village would walk three hours to fish in river reaches above and below the present location of the SB4 dam. b) The degradation of conditions in the river due to gold dredging was documented during feasibility studies for three downstream Hydro Projects (SB 4a, SB5, SB6) and confirmed during POE interviews with Environmental Protection Officers and local fishers in Vinh village. c) Since dam closure and the creation of the reservoir, gold dredging has stopped and water quality upstream of the dam has improved. On the other hand the rate of flow in the river reach above the dam (in the reservoir) has changed from "fast" to "slow" (Lotic to Lentic) and the physical characteristics, fish habitats and species of fish have changed from "river-like" to "lake-like" (Riverine to Lacustrine). d) The aforementioned change in the common species found in the reach above the dam is typical in new reservoirs and occurs quite rapidly. On dam closure as water levels rise and flows slow in the flooded reach, species living in, and adapted to, "river-like" conditions move to unchanged riverine habitats up and down stream or in tributaries. At the same time, pre-adapted lacustrine species from near-by "lake-like" habitats / water bodies move into the new habitat created in the reservoir. e) Prior to the flooding of the reservoir the Song Bung was sustainably fished by hundreds of families. Now relatively few families own the type of boats and equipment necessary to fish on the reservoir and many of them purchase the fish they consume. f) While those who have the equipment to fish in the reservoir have experienced "good catches" in the first few months following impoundment of the SB4 reservoir, it is very common that an initial relatively short period of high productivity in new reservoirs inevitably declines unless human intervention provides favorable growing conditions for fish. g) Some fishers told the POE they prefer the taste of fish from the faster flowing rivers and tributaries for their personal consumption and sell reservoir caught to outsiders in the market. h) The technical and ecological feasibility study for a reservoir fishery based on stocking or cage culture, recommended in the EIA and EMP, has not been implemented. Instead it appears that a pilot cage culture project will be introduced in 2016. FINDINGS: Related Specifically to Electro Fishing
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a) In March 2016 interviews with fishers operating five fishing boats using traditional fishing methods revealed that, in spite of reportedly good fishing on the reservoir, all 5 of the boats had caught less than half a dozen fish in 4 to 5 hours on the morning of the reconnaissance. (Appendix 6. Photo 11). b) In contrast, a single boat doing electro-fishing encountered the same morning had killed a much larger number of fish in approximately the same amount of time. (Appendix 6. Photo 12). c) Discussions with fishers both on and off the reservoir and with Environmental Protection Officers indicated that commercial Electro-fishing by outsiders is rampant in the reservoir. A single boat equipped with electro-fishing equipment can harvest 100 times as many fish as a single boat using traditional techniques. d) This unsustainable practice is having a significant impact on the ability of local fishers to feed their families. RECOMMENDATIONS: Related to the Fishery in the Reservoir Area. a) The study of the feasibility, costs, and livelihood benefits of a reservoir based fishery recommended in the 2007 EMP should be conducted by qualified and experienced Social and Fishery specialists before implementing any fish stocking or aquaculture program. RECOMMENDATIONS: Related Specifically to Electro Fishing. a) The practice of electro-fishing must be stopped at all costs. b) It is recommended that as soon as possible SB4-HPC write a letter of support to the relevant local authorities pledging the financial and moral support required to condemn and stop this unfair, unacceptable and unsustainable practice. c) Fishing restrictions / limits should be considered d) All boats using the reservoir must be registered e) All fishers operating on the reservoir must be licensed FINDINGS: Related to the Fishery Downstream of the dam a) The EIA of 2000 recommended and provided the TOR for a study to determine an appropriate environmental / compensation flow release from the SB4 dam. This study was not done and instead, an arbitrary, small and constant environmental / compensation flow of approximately 2.6 m3/s is being released from the dam. b) This small flow sustains minimal aquatic vegetation, a variety of macro-invertebrates and small fish in the remaining pools of the relatively dry river bed between the dam and the A Vuong tributary. c) The water quality downstream of the dam is much improved from the pre-project conditions and some fishers continue to fish in the shallow pools that remain in this reach. d) Based on observations by the POE and interviews with fishers who have extensive personal knowledge of fishing practices on this reach, the compensation flow is not sufficient to make fishing a productive endeavor between the dam and the A Vuong tributary where villagers had fished sustainably for decades.
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RECOMMENDATIONS: Related to the Fishery Downstream of the dam a) The fisheries feasibility study recommended in the EIA and EMP should include an assessment of the net value of increasing the compensation flow from SB4 to improve the potential for fishing between the dam and power house. b) Given the improved water quality downstream of the dam it is recommended that the SB4 PMB develop a small number of, simple community based, demonstration scale “Fish Habitat Offset” pools downstream of the dam and above the A Vuong. c) These demonstration pools can be simply and quickly excavated by enlarging naturally existing pools. The final pools should be shallow around the perimeter and measure from 5 to 10 meters in length, 3 to 6 meters in width and from 1 to 4 meters in depth. d) Based on previous experience with fish habitat restoration each demonstration "Fishery Off Set Pool" could be designed by an ecologist in a few hours and completely excavated in five hours with a mechanical excavator.
4.12 - TASK 12: Develop an Exit Strategy report as an addendum of the POE report delineating steps to ensure SB4HPMB and ADB’s cessation of their direct involvement under the EMP yet ensuring sustainability of the achieved EMP outcomes. a) NB: In view of the scope content and level of detail of the POE (environmental) report this task has been waived
by the ADB.
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APPENDIX 1
DETAILED TOR for the 2016 POE (environment) MISSION
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TOR for the 2016 POE (Environment) MISSION
Contract: 123072-s86731
Project : TA-7861 VIE: Implementation and Monitoring of Song Bung 4 Hydropower Project
Resettlement and Ethnic Minority Development Plan - 01 Panel of Expert -
Environment Specialist (45108-001)
Expertise: Panel of Expert - Environment Specialist
Source: International
Objective and Purpose of the Assignment:
ADB approved Loan 2429-VIE on 26 June 2008 for $196 million and it became effective on 16 January 2009.
The Project consists of the construction of a 156-megawatt (MW) hydropower plant on Song Bung River in
Vu Gia-Thu Bon River basin, and 116-meter (m) high roller compacted concrete (RCC) dam on the same river
with a crest length of 345 m. The dam will form a reservoir with a surface area of 15.8 square kilometers
(km2) at full supply level of 222.5 m above sea level. Water from the reservoir will be conveyed through a
3.2 kilometer (km) tunnel to the power station, and released along a short tailrace canal to the Song Bung
about 5 km downstream of the dam. The project milestones are:
Start of construction: 03 September 2010
Closure of river and diversion of flows: 16 January 2012
Start of impoundment of reservoir: September 2014
Commissioning of Generating Unit #1: October 2014
Commissioning of Generating Unit #2: November 2014
The P oje t is lo ated i Na Gia g dist i t o de i g the Lao People’s De o ati Repu li of Qua g Na Province in central Viet Nam and is predominantly inhabited by indigenous people belonging to the Co Tu
ethnic minority. About 253 households mainly Co Tu households in
Zuoih commune of Nam Giang district are to be resettled. The Project is also located near the Song Thanh
Nature Reserve, about 129 hectares (ha) of which will be inundated.
This project was classified as Category A for both environment and resettlement which required a full
environmental impact assessment (EIA) report with an Environmental Management Plan (EMP) as well as
the appointment of a Panel of Experts (POE) to verify the monitoring reports and EMP implementation.
An independent monitoring agency (IMA) Social Consult with the following mandates:
i) Monitor the implementation of mitigating measures of the construction
ii) Carry out periodic measurements: air samples (3), noise samples (5), surface water samples (2),
domestic water samples (3) and wastewater samples (3).
iii) Monitor changes in forest, terrestrial ecosystem and aquatic ecosystem
iv) Monitor waste treatment and disposal management
v) Conduct consultation meetings with stakeholders on environment issues related to the project
vi) Identify potential environmental problems and record responses of people about environmental
issues around project site
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Scope of Work:
The assignment will review the status of the EMP implementation of Song Bung 4 Hydropower Project
during late construction stage and the start of operation after impoundment, specifically on the biodiversity
and natural resource management of the environmental safeguards preparation and compliance: (i)
mitigation measures for environmental impacts especially on reforestation and vegetation/biomass
clearance; (ii) capacity of the implementing agencies for environmental management; and (iii) other aspects
relevant to compliance with ADB and GOV
environmental safeguard policies.
Detailed Tasks and/or Expected Output:
The consultant shall ensure that all works and outputs are fully compliant with relevant ADB and
Government policies and guidelines. The consultant's work shall include, but not limited to, the following:
(i) Review relevant environmental documents of the Song Bung 4 Hydropower Project such as EIA
report with EMP, reforestation impacts and offset measures, reservoir clearance plan and monitoring
reports;
(ii) Conduct site visits around the dam site, reservoir, watershed areas upstream and downstream
including the identified reforestation areas (protected forest areas and special use forest areas) within the
Song Thanh Nature Reserve (STNR) to assess the adequacy and performance of SB4 HPMB and the
contractors in terms of EMP implementation post-construction and operations;
(iii) Review the SB4HPMB reforestation plans and its contractors on the biodiversity offset areas
including planting the proper native plant species, the number and density of species, budget, staff, and
monitoring measures to ensure growth and maintenance;
(iv) Determine if the EMP provisions for mitigation and monitoring during operations are being
implemented properly by all concerned such as environmental flow;
(v) Recommend corrective actions in case mitigation measures are not sufficient and/or considered to
deviate f o e ui e e ts of ADB’s safegua d poli ies; (vi) Assess the adequacy of baseline surveys and analysis, and determine if there is a need to collect
additional baseline data during operations;
(vii) Examine the monitoring program and recommend revisions and/or additional components as
necessary;
(viii) Examine current institutional capacities of environmental management unit (EMU) of the executing
agency and other responsible agencies; and recommend capacity building measures;
(ix) Conduct a training-workshop on environmental management and monitoring during operation of
hydropower project;
(x) Consult with relevant stakeholders during field visits and record their concerns;
(xi) Assess how fishery has been affected post-inundation and how this is impacting income generation
and food security and together with the POE on social, recommend any activities to improve current
situation; and
(xii) Finalize the Exit Strategy report as an addendum of the POE report delineating steps to ensure
SB4HPMB a d ADB’s essatio of thei di e t i volve e t u de the EMP yet e su i g sustai a ility of the achieved EMP outcomes. NB: In view of the scope content and level of detail of the POE (environmental) report
this task has been waived by the ADB.
Minimum Qualification Requirements:
The Consultant should have PhD in the environmental or biological sciences or natural resource
management, and at least 15-20 years experience in conservation, protected areas management or related
41
areas especially in developing countries in Asia. It is preferable for the Consultant to have knowledge of
environment policies and biodiversity regulations, regulatory framework, legislation on environmental
impact assessments and its cross-sectoral application as a decision making tool, especially related to
environmental assessment of projects. Specific experience in reservoir-type hydropower projects is required
with safeguards or regulatory exposure. An excellent verbal and written communications skill in English and
in writing of papers, briefs, and other independent reports is required. Strong interpersonal skills and ability
to work effectively with internal/external partners and promote collaboration in a multi-cultural
environment is needed.
Minimum General Experience: 15 Years
Minimum Specific Experience (relevant to assignment): 10 Years
Regional/Country Experience: Required
42
APPENDIX 2a
2016 Mission Schedule and Activities - POE (environment)
43
SONG BUNG 4 / POE - ENVIRONMENTAL MISSION
March 04 to 23 2016
PROPOSED ACTIVITIES AND SCHEDULE
NB: Saturday*, Sunday** NB: Critical field tasks *** March 04. - Depart Vancouver / Travel March 05* & 06**
- Travel - Environmental POE member arrives in Danang. - Overnight in Danang
March 07. - Initial meetings with PMB and Key SB4 personnel. - Review & Discuss mission details: Activities, Meetings and Workshop. - Confirmation of documents requested and those to be acquired during mission. - Initial review of available background documents.
March 08. - Working meetings with selected Key SB4 staff / consultants / GoV agency monitors. - Background document review. - Detailed planning & arrangements for field reconnaissance, meetings and workshop. - Possible meeting with Independent Monitoring Agency (IMA).
March 09, 10, 11, 12*, 13** (NB: 5 days minimum required for Field Tasks. - Travel to project area. - Meet resident & / or deputy engineer.
- Interview PIC and / or Contractor’s environmental monitor. - Conduct reconnaissance surveys by truck and boat *** of: 1) restored key construction sites & roads, 2) sites
of flooded villages, 3) new resettlements, 4) perimeter of reservoir, 5) important affected tributaries, 6) reforested protected & special use, compensation, & biodiversity offset areas, 7) flooded area of STNR.
- Interview STNR and DARD staff in the field***. - Possible interview with IMA field staff. - Interview past and present fishers***at one or more locations.
- Return to Danang. March 14, 15,16 &17 - Post-field / pre-workshop debriefing with PMB - Identify information gaps. - Meetings with Key SB4 staff / consultants / GOV monitors. - Possible meeting with IMA*** - Finalize / print Workshop presentations confirm venue & arrangements March 18.
- Workshop on Sustainable Hydro Power & Watershed Management during HPP operations. March 19* & 20**.
- Begin Debriefing, and POE reports. March 21.
- SB4 debriefing. - Final meetings with Key SB4 staff. - Possible meeting with IMA***. - Travel to HCMC - Overnight in HCMC
March 22. - Depart Vietnam / Travel. March 23. -Travel
44
APPENDIX 2b
List of Participants in the Sustainable HPP & Watershed Management Workshop
45
46
APPENDIX 3
Information / Items & Meetings Requested Prior to and During the 2016 POE Mission
47
Request for Documents / Items and Meetings to be arranged by PMB
for the
March 2016 ADB POE Mission
1. EIA report and updated EMP,
2. Plans for Reservoir Clearing, Reforestation & Offset Planting, monitoring and maintenance.
3. Monitoring reports prepared during reservoir clearing and for the Reforestation and Off-set plantations.
4. Monitoring documents prepared by SB4 EMU, Contractors, PIC environmental monitor, and the IMA since the
last POE mission in 2015.
5. A list and title of monitoring documents filed in the PMB Environmental Information Management System
since dam closure.
6. An updated organization chart illustrating the reporting relationships among all institutions / agencies / units
and departments having a role in Environmental and Social Management, mitigation and monitoring during
the "Operational Phase" of the project.
7. The Organization Chart and List of Duties of the "Management and Technical units" responsible for the
management and operation of the SB4 HPP during the "Operational Phase".
8. A list, summary description, and location map for construction / rehabilitation / enhancement / monitoring
and other environmentally related activities carried out since the last POE mission in 2015.
9. A description of actions taken on items 2 through 11 in Table ES1 of the 06/2015 POE report.
10. Meetings with the EMU, IMA, STNR, DARD, PIC and local individuals fishing upstream and downstream of the
dam site before and after dam closure (as per mission schedule).
11. Support by an EMU staff member during the mission.
12. A boat, boatman and fuel for one day reservoir reconnaissance.
13. A map showing principal project infrastructures, associated work areas, camps, roads, transmission lines,
borrow areas and reservoir high and low water levels.
14. A map of the SB4 watershed covering the entire area of potential direct and indirect project impacts,
identifying reservoir high and low water levels, flooded villages, the STNR nature reserve, resettlement areas,
and reforestation / plantation areas.
15. A description and location map of existing water use / demand / off-take within the reservoir area and the
river as far as 20 km downstream.
16. All SB4 Annual Environmental Implementation Plans since the beginning of the project.
17. Environmentally relevant comments from ADB review missions in 2014 and 2015.
18. All non-conformance documentation (NCRs) since the 2015 POE mission.
19. Detailed Scope and Plans for IMA monitoring during the Operations Phase including: approach,
methodologies, schedule, sampling locations and performance indicators against which the IMA will monitor
changes in key environmental parameters and the effectiveness of mitigation / enhancement measures.
20. Documents detailing the Structure and Function of the Project Environmental Management System; including
but not limited to, the Environmental Information Management System.
21. Environmentally relevant sections of project Operational and Maintenance documents (Manuals) related to
the project (i.e. management of water release and downstream flow).
22. Emergency response manual for the operational period.
23. Environmental monitoring equipment used by the IMA / PMB.
48
ADDITIONAL DOCUMENTS REQUESTED DURING THE 2016 POE MISSION
Needed to comply with item i of the POE TOR
A revised version of the original list of documents requested for the POE mission. Under each
of the 20 items in the list please indicate the full Titles of the documents provided during and
following the POE mission. .
Please provide a "W5" style summary of all documents available only in Vietnamese with the
Vietnamese original attached.
Needed to comply with item iv of the POE TOR)
As requested during the kickoff meeting, a "W5" style summary of the actions taken in
response to each of the recommendations listed in TABLE ES1 of the last POE mission report.
Needed to comply with item iv , vi, vii, viii of the POE TOR)
SB4-HPC is requested to provide: 1) An explanation of the process used to identify and
hire the new IMA, 2) a copy of their corporate brochure and / or a summary of their
qualifications and experience, 3) a copy of the IMA proposal and 4) their detailed work
plan for monitoring during operations.
If this documentation / information is not available in English please provide a good
translation along with the Vietnamese version of the requested information.
Needed to comply with item i, iii, iv of the POE TOR)
GOV, IMA, DARD, STNR or other on monitoring of the COS.
If these are not available in English please provide a good translation along with the
Vietnamese version.
49
APPENDIX 4 a
Conservation Off Set Plantation (COS #284) Bordering on the SB4 Reservoir
50
51
APPENDIX 4b
Conservation Off Set Plantation ("COS #304") Bordering on the Song Thanh
52
53
APPENDIX 5a
List of Existing Native Trees in the COS
(pers. com.: Mr. A. Tuan, Vice Head of STNR)
54
LIST OF EXISTING NATIVE TREES IN THE COS (PERS. COM.: MR. A. TUAN, VICE HEAD OF STNR)
# VIETNAMESE NAME LATIN NAME
1. Cho Chi: Parashorea Stellata Kury
2. Sang Dao Pejgeum Arboreum
3. Son Huyet: Melanorrhoea Lauifera Pierre
4. Dau Rai: Diplerocarpus Alatus
5. Lim Xet: Peltophorum Torikinensis
6. Uoi: Sterculla Lychnophora
7. Tram trang Canarium Albumr
8. Doi Huong: Tsoongiodendron Odurum
9. Go Do Afzelia Xylocarpa
10. Nghien: Burretiodendron Hsieuma
11. Huynh Dan: Cupressus Funebris
55
APPENDIX 5b
Draft Outline of a Simplified RFP to Recruit an IMA
56
Request for Proposals to Conduct Environmental Monitoring and Reporting
During the Operational Phase of the SB4 HPP.
(Simplified Draft)
Dear Sir/ Md.
SB4 HPC requires the services of an experienced Vietnam based environmental consultant (the IMA / Independent
Monitoring Agency) to conduct the Environmental Monitoring and Reporting during the Operational phase of the SB4
HPP.
The description of the SB4 HPP project and the requirements for the Environmental Monitoring during the Operational
phase of the project are detailed in the EIA and EMP prepared for the project.
Copies of these documents will be essential to the preparation of a qualifying proposal and are available on request
from SB4 HPC.
The following paragraphs 1 through 8 outline the format, content and requirements for submitting a qualifying
proposal.
1) Identifying Information on the Firm:
Consulting Firm:
Contact Person:
Contact Address, Telephone, e-Mail:
2) Introduction:
Summary of the proposal and any explanations of deviations from the required scope and detail specified in the
EIA / EMP
3) The Environmental Consultants Relevant Experience and Capacity:
3.1) Organization of the consultants management and implementation team
3.2) Information on Key members of the environmental/social assessment team
- Name and role
- Short paragraph summarizing only relevant experience
- Full or part time employee of the firm
- Number of days devoted to the project
- CVs in similar format
4) Relevant projects carried out by the firm / this team:
4.1) Identify and describe up to ten similar / relevant projects done by the firm.
- For each project indicate: Name and year of project, name of client, and the name, contact
number and email address of a reference for the project.
5) Technical & Cost Proposal:
5.1) This section of the proposal must identify and describe all tasks and sub tasks of the monitoring work and
reporting.
5.2) Most importantly this section must describe the location, frequency and methodologies of sampling and
measurement that will be implemented to identify and evaluate changes in the environmental characteristics /
parameters specified in the EIA / EMP from pre-project conditions and during operations.
5.3) This section will provide a schedule identifying the start, end and duration of the tasks and sub tasks and
the dates of draft and final deliverables. The cost of fees and expenses and total cost of the annual monitoring
program will also be provided.
5.4) This section of the proposal must include at least four (4) XL tables as described below and as illustrated in the
attachment to this RFP.
57
TABLE #1- will identify all tasks, sub tasks and activities included in the environmental monitoring and reporting.
TABLE #2 - will have the same phases, tasks, sub tasks and activities listed in the left column but will provide
the schedule for each task, sub task and activity and indicate dates for both draft and final deliverables.
TABLE #3 - will have the same phases, tasks, sub tasks and activities listed in the left column but will identify
the expenditures and anticipated costs associated with each.
TABLE #4 - will provide a summary of the cost of fees and expenses for each phase, task and sub task as well as
total annual cost of the operational monitoring work.
NB1 : Examples of these four (4) tables are attached.
NB2 : The XL Formula function is to be used in making the spreadsheets and
calculations.
6) All proposals must follow the preceding format.
7) It is the responsibility of the consultant to ensure their proposal is fully compliant with the scope and objectives of
the operational monitoring requirements detailed in the EIA and EMP prepared for the SB4 HPP. Non-compliant
proposals may be rejected.
8) Three (3) hard copies and one (electronic copy) of the consultants proposal must be submitted to SB4 HPC before
5pm on ..date …
9) SB4 HPC will review all proposals and determine the extent to which they comply with requirements for monitoring
during the operational period as specified in the EIA and EMP. SB4 HPC will rank the proposals according their
compliance with the requirements and invite the first ranked consultant to negotiate a contract for the work. In the
event these negotiations are not successful SB4 HPC reserves the right to contact and negotiate with another bidder.
SIGNED FOR SB4 HPC
____________________ ________________
Signature Date
58
TABLES REQUIRED IN THE PROPOSAL
TASKS, METHODOLOGY AND OUTPUTS
# Tasks / Activities Methodology Outputs
1 Insert text Insert text Insert text
2 Insert text Insert text Insert text
XX Add more rows Add more rows Add more rows
TASK SCHEDULE
# Activities &
Tasks
Month 1 Month 2 Month 3
1 2 3 4 1 2 3 4 1 2 3 4
1 Insert same text
2 Insert same text
xx Add rows as necessary
FEES
No
. Task / Activity
Personnel Name No. of Days /
person / Task
Rate/Day Total Cost
1 Insert same
text
2 Insert same
text
3 Add rows as
needed
Total Fees
EXPENSES
No
.
Task /
Activity
Supplies Transportation Communications Others Total
1.
Insert same
text
2.
Insert same
text
3.
Add rows as
needed
Total Expenses
TOTAL OF ALL OPERATIONAL MONITORING COSTS
59
APPENDIX 5c
Background & Framework for Planning & Implementing an Integrated
Watershed Management Program for SB4 & SB2
60
Appendix 5c
BACKGROUND & FRAMEWORK FOR PLANNING & IMPLEMENTING AN INTEGRATED
WATERSHED MANAGEMENT (IWM) PROGRAM FOR SB4 & SB2
This Appendix to the POE (environment) report of 2016 provides:
1) An introduction to the urgent need for IWM program during the operational phase of the SB4 and SB2
Hydro Power Projects.
2) A brief description of IWM
3) Selected descriptions and illustrations of key terms and processes vital to IWM.
4) The framework for the development of an IWM program for SB4 and SB2 Hydro Power Projects that was
developed by participants in the ADB / SB4-HPC workshop held in Danang in March 2016.
NB: The valuable contribution of all participants is here-by gratefully acknowledged and their names are
provided in Appendix 2b of the POE (environment) report of 2016.
1) INTRODUCTION
This March (2016) the POE noted that, as predicted, uncontrolled access to the SB4 watershed via the
project’s road network and by boat on the reservoir is accelerating.
Continued unsustainable resource exploitation within the SB4 watershed will increasingly affect the timing
and volume of runoff and ground water inflow to the reservoir and reduce the capacity of the SB4 to provide
power and negatively affect the sustainability of livelihoods in communities within the watershed.
While ADB and SB4 PMB have done an excellent job of environmental management during construction; this
important task must be taken on by others such as DONRE and DARD during the Operational Phase.
As concluded by all present during the March 2016 POE / SB4HPC Workshop on Sustainable HPP; if the
SB4 HPP is to become a truly “Sustainable Development” it is essential that an Integrated Watershed
Management program for the SB4 and upstream SB2 watersheds be developed and implemented in the
coming months and years.
2) DESCRIPTION OF IWM
Water and forests are critical to economic, environmental and social sustainablilty. Human activities,
including Hydro Power Development, affect forest cover and the timing and volume of water availability, and
thereby have impacts on economic, environmental and social sustainablilty.
The best way to manage and protect water and forest resources is on a watershed basis using integrated
watershed management. This approach allows us to address multiple issues and objectives; and enables us to
plan within a very complex and uncertain environment.
Integrated Watershed Management (IWM) has many benefits: predictable water supply for HPP and
downstream users, improved water quality, erosion management, resilient biodiversity and habitats,
sustainable livelihoods, Improved quality of life and, greater ability for the watershed to continue to provide
valuable "ecosystem services" in spite of climate change.
Through IWM, communities cooperate to identify the activities most negatively affecting the watershed’s resources and processes. IWM provides the framework and tools to identify the strategies and develop the
plans to address the key watershed problems. IWM helps focus on priorities and will lead to science-based
decisions and actions that ensure long term economic, environmental and social sustainablilty.
3) SELECTED DESCRIPTIONS & ILLUSTRATION OF KEY TERMS & PROCESSES VITAL TO IWM.
3.1) DEFINITION OF A WATERSHED
61
A watershed is any surface from which runoff resulting from rainfall is collected and drained through a
common point. It may be a few hectares or hundreds of hectares in size.
A watershed includes physical, biological and socio economic features which should all be considered in
any watershed management program
3.2) DEFINITION OF INTEGRATED WATERSHED MANAGEMENT (IMW)
The process of planning & carrying out activities involving the manipulation of natural, agricultural &
human resources within a watershed to provide the outcomes needed by the watershed community.
3.3) OBJECTIVES OF IWM
Protect, conserve & improve the land for more sustainable production.
Improve the quality of water originating in the watershed.
Stop soil erosion &reduce the effect of sediment in the watershed.
Rehabilitate deteriorating lands.
Moderate flood peaks in downstream areas.
Increase infiltration of rainwater.
Improve & increase production of timber, fodder & wild life.
Enhance the ground water recharge.
Reduce the occurrence of floods and the resultant damage by adopting strategies for flood
management.
Reduce occurrence of water borne disease by improving vegetation and waste disposal facilities.
62
3.4) SOCIAL ENVIRONMENTAL ECONOMIC & SCIENTIFIC ASPECTS OF IWM
63
3.5) FOCUS AND RESULTS OF THE IWM PROCESS
3.6) KEYS TO SUCCESSFUL “INTEGRATED WATERSHED MANAGEMENT”
Include relevant Agencies, Organizations, & local stakeholders
Make use of available information and expertise
Involve participants in the learning process
Incorporate all perspectives
Define a common goal
Focus on action & change
Deal with power and conflict consciously
Base all agreements on cooperation
Encourage top down and bottom up strategies
Incorporate principles of AEM (plan-act-monitor-improve)
64
3.7) HOW IWM IS IMPLEMENTED
65
3.8) KEY PARTICIPANTS IN THE IWM PROCESS
3.8) PARTICIPANTS NEEDED FOR EFFECTIVE IWM
a) IWM COMMISSION MEMBERS: (EMPOWERED AND MOTIVATED)
• CHAIRPERSON
• GOVERNMENT REPRESENTATIVES - Local, Regional & Higher
• AGENCIES - Social, Health, Environment, Water, Lands, Forests, Fish, Wildlife, Other
• UTILITY MANAGEMENT - Electrical, Water, Other.
• LOCAL STAKEHOLDERS - Village leaders, Land owners, ETC.
• EXPERTS - As needed.
• ADMINISTRATION – Facilitator / Secretary
b) IMPLEMENTATION TEAM MEMBERS: (CAPABLE MOTIVATED & SUPPORTED)
• Team leader / Trainer
• Agriculture sp.
• Soils sp.
• Hydrology sp.
• Civil engineer sp.
• Forest management sp.
• Health sp.
• Animal science sp.
4) FRAMEWORK FOR DEVELOPMENT OF AN IWM PROCESS FOR SB4 AND SB2 HYDRO POWER
PROJECTS
The Framework for development of an IWM program for SB4 & SB2 HPP was developed by participants in
the ADB / SB4-HPC workshop on Sustainable Hydro Power & Watershed Management held in Danang, in
March 2016. The participants' enthusiasm, hard work and valuable contribution are here-by gratefully
acknowledged and their names are provided in Appendix 2b of the POE (environment) report of 2016.
66
At this stage the Framework for development of the IWM for SB4 & SB2 HPP consists of the following 5
tables: 1) the IWM commission for sb2 & sb4, 2) IWM implementation team, 3) IWM priority policies &
actions, 4) Potential funding for policies / actions, 5) List of relevant NGOs & ongoing projects.
The next step in developing and implementing an IWM program for SB4 & SB2 HPP is "Urgent and
Important" to the long term sustainability of HPP power generation and livelihoods of watershed residents.
As shown in the following tables the next step will require the support and commitment of others including
but not limited to: SB4-HPC and SB2 management, DONRE, MONRE, DARD, Nam Giang (NG) People's
Committee, and ideally ADB.
Table 1
SB4 /SB2 INTEGRATED WATERSHED MANAGEMENT (IWM)
MEMBERS OF THE INTEGRATED WATERSHED MANAGEMENT (IWM) COMMISSION
No Agency/Organization Representative/Member
Title Relevance / Role
1
Nam Giang (NG)
People's
Committee
Ms. Pham Thi Nhu -
Vice Chair
Management of Agriculture and Forestry
in NG district
2 SB2 HPMB Mr. Vuong Thanh Chung
Director
Management of relevant
departments in SB2-HPMB
3 SB4 HPMB
(now SB4-HPC)
Mr. Nguyen Son
Director
Management of relevant departments of
SB4-HPC who can make decision
4 NG DARD Mr. Nguyen Dang Chuong
Head of DARD
Identification and selection of team
members to implement the Agriculture /
Forestry / Fishery and related activities
5 NG DONRE
Mr. Nguyen Cong Binh
Vice Head (will be the Head in
near future)
All aspects of policy / strategy / planning
for natural resource management in Nam
Giang district
6
NG AFES (Agriculture
and Forestry Extension
Station)
Mr. Ton That Nhat
Vice head
Design and manage programs and assign
experts to implement extension activities
7 NG Vet station Mr. Le Dac Phu Design and manage programs related to
controling animal disease and epidemics
8 NG Forest Protection
Unit
Mr. Dinh Anh Tuan
Head
Overall management of forest and
reforestation in NG district
9 South Bung River
Protection Forest Unit
Mr. Do Tuan
Head
Overall management of forest &
reforestation for South Bung River
10 Song Thanh Natural
Reserve
Mr. Le Duc Tuan
Head
Overall management of forest and
reforestation for Thanh River
67
11
All Heads of related
Communal People's
Committees
Ta Poo commune
Zuoih commune
Cha Val commune
La De commune
Ta E commune
Cha Chun commune
Dac Pring commune
Dac Pre commune
Monitoring/Following up/ Assigning the
communal staff to implement activities
at the commune and village level
12 NG District Heath
Station Mr. Cho Rum Vom
Manage and implement the programs for
health improvement
13 Consultants As Needed As Needed
Table 2
SB4 /SB2 INTEGRATED WATERSHED MANAGEMENT (IWM) THE
IMPLEMENTATION TEAM
No Specialist Organization Role/Task
1 Agriculture DARD
2 Representatives from
all affected villages Village Communities
3 Soils DONRE + DARD
4 Hydrology SBHPC + SB2HPMB
5 Civil Engineer SBHPC + SB2HPMB
6 Forest manager
NG Forest Protection Unit
South Bung River Protection
Forest Unit
7 Fishery specialist DARD
8 Health specialist NG Health station
9 Animal / science / Vet NG Vet station
Table 3
SB4 /SB2 INTEGRATED WATERSHED MANAGEMENT (IWM) PRIORITY POLICIES +
ACTIONS
No Policies / Actions Expertise / Resources required on
Implementation Team Details
1 Develop IWM plan Full IWM Commission
2 Reforestation DARD + Villagers
3
Capacity building for
villagers / communal
staff in SB2&SB4
watersheds
DONRE+ DARD + South Bung River
Protection Forest Unit
4
Support Livelihood
program for people living
in watersheds
DARD
Agriculture &Forestry Extension Station
(AFES)
Vet Station
68
5
Increase awareness of
people on sustainable
practices in the
SB2&SB4 watersheds
DONRE+ DARD + South Bung River
Protection Forest Unit
6
Develop mechanisms
and implement to
prevent by fishing
electrical impulses in the
reservoir
NG DPC + NG Forest Protection
Unit + South Bung River Protection Forest
Unit + All related CPCs + representative of
villages
7 Support to develop
reservoir fisheries DARD + Villagers
8 Monitoring/Evaluation Commission & implementation team &
Consultants
Table 4
SB4 /SB2 INTEGRATED WATERSHED MANAGEMENT (IWM) NGOs &
PROJECTS ACTIVE IN THE SB2 & SB4 WATERSHEDS
No NGOs Projects
1 World Vision (WV)
Area Development Proiect (ADP) in Nam Giang District
( 1st stage 2014-2017: for Ca Dy, Thanh My, Ta Poo, and Cha Val
commune)s
2 ADB Protecting the biological corridors
in Mekong River subregion
3
DEUTSCHE
ZUSAMMENARBEIT -
GERMANY
Protection and Inclusive Management
of Forest Ecosystems in Quang Nam, Kon Tum, and Gia Lai provice (KFW
10 Project)
4
Company for small and
medium hydropower in
central of Viet Nam (Loan
by ADB)
Dac Pring Hydropower Project
Table 5
SB4 /SB2 INTEGRATED WATERSHED MANAGEMENT (IWM)
POTENTIAL SOURCES OF FUNDING
No Policy / Action Potential Source of
Funding Budget for 1 year Pilot
1 Develop IWM plan ADB TO BE DEVELOPED
2 Site Rehabilitation &
reforestation SB2 + SB4 + DARD TO BE DEVELOPED
3
Capacity building for
the villagers /
communal staff in
SB2&SB4 watersheds
ADB TO BE DEVELOPED
69
4
Support Livelihood
program for People
whose live in SB2&SB4
watersheds
ADB TO BE DEVELOPED
5
Increase the
awareness of people
on sustainable
development in
SB2&SB4 watersheds
DONRE + NG Forest
Protection
Unit + South Bung River
Protection Forest Unit +
ADB
TO BE DEVELOPED
6
Develop and
implement measures
to prevent electro
fishing in the reservoir
SB4-HPC + DONRE + NG &
South Bung River
Protection Forest Units
TO BE DEVELOPED
7
Support to develop
reservoir and
downstream fisheries
ADB TO BE DEVELOPED
8 Implementation
Monitoring/Evaluation ADB TO BE DEVELOPED
70
APPENDIX 6
MISSION PHOTOS
71
Photo 1: March 2015 trees planted in COS area bordering
reservoir were choked by weeds
Photo 2: March 2016 maintenance in 2015 has greatly
improved conditions in the COS.
Photo 3: With appropriate maintenance the trees in the COS
have reached an average height of 0.75 to 1.5 meters.
Photo 4: Below the dam some aquatic vegetation,
invertebrates & small fish survive in shallow pools.
72
Photo 5: Compensation flow is not sufficient to make fishing a
productive endeavour below the dam.
Photo 6: In some areas excessive clearing has left erosion
prone, unstable areas on the reservoir shore.
Photo 7: In some areas insufficient clearing has resulted in
flooding of forest contributing to accidents involving small
boats.
Photo 8: Poor reclamation planting & maintenance
procedures have reduced the survival of trees intended to
rehabilitate construction areas.
73
Photo 9: Uncontrolled access to the watershed by hunters,
loggers a d far ers ia the proje t’s road et ork o ti ues to accelerate.
Photo 10: Uncontrolled exploitation in the watershed
threatens the long term sustainability of local livelihoods and
current levels of power production by SB4.
Photo 11: These Fishers using traditional fishing methods had
caught less than half a dozen fish in 4 to 5 hours.
Photo 12: This single boat equipped for electro-fishing killed
many more fish in the same time.