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Critique of the EIA for the ADPR Project: Environmental Impact Assessment for the Agricultural Development and Poverty Reduction Project in Xiangride-Balong, Qinghai. Qinghai Institute of Environmental Science, Xining, Qinghai, PRC. October, 1998.

By Catherine Moore, Canada-Tibet Committee, Montreal

Given its brevity and format, the EIA is woefully inadequate. There is scant elaboration about how the information about the biophysical environment was obtained. Was local knowledge accessed?

The potential impacts during the construction and operation stages, the corresponding mitigation measures, and the monitoring procedures are addressed within the limited confines of a table.

Cumulative and synergistic effects are not included. What are the impacts of the attendant industrial development? What are the impacts of the extraction of the "rich metal and non-metal mineral resources, which are worthy of exploitation" (copper, iron, gold, lead, zinc, coal, natural gas, and oil)? (p.31)

Many questions are not addressed.

(P.8) There is an inherent bias in the composition of the assessors, given their almost exclusive background in engineering.

The engineering perspective is largely interventionist with an orientation given to command and control rather than accommodating to the conditions of the natural environment.

There is questionable expertise in their designated responsibility field. Engineers are responsible for the assessment of ecology, hydrology, geology, and geography.

According to their names, the assessors are without representation from the minorities who will be impacted.

(P.9) The EIA contends that "the natural ecosystem will be improved as economic activity increases". This has yet to occur in human history and the statement is contradicted elsewhere in the EIA.

(P.13) Pesticide use is integral to the project design. q Not all the pesticides to be used are identified. "The major pesticides are dipterex, rogor, furandan, phoxim, etcŠThe main pesticides are bavastin, etc."

€ Their impact is not addressed in terms of type of pesticide or concentration. What is the potential for the contamination of crops and livestock, toxic impact on non-target species, or groundwater contamination?

€ The cost of pesticide use reduces net profit. This does not appear to have been considered. q Alternatives are not explored. Red spiders, aphids, and grubs are identified as the main pests. Research has demonstrated that they can be controlled through biological or mechanical means. E.g. manual removal of aphids.

(P.13) Fertiliser use is similarly integral to the project design. Their potential for heightening soil salinity is not addressed.

(P.14) "Šthe artificial grassland will be constructed with improved species to get rid of the plant diseases and insect pests." What are these "improved species"? What impact will their introduction have on native species? What ecological role do the insects perform and what consequences may ensue from a depletion or elimination of the insect population?

(P.15) "The ways of forestry construction are to establish artificial forest, recover and preserve natural forest." Species that will constitute the "artificial forest" are not identified nor is their impact on native species. The impact of harvesting the 400ha of "economic forest" and 346ha of "fuel forest" is not addressed.

Irrigation, supplied by surface water and groundwater, is vital to success of project, yet many related issues are not addressed in the EIA.

€ (P.37) "The agricultural system can only be established on a strip of appropriate soils provided that sufficient water resources of adequate quality are made available. If the water supply cannot be guaranteed, or the irrigation systems stops working due to unpredicted events or inefficient management, the crops and the windbreak belts will be severely impacted and may even perished (sic). Given the slow establishment and very long reproduction cycle of the primary sand fixation vegetation, abandoned land would be desertified rapidly and may suffer irreversible deterioration. This could lead to the failure of other adjacent areas through the movement of wind blown sand."

(P.16) Re surface water supply:

€ Estimates of losses from reservoirs and canals from high evaporation rates and bed leakage are not provided.

€ What is the water quality?

€ To what degree will mercury and methane be released in the reservoirs?

€ To what extent will the reservoirs be subject to sedimentation?

€ What are the impacts on the aquatic ecosystems both upstream and downstream from the dams?

€ Impacts accruing from the construction of the dams and canals are only briefly addressed in table.

(P. 17) Re groundwater supply:

€ It is stated that the "hypothetical groundwater supply capacity is 402,000,000m3" (p.24). The criteria that define "hypothetical" are not provided. This is particularly pertinent as "there have been no regular water level measurements within this zone" (p.26).

€ What is a sustainable extraction rate?

€ A lowering of the water table is expected (p. 25) yet the potential for the attendant drying up of lakes and oases, reduced discharge in rivers with its associated heightened concentration of pollutants and sedimentation, land surface subsidence, and reduced irrigation capability is not addressed.

€ The variability in water table levels is recognized, a groundwater model having indicated "a natural annual water table variation of 0.11 to 0.58m". The coincidence of a natural low level with an anthropogenically induced lowering of the water table may have catastrophic consequences.

€ How is the quality of groundwater to be maintained and monitored?

€ Where the groundwater is already saline, its utility in irrigation is questionable.

€ The quality of the groundwater may be further undermined by the leaching of pesticides and fertilisers, the potential for which is not addressed.

€ The release of fossil water from the accelerated melt of snow and ice may cause an erroneous over-estimate of the long-term water availability. Also, this meltwater commonly accumulates behind ridges of moraine. When it breaks through, as it inevitably does, it often becomes a violent torrent. Can the dams withstand this unanticipated force?

€ The extreme diurnal and seasonal variability in discharge that characterises this region lends significant uncertainty to estimates of available water resources. This is not addressed in the presentation of data.

€ The impact on current users of the water supplies is not addressed. Will they maintain access to the water supplies in terms of the quantity and quality established by historical precedent?

(P.17) Power transmission lines and transformers are examined in a mere twenty words. "The high-voltage power line is 337.1km, including 211.1km for the 10kV and 125km for the 35kV, with two transformer stations." There is no specification of energy source. The environmental impact is exceedingly brief. Addressing only the "construction of the project power supply" it identifies, without elaboration, four "possible environmental issues: soil erosion; soil and vegetation ruin; flying dust and noise; and public safety". There is no consideration of the impact deriving from the generation, transfer, and use of the energy.

(P.17) "In the project area, a simply (sic) road of 541.9kmŠwill be built." Soil erosion is identified as the only "possible environmental issue" (p.47). The impact of road construction and use on wildlife habitat, migration routes, breeding grounds, and mortality (animal road kill) is not examined. Potential cumulative effects are not explored.

(P. 18) The move-out area has been seriously degraded. E.g. soil erosion, diminished soil fertility, water pollution, reduced extent of arable land. Beyond the brief measures indicated in the table, the EIA does not specify any action to ensure that the environmental degradation of the move-out area is not repeated in the move-in area.

(P.26) The assessment of the "ecosystem quality in the move-in area" is a summary condemnation of the project. "The ecosystem in the project move-in region is fragile. The systemic structure is simple, unstable and lacks the ability of self-reestablishment. The climate in the project is dry and the salt content of soil and groundwater is quite high, so that the main vegetation species are xerophytes and halophytes. The vegetation is comparatively sparse and species assemblages are simple and have low productivity. The ecosystem stability is poor and it is easily disturbed by activities that result in degeneration. Set against this it should be remembered that most of the naturally occurring species are well adapted to this very harsh climate. Thus it can be seen that once the ecological system or its structure is damaged or destroyed, the system or its structure may change and not easily recover."

(P. 32) Tourism is dismissed in 19 words. "The opening up of the Balong International Game Zone is beneficial to the development of tourism in the region." This in itself warrants an assessment of both environmental and cultural impact.

(P. 33) Three classes are designated in terms of degree of impact "great", "medium", and "little". The criteria to assign degree of impact, i.e. to establish class limits, are not indicated. Rather, reference is made to a World Bank document, "The need for screening, the degrees of impact and the evaluation categories are listed in Environmental Evaluation (OD04.01, the Working Guide of the World Bank". Yet the specific criteria that pertain to this project are not identified. This lack of definition concerns not only the overall designation of this project as a Category B in terms of screening level, but also the degree of impact on individual components of "the natural resources, biological resources, and the social environment". The project merits a Category A screening level given:

€ the construction of dams. The "biggest dam is 39m high" with a top length of 204m, with a "sub-dam on the left bank" that is 21m high and 189.6m in top length and a "sub-dam on the right bank" that is 26m high and 480m in top length. (p.16)

€ the diversion of water resources. E.g. "Over 311.6km (of) branch canals will be built in four irrigation regions." (p.16)

€ the transfer of human populations. "The population of 61,775 in seven counties will be resettled." (p.10). Note: reference is also made to "57,775 migrants" (p.10).

(P.37) "The project region isŠecologically sensitive." Desert pavement, a surface layer of closely fitting pebbles, rocks, and rock fragments, typically develops on desert soils. It occurs in the Sahara, Australia, American SW, and Gobi. It stabilises the surface by protecting the underlying finer particles from erosion. However, it is damaged by vehicle traffic and other human disturbance. Erosion of the surface results. There are inevitable impacts from this erosion and the subsequent deposition of the sediment. Among the impacts is a high risk of desertification.

(P.41) Saltmarsh currently dominated by Carex spp. "will be replaced with salt grassland vegetation, with (the) reed Stipa purpurea as the principal plant species". The only impact identified is that "parts of the area will probably face sand desertification unless some necessary artificial measures are exerted". There is no elaboration concerning:

€ which parts of the area are vulnerable and why

€ what are the necessary artificial measures

€ what are the ecological ramifications of this enforced transformation of a wetland into a grassland with its attendant change in species assemblage and physical structure

€ the loss of ecological services provided by wetlands.

€ Wetlands remove suspended sediments that might otherwise silt-up rivers and reservoirs, impair photosynthesis through heightened turbidity, or adsorb heavy metals and pesticides.

€ Numerous wetland plant species can immobilize such contaminants as heavy metals, pesticides, viruses, and coliform bacteria.

€ In a similar way, surplus nutrients, particularly nitrogen and phosphorus, can be removed, reducing the risk of eutrophication.

€ With their capacity to absorb, store, and slowly release large amounts of water, riverine wetlands are able to moderate discharge rates and lower flood risk.

€ Wetlands provide habitat and vital breeding and feeding grounds for a diverse array of organisms.

The potential impact of climate change is not addressed.

While the plight of the impoverished population in the move-out area is real, the reduction of their poverty will not be realised by moving them to an area that is already marginal in its ability to accommodate human occupation.

The project as currently proposed is not sustainable.

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