Environmental Assessment Report


Organizational Structure of the Environmental Protection Department



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2.7.2 Organizational Structure of the Environmental Protection Department

According to Decree # 295 of May 25, 2000 and Decree # 59 as of February 24, 2001 of the Government of the Kyrgyz Republic the following executive and specially authorized state bodies are responsible for enforcement of constitutional principles and legislative acts in the domains of ecology and environmental protection:




  1. State Agency for Environmental Protection and Forestry (SAEPF);

  2. State Forestry Department;

  3. Ministry of Health (MoH);

  4. Ministry of Internal Affairs

  5. Ministry of Agriculture, Water and Processing Industry (MAWPI);

  6. State Geology and Mineral Resources Agency under the Government of the Kyrgyz Republic;

  7. State Real Estate Registration Agency under the Government of the Kyrgyz Republic;

In line with the decree, Bodies of Public Prosecution, the Ministry of National Security (MNS) of the Kyrgyz Republic, the Interior Ministry of the Kyrgyz Republic, and the State Customs Inspectorate under the Ministry of Finance (MoF) of the Kyrgyz Republic shall assist SAEPF bodies and other specially authorized bodies on environmental protection in implementing measures aimed at protection and rational use of natural resources, and provision of environmental safety.





  1. METHODOLOGY

This environmental review was prepared in conformance with World Bank OP 4.01 to meet Bank requirements for Environmental Assessment of Financial Intermediary lending operations. In preparing this document a comprehensive review of current environmental legislation of the Kyrgyz Republic was carried out including contemporary laws, decrees, and regulatory guidelines. Interviews were conducted with appropriate national agencies responsible for enforcement of environmental regulations, monitoring of environmental quality and promulgation of best practice guidelines for environmental management. Interviews were conducted with SAEPF staff in the Department of Environmental Protection, and with SAEPF staff at at oblast level in Osh and Jalalabad and at raion level in Jalalabad Oblast. Field visits were made to several Aiyl okmotus where the team met with community representatives and local officials to discuss the range of activities and sub-projects that were expected to be implemented under the project. During the field visits the team was able to learn about operational procedures of SAEPF with regard to review, clearance and monitoring of small scale development and infrastructure projects of the type anticipated to be carried out under the VIP-2 through interviews with field based SAEPF personnel. The team also met and interviewed officials responsible for monitoring and enforcement of environmental regulations promulgated by the Ministry of Health (MoH), the Ministry of Agriculture, Water and Processing Industries (MAWPI) including the Department of Plant Protection, the Institute of Ecology and several non-governmental organizations.


The range of potential sub-projects treated in this review was derived from project preparation documents supplied by the VIP-2 Project Preparation Unit that identify the potential range of small scale enterprise activities being considered for support under the VIP-2 and the requests anticipated from rural communities for renovation, rehabilitation and extension of rural infrastructure. These documents cover a broad range of potential project investments in the agriculture, livestock, craft, trade, marketing, and service sectors. The approach adopted in preparing this report has been to provide guidelines that can be applied to screen and assess the broadest practical range of sub-projects with regard to their potential environmental impacts and to provide guidance to VIP-2 management at various levels for screening and scoping of project proposals and development of environmental management and monitoring plans. Checklists for project screening, guidelines for managing the environmental review process, formats for environmental management and monitoring plans and best practice recommendations for representative sub-project activities have been included as attachments to Guidelines for Environmental Review of Micro Projects of this report with the intention that they will be incorporated into the VIP-2 Operational Manual to guide project implementation.
A two-day seminar/workshop was held on May 19-20, 2003 in Bishkek for the purpose of discussing the findings of the Draft Environmental Review and receiving feedback from a range of constituents and stakeholders. Participation included personnel from SAEPF based in the Oblast administrations, representatives from Aiyl Okmotu administrations, community representatives, and national environmental non-governmental organizations. Recommendations received from the participants have been incorporated in the final version of this Environmental Review and into the Guidelines for Environmental Review of Micro-projects under the VIP-2 (Volume 1). Participants in the seminar and workshop are listed in Appendix E.


  1. THE ENVIRONMENT




    1. Overview

The Kyrgyz Republic is located in the north-eastern part of Central Asia. It shares borders with China, Kazakhstan, Tajikistan and Uzbekistan. The national territory is 199,900 sq. km of which more than 94% lies at elevations above 1000m and 40% above 3000m. The Kyrgyz Republic occupies the western versant of the Tien Shan and the northern versant of the Pamir-Alai mountain systems. Altitudes range from 401m to 7439m.


The principal rivers (including the Naryn, Karadarija, Chatkal and Chu) are associated with four non-draining Central Asian basins, the Aral, Tarim, Issyk Kul and Balkhash basins. Total annual flow is approximately 50 cubic kilometers. There are 1923 lakes in the Kyrgyz Republic that cover approximately 4.4% of the national territory. The largest of these are Issyk Kul (6236 sq. km), Son-Kul (275 sq. km) and Chatyr-Kul (175 sq. km).
The Kyrgyz Republic lies more than 3000 km from the nearest ocean and, overall, has an arid continental climate. Climatic conditions vary greatly with altitude and topography. Average temperatures in the lowland foothills and valleys range from 0 degrees C in January to greater than 29 degrees C in July with monthly precipitation from 10 to 100mm. At the other extreme, cold temperatures (January temperatures of -20 to -30 degrees C and July temperatures below 6 degrees C) and higher precipitation (exceeding 150mm in spring and summer months) characterize mountainous areas. At elevations above 3500 - 4000m, snow and ice are permanent.
The population of the Kyrgyz Republic is approximately 4.85 million people. Approximately 35% live in urban centers and the remaining 65% in rural areas. Overall population density is 24 persons per sq. km. Excluding the Bishkek metropolitan area, population density among the other seven Oblasts ranges from six to forty persons per sq. km. Since 1989, the overall percentage of the population living in urban areas has decreased by about 3%.


    1. Biodiversity

The Kyrgyz Republic is comprised of 21 different ecosystems. Forests, including shrub lands, cover approximately 7600 sq. km or 3.8% of the national territory. Forest types include fir forests (2772 sq. km), juniper forests (2680 sq. km), broadleaf forests (464 sq. km), riverine (tugai) forest (226 sq. km), fruit and nut forests (98 sq. km). The relative proportions of forest types represented are: shrub and bush lands (44.5%); coniferous forests (pine, fir, larch, tree juniper), (36.4%); deciduous hardwoods (ash, maple, elm, walnut, mixed) (4.5%); deciduous softwoods (birch, aspen poplar, willow), (1.9%); and mixed fruit and nut trees (12.7%).


Other ecosystems include: savanna (6081 sq. km); criophyllic and mid-montane meadows (36,006 sq. km); mid-montane and foothill steppes (18,466 sq. km); cryophillic and mid-montane deserts (21,656 sq. km); foothill deserts (8768 sq. km); and montane glaciers.

Grasslands, including mountain meadows, steppes and foothills cover more than 26% of the national territory and cultivated lands represent approximately 6.28%. Cryophilic, mid-montane and foothill deserts cover 16% of national lands. Wetlands account for approximately 4% of national lands.


Species diversity of flora and fauna is notably high relative to adjacent Central Asian republics as is the proportion of species recorded as endemic to the Kyrgyz Republic. This is likely due in part to the geographical location of the Kyrgyz Republic encompassing large sections of the Tien Shan and Pamir - Alai mountain systems and also to relatively less information available on flora and fauna of adjacent regions.
The information available on fauna and flora varies by taxon. For vertebrates and higher vascular plants, overall species richness and general distribution patterns are relatively well known. Some lower plants, in particular, fungi are also relatively well known. For invertebrates, the arthopods and molluscs are relatively well surveyed with 10,290 and 168 species recorded, respectively. For both of these groups a relatively high proportion of species (30% and 60%, respectively) are considered endemic although this may reflect to some extent a relative lack of information in adjacent countries.
There are more than 500 species of vertebrates recorded from the Kyrgyz Republic of which 14 are considered endemic. Fifty species are listed in the national Red Data Book and may be considered vulnerable.
The recorded avifauna consists of 368 bird species of which 32 are listed in the national Red Data Book. The principal threats are from capture of birds of prey and unregulated export for the falconry trade.
The known mammal fauna includes 83 species of which 13 are listed in the national Red Data Book. Notable elements include the snow leopard (Felis uncia), Marco Polo sheep (Ovis ammon karelini) and the endemic giant Menzbier's marmot (Marmota menzbieri). Wolves (Canis lupis) are common in rural areas of the country.
Thirty-three species of reptiles and four amphibians are known from the Kyrgyz Republic of which two of each class are thought to be endemic. Three reptile species are listed in the national Red Data Book. Sixty-eight native species of fishes have been recorded of which 12 are considered endemic and 4 are listed as vulnerable.
The native flora of the Kyrgyz Republic is incompletely know but is estimated to contain some 4000 species of higher plants (200 endemic) and 1936 species of mushrooms (fungi) of which 26 are endemic. The national Red Data Book lists 71 plant species of which 54 are considered threatened.
Forest cover of the Kyrgyz Republic is estimated to have been reduced by over 45% between 1930 and 1978. Between 1978 and 1998 forest cover has increased by about 30% to about 70% of the original forest area. Juniper forests and fruit and nut forests (particularly pistachio and almonds) have experienced overall declines of 35 - 50% in area.


    1. Land Use and Rural Economy

Agriculture is important to the Kyrgyz economy, accounting for nearly 30% of the GDP and more than one-third of employment. Agriculture-related industries, mostly agribusiness enterprises employ an additional ten percent of the labor force. The combined total of agriculture and agribusiness activities account for more than 50% of GDP and nearly 50% of employment.


More than 80% of arable land is used in irrigated agriculture. The principal crops are grains (wheat, rice, barley, maize), potatoes, vegetables, sugar beets, cotton and oil seeds (sunflower, rapeseed). The predominant cereal crop is winter wheat, accounting for over 40% of cereal production. Tree crops include nuts (walnuts, pistachio, almonds) and fruits (apples, plums). Hay and fodder are principally produced on irrigated land totaling 284,000 ha. (approximately 20% of total arable lands).
Livestock rearing has historically been a mainstay of the rural economy. The major livestock products are meat, milk, eggs and wool. At its peak during the Soviet era (1990), the 8.8 million hectares of natural grazing lands supported more than 10.2 million head of sheep and goats and 1.2 million cattle. This intensity of grazing pressure was unsustainable and the impacts on fragile grazing lands were profound with approximately 1/3 of the natural grazing lands experiencing moderate to severe effects of overgrazing (erosion, spread of weeds, shrubs, unpalatable vegetation).
Subsequent to the breakup of the Soviet economy the number of grazing livestock has decreased by nearly two-thirds. By 1995, the number of sheep and goats had been reduced to 4.3 million, and by 1999 to 3.8 million. Cattle showed a similar but less precipitous decline from 1.2 million in 1990 to 0.87 million in 1995 and a modest increase to 0.93 million head by 1999. Relief from grazing pressure has resulted in some recovery of the fragile alpine meadows, tundra and arid steppes.
Historically, pasture lands were segregated by elevation and seasonality of use. Spring-autumn pastures cover 2.6m ha in the mid-montane zone (30% of the total), summer pastures in the steppe and alpine zone cover 3.8m ha (44%) and winter pastures in the foothill steppe, semi-desert and desert ecosystems represent 26% of the total. With changes in the management system associated with elimination of the kohlkoz and sovkoz structures, livestock grazing is now concentrated year round in the winter-spring-autumn pastures and the summer pastures are seldom used. This has resulted in an elevated stocking rate in the lower pastures, many of which are showing signs of rapid and substantial degradation due to overgrazing.


    1. Important Environmental Issues

The main environmental problems concern the degradation of natural forests and pasture lands caused by overgrazing and a breakdown in the previous system of stock rotation. Degradation of land cover contributes to desertification, results in soil erosion and reduction in soil fertility, and causes changes in the hydrological regime. Erosion has a detrimental effect on water quality and contributes to sedimentation in reservoirs and to reduced performance and increased maintenance costs of irrigation infrastructure. Effects of increased runoff due to erosion and deterioration of land cover contribute to increased flooding and risks of landslides and mudflows.


Soil contamination and water pollution are the other principal environmental concerns. Where ground water is used for irrigation there is some risk of soil salinization and subsequent loss of fertility. Mining and mineral processing activities pose contamination risks for soils as well as surface and ground waters. Both soil and water pollution carry risks of an impact on human health.
Degradation of soils, desertification due to land degradation, and contamination by mining or mineral processing wastes and agrochemicals pose potential risks to the integrity of natural habitats and to their biological diversity.



  1. ASSESSMENT


5.1 General
The project is expected to have a number of directly and indirectly positive environmental effects. The renovation of social infrastructure (schools and clinics) and economic infrastructure (roads, markets, water supplies) will improve the socioeconomic conditions of the rural populations and contribute to reducing rural poverty. The project's emphasis on capacity building for local management and administration, including local screening of projects for environmental impacts, incorporation of mitigation measures into project design and monitoring of implementation, will contribute to improving the capacity of local authorities for environmental monitoring and management overall.
For investments in community infrastructure, most potential impacts can be avoided by adherence to good practices in construction and renovation methods that are well defined within the existing building codes and regulatory norms promulgated by sectoral agencies (e.g. health, agriculture, forestry, water). If project-financed mitigation is included in sub-project design as intended, the cumulative and residual impacts will be negligible.
5.2 Potential Category A and Category B Sub-projects
Potential sub-projects that would require full (Category A) environmental assessments are those that involve distribution and application of pesticides (depending on the scale, small scale applications would be classified as Category B), and mining activities that include ore processing. The Kyrgyz Republic is a signatory to the Stockholm Convention on Persistent Organic Pollutants that prohibits the import, formulation or use of convention-listed pesticides within the national territory. The Kyrgyz Republic has endorsed the adoption of FAO guidelines (that are generally accepted as an international standard) on use and handling of pesticides and the promotion of integrated pest management. The Department of Plant Protection (Ministry of Agriculture, Water and Processing Industry - MAWPI) has promulgated regulations promoting safe use and storage of approved pesticides and provides training, licensing and regulation of pesticide use consistent with the Stockholm Convention and the FAO Guidelines. These would apply to any sub-projects involving purchase, distribution or application of pesticides. The Law on Mining Waste Tailings and Heaps (June 26,2001) regulates the management of mining and processing spoil and regulations promulgated by the Ministry of Environment and Emergency Situations define limits of toxic discharges into soil, air, surface and ground waters.
Types of sub-projects that would potentially require Category B environmental review and preparation of environmental mitigation plans, are feed lots for livestock and possibly some agro-processing operations depending on their size, scale and location and the quantity and nature of anticipated wastes they would generate. To obtain operating permits, such operations would need to demonstrate compliance with standards promulgated by SAEPF, the Ministry of Health, and MAWPI.


    1. Project Benefits

The sub-projects financed by project grants and loans are generally benign and non-threatening to the environment provided that appropriate mitigation measures are incorporated into project design and are properly implemented. For the purpose of this review, potential sub-projects are grouped into 14 categories.


Table 1. Sub-project Groups and Benefits


Sub-project Group

Benefits

Agricultural Diversification or High Value Specialization (e.g. flower, fruit, seed, fish, livestock production)

Increased production and rural income, contribution to national food security, improved rural economy

Agro-processing ( e.g. dairy, poultry, wool, mushrooms, honey, juice, vegetable and fruit canning

Increased household income and rural employment, increased potential exports

Handicrafts (e.g. felt, carving, weaving)

Increased rural income and employment, trade and potential exports

Tradesman Workshops (e.g. blacksmith, carpentry, plumbing and electrical)

Increased household income and employment

Forestry (woodlots)

Increased income, employment and sustainable local supply of building materials and household energy

Mining and Energy (artisanal coal and gemstone mining, clay for brick making, sand and gravel, microhydro and biogas)

Increased rural income and employment, energy supply for households and small and medium enterprises, building materials

Renovation of public buildings, rural roads and market infrastructure

Enhanced social and economic services and improved marketing

Small-scale irrigation and rural water supply

Improved human health and productivity of arable lands

Support services (e.g. veterinary, medical, dental, crop protection)

Enhanced human and animal health, crop and livestock productivity

Transport and communications

Improved rural economy, information flow and marketing

RetAiyl and wholesale trade and storage facilities

Improved rural economy and rural income

Recreation and tourism (e.g. accommodations, trekking, food services)

Increased rural income and employment, income diversification

Education, public health and social services (clinics, training centers)

Improved health and well-being, expansion of livelihood options

Financial, legal and other services (e.g. microcredit, equipment leasing, accounting, business planning)

Increased potential for generating household income and employment, expanded range of livelihood options


    1. Potential Impacts

The most significant environmental concerns will be associated with sub-projects for livestock production, agriculture intensification if the latter involve pesticide distribution and application and small-scale mining. The level of impact of these project types is potentially high but can be effectively mitigated if appropriate safeguards are included in sub-project implementation.


5.4.1 Livestock Production
The reduction in livestock numbers that has occurred since the Kyrgyz Republic became independent has resulted in some recovery of natural pastures from the effects of previous overgrazing. Livestock projects need to take into account the carrying capacity of natural and improved pastures and incorporate appropriate stock movement and rotation schedules to avoid overgrazing. The extension service of the MAWPI and the rangeland management authority can provide appropriate guidance on stocking rates, pasture rotation and pasture management methods to achieve modest increases in production while avoiding land degradation and accomplishing rehabilitation of previously degraded lands. Livestock production projects should include pasture improvement and rehabilitation work as an integral component of project implementation. If appropriate stocking rates and rotation schedules are adopted and combined with investment in pasture rehabilitation or improvement, it should be possible to sustainably increase livestock production above current levels in some areas. Reliable monitoring of grazing lands to ensure timely interventions to avoid soil erosion and avoid overstocking should be incorporated into sub-project design.
Forest lands cover less than 4% of the national territory but contain more the 50% of indigenous biological diversity. They represent an important and diminishing natural resource. Intensive grazing within these areas presents risks to the ecological integrity of forest ecosystems and to their ability to regenerate and maintain their biodiversity. Regulation of grazing within forest areas will be necessary to avoid degradation. Evaluation of potential livestock sub-projects should take into account their potential impact on forests.

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