Yangtze River Protection and Ecological Restoration
Program for Results (Hubei)
(P178338)
Environmental and Social Systems
Assessment
The World Bank
October 2022
Official Use
Contents
1. Introduction 1
2. Program Description 4
2.1 Government Program 4
2.2 The PforR Scope 4
2.3 Program implementation agencies 6
3. E&S Impact Assessment 9
3.1 E&S Exclusion 9
3.2 E&S Assessment Scope 10
3.3 E&S Benefits 11
3.4 E&S Impacts 11
3.5 E&S Risk Rating 17
4. Environmental Management System Assessment 20
4.1 General Principles 20
4.2 EIA and Follow-up Management System 21
4.3 Pollution Control System 29
4.3.1 Domestic wastewater management 29
4.3.2 Rural domestic solid waste management 32
4.3.3 Livestock/poultry manure management 35
4.3.4 Mulch film management 38
4.4 Ecological Environment Protection System 40
4.4.1 Natural habitats protection 40
4.4.2 Water and soil conservation 43
4.4.3 Water management under RCS 46
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4.5 Health and Safety Management System 49
4.6 Consistency with the Bank’s Core Principles 52
5. Social Management System Assessment 55
5.1 Correlation Analysis with Bank Principles 55
5.2 Assessment of Social Regulations and Policies 59
5.2.1 Core Principle #1: Sustainable social risks management system 59
5.2.2 Core Principle #2: Cultural heritage management system 62
5.2.3 Core Principle #3: Public and worker safety management system 63
5.2.4 Core Principle #4: Involuntary resettlement management system 65
5.2.5 Core Principle #5: Management system for ethnic minorities and vulnerable groups
68
5.2.6 Core Principle #6: Social conflict management system 72
5.3 Assessment of Social Management Mechanism and Capacity 72
5.4 Assessment of the Social Effects of Implementation 80
5.4.1 Core Principle #1: Sustainable social risks management system 81
5.4.2 Core Principle #2: Cultural heritage management system 86
5.4.3 Core Principle #3: Public and worker safety management system 86
5.4.4 Core Principle #4: Involuntary resettlement management system 89
5.4.5 Core Principle #5: Management system for ethnic minorities and vulnerable groups
91
6. Public Participation and Grievance Redress Mechanisms 96
6.1 Public Participation 96
6.1.1 Initial participation activities 96
6.1.2 Public consultation on the ESSA 97
6.2 Grievance Redress Mechanisms 97
7. Conclusions, Recommendations, and Action Plans 98
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7.1 Conclusions 98
7.2 Recommendations 99
7.3 Action Plans 99
8. Management and Monitoring 101
8.1 The Borrower 101
8.2 The Bank 101
Appendix 1: Boundary of Hubei Government Program and the PforR 103
Appendix 2: E&S Risks/Impacts Assessment 110
Appendix 3: Comparison with the Bank PforR Policy and Directive 117
Appendix 4: Stakeholder Analysis 145
Appendix 5: Stakeholder Engagement 148
Appendix 6: Feedback of Public Consultation on the ESSA 150
Appendix 7: Field Visit Records 152
Appendix 8: Special Survey on Program Activities in Ethnic Minority Areas 155
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Abbreviations and Acronyms
AEPS Agricultural Environment Protection Station
ARAB Agriculture and Rural Affairs Bureau
BOD5 five-day biochemical oxygen demand
CAB Civil Affairs Bureau
COD chemical oxygen demand
CPC Communist Party of China
CPMO central program management office
CWRC Changjiang Water Resources Commission
DLI disbursement-linked indicator
DMS detailed measurement survey
DPF Disabled Person’s Federation
DRC development and reform commission
EEB Ecology and Environment Bureau
EHS environment, health, and safety
EIA Environmental Impact Assessment
EMS environmental management system
ERAB Ethnic and Religious Affairs Bureau
ESSA Environmental and Social Systems Assessment
FALU facility agriculture land use
FB Finance Bureau
FGB Forestry and Grass Bureau
GIIP good international industry practice
GRM grievance redress mechanism
HRSSB Human Resources and Social Security Bureau
HURDB Housing and Urban-Rural Development Bureau
IPF Investment Project Financing
LAR land acquisition and resettlement
LET law enforcement team
LURT land use right transfer
MEE Ministry of Ecology and Environment
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MLS minimum living security
MOF Ministry of Finance
MWR Ministry of Water Resources
NDRC National Development and Reform Commission
NGO non-government organization
NIMBY not in my back yard
NPS non-point source
NRB Natural Resources Bureau
OHS Occupational Health and Safety
O&M operation and maintenance
PAP program action plan
PforR Program-for-Results
PIU Program Implementation Unit
PPE personal protective equipment
PPMO Provincial Program Management Office
PSC Program Steering Committee
RCO river chief office
RCS river chief system
RRB Rural Revitalization Bureau
SIA Social Impact Assessment
SSRA Social Stability Risk Assessment
TA Technical Assistance
UMLEB Urban management and law enforcement bureau
WRB Water Resources Bureau
WF Women’s Federation
WWTP wastewater treatment plant
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1. Introduction
Background
1. The River Chief System (RCS) is a network of government officials at the provincial,
municipal, county, township, and village levels, who are assigned responsibility for outcomes along
each section of every significant waterway. It helped to raise the importance of water-related
issues and proved very useful in addressing challenges of coordination and cooperation between
responsible departments and regions. Implementation of the RCS is supported by River Chief
Offices (RCOs) that usually sit within water departments at the respective levels.
2. In 2016, China initiated a national strategy of the Yangtze River Economic Belt (YREB)
development to overcome the challenges of water pollution and ecological degradation in the
Yangtze River and its tributaries. To support this national strategy, the State Council approved the
Yangtze River Protection and Ecological Protection (YRPERP) Program for World Bank financing,
covering three provinces, Hunan, Jiangxi, and Hubei, in 2021. The YRPERP Program (P171644,
covering Jiangxi and Hunan provinces) was approved by the Board of Directors of the World Bank
in December 2021.The YRPERP consists of two parts, one is the investment project financing part
(IPF, US$7.5 million), including policy and technology research, watershed management
coordination mechanism, capacity building, etc., the second is the program-for-results part (PforR,
US$400 million) to support Hunan Province to implement the "Dongting Lake Water Environment
Comprehensive Management Plan (2018-2025)" and Jiangxi Province to implement the "Five
Rivers, One Lake and One River Basin Protection and Management Plan (2020-2035)". With the
program development objectives (PDO) to improve institutional coordination, enhance ecological
protection and reduce water pollution loads in selected regions of the Yangtze River Basin, the
Program has three results areas (RAs), namely RA1 - improving institutions and innovations, RA2 -
advancing ecological protection through integrated river basin management, and RA3 - reducing
water pollution and transmission of plastic waste. At present, the Program (P171644) has been
approved by the World Bank's Board and is ready to sign agreements.
3. In June 2022, the YRPERP Program for Hubei (hereafter the PforR) was endorsed by
Chinese Government to support the Yangtze River protection and ecological restoration in Hubei
Province from 2023 to 2027. The PforR will continue the overall development goal of the whole
Yangtze Program and be implemented under the national coordination mechanism established
under the Program.
Objective and Tasks of the ESSA
4. This Environmental and Social Systems Assessment (ESSA) is prepared as an instrument
to address the environmental and social (E&S) risks and impacts of the PforR using national and
local E&S legal frameworks and management systems. In the ESSA, the applicable national and
local E&S frameworks and systems have been reviewed and assessed, compliance with the
Bank’s PforR core principles and requirements has been analyzed, and actions and
recommendations have been proposed to fill the gaps to improve the implementation performance
of the systems. The main tasks of the ESSA follow:
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1. Assess the potential E&S impacts and risks of the PforR activities.
2. Assess the applicable national and local E&S policies and regulations.
3. Assess the implementation procedures, institutional settings and personnel arrangements
of the provincial and local E&S management systems.
4. Assess the institutional capacity and performance of E&S management authorities.
5. Propose recommendations and actions to improve the performance of the E&S
management systems as required by China's regulations and the Bank’s core principles.
Procedures and Methodologies of the ESSA
6. The ESSA is the joint responsibility of the World Bank (hereafter the Bank) and the
borrower. The World Bank team implements the assessment and prepares the report, and the
team also largely relies on the assistance of Chinese governments, especially in data collection
and stakeholder engagement at the various stages of the PforR preparation.
7. At the Identification stage, the ESSA team conducted the risk screening in two steps:
applying the exclusion criteria to eliminate activities that are not eligible for PforR financing; and
completing the preliminary risk screening process. At the Preparation and Appraisal stages, the
ESSA team carried out a comprehensive ESSA in accordance with the agreed scope of work by
assessing the E&S benefits, impacts and risks of the PforR activities, assessing the domestic E&S
management systems in terms of applicable legal frameworks, institutional arrangements, and
implementation performance, and proposing recommendations and actions to fill the gaps between
the E&S systems and the Bank’s PforR policies. Appropriate consultations with key stakeholders
will take place on the draft ESSA report to agree on the recommended actions which will be
incorporated into the PAP, and the final ESSA will be disclosed on the Bank and governments’
websites in due course.
8. There are demonstration six counties/cities in the PforR (Hubei). To ensure a successful
assessment, the ESSA team conducted information collection and stakeholder engagement by
various means and carried out field visits to five of the six demonstration counties (Enshi, Lichuan,
Jianshi, Badong, Xuan’en, and Honghu). Due to the impact of COVID-19, the ESSA team could not
visit Xuan’en County physically, but conducted face-to-face interviews with Xuan’en’s key
government authorities at a third county and collected and reviewed relevant documents similar to
that of the other five counties. The selection of the sample sites within a county/city for the field
investigation took into account the following main factors: (1) covering both Qing River and Honghu
Lake watersheds of the project in terms of geographic scope and distribution; (2) containing
representatives of minority villages; (3) typical activities of similar in nature and scale to those in
the Program.
1. Primary information collection and analysis: Primary information was also obtained in
multiple ways, including questionnaire, on-site consultation and interview, and field visit,
etc. In June 2022, the ESSA team conducted a series of on-site meetings with provincial
and county-level governments in three sample cities, namely Honghu, Enshi, and Lichuan,
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to understand the management mechanisms of the E&S systems; meanwhile visited the
sites of typical activities in the sample cities to learn the actual implementation
effectiveness of the E&S systems. In addition, questionnaire survey has been done to the
other three demonstration counties to get more evidence for the E&S systems
assessment.
2. Whole process stakeholder engagement: Throughout the PforR cycle since the
identification till the ESSA preparation, the ESSA team kept communicating with a variety
of stakeholders at each step. During the preparation of this report, the ESSA team
interviewed various relevant government departments at the provincial and county levels
and consulted different representatives of potentially affected community/village leaders
and residents: women, the poor, and minority residents by means of face-to-face
meetings, interviews, virtual conferences, etc.
3. ESSA consultation: In September 2022, robust consultation (both face-to-face and virtual)
on the ESSA was conducted with government authorities at the provincial and county
levels in Hubei. The first version of the draft ESSA was sent to all relevant provincial-level
authorities and all relevant county-level authorities who had provided written feedback to
the ESSA team. Virtual meetings were also carried out with all these government
authorities for detailed discussions. The feedback has been incorporated into the ESSA
and the activities about data collection and consultation are listed in Appendix 5. The
governments of Enshi Prefecture and Honghu City have disclosed the ESSA on the
official websites of local DRCs on 9 and 10 October, respectively.
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4. Program Description
2.1 Government Program
5. Hubei Province, located in the middle reach of the Yangtze River, is critical for
protection and restoration of the whole basin, since it has the longest river reach of the Yangtze
River, two of the eight major tributaries, the largest number of lakes, and rich biodiversity resources.
To support the national strategy of YREB development, Hubei province issued the “Hubei’s 14th
FYP for YREB Green Development�? (hereafter the Hubei government program) on November 21,
2021, covering all 103 counties/cities of the province which are entirely within Yangtze River Basin,
to protect the ecological environment in important rivers and lakes for green development in Hubei.
With a total investment of USD4.2 billion, the Hubei government program has the following areas
of development (typical activities are presented in Appendix 1):
1. Land-based ecosystem protection and restoration;
2. Integrated water environment management for key basins;
3. Coordinated basin ecological environment improvement;
4. Agriculture green development;
5. Deepening inter-jurisdiction cooperation in green development;
6. Solid waste classification and resource utilization;
7. Upgrading urban and township environmental infrastructure;
8. Rural living environment improvement;
9. Establishment of long-term mechanisms for protection of Yangtze River in Hubei
province; and
10. Supporting green development pilots and demonstrations.
2.2 The PforR Scope
11. Investment boundary: The Bank is to provide a total IBRD loan of US$200 million over a
5-year period from 2023 to 2027 to support relevant activities under following sub-programs of the
Hubei governmental program: land-based ecosystem protection and restoration; integrated water
environment management for key basins; agriculture green development; deepening inter-
jurisdiction cooperation in green development; solid waste classification and resource utilization;
upgrading urban and township environmental infrastructure; and establishment of long-term
mechanisms for protection of Yangtze River in Hubei province. Boundary of the Hubei
governmental program and the PforR is shown in Appendix 1.
12. Geographic coverage: The PforR will be implemented in six demonstration cities/counties
within the basins of Qingjiang River and Honghu Lake: Enshi, Lichuan, Jianshi, Badong, and
Xuan’en cities/counties of Enshi Prefecture; and Honghu City of Jingzhou Prefecture.
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13. Program development objective (PDO): As same as the overall objectives of the
Program for Jiangxi and Hunan, the PDO of Program for Hubei is to improve institutional
coordination, enhance ecological protection and reduce water pollution in Hubei province of the
Yangtze River basin. The achievement of the PDO will be measured through the following outcome
indicators: (a) Strengthened river chief system (RCS) for institutional coordination; (b) Improved
water environment management system for the demonstration sub-basins; and (c) Reduced
pollutant loads entering waterways in the demonstration cities/counties.
14. Result areas: The PforR will support the following three RAs to be implemented in Hubei:
RA1 - Improving Institutions and Innovations (provincial level): It aims to support
institutional coordination improvements for inter-jurisdictional cooperation and cross-
sectoral coordination in Hubei Province.
RA2 - Advancing Ecological Protection through Integrated River Basin Management (sub-
basin level): It aims to support ecological protection and climate resilience of river and lake
ecosystems in the demonstration sub-basins of Qingjiang River and Honghu Lake basins.
RA3 - Reducing Water Pollution and Transmission of Plastic Waste (county level): It aims
to reduce point and non-point source (NPS) pollution in demonstration cities/counties.
15. Typical activities and expected outcomes: The typical activities within the PforR
boundary and their intermediate outcomes with disbursement-linked indicators (DLIs) are
presented in Table Error! Reference source not found..
Table 2-1: PforR Activities and Expected Outcomes
RAs Typical Activities Intermediate Outcomes DLIs
1. Improving Demonstration province: 1. Hubei-Hunan-Jiangxi
Institutions Tripartite Water
and (a) Establishment of tri-provincial Environment Coordination
Innovations cooperation mechanism for ecological Mechanism established
environment protection with focus on
river/lake protection; 2. River Chief System
platform integrated
(b) Strengthening of RCS
coordination through the integration of 3. Provincial level policies,
county and municipal, provincial, and regulations and guidelines
basin-level RCS information platforms on water environment and
with required data-sharing and plastic waste management
applications; issued (Number)
(c) Development of provincial-level 4. Public engagement manual
policies, regulations and guidelines on for the river/lake chief
integrated water environment, ecological system developed and
protection, and plastic waste disseminated (Yes/No)
management; and
5. People engaged in
(d) Public engagement in water river/lake protection
environment management, through activities (Number
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RAs Typical Activities Intermediate Outcomes DLIs
awareness campaigns, participatory (Thousand))
management and river cleanup activities,
and development and dissemination of 6. Women civil river chiefs in
public engagement manual for the RCS, demonstration
targeted at climate awareness and cities/counties
women’s participation. (Percentage)
2. Advancing Demonstration sub-basins: 7. Water allocation schemes DLI 1: Improved
Ecological for the demonstration sub- water environment
Protection (a) Strengthening of integrated basins implemented management system
through water environment management (Yes/No) in the demonstration
Integrated systems, including integrated water sub-basins
River Basin environment protection plans; 8. Ecological flow/water depth
Management requirements determined DLI 2: Additional land
(b) Improving water environment for demonstration sub- area under
monitoring systems basins (Yes/No) sustainable
(c) Development of river health landscape
9. Improved sub-basin water management
assessment and/or ecological flow environment monitoring
guidelines based on national standards; network (Number of new or
(d) Implementation of water upgraded water quality
allocation schemes based on national monitoring stations)
standards; 10. Increase in
(e) Determination of ecological flow sustainably managed land
requirements and incorporation into area -Additional land area
county water allocations to ensure long- with soil and water
term restoration and protection of the conservation measures
freshwater ecosystem services, and (km2)
(f) Financing of sustainable soil and
water conservation activities, with
emphasis on sustainability of outcomes.
3. Reducing Demonstration cities/counties: 11. Improved county and DLI 3: improved
Water township domestic township domestic
Pollution and (a) Improved integrated wastewater wastewater service wastewater service
Transmission management systems and services at systems (Text) systems
of Plastic township level;
Waste 12. Plastic waste DLI 4: demonstration
(b) Prevention of plastics entering (agricultural film) prevented cities/counties
waterbodies through collection and from entering water bodies meeting annual
recycling of agricultural plastic film; (Metric ton) targets for manure
(c) Reduced nutrient runoff via utilization
13. Demonstration cities/
improved management and utilization of counties with integrated
livestock/poultry manure, focusing on and market-based
large-scale animal farms; and municipal waste
(d) Improved integrated urban-rural management system
domestic solid waste collection and (number)
transportation systems and services in 14. Demonstration cities/
the demonstration cities/counties. counties meeting annual
targets for animal manure
utilization (number)
2.3 Program implementation agencies
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15. The PforR will be implemented across various sectors at different levels to ensure efficient
and effective supervision and coordination.
16. The Program Steering Committee (PSC) led by the Office of the Leading Group for the
Development of the YREB under National Development and Reform Commission (NDRC) (YREB
Coordination Office) has been established under the P171644, which will continue providing
coordination and guidance for this PforR. The YREB Coordination Office works in coordination with
other NDRC departments including the Rural Economy, Environment and Natural Resources, and
Regional Revitalization, to promote implementation of the national YREB strategy through policy
formulation and high-level planning. The PSC will be headed by a senior official of the YREB
Coordination Office and comprise representatives from the Ministry of Finance (MOF), Ministry of
Water Resources (MWR), Ministry of Ecology and Environment (MEE), etc. The PSC will be
responsible for providing overall coordination and guidance for the Program. It will be supported by
the central program management office (CPMO) established under P171644 and hosted in the
Changjiang Water Resources Commission (CWRC), the basin organization for the Yangtze River
basin.
17. A provincial Program Management Office (PPMO) will be hosted by the Hubei Provincial
DRC. The PPMO is responsible for coordinating activities among sector departments in the
province. The PDRC has established a Provincial YREB Office, corresponding with the national
YREB Coordination Office at NDRC that is responsible for realizing the objectives of the national
YREB strategy at the provincial level. The PPMO is responsible for preparation of provincial-level
Program documents and Program implementation management. They will report to the Provincial
PSC, which will comprise senior representatives from relevant departments and be responsible for
program-related strategic directions and policy guidance within the province. The PMOs at county
level (set up under local DRCs) are responsible for overall implementation of county-level activities.
Program Implementation Units (PIUs) have also been established to include relevant government
authorities at different levels. The provincial-level authorities are responsible for overall
management and supervision and the county-level authorities for designing, implementing, and
monitoring specific PforR activities.
18. As required by the Bank and confirmed by the PPMO and the six demonstration counties,
dedicated environmental and social staffs will be assigned at both the provincial and county PMOs
for monitoring the environmental and social management measures during the PforR
implementation phase. Detail roles and responsibilities of the PMOs and PIUs are discussed in
Section 8. Subject to specific environmental and social systems that are relevant to the program
activities, related government authorities are responsible for management of corresponding
impacts and risks on environment and social aspects, e.g., policies/standards formulating,
guidance, supervision. Section 4 and 5.3 discussed the details of related government authorities
on different levels. On the other side, the environmental and social focal points of related PIUs and
enterprises will be assigned for implementation of environmental and social management
measures that are related to the program. In addition, external services are also available for
government authorities or PIUs to strengthen its capacities where needed, including training,
technical supports and staffing.
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19. Take the management of Occupational Health and Safety (OHS) risks and impacts as an
example, the Office of Occupational Health and Safety (OHS) at Hubei provincial health committee
is responsible for the whole provincial OHS management, while the county health committee is
responsible for the OHS issues in the county level. Enterprises in the county which have OHS risks
should establish/assign dedicated departments/people to responsible for OHS management, for
example, OHS assessment, management, monitoring and reporting to the local county health
committee. The county health committee carries out supervision to related enterprises in random.
Where constraint of staff, the representatives of health and safety management in the township
governments where the enterprises physically located will be asked to support the supervision.
Meanwhile, trainings for the staffs of related OHS management staffs are organized by the
provincial and county health committees regularly every year. Normally, the OHS hazard
testing/monitoring and occupational medical check-ups are conducted by qualified third-party
vendors.
20. Hubei provincial government has experience in implementing foreign loan projects and has
implemented several foreign loan or grant projects. In addition to this PforR, the government is also
actively preparing for the World Bank Green Agricultural and Rural Revitalization Program for
Results Phase 2 (P178907).
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21. E&S Impact Assessment
3.1 E&S Exclusion
22. Purpose: During the ESSA preparation, the Bank's core principles and requirements on
E&S screening have been fully considered, and screening has been conducted on the government
program activities to (1) identify and exclude activities with significant E&S risks/impacts and (2)
define the scope of activities to carry out ESSA.
23. Exclusion criteria: Under the Bank PforR Policy, activities that are “judged to be likely to
have significant adverse impacts that are sensitive, diverse, or unprecedented on the environment
and/or affected people are not eligible for financing and are excluded from the Program.�? More
specifically, following criteria are applicable to exclude activities with significant E&S impacts:
24. Significant conversion or degradation of critical natural habitats or critical cultural heritage
sites.
25. Air, water, or soil contamination leading to significant adverse impacts on the health or
safety of individuals, communities, or ecosystems.
26. Workplace conditions that expose workers to significant risks to health and personal safety.
27. Activities involving relocated minorities
28. Land acquisition and/or resettlement of a scale or nature that will have significant adverse
impacts on affected people or the use of forced evictions.
29. Large-scale changes in land use or access to land and/or natural resources (e.g.,
ecological resettlement).
30. Adverse E&S impacts covering large geographic areas, including transboundary impacts,
or global impacts such as GHG emissions, new or significant expansion of large-scale
water (surface and groundwater) resource infrastructure, including large dams, or
activities involving the allocation or conveyance of water, including inter-basin water
transfers or activities resulting in significant changes to water quality or availability.
31. Significant cumulative, induced, or indirect impacts.
32. Activities that involve the use of forced or child labor.
33. Marginalization of, discrimination against, or conflict within or among social (including ethnic
and racial) groups.
34. Activities that would (a) have adverse impacts on land and natural resources subject to
traditional ownership or under customary use or occupation; (b) cause relocation of ethnic
minority groups from land and natural resources that are subject to traditional ownership
or under customary use or occupation; or (c) have significant impacts on ethnic minority
cultural heritage.
35. Excluded activities:
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36. Activities that would involve large-scale infrastructure construction or large-scale land
acquisition;
37. activities that would involve acquisition of basic farmland;
38. activities that would involve returning lake/river by requisition of water/land/fishing materials;
39. activities that would involve relocation or closure of livestock or poultry farming;
40. TA activities that implementation of whose outputs may lead to downstream activities of
high E&S risks;
41. activities that are classified as domestic Category A (Environmental Impact Assessment
Report category) projects;
42. activities that would be conducted in environmentally sensitive areas (including the legally
established protected areas and the regions sensitive to environmental impacts) as
defined in the Construction Project EIA Classification Catalogue;
43. activities that would be conducted in areas with significant legacy pollution; and
44. activities that would construct treatment/disposal facilities for domestic solid waste and
wastewater sludge, etc.
3.2 E&S Assessment Scope
45. Physical activities under the PforR: After excluding the above-mentioned activities, the
main physical activities that the PforR will support include: (1) county and township wastewater
treatment plants (WWTPs, typically 400 - 60,000m3/day) and pipelines; (2) domestic solid waste
collection and transfer; (3) livestock and poultry manure treatment and utilization (for returning to
farmland as fertilizer or producing organic fertilizer as raw materials) (4) collection of agricultural
mulch film; (5) soil and water conservation (small river basins management, turning slope to
terrace, and rocky desertification control, etc.). These physical works would produce certain direct
and/or indirect E&S impacts in construction and operation.
46. TA activities under the PforR: Policy study, public participation, and other TA activities
will also be supported by the PforR, including (i) Integration of county, municipal, provincial, and
basin RCS information platforms; (ii) establishment of tri-provincial cooperation mechanism for
ecological environment protection; (iii) development of provincial-level policies, regulations and
guidelines on integrated water environment, ecology, and plastic waste management; (iv)
development and dissemination of public engagement manual for the RCS; (v) strengthening of
integrated water environment management systems; (vi) improving water environment monitoring
systems; (vii) development of river health assessment and/or ecological flow guidelines; (viii)
implementation of water allocation schemes; and (ix) determination of ecological flow requirements,
etc. Implementation of the TA activities would have minimal or no direct adverse E&S impacts, but
implementation of the outputs of some TA activities may induce indirect E&S effects.
47. Associated/linked facilities/activities: As per the Bank's PforR ESSA Guidance,
associated (or linked) activities refer to activities that would be required to meet the PforR
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objectives but that are not explicitly defined as PforR activities or included in the expenditure
framework. The PforR will not involve any associated or linked activities/facilities defined by the
Bank’s ESF or Safeguards Policies. Per the site visits and E&S due diligence review, the ESSA
team identified that some of the PforR activities will cause induced impacts to certain downstream
facilities/activities, for instance: (1) The domestic solid waste and the WWTP sludge will be
transported to existing sanitary landfills or incineration power plants for disposal. (2) The
composted livestock/ poultry manure will be used as fertilizers on farmland or woodland or as raw
materials to produce commercial organic fertilizers. (3) The mulch films will be sent to existing
waste plastics recycling factories to produce plastic products. These relevant downstream facilities
have existed, and the Program will not directly lead to the new construction or expansion at these
downstream facilities. Therefore, those relevant existing downstream activities/facilities are not
linked or associated facilities or activities of the Program. The ESSA (in below Para. 29 and Table
3-1) will further screen the induced impacts that are foreseeable as a result of the Program
operation at these relevant existing downstream facilities (including landfills, incineration plants and
plastic recycling treatment plants) in the demonstration cities/counties.
3.3 E&S Benefits
48. The PforR will have obvious positive E&S benefits for the demonstration areas through
implementing a series of ecological rehabilitation and pollution control activities, including reduced
pollutants discharge, improved river and lake water quality, and rehabilitated landscape, which will
greatly improve local ecological and living environments, and contribute to the ecological
rehabilitation of the Yangtze River Basin.
3.4 E&S Impacts
49. The PforR activities will also generate certain negative E&S impacts for which a general
description is provided in the following sections while the E&S impacts of typical PforR activities
are given in Appendix 2.
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Direct and indirect impacts
50. The construction, operation, or agricultural production activities under the PforR, such as
domestic wastewater collection and treatment, domestic solid waste collection and transfer,
livestock and poultry manure treatment and utilization, agricultural film collection, and water and
soil conservation, will have certain direct and/or indirect E&S impacts.
51. Major environmental impacts:
52. Environmental pollution: (i) Construction stage: Dust, noise, wastewater, and solid waste
will be generated, but they are usually temporary, short-term, small-scale, and site-
specific and can be properly managed by applying good techniques and construction
practices and disappear right after the construction is completed. (ii) Operation stage:
Oder, treated effluent, and sludge would be generated at county and township WWTPs.
Odor and leachate would be produced at domestic solid waste collection and transfer
facilities. Improper disposal of collected mulch film residues might cause secondary
pollution to the environment. Inadequate treatment or improper use of livestock/poultry
manure might produce odor, wastewater, and biogas residue and slurry. These impacts
are normally predictable, can be avoided or mitigated using known and demonstrated
techniques and/or management measures, and are unlikely to cause significant
environmental risks.
53. Ecological impacts: (i) Design stage: The PforR activities will take place in built-up areas
or agricultural farming areas around villages and townships which have been disturbed by
human activities and dominated by artificial ecosystems. The environmental exclusion of
this PforR have made the activities that might affect critical natural habits excluded from
the PforR scope. In addition, the EIA process of each specific physical project under the
PforR will strictly follow the national ecological redline mechanism and project siting will be
subject to approval by relevant government authorities. Accordingly, site selection of the
PforR activities is unlikely to cause significant implication on critical natural habitats or
ecosystems. (ii) Construction stage: Construction activities would only disturb vegetation
at construction sites or cause some site-specific soil erosion, which can be avoided or
mitigated using known and demonstrated techniques and/or management measures and
get restored right after the construction is completed. (iii) Operation stage: Operation of
physical facilities and implementation of agricultural activities under the PforR are unlikely
to have adverse impacts on natural ecosystems; instead, they will improve regional
ecological quality.
54. Health and safety risks: (1) Construction stage: There are potential health and safety risks
in excavation, high-altitude working, and driving machinery and vehicles, etc. (2)
Operation stage: Risks such as untreated wastewater overflow from township-level
WWTPs in accidents, odor from domestic solid waste and livestock/poultry manure, and
dead animals from livestock/poultry farms would potentially threaten the health of workers
and nearby public. However, these risks are predictable and can be avoided or mitigated
using known and demonstrated techniques, management, and/or training measures.
55. Major social impacts:
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56. Labor impacts: Risks of infringing the rights and interests of workers in construction units
and operation management units, risks of living environment in camps and workers’ living
quarters, risks of disturbance to surrounding communities, and occupational health and
safety risks of workers, etc.
57. Community impacts: This PforR support the use of organic fertilizers and the soft capacity
building of non-physical projects in the collection of waste agricultural film. The
implementation of these activities will not cause direct losses to farmers and will enhance
farmers' environmental awareness and gradually change their farming methods and living
habits, and this change requires farmers to master certain production and living methods
and improve their own capabilities. The site selection of physical projects such as sewage
treatment facilities, garbage collection and treatment facilities, and manure recycling
facilities may have NIMBY effects, such as affecting the living environment and property
value of community residents. There is also a risk of the transmission of infection diseases
due to the migrant workers in the community. During construction and operation,
community health and safety problems may arise due to increased traffic, as well as noise
and dust. The construction process and operation process may have problems affecting
the community environment, traffic, and safety.
58. Land use and involuntary resettlement: Construction of urban sewage system, solid
waste collection system, and construction of manure treatment facilities involve small-
scale land acquisition and temporary land use. For example, a township sewage
treatment plant covers an area of about 5 mu (0.3 hectares), and a small solid waste
transfer station covers an area of about 0.5 Mu (330m2), about 5 mu (0.3 hectares) of
large-scale waste transfer and compression station, and about 5-10 mu (0.3-0.6 hectares)
of manure treatment facilities. For large-scale sewage treatment plants at the county level,
the land acquisition area is larger than the above-mentioned activities, with an area of
about 30 mu (2 hectares). The PforR explicitly excludes relocation activities involving any
ethnic minorities and minimizes land occupation. The assessment of possible small-scale
impacts on minority land use indicates that existing policies, regulations, and enforcement
systems are well placed and sufficient to protect their interests and restore their
livelihoods. During the implementation period, strengthen monitoring, so as to avoid and
reduce the impact on ethnic minorities as much as possible, and get reasonable
compensation when the impact occurs.
59. Ethnic minority impacts: Some project activities are located in ethnic minority areas. The
project design, construction, and maintenance need to carefully listen to ethnic minority
opinions, avoid and reduce major negative impacts on ethnic minorities, and respect
ethnic minority cultures and customs.
60. Rights and interests of vulnerable groups: the project construction may increase the
living costs of vulnerable groups, such as sewage treatment charges, solid waste
collection costs, etc. In addition, the voice and interests of vulnerable groups should be
reflected in engineering design, construction and operation management (e.g., sewage
treatment facility location, etc.).
61. Women's rights: A large number of rural women will benefit from the Program, and
women's opinions should be carefully listened to in Program’s project design, construction
and maintenance.
Induced impacts
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62. Induced E&S impacts of relevant activities of the Program: The downstream
facilities/activities associated with the Program will induce environmental and social impacts. In
June 2022, the ESSA team conducted site visits and due diligence to some sample facilities
relevant to the Program such as landfills, incineration plants, and waste plastics processing plants
in Honghu, Lichuan, and Enshi cities. Relevant track records on their E&S management were
obtained and reviewed, in terms of EIA and approval, environmental acceptance check for
construction completion, pollutant discharge permit, pollutant monitoring report, government
authorities’ inspection records, etc. Accordingly, the ESSA team conducted E&S risk identification,
screening, and rating for these linked facilities/activities (Table 3-1). The due diligence
investigation reveals that the domestic E&S management systems for these relevant
facilities/activities are well-established and can properly manage the E&S impacts of these
facilities/activities, and the overall E&S risks are controllable.
Table 3-1: Induced E&S Impact Screening
Relevant existing E&S impacts and management E&S risk
downstream rating
facilities/activities
Existing sanitary landfills or The existing sanitary landfills or incineration power plants had The general
incineration power plants involved land acquisition around 50 to 100 mu; and some labors E&S risk is
will receive, treat, and were involved during the construction and around 15 labors are Moderate to
dispose the domestic solid involved during the operation. The nature of these facilities Substantial.
waste and the WWTP determines that they usually generate various pollutants such as
sludge from the PforR. leachate, biogas, and odor which will have negative impacts on the
environment without proper management measures.
China has sound regulations, policies, standards, and guidelines on
managing the E&S impacts of these facilities/activities. The visited
sanitary landfills and incineration power plants have fulfilled their
E&S management duties in terms of EIA, SIA, environmental
acceptance check for construction completion, pollutant discharge
permitting, pollutant monitoring, etc. The related leachate, odor,
landfill gas, incineration emissions, fly ash and other pollutants have
been properly managed and monitored under strict supervision of
local government authorities such as HURDBs and EEBs, etc.
Composted livestock/ Crop farmer will calculate their farmland’s capacity of taking the The general
poultry manure will be used composted manure in accordance with relevant technical guidelines E&S risk is
as fertilizers on farmland or when receiving the treated manure from livestock/poultry farmer. Moderate.
woodland The agreement between the two parties will have to be submitted to
local ARAB for registration. This can help prevent excessive use of
manure fertilizers in farmland.
Existing organic fertilizer The existing organic fertilizer factories had involved land acquisition The general
factories will receive the around 10 to 30 mu; and some labors were involved during the E&S risk is
manure as raw materials to construction and around 5 labors are involved during the operation. Moderate.
produce commercial The nature of these facilities determines that they usually generate
organic fertilizers and sell various pollutants such as wastewater, biogas, and odor which will
them through mature have negative impacts on the environment without proper
market mechanism. management measures.
China has regulations, policies, and guidelines on managing the
E&S impacts of these factories. The visited organic fertilizer factory
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Relevant existing E&S impacts and management E&S risk
downstream rating
facilities/activities
has fulfilled their duties in EIA, SIA, environmental acceptance check
for completion acceptance, pollutant discharge permitting, etc. The
related wastewater, odor, and other pollutants have been properly
managed. The produced organic fertilizer products cannot enter the
market until they pass the quality assurance inspection and obtain
certification from ARABs.
Existing waste plastics The waste plastics recycling facilities had involved land acquisition The general
recycling facilities will around 10 to 20 mu; and some labors were involved during the E&S risk is
receive the mulch films as construction and around 5 labors are involved during the operation. Substantial.
raw materials to produce The nature of these facilities determines that they usually generate
plastic products and sell various pollutants such as wastewater, dust, and organic gas
them through mature emission which will have negative impacts on the environment
market mechanism. without proper management measures.
China has policies and guidelines on managing the E&S impacts of
waste plastic processing facilities/activities. The visited waste
plastics recycling factory has gone through certain E&S
management procedures such as EIA and been under supervision
of local EEB.
Downstream E&S impacts of TA activities
63. The TA activities such as conduction of public engagement under the RCS mechanism,
implementation of water allocation schemes, determination of ecological flow requirements, and
development of regulations, policies, and guidelines on water environment management, etc. will
help strengthen institutional capacity, raise public awareness of river and lake protection, and
improve water environment, so the long-term E&S effects are positive. Except that the TA activities
involve some labor issues, the implementation will have minimal or no direct adverse E&S impacts.
However, once the outputs of some TA activities become effective, they may trigger downstream
investments, which might induce indirect E&S impacts (see Error! Reference source not found.).
For example, if the research results of the water allocation and ecological flow schemes are put
into practice, there would be certain changes in various sectors’ water use; but it is unlikely to
induce significant adverse E&S impacts since the research is aiming to optimize existing water
allocation scheme fully considering and balancing the water demand of various sectors such as
industry, agriculture, human life, and ecosystem, etc. In summary, the TA activities under the PforR
are not likely to create high downstream E&S risks but it is obligatory that the TORs should clearly
state the requirements of carrying out E&S assessment during the TA implementation to ensure
that potential downstream E&S impacts are identified, assessed, and included in the TA outputs
with mitigation measures recommended. During the implementation of the PforR, the Bank will
provide support in preparation and implementation of the TA activities to make sure downstream
E&S impacts to be sufficiently considered.
Cumulative E&S effects
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64. During the implementation, different types of activities under the PforR (such as township
WWTPs, domestic solid waste collection and transfer, livestock/poultry manure treatment and
utilization, mulch film collection, soil and water conservation and other physical projects; and
development of policies on water environment management and other TA activities), other
investment activities under the Hubei government program (such as urban and rural living
environment improvement, industrial wastewater treatment, green agriculture development, etc.),
and other related projects in the basin or region (such as the World Bank Yangtze River Protection
and Ecological Protection PforR (P171644), the World Bank Green Agricultural and Rural
Revitalization PforR Phase 2 (P178907), etc.) may be implemented simultaneously or alternately
with each other. This might cause certain synergistic effects or cumulative impacts on the natural
or social environment of the Yangtze River Basin or Hubei Province. However, firstly, for the PforR
activities or other projects, the relevant land use must satisfy the requirements of local land use
master plans, which can ensure that the land use in a specific period be managed as required and
will not be carried out disorderly. Secondly, these activities will be carried out in different cities or
counties, so it is unlikely to have many development and construction activities going on at the
same time in the same place or on the same river, and their site-specific E&S impacts are unlikely
to become significantly cumulative (e.g. synergistic dust, noise, wastewater, solid waste,
vegetation disturbance, sediment into rivers, interference of migrant workers to local communities,
price changes, etc.). Thirdly, based on the PforR nature and the E&S exclusion criteria, the PforR
activities will not be carried out in environmentally or socially sensitive areas, nor will they include
water diversion, replenishment, and other activities that would physically influence the river
systems; instead, the PforR activities are all small-scale works for the purpose of environmental
protection and will not add negative cumulative E&S impacts in the region or basin. Finally,
together with the Hubei government program activities and other relevant projects, the PforR will
promote the cumulative net benefits to realize, by reducing pollutants discharge and improving
water environment in the Yangtze River Basin in Hubei Province, which is reflected in following
aspects:
65. Reduction of pollution discharge: The township-level WWTPs and sewerages to be
constructed/upgraded under the PforR will largely prevent pollutants from entering
surface-water bodies. They can usually realize a COD reduction of 70‒95%, an ammonia
nitrogen reduction of 80‒97%, a total phosphorus reduction of 50‒90%, and a total
nitrogen reduction of 70‒90%1. In addition, the livestock/poultry manure treatment and
utilization activities will also diminish pollutant discharge from numerous farms in the
region, usually realizing a COD reduction of 40‒95%, a BOD5 reduction of 60‒96%, a
coliform reduction of 70‒97%, and a total phosphorus reduction of 50‒95%2. The
improved domestic solid waste collection and transfer systems under the PforR will further
reduce NPS pollution in the basin. Together with other green development activities (e.g.,
industrial wastewater treatment, green agricultural farming, etc.) in the middle reaches of
the Yangtze River, the PforR will make a cumulative contribution to pollution reduction and
water quality improvement in the basin and the region.
66. Improvement of soil erosion: By constructing water and soil conservation forests and
works in the Qingjiang and Honghu basins in Hubei Province, the amount of regional soil
erosion can be effectively reduced. Together with other relevant investments under the
1 The estimation is based on the statistics of existing WWTPs under similar projects.
2 The estimation is based on the environmental monitoring reports of the World Bank/GEF
Guangdong Agriculture Pollution Control Project.
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Hubei government program (e.g., development of high-standard farmland), the PforR will
have cumulative contribution to soil erosion reduction in the basin and the region and will
help the province to achieve the objective of increasing the soil and water conservation
rate by 1.49% to 84.46% by 2025.
67. Improvement of river ecological environment: By ensuring ecological flow, managing
point and non-point pollution sources, and conducting soil and water conservation,
together with other relevant activities under the Hubei government program, the PforR will
largely reduce the amount of pollutants and sediments into rivers and increase or secure
ecological flow, so as to effectively improve the ecological environment quality of each
river, improve water quality, and enhance ecological functions, which will create huge
cumulative environmental benefits for the entire basin.
68. Strengthening of management capacity: Combined with other World Bank projects
implemented in the region, the activities of policy development, public engagement, and
RCS improvement under the PforR will further enhance the institutional organization,
improve the regulatory system, and strengthen the management capability on integrated
river basin management, thereby generating long-term benefits.
3.5 E&S Risk Rating
69. The E&S risks of the PforR activities have been rated applying four criteria: (1) likely E&S
effects, (2) E&S contextual risks, (3) institutional capacity and complexity risks, and (4) political and
reputational risks. The analysis concludes that these activities have different levels of E&S risk. A
few have potentially high risks and need to be excluded, whereas others have substantial,
moderate, or low risks that can be mitigated through proper E&S management measures. The
following sections provide a general E&S risk rating, and the details are presented in Error!
Reference source not found..
Likely E&S effects
70. Based on the PDO of the PforR and the above assessment of the E&S benefits and
impacts, it’s understood that the ecological rehabilitation and pollution control activities under the
PforR will generate E&S benefits including pollution reduction, improved river and lake water
quality, and reduced soil erosion, which will greatly improve the local ecological and living
environments and contribute to the ecological rehabilitation of the Yangtze River Basin. Meanwhile,
the adverse E&S impacts are predictable and can be avoided or mitigated by applying known and
demonstrated techniques and management measures under the domestic E&S management
systems.
71. Considering the wide coverage and various types of the PforR activities, it is therefore
concluded that the overall rating of the likely E&S effects is Substantial.
E&S contextual risks
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72. Except that policy development and other TA activities may cover a larger region or basin,
all physical activities under the PforR will be conducted in township or rural areas in Hubei. Under
China’s strict management mechanisms about nature reserves and ecological protection red lines,
and considering the Bank’s E&S exclusion principle, the PforR activities are unlikely to be
conducted in environmentally sensitive areas. Regular operation and maintenance of township-
level WWTPs, domestic solid waste transfer stations, mulch film collection spots, and livestock/
poultry manure treatment facilities will take place in or close to existing townships or villages
instead of environmentally sensitive areas such as nature reserves. In addition, activities that
would be conducted in areas with significant legacy pollution (e.g., industrial or mining pollution)
are also excluded from the PforR. To sum up, the environmental context risk is deemed Moderate.
73. Most program facilities (such as livestock and poultry manure recycling facilities) are
located on existing breeding farms without additional land use, and a few facilities may be located
away from breeding farms but are small in scale. The PforR is a green agricultural development
program and many activities, such as FALU and LURT, do not involve permanent land acquisition,
which needs a transfer from collective agricultural land to state-owned construction land. Instead,
the land can be used without changing the nature of collective-owned. And, according to the
regulations, these land use modalities are subject to voluntary negotiation and the lease price and
payment mode can be negotiated (not being compulsory) and the land used shall be reclaimed
after use. In this context, the risk of involuntary resettlement is low. These facilities are located in
remote corners of the countryside, keeping a distance from residential areas and public facilities
(such as schools, markets, and water sources), without affecting the daily life and health of
residents. Replacement of chemical fertilizer with organic fertilizer does not require completely
changing from chemical fertilizer to organic fertilizer. It just suggests using organic fertilizer and
decreasing the use of chemical fertilizer, and farmers might choose to use organic fertilizer freely.
While some activities will be located in ethnic minority areas, an analysis of secondary data shows
that these areas are not characterized by socio-economic disadvantage. The Program will not
require acquisition of entire individual farm holders or require the end of fertilizer use. Residents
and government departments in some areas still have little awareness of solid waste classification,
the public lacks a basis for judging the ecological health of rivers and lakes, and there is no
corresponding guidance document on the prevention and control of NPS pollution in rural areas.
These issues will be addressed through activities such as farmer training, facility improvement,
management, and monitoring enhancements. Therefore, given the low level of environmental
awareness among the beneficiary population, the social contextual risk of this Program is
moderate.
74. Therefore, the overall rating of the E&S contextual risks is Moderate.
Institutional capacity and complexity risks
75. The E&S risks/impacts management will involve various government authorities,
such as development and reform commission (DRCs), finance bureaus (FBs), ecology and
environment buraus (EEBs), housing and urban-rural development buraus (HURDBs), urban
management and law enforcement bureaus (UMLEBs), natural resources buraus (NRBs), water
resources bureaus (WRBs), agriculture and rural affairs buraus (ARABs), forestry and grass
buraus (FGBs), emergency management bureaus (EMBs), human resources and social security
bureaus (HRSSBs), health commissions (HCs), culture and tourism bureaus (CTBs), civil affairs
bureaus (CABs), and women’s federations (WFs), etc. These authorities perform regular E&S-
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related duties as per national/local regulations with sufficient institutional organization, staffing, and
budgets. Since the PforR activities are widespread in Hubei covering various regions and involving
numerous sectors, different authorities should make efforts to work together to implement the
PforR. DRC is the most powerful government authority in China, so Hubei provincial DRC, under
which the Yangtze River Belt Division works as the PPMO, has a strong capacity in cross-sector
coordination. All authorities concerned will handle their responsibilities in the PforR implementation
and the related E&S management under the instruction of central and provincial governments and
the coordination of the PPMO.
76. Therefore, the overall rating of the institutional capacity and complexity risks is
Moderate.
Political and reputational risks
77. The PforR will help improve ecological environment and reduce pollution in the
Yangtze River basin in Hubei, which is an important measure to implement the basin protection
and development strategy and consistent with national and local policies and plans with high
political security. Local people will largely benefit from the PforR and will make efforts to support it.
There will be minimal or no political risk to the PforR, which has been demonstrated by a variety of
similar projects that were successfully implemented in the past.
78. Therefore, the overall rating of the political and reputational risks is Low.
79. As a conclusion, the overall rating of the E&S risks associated with the PforR is
Substantial.
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4. Environmental Management System Assessment
4.1 General Principles
80. The Bank’s PforR ESSA Guidance provides six core principles for E&S system
assessment, of which the first three are associated with environmental management systems
(EMSs):
Core Principle #1 is about environmental assessment and management. Program EMSs
are designed to promote environmental sustainability in the program design; avoid,
minimize, or mitigate adverse impacts; and promote informed decision-making relating to
a program’s environmental effects (social impact assessment and management will be
described in Chapter 5).
Core Principle #2 is about natural habitat protection. Program EMSs are designed to
avoid, minimize, or mitigate adverse impacts on natural habitats resulting from the
program (physical cultural heritage protection will be described in Chapter 5).
Core Principle #3 is about health and safety management. Program EMSs are designed
to protect public and worker safety against the potential risks associated with exposure to
toxic chemicals, hazardous wastes, and otherwise dangerous materials under the
program (other items on health and safety will be described in Chapter 5).
81. China has substantially sound EMSs to respond to the Bank’s principles. Since the
“Environmental Protection Law�? became effective in 1979, China has been building up a legal
framework for environmental protection and pollution control. This framework consists of more than
80 laws, 120 departmental bylaws, more than 1,000 technical guidelines and standards, and
numerous local regulations. It is run under an institutional structure led by EEBs and assisted by
multi-sectoral authorities. The “Environmental Protection Law�? provides fundamental legislation for
China’s environmental protection and pollution control, stipulating basic requirements on
environmental management in terms of ecological protection redlines3, ecology and biodiversity
protection, EIA, "Three Simultaneousness"4, pollutant discharge permitting5, information
disclosure, and public consultation, etc.
3 China sets up ecological redlines in critical areas that have ecological significance,
environmental sensitivity, or vulnerability to strengthen protection of these areas.
4 Three Simultaneousness mechanism: The pollution prevention and control facilities of a
construction project must be designed simultaneously, constructed simultaneously, and
put into operation simultaneously with the main components of the project.
5 Enterprises and public institutions subject to pollutant discharge permit management
should discharge pollutants according to the pollutant discharge permit, and pollutant
discharge is prohibited without qualitied discharge permits.
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82. Following the Bank’s core principles and China’s environmental management
requirements, the Bank’s ESSA team classified the domestic EMSs that handle the environmental
issues related to the PforR activities (e.g., county/township WWTPs, domestic solid waste
collection and transfer, livestock/poultry manure treatment and utilization, mulch film collection, and
water and soil conservation, etc.) into four groups: (i) EIA and follow-up management system, (ii)
pollution control system, (iii) ecology protection system; and (iv) environmental safety and health
management system. The legal and regulatory framework, management mechanism, institutional
arrangement, and implementation performance for each system are reviewed, assessed, and
compared with the Bank’s core principles to identify any gaps to address during the PforR
implementation. The EMSs that will serve the PforR activities are listed in Table 4-1.
Table 4-1: Domestic EMSs Applicable to the PforR
Bank core Environmental impacts Domestic EMSs Responsible
principles authorities
1. Environmental 1. Construction stage: dust, noise, 3. EIA and follow-up 5. EEBs
assessment and wastewater, and solid waste generated in management system 6. ARABs
management construction of physical works. 4. Pollution control 7. HURDBs
2. Operation stage: effluent, sludge, and odor system (domestic
from WWTPs; odor, wastewater, biogas slurry wastewater, domestic
and residue from livestock/ poultry manure solid waste, livestock
treatment facilities; odor and leachate from and poultry manure,
domestic solid waste transfer stations; agricultural mulch film,
potential secondary pollution in mulch film etc.)
collection, etc.
2. Natural habitat 8. Design stage: site selection will relate to 11. Ecology 12. NRBs
protection local ecological protection redlines. protection system 13. FBs
9. Construction stage: vegetation and habitat (natural ecology 14. EEBs
disturbance; soil erosion, etc. protection, soil and 15. WRBs
10. Operation stage: minimal or no water conservation,
impacts. RCS water
environment
management)
3. Health and 16. Construction stage: workers’ health 18. Environmental 19. HCs
safety and safety risks. safety and health 20. EMBs
management 17. Operation stage: environmental management system 21. EEBs
accidents e.g., untreated wastewater overflow 22. ARAB
from WWTPs; risks to workers OHS and s
public health caused by odor from domestic 23. HURD
solid waste transfer stations and Bs
livestock/poultry farms; risks to workers OHS
and public health caused by dead animals at
livestock/poultry farms; etc.
4.2 EIA and Follow-up Management System
Legal framework
24. Based on the “Environmental Impact Assessment Law�? and combined with a series of
relevant regulations, standards and guidelines, China has established a comprehensive EIA and
follow-up management system for construction projects, including EIA, "Three Simultaneousness",
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environmental acceptance check for construction completion, pollutant discharge permitting, etc.
This system is under development towards a project life-cycle environmental management for
construction projects.
25. Environmental Impact Assessment Law (amended in 2018): It’s required that when
preparing government programs/plans6 and construction projects, potential environmental impacts
should be identified and assessed, mitigation measures should be recommended, and follow-up
monitoring and supervision should be conducted. It also stipulates basic requirements on EIA
classification, EIA approval hierarchy, and ban from construction without EIA approval, etc. Entities,
experts, and individuals are encouraged to participate in public consultation on an EIA.
26. Construction Project Environmental Protection Management Regulations (2017
Amendment): It reinforces the requirements on EIA screening and classification, EIA approval
hierarchy, “Three Simultaneousness�?, and environmental acceptance check for construction
completion, etc.
27. Pollutant Discharge Permit Management Regulations (2021): Enterprises, public
institutions, and other entities that generate pollutants in their operations are not allowed to
discharge pollutants into the environment unless they obtain a proper pollutant discharge permit.
28. Measures of Public Consultation in EIA (2018 Amendment): If a construction project or a
government program is likely to have potential significant impacts on the environment, it is required
to carry out public consultation during preparing EIA report.
29. Construction Project EIA Follow-up Supervision Regulations (trial, 2015): From EIA
preparation till project commissioning, EEBs should oversee whether mitigation measures are
implemented as per EIA instruments and approval documents. After the project becomes
operational, EEBs should check whether relevant environmental regulations are complied with and
whether post EIAs are conducted.
30. Regulations on Environmental Acceptance Check for Construction Completion
(2017): The Project Implementation Unit (PIU) is responsible for undertaking environmental
acceptance check for construction completion, preparing an investigation or monitoring report, and
disclosing it to the public. The project is not allowed to start commissioning until proper mitigation
measures and pollution control facilities are put in place with a pollutant discharge permit obtained
following relevant requirements. The project should not start formal operation until the mitigation
measures and/or the pollution control facilities have passed the environmental acceptance check.
6 These refer to land use plans; regional, basin, and sea area construction and use plans; as well as
special plans for industry, agriculture, stockbreeding, forestry, energy, water resources, traffic,
urban construction, tourism, and natural resource development.
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31. Construction Project EIA Classification Catalogue (2021): Criteria are given for
classifying environmental impacts of 173 types of projects in 55 sectors into three levels (Class A -
significant, Class B - moderate, and Class C - minor), based on project nature, project scale, and
contextual environment.
32. Fixed-Source Pollutant Discharge Permit Classification Catalogue (2019): Criteria are
given for classifying pollutant discharge permits of 112 types of operations into three categories
(focus management, general management, and registration management), based on pollutant
production, pollutant discharge, and impacts on the environment.
33. Mechanism of Information Disclosure for Construction Project EIA (2015): PIUs are
required to disclose environmental information including EIA instruments and project progress
(before, during and after the construction) throughout the project life cycle from site selection,
construction, to operation. EEBs should disclose information about EIA instruments approval and
supervision findings throughout the project life cycle.
34. EIA Technical Guidelines: China has developed more than 20 sets of EIA technical
guidelines, including the General Guidelines and a series of specific guidelines on different
environmental factors such as surface water, groundwater, soil, air, noise, and ecology and on
different industries such as water engineering, hydropower, coal, pharmacy, and steel, etc. The
General Guidelines provides fundamental guidance on EIA preparation in terms of alternatives
analysis, positive and negative impact assessment, long-term and short-term impact assessment,
direct and indirect impact assessment, cumulative impact assessment, mitigation measures, cost
estimate, and environmental management and monitoring plans, etc.
35. Pollutant Discharge Permit Application and Issuance Guidelines: China has developed
more than 70 guidelines on how to apply and issue pollutant discharge permits, including General
Guidelines and a series of specific guidelines for important industries (e.g., non-ferrous metals,
food processing, coal, pharmacy, steel, livestock and poultry farming, municipal sanitation, and
water and wastewater treatment, etc.). The entities subject to the permits are required to submit
pollutant discharge information, conduct pollutant monitoring, keep environmental management
track records, and prepare implementation reports. The guidelines also recommend good technical
practices on prevention and control of wastewater, waste gas, odor, and solid waste, etc.
36. Guidance on Ecology and Environment Zoning Management under the "Three Lines
and One List" Mechanism (Trial, 2021): It requires that ecological functions be kept from
degrading by applying ecological protection redlines; the environment be protected from
deteriorating by holding the environmental quality bottom lines; natural resources be conserved
by keeping the utilization limit lines; and construction or operation activities that are to be carried
out in any ecology and environment zones follow the lists of environmental entry criteria to
strengthen pollution control. The "Three Lines and One List" mechanism provides a strong
fundament for implementing strategic EIAs, program EIAs, and project EIAs and a basis for other
environmental work.
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37. Local regulations: Under the national environmental legal and regulatory framework,
Hubei provincial and municipal governments have developed corresponding local regulations and
documents, such as the “Hubei EIA Approval Hierarchy�? (2019), the “Hubei Enhancement of
Construction Project Three Simultaneousness and Environmental Acceptance Check for
Construction Completion�? (2021), the “Hubei Pollutant Discharge Permitting Management Methods�?
(trial, 2018), the “Enshi Implementation of Ecology and Environment Zoning Management under
the Three Lines and One List Mechanism�? (2021), and the “Jingzhou Implementation of Ecology
and Environment Zoning Management under the Three Lines and One List Mechanism�? (2021), etc.
These documents provide detailed procedures and requirements on project siting, EIA approval by
EEBs at different levels, pollutant discharge permitting, and other related issues.
Implementation mechanism and procedures
38. Environmental impact screening and classification: China has established a
detailed and comprehensive catalogue for screening environmental impacts and classifying EIA
processes proportional to project nature, location, scale, environmental context, etc. Environmental
impacts of construction projects are classified into three levels, namely Class A - significant
impacts, Class B - moderate impacts, and Class C - minor impacts. Correspondingly, the EIA
instruments are divided into three categories, namely EIA report (Class A), EIA form (Class B), and
EIA registration (Class C). With the environmental exclusion, the PforR will not include any Class A
projects; then the physical works to be supported by the PforR such as township-level WWTPs,
domestic solid waste transfer stations, and livestock/poultry manure treatment and utilization
facilities will be subject to EIA form or EIA registration (as indicated in Table 4-2); while other
physical activities such as mulch film collection would not involve EIA process due to the minor
impacts on the environment. This section only gives an initial analysis of EIA classification related
to the PforR activities and specific types of EIA instruments applicable to each project will be
determined by local EEBs during the PforR implementation.
Table 4-2: EIA Classification for the Key Physical Activities under the PforR
PforR activities Sectors EIA Categories
Category A: Category B: Category C:
EIA report EIA form EIA registration
Township and Wastewater Construction or Construction or Others (except for
county-level treatment and expansion of WWTPs expansion of WWTPs WWTP upgrading,
WWTPs recycling with a capacity of with a capacity of 500 t/d septic tank effluent
100,000 t/d and above and above but less than recycling,
100,000 t/d settlement tanks)
Domestic Urban and / Construction of new pipe Others
wastewater township pipe networks in
collection systems networks environmentally
sensitive areas
Domestic solid Domestic solid / Transfer capacity is 150 /
waste transfer waste (including t/d and above
kitchen waste)
transfer stations
Livestock/poultry Fertilizers Production of nitrogen Others /
manure used as fertilizers, phosphorus
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PforR activities Sectors EIA Categories
Category A: Category B: Category C:
EIA report EIA form EIA registration
organic fertilizers manufacturing fertilizers, or compound
fertilizers by chemical
methods
39. EIA preparation: PIUs are responsible for the quality and conclusions of EIA
instruments for their projects, and the agencies engaged to prepare the EIAs also have certain
responsibilities. Under the national EIA engineer qualification system, chief technical personnel
that are in charge of preparing EIA instruments must be certified EIA engineers who have passed
the national exam and gotten related certifications.
40. EIA technical review: In principle, EIA instruments should go through a technical
review before approval. Technical review of EIA report for a Class A project is usually undertaken
by a panel of at least 3 independent experts who will be randomly selected from EEBs’ expert
database. EIA forms for Class B projects can be reviewed by either an expert panel or by staff of
EEBs.
41. EIA approval: EIA report and EIA form should be submitted to competent EEBs for
approval, while a simple EIA registration can be done online by PIUs themselves. EIA instruments
(reports and forms) are approved by EEBs at different levels proportional to nature and scale of the
corresponding projects, magnitude of the environmental impacts, and sensitivity of the
environmental context, etc.
42. Public consultation and information disclosure: In EIA process, PIUs (or under
the assistance of EIA agencies) should carry out public consultation as required or needed,
generally through interviews, meetings, questionnaires, etc. The PforR doesn’t include Class A
projects that are subject to mandatory public consultation; while for Class B projects, public
consultation is not compulsory, but local EEBs would usually suggest the PIUs to conduct proper
public consultation if the projects are possible to have potential impacts on adjacent people (e.g.,
manure treatment facilities generate odor that would influence residents nearby). In addition, it’s
legally required that EIA instruments and approval comments be disclosed to the public for all
construction projects.
43. Environmental ‘Three Simultaneousness’: Design, construction, and operation of a
pollution control facility that is to support a construction project must be carried out simultaneously
with the project main parts. The project design report must include a specific chapter to specify
mitigation measures, pollution control facilities, and necessary cost estimates. To ensure the
pollution control facilities be built properly as designed, the PIU is responsible for including the
physical works of pollution control facilities into civil contracts and ensuring construction/installing
schedule and budget to be sufficient. The PIU is also responsible for implementing other mitigation
measures that are recommended in the EIA instruments and approval documents. The project is
not allowed to start operation until all pollution control facilities and mitigation measures have
passed the environmental acceptance check for construction completion.
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44. Environmental management in construction: PIUs are responsible for
implementing proper measures to mitigate environmental impacts during construction. As per
China’s “Standard Construction Bidding Regulations�?, a bidding document should include an
environmental protection chapter to include the mitigation measures that are recommended in the
approved EIA instruments. A standard civil work contract will also include an environmental
protection chapter to clarify the contractor’s duties on environmental management such as
implementing the mitigation measures. After the contract is signed, the contractor should develop
construction implementation programs which should include environmental management plans that
are reviewed and agreed upon by the PIU and supervision engineer prior to construction
commissioning. During construction, the PIU and supervision engineer will oversee the
implementation of the environmental management plans.
45. Environmental acceptance check for construction completion: When construction of a
project is completed, the PIU (or under the assistance of qualified agencies) should carry out a
specific check for environmental acceptance, by undertaking tests/investigations, preparing an
environmental acceptance check report, and seeking relevant experts’ comments. The PIU should
disclose the environmental acceptance check report within 5 working days once the report is
completed and keep it open to the public for at least 20 working days. Within 5 working days after
the disclosure, the PIU should log into the national platform for environmental acceptance check to
upload the project description, the review comments on the environmental acceptance check, and
other basic information etc. This information will be disclosed to the public by EEBs who will
supervise the procedures of the environmental acceptance check.
46. EIA Follow-up supervision: The follow-up supervision during EIA is to check
whether EEBs have justly fulfilled their duties in EIA approval, whether technical review agencies
have provided rational review comments on the EIA, whether EIA agencies have done accurate
EIA based on true data and in a reliable way, and whether PIUs have gone through proper EIA
procedures and conducting public consultation as required. The follow-up supervision after EIA is
to check whether EEBs have fulfilled their duties in “Three Simultaneousness�? supervision and
whether PIUs have implemented the “Three Simultaneousness�? and other environmental
management measures as required in the stages of design, construction, environmental
acceptance check, and operation.
47. Pollutant discharge permitting: Entities that are to discharge pollutants to the
environment are classified to three categories based on the quantity of pollutant production and
discharge and the potential impacts on the environment: (1) an entity with a large amount of
pollutant production or discharge or substantial environmental impacts is subject to focus
management; and (2) an entity with a medium level of pollutant production and discharge and
moderate environmental impacts is subject to general management; and (3) an entity with minimal
pollutant production and little environmental impacts is subject to online registration instead of
permitting. Any entity that is subject to pollutant discharge permitting should strictly follow the
permit requirements when discharging pollutants, conduct monitoring of the effluents/emissions,
establish environmental management and monitoring records and archives, and submit regular
reports to EEBs. Entities under focus management must install and maintain automatic monitoring
devices and connect them with the EEBs’ online systems. The indicative pollutant discharge
permitting classification for the PforR activities such as wastewater treatment, domestic solid waste
transfer, and livestock/poultry manure treatment and utilization (organic fertilizer production), etc. is
shown in Table 4-3; while other activities may not be subject to the permitting requirements. This
section only gives an initial analysis on permitting classification, and specific types of permits that
are applicable to the PforR activities will be determined by local EEBs during implementation.
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Table 4-3: Pollutant Discharge Permitting Classification for the Key PforR Activities
PforR Sectors Categories of Pollutant Discharge Permit
activities
Category A: focus Category B: general Category C: registration
management management management
County/ Wastewater Centralized industrial Domestic WWTFs (>=500 Domestic WWTFs (<500
township- treatment wastewater treatment; t/d and <20,000 t/d) t/d)
level WWTPs and recycling or domestic WWTFs
(>=20,000 t/d)
Domestic Sanitation Incineration or landfill Other facilities for disposing Centralized human feces
solid waste management facilities for disposing domestic solid waste (incl. treatment facilities (<50
transfer domestic solid waste kitchen waste) and sludge t/d); or domestic solid
(incl. kitchen waste) from WWTFs; centralized waste transfer stations
and sludge from human feces treatment (<150 t/d)
WWTFs, etc. facilities (>=50 t/d); or
domestic solid waste
transfer stations (>=150 t/d)
Livestock/ Fertilizer Production of nitrogen Production of potassium Others
poultry production fertilizers, phosphorus fertilizers, organic fertilizers,
manure fertilizers, or compound microbial fertilizers, or other
treatment fertilizers (excluding fertilizers (excluding mere
and mere mixing or sub- mixing or sub-package
utilization package process) process); or mere mixing or
sub-package process of
nitrogen fertilizers
Institutional organization and performance
48. EEBs are responsible for project EIA and follow-up management. The EIA and
Pollution Control Department under the Ministry of Ecology and Environment (MEE) is responsible
for overseeing EIAs and project life cycle environmental management at national level.
49. Provincial EEB of Hubei has a division of EIA and Pollution Control (4 staff
members) responsible for approving EIAs of large-scale projects or cross-city projects within the
province in accordance with the “Hubei EIA Approval Hierarchy�? (2019). Every year about 30
projects would go to Hubei Provincial EEB for EIA approval, covering the sectors of water
engineering, energy, transport, nuclear, and radiation, etc. This division is also responsible for
approving EIAs for government programs and policies and managing pollutant discharge permitting.
The provincial Environmental Assessment Center (20 staff) provides coordination services to the
provincial EEB in EIA approval. The provincial Environmental Law Enforcement Bureau (40 staff
members), responsible for organizing and guiding lower-level EEBs’ work in EIA follow-up
management, coordinating interprovincial environmental disputes, and investigating significant
environmental issues within the province etc., randomly selected 214 focus enterprises (10% of all)
to carry out on-site inspection in 2021 and have asked the problematic enterprises to solve their
issues e.g., inadequate online monitoring, inadequate operation of pollution control facilities, and
inadequate compliance of pollution discharge permits, etc.
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50. Municipal EEBs also have divisions of EIA approval (4-5 staff members) that are
responsible for approving EIAs for (i) projects that are approved by provincial government but are
not subject to provincial EEB’s approval of EIAs; (ii) projects that are approved by municipal
government; and (iii) projects that cross cities/counties in the municipal jurisdiction. Enshi and
Jingzhou municipal EEBs are involved in the PforR and each of them have completed EIA
approval for about 40 projects every year covering various sectors such as chemical, hospital,
livestock and poultry farming, transport, and water engineering, etc. Under each municipal EEB,
there is an environmental law enforcement team (LET, about 20 staff members) responsible for
EIA follow-up management within the municipal jurisdiction.
51. County EEBs are branches of municipal EEBs and have divisions of EIA approval (2-5
staff members). They are responsible for approving EIA forms for projects that are approved by
county/city governments. For example, Lichuan County EEB completed approval of 14 EIA forms
and 29 EIA registrations in 2022, 20% of them are about township WWTPs, organic fertilizer
production, and ecological rehabilitation etc. Each county EEB has an environmental LET
responsible for inspecting construction pollution, “Three Simultaneousness�?, construction
completion, and compliance of pollution discharge permits through spot check, special check, or
surprise check by means of drones, third-party services, maps, and site visits, etc. In addition,
there are usually one to two full-time environmental officials in each township government to report
to and support upper-level EEBs.
52. Information on EIA instruments and pollutant discharge are open to the public
through various online platforms such as the EIA Information Disclosure, the Pollutant Discharge
Permit Management, and the Pollution Source Monitoring Center, etc. In addition, the MEE has
other channels such as the National Ecological and Environmental Complaint and Reporting
Platform, the minster’s mailbox, the 12369 Environmental Hotline, the 12369 WeChat account, and
the 12345 Government Service Hotline for the public to report environmental complaints, track
feedback, and voice their opinions. For example, Honghu EEB had received and handled 320
cases of environmental complaints in 2021.
53. During the field visit, the ESSA team reviewed various track records on environmental
management for such sample facilities/activities as county/township WWTPs, domestic solid waste
transfer stations, livestock and poultry farms, and organic fertilizer production, etc. In general, their
EIA preparation, approval, and follow-up environmental management have been implemented as
required. For example, the Yanwo WWTP (1000m3/day) in Honghu City completed the EIA
preparation and approval in 2017, carried out the environmental acceptance check and obtained
the pollutant discharge permit in 2020, and have been carrying out routine monitoring exercises
(influent, effluent, odor, and noise) and sharing the monitoring data with local EEB through the
Hubei Pollution Source Monitoring Information and Sharing Platform. Another example in Lichuan
County, the Huaishan Cattle Farm (480 cattle per year) went through the EIA registration and
pollutant discharge permitting registration in 2020 and then got another EIA form prepared and
approved for constructing a 50,000 tone/year organic fertilizer production plant.
Brief summary
54. The EIA and follow-up supervision system, covering EIA, environmental acceptance
check for construction completion, pollutant discharge permitting, and pollutant monitoring etc. has
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been implemented in China for decades and has kept improving towards project life cycle
management. It is known from the ESSA team’s due diligence investigation that the sample
activities implemented in the past few years have gone through proper EIA and follow-up
management procedures as required. EEBs carried out inspection and supervision in different
ways to oversee projects’ performance in avoiding, reducing, or mitigating negative impacts on the
environment. The system is deemed satisfactory and complies with the Bank’s core principles.
4.3 Pollution Control System
4.3.1 Domestic wastewater management
55. The PforR will support development of domestic wastewater collection and treatment in
demonstration cities/counties and townships in Hubei Province. The ESSA team, therefore,
conducted due diligence to the related pollution control system.
Legal framework
56. Water Pollution Prevention and Control Law (amended in 2017): Entities responsible for
O&M of municipal WWTPs should obtain proper pollutant discharge permits as required, be
responsible for effluent quality, and treat and dispose of sludge in an appropriate way.
57. Municipal Stormwater Discharge and Wastewater Treatment Regulations (2014):
Entities responsible for O&M of municipal WWTPs should ensure the effluent quality satisfy
national and/or local pollutant discharge standards; monitor influent and effluent quantity and
quality following relevant regulations; dispose of sludge in a safe way; and report to local HURDBs
and EEBs the information on wastewater treatment quality and quantity, and sludge production and
disposal, etc.
58. Hubei Water Pollution Prevention and Control Regulations (2014): Municipal domestic
wastewater should be centrally treated. Entities responsible for O&M of centralized WWTPs should
apply for and obtain proper pollutant discharge permits from local EEBs following legal
requirements.
59. Hubei Soil Pollution Prevention and Control Regulations (2016): Entities that produce,
transport, store, or dispose of sludge should utilize the sludge as resources and/or treat it
harmlessly. It is prohibited to apply wastewater or sludge that do not meet farming standards onto
farmland.
60. 14th-Five-Year Plan for Municipal Wastewater Treatment and Resource Utilization
(2021): Capacity building should be promoted to improve wastewater collection and treatment in
the important townships of the Yangtze River Economic Belt. In townships, it’s encouraged to use
“biological and ecological�? technology in wastewater treatment and choose appropriate ways
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based on local conditions to build centralized WWTPs or connect to adjacent networks. Any new
WWTP should have a clear way of sludge disposal. Combined sludge disposal is the best choice
for cities/counties and their townships. Priority should be given to sludge stabilization and harmless
disposal, then sludge utilization as resources can be considered steadily.
61. Technical Guidance for WWTP Operation, Supervision, and Management (HJ2038-
2014): It clarifies specific O&M regulations on wastewater, sludge, odor, and noise treatment
processes and stipulates the requirements on setup of special laboratories and development of
environmental emergency plans, etc.
62. Discharge Standard of Pollutants for Municipal Wastewater Treatment Plant
(GB18918-2002): Based on the functions and targeted quality of effluent receiving water and the
wastewater treatment techniques, the effluent discharge standards applicable to WWTPs are
categorized to three classes, namely Class I (IA and IB), Class II, and Class III, in terms of 19
major water pollutants, e.g., COD, BOD5, SS, TP, TN, NH3-N, grease, oil, heavy metals, etc.
According to the requirements on local air quality and air pollution control techniques, the air
emission standards applicable to WWTP boundaries are also categorized to three classes for NH4,
H2S, odour, and methane. Sludge should be stabilized and dewatered, and the pollutant contents
should comply with relevant standards when the sludge is used for farming.
63. Hubei has also issued relevant local regulations, such as the “Hubei Township Domestic
Wastewater Treatment Guidance�? (trial, 2017), the “Hubei Township Domestic Wastewater
Treatment Facilities O&M Guidance�? (trial, 2017), and the “Hubei Municipal Wastewater Treatment
Upgrading Action Plans (2020)�?, etc.
Implementation mechanism and procedures
64. Hubei Province has established a clear mechanism for municipal WWTPs management.
Unified O&M: Bidding for construction and O&M of WWTPs at township and county levels should
be organized in a unified way by county governments. Entity who undertakes WWTP construction
should bear the corresponding O&M responsibility and the O&M funds should be borne by county
governments. Simultaneous construction of pipelines with WWTPs: Pipelines must be planned,
designed, constructed, and put into operation simultaneously with the associated WWTPs. It’s
promoted to build separate sewer systems, and existing combined sewers should be gradually
transformed into separate systems in due time. Advanced wastewater treatment: Five important
processes including pre-treatment, biological treatment, advanced treatment, sludge treatment,
and management control should be applied to municipal WWTPs. All WWTPs at county and
township levels should apply Class IA standard of GB18918 for effluent discharge, and more
stringent standards would be used in ecologically sensitive areas. Sludge treatment and disposal
facilities should be constructed simultaneously with the county and township WWTPs.
Institutional organization and performance
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65. As the key sector authority, Hubei Provincial HURDB has an Urban Development
Department (8 staff members) to manage municipal WWTPs at city and county levels, and a
Township Management Department (7 staff members) to manage WWTPs at township level.
County-level HURDBs also have corresponding divisions (1-6 staff members) to specifically
supervise the construction and O&M of WWTPs at county and township levels. As the
environmental protection and pollution control authorities, EEBs at county level delegate their
environmental LETs to oversee the O&M performance of WWTPs, the compliance of pollution
discharge permits, and the concentrations of discharged pollutants through spot check, and special
inspection, etc.
66. Hubei is the first province in China to have achieved domestic wastewater treatment
covering all cities, counties, and townships. More than 80% of WWTPs in Hubei are constructed
and operated through various forms of PPP with integration of wastewater collection and treatment
services. For example, Biyuan, Bohua and Tianchuang companies have been entrusted to operate
township WWTPs in Enshi, Lichuan and Honghu cities, respectively. These third-party companies
provide professional O&M services as per the signed service agreements. Their O&M personnel
have been trained and are holding professional certificates on facilities operation and safety
management. This mechanism helps ensure effective O&M, funding, and pollutants monitoring, etc.
In Lichuan, with the implementation of the “Lichuan Township WWTPs PPP O&M Performance
Verification Plan�?, a consulting firm was engaged to work with local HURDB, EEB, and FB to form
a verification team and conducted monthly and semi-annual assessment of the third-party
company’s O&M performance. The assessment records provided to the ESSA team show that the
O&M performance were deemed satisfactory. Apart from this, a small number of township-level
WWTPs are operated by county level HURDBs instead, for which regular operation, maintenance,
and monitoring can also be ensured, though some O&M personnel need to improve professional
skills.
67. All municipal WWTPs in Hubei are required to meet Class IA standards of GB18918, and
currently more than 90% of the monitoring cases are satisfactory. It’s identified from the due
diligence investigation to Honghu, Enshi and Lichuan cities that, in addition to online automatic
monitoring of quality and quantity of influent and effluent, the O&M companies of the WWTPs also
use their own laboratories or engage professional agencies to conduct more comprehensive
environmental monitoring. For example, at Yanwo Township WWTP of Honghu City, online
monitoring is undertaken to the parameters of pH, COD, NH3-N, TP and TN following the
requirements of the pollutant discharge permit; in addition, manual sampling is also carried out
quarterly to test color, SS, BOD5, fecal coliform, anionic surfactant, oil, and grease; and manual
sampling is conducted semi-annually to heavy metals (e.g. total mercury, alkyl mercury, total
cadmium, total chromium, hexavalent chromium, total arsenic, and total lead) and gas emissions
(e.g. ammonia, hydrogen sulfide, and odor). These monitoring data have been disclosed on the
"Hubei Pollution Source Monitoring Information Disclosure Platform". The ESSA team took a brief
analysis of some sample monitoring data and found that the effluent of the WWTPs satisfied the
Class IA standards. Since the pre-treatment and the sludge treatment processes where more odor
is generated have been enclosed, the tested odor could also meet the standards based on the
monitoring data.
68. Sludge is usually dewatered to contain 80% of water within the county/township WWTPs
and then sent to larger urban WWTPs for advanced drying treatment before being delivered to
landfill site (in Honghu City) or used as garden fertilizers (in Enshi City) or transported to organic
fertilizer plants as raw materials (in Lichuan City). In the process of sludge transfer, four copies of
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records are made and given to four related parties including tsludge generation entity,
transportation agency, receiving entity, and local HURDB.
Brief summary
69. It’s demonstrated that the regulatory framework, implementation mechanism, and
institutional arrangement about county and township WWTPs management are well established
especially under the professional services of third-party O&M companies. The system is found
equivalent to the WBG’s EHS Guidelines for Water and Sanitation and it covers good international
industry practice (GIIP). It can well manage the related environmental issues and promote
sustainable wastewater treatment and complies with the Bank’s core principles.
4.3.2 Rural domestic solid waste management
70. The PforR will support integrated urban-rural domestic solid waste collection and transfer in
demonstration cities/counties in Hubei. The EESA team, therefore, carried out investigation on
pollution control within this system.
Legal framework
71. Solid Waste Pollution Prevention and Control Law (amended in 2020): Integrated
management systems should be established for domestic solid waste sorting, collection, transfer,
and disposal. Cleaning, collection, transportation, and treatment of urban and rural domestic solid
waste should comply with relevant regulations to prevent pollution to the environment.
72. Air Pollution Prevention and Control Law (2018 Amendment): Any entity who emits odor
to the atmosphere should take measures to prevent odor from influencing adjacent residents.
73. Soil Pollution Prevention and Control Law (2019): Measures should be taken as per
laws/regulations to prevent soil pollution in construction and operation of solid waste disposal
facilities.
74. Hubei Soil Pollution Prevention and Control Regulations (2016): Proper mechanisms
should be established to improve urban and rural domestic solid waste collection, transfer, and
treatment. Corrosion resistance, seepage prevention, dust removal and other measures should be
taken at landfill and incineration facilities to prevent soil pollution.
75. Hubei Air Pollution Prevention and Control Regulations (2018): Solid waste treatment
plants and transfer stations should be sited in a rational way. Proper distances should be kept from
adjacent sensitive receptors; purification facilities should be installed; and other measures should
be taken to reduce odor emissions and impacts.
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76. The 14th Five-Year Plan on Domestic Solid Waste Sorting and Treatment
Development (2021): It’s required to improve domestic solid waste sorting, collection, and transfer
facilities; promote recycling facilities; promote kitchen waste treatment facilities; improve hazardous
waste collection and transportation systems; pilot demonstrations of small-scale incineration
facilities; and develop comprehensive solid waste disposal bases.
77. Rural Domestic Solid Waste Collection, Transportation, and Treatment Technical
Standards (GB/T51435-2021): Rural domestic solid waste can be divided into five categories:
recyclables, perishables, hazardous waste, construction waste, and other garbage. Transportation
and disposal of recyclables should connect to existing recycling systems. Hazardous waste should
be collected and treated by qualified entities. Construction waste should be collected separately
and buried nearby. Perishable waste should be collected separately and used as resources locally.
Rural domestic solid waste collection sites should be sited by keeping a proper distance from
concentrated residential regions and environmentally sensitive areas such as farmlands, rivers,
ponds, and drinking water sources, and should be equipped with ventilation, dust removal,
deodorization, and acoustic insulation facilities, etc. Domestic solid waste transfer stations should
set up at townships and the ventilation, dust removal, deodorization, and acoustic insulation
facilities should be well operated and maintained.
78. In addition, China has developed other guidelines on domestic solid waste management
such as the “Technical Guidelines for Domestic Solid Waste Collection and Transportation�?
(CJJ205-2013), and the “Technical Guidelines for Domestic Solid Waste Transfer Stations�?
(GJJ47-2006), etc. Hubei Province has also issued relevant regulations including the “Hubei Urban
and Rural Domestic Solid Waste Sorting Plan�? (2021-2025), the “Hubei Promoting Urban and Rural
Domestic Solid Waste Sorting Work Plan�? (2019), the “Hubei Kitchen Waste Management
Measures�? (2020), and the “Hubei Urban and Rural Domestic Solid Waste Sorting Technical
Guidelines�? (2020) etc. In addition, the “Hubei Urban and Rural Domestic Solid Waste
Management Regulations�? has also been developed and is under review.
Implementation mechanism and procedures
79. Following the national government’s requirements on domestic solid waste sorting and
utilization, Hubei Province has developed implementation mechanisms: (1) Reduction: Reduce
excessive packaging of products, encourage residents to use special containers to store kitchen
waste, call for "Clear Your Plate" campaigns in catering industry, collect residents’ decoration
waste at designated locations, and use waste fruits and vegetables as resources, etc. (2) Sorting:
Divide urban domestic solid waste into "hazardous waste, recyclables, kitchen waste, and other
waste"; and divide rural domestic solid waste into "hazardous waste, recyclables, perishables, and
other wastes". (3) Collection: Set up environment-friendly domestic solid waste collection sites
and adopt unified logos for collection sites and containers throughout the province. (4)
Transportation: Improve separate transportation of different types of domestic solid waste and
prohibit mixing after sorting. (5) Disposal: Promote hazardous waste disposal and enhance whole-
process pollution control; accelerate kitchen waste disposal facilities development; encourage to
use rural perishable waste as fertilizers; accelerate incineration facilities development; and
encourage recycling of large-size solid waste, etc.
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Institutional organization and performance
80. Ministry of Housing and Urban-Rural Development is responsible for top-level design and
guidance of rural domestic solid waste management nationally. Hubei Provincial HURDB is
responsible for planning, construction, and management of province-wide rural solid waste
collection, transfer, and disposal systems. Rural solid waste collection and transfer activities under
the PforR will be managed by HURDBs or other authorities at county level. For example, in
Lichuan, the responsible authority is the Urban Management and Law Enforcement Bureau
(UMLEB, 8 staff members); a special office has been established for domestic solid waste
management; and there are also one to three staff members designated at each township to
support the regular bimonthly inspections.
81. As reported by Hubei Provincial HURDB, since 2017, a domestic solid waste management
system has been established following the principles of “household sorting, group cleaning, village
collection, township transfer, county treatment�? throughout the province. Under the system, 156
domestic solid waste treatment facilities and 1987 township transfer stations have been
constructed. The ESSA team learned from the field visits in Honghu that 19 townships have set up
deep buried garbage bins. Each garbage bin is equipped with GPS devices and monitored over the
city’s online platform. The deep buried garbage bin is designed to have a cover, which can help
prevent odor from spreading. There are 40 lifting transfer vehicles (16 ton), 19 inspection vehicles,
and 2 safety check vehicles in Honghu; and the Urban Management Bureau signed a contract with
two companies (Jinlv and Longcheng) to provide integrated collection and transportation services
especially for the 455 deep buried garbage bins in 10 townships (e.g., Xiaogang) and 341 deep
buried garbage bins in 9 townships (e.g., Yanwo), respectively.
82. In the process of compressing solid waste, a small amount of leachate will be generated. In
general, township-level transfer stations only have storage tanks instead of leachate treatment
facilities. The leachate is then transported to leachate treatment stations at local landfill sites or
incineration plants. The ESSA team conducted field visits to some sample landfills and incineration
plants in the three sample cities. These facilities are operated under the strict supervision of local
HURDBs that are the sectoral authorities; and they are also under the strict supervision of local
EEBs since they belong to important pollutant discharge units. Therefore, the pollution control
measures are relatively sound and comprehensive at these facilities and pollutant monitoring
exercises are undertaken regularly, which can help to make the related environmental risks
become controllable.
Brief summary
83. Hubei has a sound legal framework, rational institutional arrangement, and sufficient
staffing on urban/rural domestic solid waste management, and the system is found equivalent to
the WBG’s EHS Guidelines for Waste Management Facilities and it covers GIIP, which makes it a
qualified system to meet the need of domestic solid waste collection and transfer under the PforR.
The government is also making effort to realize a whole process of solid waste classification and
recycling. The ESSA team also noted some problems in the investigation, for example some solid
waste transfer stations needed to improve odor collection and treatment measures.
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4.3.3 Livestock/poultry manure management
84. The PforR is to support improvement of manure management and utilization for existing
livestock and poultry farms. The ESSA team, therefore, carried out investigation to the related
pollution control system.
Legal framework
85. Water Pollution Prevention and Control Law (amended in 2017): Livestock and poultry
farms should have proper facilities to treat or utilize manure and wastewater, and sustainable O&M
should also be ensured to guarantee the treated effluent to meet relevant discharge standards.
86. Solid Waste Pollution Prevention and Control Law (amended in 2020): Entities that
operate livestock and poultry farms should collect, store, utilize, or dispose of manure and other
solid waste in a proper and timely manner.
87. Air Pollution Prevention and Control Law (2018 Amendment): Livestock and poultry
farms should collect, transport, and treat wastewater, manure, and dead animals to prevent odor
emission.
88. Soil Pollution Prevention and Control Law (2018): Collection, storage, utilization, or
disposal of livestock/poultry manure, biogas residues, and biogas slurry should be under
supervision and inspection to prevent pollution to soil.
89. Livestock Farming Law (2015): Livestock and poultry farms should have proper facilities
to treat and/or utilize manure, wastewater, and other waste. Any violation that may result in
environmental pollution should take corrective measures and compensate for related losses.
90. Large-scale Livestock and Poultry Farming Pollution Prevention and Control
Regulations (2013): The carrying capacity of the environment and the needs of pollution control
should be considered in husbandry development, and the species, scale and total amount of
livestock and poultry farming should be determined in a scientific way. Various ways of utilization of
livestock and poultry manure is encouraged, e.g., returning manure to farmland, producing biogas,
and manufacturing organic fertilizers, etc.
91. Hubei Livestock Farming Regulations (2014): Large-scale livestock and poultry farms
are required to go through farming registration, obtain farming codes, and establish farming
archives. No livestock and poultry farms are allowed to start operation if they don’t have proper
pollution control facilities, or their pollution control facilities are not qualified, or they don’t entrust
thirty parties to treat or utilize their wastes when they cannot do it by themselves. Livestock and
poultry farms should ensure that their pollution control facilities are well operated.
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92. Livestock and Poultry Pollution Control Technical Policy (2010): It stipulates the
general principles of pollution reduction, clean production, resources utilization, and secondary
pollution control for livestock and poultry manure management.
93. Livestock and Poultry Manure Harmless Treatment Guidelines (GBT36195-
2018): The guidelines specify technical requirements on farm layout, manure storage, wastewater
treatment, manure treatment and utilization, farm management, dead animal disposal, pollutant
monitoring, etc.
94. China has promulgated other relevant policies, guidelines, and standards, such as
the “Further Clarifications on Applying Livestock Manure to Farmland and Supervising Livestock
Farming Pollution�? (2020), the “Technical Guidelines on Livestock Manure Composting�?
(NY/T3442-2019), the “Technical Guidelines on Livestock Manure Application to Farmland�?
(GBT25246-2010), the “Technical Guidelines on Livestock Farming Pollution Control Engineering�?
(HJ497-2009), the “Livestock Pollutant Discharge Standards�? (GB18596-2001), the “Technical
Guidelines on Land Capacity of Carrying Livestock and Poultry Manure�? (2018), etc.
95. Hubei has also developed a series of relevant local regulations, such as the “Hubei Joint
Meeting Mechanism for Livestock and Poultry Manure Treatment and Utilization�? (2018), the
“Hubei Work Plans on Livestock and Poultry Manure Utilization�? (2017), the “Hubei Verification
Methods for Livestock and Poultry Manure Utilization�? (trial, 2017), the “Hubei Technical Guidelines
on Livestock and Poultry Farming Zones�? (trial, 2016), and the “Hubei Livestock and Poultry Farms
Registration Methods�? (2015), etc.
Implementation mechanism and procedures
96. Pollution prevention: (1) Prepare local livestock and poultry farming pollution control plans.
(2) Define and apply different zones related to livestock and poultry farming, including forbidden
zones, restricted zones, and farming zones. (3) Construction, rehabilitation, or expansion of
livestock and poultry farms or manure treatment facilities should follow relevant government plans
and carry out EIAs.
97. Pollution management: (1) Good farming practices and techniques (e.g., dry collection of
manure, biological fermentation bed, etc.) should be applied to reduce the generation of
wastewater and odor. (2) Specific manure storage areas must be set up by using anti-seepage,
anti-runoff, and stormwater-wastewater separation techniques. (3) Measures should be taken to
prevent manure from dropping and leaking in collection and transportation activities. (4) Reuse of
treated manure in farmland or discharge to the environment should comply with applicable national
and/or local standards. (5) If livestock/poultry manure, biogas residue, and biogas slurry are used
as fertilizers in farmland, a utilization plan should be developed to determine the farmland type,
planting pattern, and manure application time and quantity based on the livestock and poultry
farming capacity. Applying treated manure as fertilizers in farmland must match the farmland’s
carrying capacity; and if there is not enough farmland, third-party entities should be engaged to
utilize the manure.
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98. Utilization: Return livestock and poultry manure to farmland or use them to make fertilizers
and biogas; integrate livestock and poultry farming together with crop farming; develop machinery
in manure utilization; and enhance management of commercial organic fertilizer products that are
made from livestock and poultry manure, etc.
Institutional organization and performance
99. County ARABs are responsible for guiding, serving, and overseeing livestock and poultry
manure treatment and utilization, and each county ARAB has a livestock and poultry management
division to undertake related daily inspection and routine management. For example, in Lichuan,
the Livestock and Fishery Division (5 staff members), the Soil and Fertilizer Division (5 staff
members), and the township-level Husbandry and Veterinary Service Centres (54 staff members)
under the ARAB carry out regular inspections on the O&M of manure treatment and utilization
facilities, conduct supervision on farmers’ practices of applying manure fertilizers to farmland, and
provide instructions and services to farmers once a month. Another example, the Livestock and
Veterinary Station under Badong ARAB would check all new farms and require them to establish
appropriate manure treatment facilities during preparation and organize professionals to provide
training and guidance to existing livestock and poultry farms to improve their manure management.
Meanwhile, EEBs are responsible for inspecting pollution control performance related to livestock
and poultry farming. County level environmental LETs (7-26 staff members) conduct spot checks,
special checks, and joint inspections on the farms’ performance in terms of EIA preparation and
approval, Three Simultaneousness, environmental acceptance check, pollutant discharge
permitting, pollution reduction, and pollutant monitoring, etc.
100. There are more than 20,000 large-scale livestock and poultry farms in Hubei, and
they have completed registration at local ARABs to report the information about farm siting,
farming conditions, epidemic prevention, manure treatment, dead animal treatment, agreements on
manure fertilizers utilization, EIA instruments, and pollutant monitoring reports, etc. The
registrations are reviewed by county, municipal and provincial ARABs level by level. As a reward
for the registration, they could enjoy certain privileges following relevant national and/or provincial
policies. Through this way together with on-site inspections, ARABs are improving supervision on
livestock and poultry manure treatment and utilization.
101. The ESSA team found in the field visits and investigations that good practices such as dry
collection of manure and other techniques that governments promote have been widely applied at
large-scale farms. Separation of dry and wet manure at animal houses helps reduce the amount of
washing wastewater and the odor emission from wet manure. It’s also found that the related
environmental management requirements in terms of EIA, environmental acceptance check,
pollutant discharge permitting, and pollutant monitoring has been largely fulfilled at the large-scale
farms. (1) Wenshi Pig Farm is raising about 2,300 pigs a year in Honghu. They separate the
manure into dry parts and wet ones. The dry manure is composted and then sold to organic
fertilizer factories; while the wet parts together with the washing wastewater is delivered to and
treated at the "UASB+A2O" process of the wastewater treatment system (300 tons/day) within the
farm and the treated effluent is discharged into the oxidation pond (lagoon) after meeting Class I
standard of the “Integrated Pollutants Discharge Standards�?. The biogas generated in the UASB
process is burned as waste gas emission; the biogas residue together with the sludge and the dry
manure are composted to be fertilizers; and the biogas slurry goes back to the A2O process for
treatment. (2) Huaishan Cattle Farm is under upgrading to raise 1000 cattle in Lichuan. The
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techniques of dry manure collection and biological fermentation bed have been applied in the
upgraded cattle sheds. 60cm thick of fermentation beds are established using straws, saw dusts,
and rice husks as bedding materials, which can effectively absorb not only manure and urine but
also odor. The dry manure combined with the bedding materials are collected and delivered to the
composting zones within the farm and turn into semi-finished organic fertilizers for sale. The wet
manure goes into digestors for fermentation. A part of the generated biogas is used for gas supply
in the farm and the rest is burnt through torches; the generated biogas residues are composted
together with the dry manure; and the biogas slurry is applied in adjacent farmland. They still have
some cattle sheds in the farm waiting for upgrading where odor issues are significant.
Brief summary
102. It’s concluded that Hubei has sound legal framework and complete institutional organization
which are sufficient to well manage the pollution issues related to livestock and poultry farming.
The due diligence also discovered that some old farms lack odor treatment measures, so it’s
suggested to apply proper techniques such as dry manure collection, biological fermentation bed,
and deodorant spraying to reduce odor impacts.
4.3.4 Mulch film management
103. The PforR is to support agricultural mulch film collection in the demonstration
cities/counties of Hubei. The ESSA team, therefore, carried out investigation to the related pollution
control system.
Legal framework
104. Solid Waste Pollution Prevention and Control Law (amended in 2020): Entities that
generate straw, mulch film residues, pesticide packages, and other cropping waste should promote
recycling and prevent pollution.
105. Soil Pollution Prevention and Control Law (2018): Farmers are encouraged to use
biodegradable agricultural mulch films. Producers, sellers, and users should recycle waste mulch
films in a timely manner. Entities and individuals are encouraged to recycle agricultural mulch films.
106. Hubei Soil Pollution Prevention and Control Regulations (2016): Enterprises,
organizations and individuals involved in waste plastic recycling should take measures to prevent
soil pollution.
107. Agricultural Mulch Film Management Regulations (2020): Agricultural mulch film
producers and sellers should establish and keep mulch film sales records; farm owners, farmer
cooperatives, and other users should establish and keep use records; mulch film collection and
recycling entities should keep collection and recycling records; and mulch film users should pick up
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mulch film residues in a timely manner and deliver them to collectors or recycling enterprises
instead of dumping, burying, or burning them.
108. The National Plastic Pollution Control Action Plans (2021): Forbid production or selling
of any polyethylene mulch film that is thinner than 0.01mm. Encourage scientific research and
practical application about fully biodegradable mulch films. Promote mulch film recycling, develop
demonstration counties, and promote mechanized picking, professional recycling, and resource
utilization. Support waste plastics recycling projects. Strengthen environmental management in
waste plastic recycling to prevent secondary pollution.
109. Technical Guidelines on Waste Plastics Recycling (GB/T 39171-2020): The guidelines
specify the general requirements on waste plastics recycling in terms of collection, sorting, storage,
and transportation, etc.
Implementation mechanism and procedures
110. Waste reduction: Prohibit to produce or sell polyethylene mulch film that is thinner than
0.01 mm; accelerate scientific research on fully biodegradable mulch films; and promote
demonstration of applying degradable films for main crops.
111. Improve picking and collection: Establish agricultural mulch film collection stations,
introduce marketing mechanism, and promote mechanical picking and professional collection.
112. Resources recovery: Governments support waste plastics recycling activities.
113. Pollution prevention and control: Strengthen environmental management of waste
plastic recycling enterprises and remedy unqualified enterprises and illegal activities to prevent
secondary pollution.
Institutional organization and performance
114. The provincial DRC and EEB has establish a joint meeting mechanism involving relevant
government authorities to guide and coordinate plastics pollution control. Local governments are
the responsible parties for plastics pollution management. ARABs are responsible for supervising
mulch film collection, building recycling systems, and inspecting any illegal use of mulch films.
115. Local agricultural environment protection stations (AEPSs) or agricultural service centers
(4-8 staff members) under county ARABs are responsible for daily work in mulch film management.
For example, Lichuan AEPS (4-8 staff members) has set up 70 mulch film collection sites and one
mulch film sorting and transfer center, conducted experiments on biodegradable mulch films
application, and provided biodegradable mulch films to farmer cooperatives and large farms free of
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charge. Another example, Jianshi AEPS (4 staff members) has set up 94 mulch film collection sites
and one county-level mulch film recycling center; frequently visited villages and farmland;
supervised people to pick up mulch films that spread around the fields, ditches, roadside, wire
poles, and trees, and successfully collected 247 tons of mulch films in 2020. Local environmental
LETs (7-30 staff members) under county EEBs, monitor and supervise pollution control related to
mulch film collection and recycling by the ways of spot checks, special checks, and joint
inspections, etc. As reported by some demonstration cities/counties, it’s still not easy to well
manage mulch films at present mainly because of high recycling costs, lack of policy incentives,
and insufficient technology popularization.
Brief summary
116. Hubei has an improving system composed of legal framework, institutional arrangement,
and implementation mechanism, which is qualified to manage mulch film issues and expected to
be improved through implementing the PforR.
4.4 Ecological Environment Protection System
4.4.1 Natural habitats protection
117. Implementation of the physical works and agricultural activities under the PforR may relate
to local natural ecosystem and ecological protection redlines, so the ESSA team conducted
investigation to the relevant management systems.
Legal framework
118. Wetland Protection Law (2022): Wetlands are classified into important wetlands and
general wetlands for better management in China. Except for national major projects, no other
project is allowed to occupy national important wetlands. All construction projects are required to
avoid wetlands in site or route selection; and if it is impossible to avoid wetlands, efforts should be
made to minimize occupation and proper measures should be taken to mitigate the adverse
impacts on the ecological functions of the wetlands. If site or route selection cannot avoid national
important wetlands, comments must be sought from the national FGB. If provincial important
wetlands or general wetlands are involved, comments must be sought from the FGBs at county
level or above.
119. Wild Animal Conservation Law (2018 Amendment): If a construction project may have
adverse impacts on nature reserves or wild animals’ migration routes, the EEB that is in charge of
reviewing and approving the EIAs, should seek opinions of the same-level wildlife protection
authorities. Any illegal hunting of wild animals and destruction of natural habitats are prohibited.
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120. Wild Plant Protection Regulations (2017 Amendment): If a construction project may have
adverse impacts on growing environment of national or local protection wild plants, the PIU must
ensure the impacts be assessed appropriately in the EIA. Any entities or individuals are prohibited
to illegally collect wild plants or damage their growing environment.
121. Nature Reserve Regulations (2017 Amendment): A nature reserve must be set up to
protect an important habitat. No one is allowed to enter core zones of nature reserves (except for
approved scientific research activities). No production facility is allowed to be built in core and
buffer zones of nature reserves. No production facility that may pollute the environment or destroy
natural resources or landscape is allowed to be built in experimental zones.
122. EIA Technical Guidelines - Ecological Impacts (HJ19-2022): Efforts should be made to
avoid occupation of any ecological sensitive areas when selecting site or route for a construction
project. Ecological impacts at different stages should be identified, predicted, and evaluated.
Feasibility of the project should be determined by taking consideration the ecological impacts.
Ecological protection measures should be proposed in accordance with the mitigation hierarchy of
avoidance, reduce, restoration, and compensation.
123. Guidelines on Establishing National Park-based Nature Conservation Systems (2019):
The aim is to build a Chinese special natural protection system dominated by national parks.
Nature conservation sites are classified into three categories based on the ecological value and
significance: national parks, nature reserves, and natural parks.
124. Guidance on Defining and Applying Three Control Lines in Territorial and Spatial
Planning (2019): The three control lines, namely, ecological protection redlines, permanent
farmlands, and urban development boundaries, should be defined and applied in an integrated way.
When defining ecological protection redlines 7, priority should be given to areas that have
extremely important ecological functions, such as important water conservation, biodiversity
maintenance, water and soil conservation, wind prevention and sand fixation, and coastal
protection, etc., as well as areas that are extremely sensitive or fragile in terms of soil erosion,
desertification, rock desertification, and coastal erosion, etc.
125. Opinions on Defining and Applying Ecological Redlines (2016): It aims to protect
important ecological spaces by applying redlines to keep the ecological functions from degrading,
the area of scope from reducing, and the natural characteristics from changing. The objective is to
protect the country’s ecological safety and promote sustainable economic and social development.
In principle, the ecological protection redlines should be regarded and managed as the areas
within which developments are prohibited.
Implementation mechanism and procedures
7 Ecological protection redlines refer to the areas that have special and important
ecological functions and need mandatorily strict protection.
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126. Mechanism of nature conservation sites: The FGBs have started to reorganize and
reclassify the country’s natural and ecological resources8, based on their nature, value, and
significance, to form a nature conservation system composed of national parks, nature reserves,
and natural parks. National parks and nature reserves have core areas and ordinary areas. Human
activity is prohibited in core areas and restricted in ordinary areas. Natural parks are managed as
ordinary areas in principle.
127. Mechanism of ecological protection redlines: Government authorities such as NRBs
and EEBs integrate and reorganize the areas that have important ecological functions (such as
water conservation, biodiversity maintenance, water and soil conservation, wind prevention and
sand fixation, and coastal protection, etc.) and the areas that are extremely sensitive or fragile (e.g.,
soil erosion, desertification, rock desertification, and coastal erosion, etc.) and include them into
the scope of ecological protection redlines. Once the redlines are defined, development activities
within the redlines will be prohibited in principle. NRBs take the lead in approving site selection and
land use for construction projects. PIUs should seek opinions of FGBs and EEBs to confirm that
the project sites do not occupy any ecological protection redlines before NRBs complete the review
of site selection and land use application and report to the corresponding government for approval.
128. Mechanism of ecological impacts assessment: Any kinds of ecological and/or
environmental sensitive areas should be avoided in site selection of a construction project following
the requirements on ecological protection redlines, land planning, and ecological environment
zoning. Ecological impacts at different stages (construction, operation, and dismission) of the
construction project should be identified, predicted, and evaluated properly. Ecological protection
measures should be proposed in accordance with the mitigation hierarchy of avoidance, reduce,
restoration, and compensation. Proper ecological management and monitoring plans should be
developed, and rationality of the project should be determined by taking consideration the
ecological impacts.
Institutional organization and performance
129. FGBs: Management of nature conservation sites is the responsibility of FGBs. County level
FGBs usually have wildlife protection divisions or forest management divisions (4-7 staff members)
responsible for planning and managing the nature conservation sites and protecting and monitoring
the natural resources within the jurisdiction. They also undertake regular inspections on natural
conservation sites with the assistance of the forest service centers, township forest stations, state-
owned forest farms, etc.
8 Nature reserves, scenic areas, geological parks, forest parks, ocean parks, wetland parks,
glacier parks, meadow parks, desert parks, meadow scenic areas, aquatic germplasm
resource conservation areas, wild plant habitat conservation areas, nature mini-reserves,
and key wild animal habitats.
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130. NRBs: Management of ecological protection redlines is the responsibility of NRBs. By the
end of 2020, all provinces in China have completed defining local ecological protection redlines
and started to put them into application. Hubei Province has also formulated the "Hubei Ecological
Protection Redlines Definition Scheme" in 2018. County level NRBs usually have rural land
planning divisions (1-7 staff members) responsible for defining and applying regional redlines and
reviewing construction projects’ land use application and site relationship with local redlines. NRBs
usually use ArcGIS systems to precisely position and manage ecological redlines. In addition, the
Ministry of Natural Resources monitors nationwide land changes using special satellites. Once any
project site is found against the redlines, the responsible FGBs would be asked to carry out
immediate correction actions and might receive punishment. The ecological redlines system has
been run well.
131. EEBs: Management of nature conservation sites and ecological protection redlines will
depend on close cooperation of EEBs. Illegal construction of mines, roads, or dams in nature
conservation sites is subject to administration and punishment from EEBs. County EEBs usually
have EIA divisions (2-5 staff members). They support NRBs in defining ecological redlines; review
project siting and related redlines by consulting with NRBs in EIA approval; and examine the
ecological impact assessment and mitigation measures included in the EIA, etc. This mechanism
has been implemented very well in the EIA process of construction projects.
Brief summary
132. The proposed activities under the PforR will be implemented in rural areas that have been
disturbed by human beings, which will involve agricultural farming activities on farmland or small-
scale infrastructure on construction land. Therefore, the PforR activities are unlikely to occupy any
nature reserves or critical natural habitats. Meanwhile, the environmental exclusion principles set in
this ESSA will exclude activities that might affect any environmentally sensitive areas (e.g.,
ecological protection redlines) from the PforR scope. It’s concluded that China has established an
effective ecological protection system including established legal framework, rational institutional
arrangement, sufficient staffing, and sound implementation mechanism. The system is capable to
prevent the PforR activities from seriously affecting natural habitats and complies with the core
principles of the Bank.
4.4.2 Water and soil conservation
133. To prevent soil erosion and ecological damage caused by construction projects, China has
established a water and soil conservation (WSC) system under the management of WRBs which is
parallel with EIA process for construction projects. The ESSA team, therefore, conducted
investigation to the WSC system.
Legal framework
134. Water and Soil Conservation Law (2010 Amendment): For any construction project that
may lead to soil erosion, the responsible PIU should prepare a WSC plan and submit it to the
corresponding WRBs for approval. For any construction project that is subject to WSC plans, the
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related WSC works must be designed, constructed, and put into operation simultaneously with the
project main parts. Once the construction is completed, the WSC works must be checked for
acceptance. The project is not allowed to put into operation if the check is not conducted or
accepted.
135. Regulations on Preparation and Approval of Water and Soil Conservation Plans
(2017 Amendment): Any entities or individuals that may cause soil erosion must prepare and
submit WSC plans for their construction activities. WSC plans are classified to WSC report and
WSC form. The related entities or individuals are responsible for the preparation of the WSC plans.
A construction project is not allowed to start construction until its WSC plans have been approved
by WRBs.
136. Measures for Construction Projects Water and Soil Conservation Supervision (2019):
PIUs are responsible for WSC check. They should independently carry out the WSC check and
have the check reports produced and registered before the projects are put into operation or the
construction acceptance is done. After the check results show that the WSC works are qualified for
acceptance, the responsible WRBs should disclose the check reports to the public on their official
websites or other websites known to the public in a timely manner for at least 20 working days.
137. Water and Soil Conservation - Guidelines on Technical Control (GB/T16453): This
series of guidelines include six specific technical guidelines, targeting to different type of soil issues
such as slope land, wasteland, gullies, small-scale water works, wind and sand control, and slope
disintegration. The guidelines provide technical details on water and soil conservation measures
under different situations.
138. Water and Soil Conservation - Guidelines on Check for Acceptance (GB/T15773-2008):
It specifies the conditions, organizations, contents, procedures, and outcomes of three types of
WSC checks, namely single work check, phase-based check, and completion check.
139. Guidelines on Water and Soil Conservation Works Design (GB51018-2014): It’s
required to conduct appropriate investigation, survey, and experiment when designing WSC works
based on the collected data about geology, landscape, meteorology, hydrology, soil, vegetation,
soil erosion, and social and economic conditions, etc.
140. In addition, there are other national and local guidelines such as the “Water and Soil
Conservation - General Guidelines on Planning�? (GB/T15772-2008), the “Technical Guidelines on
Comprehensive Management of Water and Soil Conservation�? (SL534-2013), the “Technical
Guidelines on Ecological and Clean Small River Basins Development�? (SL534-2013), the
“Guidelines on Water and Soil Conservation Monitoring for Construction Projects�? (trial, 2015), the
“Hubei Specific Measures for Implementation of the National Water and Soil Conservation Law�?
(2016), the “Hubei Technical Guidelines on Ecological Control of Rocky Desertification in Karst
Areas�? (DB42/T1261-2017), etc.
Implementation mechanism and procedures
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141. Classification: All construction projects that are subject to WSC plans should finish the
WSC reporting and approval procedures as required: (i) a project with land acquisition/occupation
over 5 ha, or earthwork or stonework over 50,000 m3 is subject to preparation of a WSC report; (ii)
a project with land acquisition/occupation below 5 ha but over 0.5 ha, or earthwork or stonework
below 50,000 m3 but over 1,000 m3 is subject to preparation of a WSC form; and (3) a project with
land acquisition/occupation below 0.5 ha, or earthwork or stonework below 1,000 m3 is exempted
from preparation of WSC plans, but the responsible entity or individual should take measures to
prevent soil erosion.
142. Approval: For a project that is subject to approval by central government, the WSC reports
should go to national or provincial WRB for approval. For a project that is subject to approval by
local governments, the WSC reports should be approved by the same level WRBs, while WSC
forms should be approved by county level WRBs.
143. Check for acceptance: PIUs should ensure their contractors implement WSC measures
and facilities following the design schemes and should organize WSC supervision during the
construction. Prior to the project operation or completion acceptance, PIUs should ensure the WSC
monitoring devices are in place, carry out WSC check for acceptance, report to and get feedback
from local WRBs, and disclose relevant information to the public as required.
144. Monitoring: PIUs should monitor the disturbed land, borrow areas, spoil areas, soil erosion
potentials, and WSC measures associated with their construction projects, and report the
monitoring results to the WRBs that approved the WSC plans in a timely manner.
145. Supervision and inspection: WRBs are responsible for overseeing the WSC performance
of construction projects, in terms of the compliance of the WSC plans, and the implementation of
the WSC check, etc.
Institutional organization and performance
146. County level WRBs are the key authorities involved in WSC plans approval and supervision
associated with the PforR activities. The investigation to the sample cities/counties reveals that
county level WRBs have water resources divisions (3-5 staff members) responsible for approving
WSC plans for construction projects that are subject to approval by local governments. The
procedures of WSC plans submission, review, and approval are usually going through at local
Administrative Review and Approval Hall. For example, Honghu WRB has completed approval of
WSC plans for 30 projects in 2021. Some counties have WSC stations (10-15 staff members)
under local WRBs, while other counties have independent WSC bureaus. They all have water
LETs (about 15 staff members) to carry out inspections by means of remote sensing and on-site
visits. The inspections carried out by random sampling at the annual rate of at least 10% are
usually targeting the implementation of WSC measures, WSC check, and WSC monitoring, etc.
Brief summary
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147. Hubei has established an effective WSC system composed of sound legal framework,
implementation mechanism, institutional arrangement, and staffing. The system is qualified to
manage the WSC work and help improve ecological environment under the PforR. It complies with
the core principles of the Bank.
4.4.3 Water management under RCS
148. The activities under the PforR will focus on Yangtze River protection and ecological
restoration, for which a river chief system (RCS) and a lake chief system (LCS) established in
China will play an important role in water environment management of the Yangtze River basin.
The ESSA team, therefore, conducted basic research on the RCS/LCS.
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Legal framework
149. Yangtze River Protection Law (2021): Strictly restrict waterway projects in the ecological
protection redlines, nature reserves, and aquatic habitats of the Yangtze River basin. Prohibit any
illegal use or occupation of riverbanks or lake banks in the Yangtze River basin.
150. Opinions on Implementing River Chief System (2016): Establish a comprehensive RCS
based on “ecological priority, green development, problem orientation, and adaptation to local
conditions�?. It aims to achieve integrated development of “both right bank and left bank�? and “both
upstream and downstream�?; develop specific management policies to each river; balance the
relationship between river protection and river development; and improve rivers’ ecological
functions by letting rivers recuperate, etc.
151. Opinions on Implementing Lake Chief System (2018): Establish a comprehensive LCS
and develop specific management policies to each lake. It aims to strengthen lake protection,
improve ecological environment, increase lake health, and remain sustainable functions of the
lakes.
Implementation mechanism and procedures
152. A joint meeting mechanism for RCS/LCS has been established in each sample city/county,
led by the head of county government, and supported by various government authorities such as
DRC, FB, WRB, NRB, EEB, HURDB, ARAB, CTB, FGB, etc. The missions include water
resources conservation, water bank management, water pollution prevention and control, water
environment improvement, and water ecosystem restoration, etc. Under this mechanism, each
river or lake has a specific chief designated from governments at provincial, municipal, county,
township, or village levels, responsible for cross-sector and cross-region coordination.
Institutional organization and performance
153. The RCS/LCS has been established in China since 2016, and there have been more than
1.2 million river/lake chiefs assigned so far of which 460 thousand are in the Yangtze River Basin.
The ESSA investigation discovers that, a five-level RCS/LCS has been established at the
provincial, municipal, county, township, and village levels in Hubei. In each demonstration
city/county, there is a RCS/LCS office (2-5 staff members) set up under the county WRB to deal
with daily work related to RCS/LSC. Through multi-sectoral coordination at big basin levels, large -
scale projects have been implemented, in terms of urban and rural domestic wastewater collection
and treatment, agricultural NPS pollution control, livestock/poultry and aquaculture pollution control,
WSC, rivers and lakes cleaning (illegal occupation, mining, stacking, or construction), river and
lake ecological flow provision, and regular water environment monitoring (water quantity, water
quality, and water ecology), etc. Meanwhile, small-scale activities (e.g., elimination of untreated
wastewater discharge, floatage on water surface, and garbage on river/lake banks) covering more
small river/lake basins have also been carried out in a more detailed and more frequent way at
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county, township, and village levels. For example, in addition to the 323 rivers longer than 2km and
the 53 reservoirs in Lichuan, another 1,567 small and micro water bodies are also included in the
scope of RCS/LCS, for which they have designated 295 river/reservoir chiefs, 306 messengers,
and 158 cleaners at village level and established a long-term people-based management
mechanism.
Brief summary
154. Hubei has established effective RCS/LCS composed of sound legal framework,
implementation mechanism, institutional arrangement, and staffing. The system is deemed efficient
to help improve ecological environment of the Yongtze River Basin and complies with the core
principles of the Bank.
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4.5 Health and Safety Management System
155. This section is to assess safety and health protection from environmental emergency of
WWTPs, exposure to hazardous chemicals (e.g., H2S, NH4), and dead animals at livestock farms,
etc. For regular health and safety risks in construction and operation associated with the PforR
activities, China has established specific OHS systems, which will be discussed in Chapter 5.
Legal framework
156. Occupational Diseases Prevention and Control Law (2021 Amendment): It stipulates
basic requirements on prevention of occupational diseases caused by exposure to toxic and
hazardous substances at workplace. The "three simultaneousness" mechanism should be applied
to ensure that occupational health protection facilities be designed, constructed, and put into
operation simultaneously with the project main parts.
157. Animal Epidemic Prevention Law (2021 Amendment): Entities or individuals who
undertake livestock and poultry farming activities should manage to treat dead animals in a
harmless way or engage professional agencies to treat and dispose of dead animals in a harmless
way following relevant regulations.
158. Hazardous Chemicals Management Regulations (2013 Amendment): Enterprises are
responsible for well managing hazardous chemicals, providing training on hazardous chemicals
management to workers, and equip workers with proper PPE.
159. Environmental Emergency Management Measures (2015): Enterprises should prepare
environmental emergency plans based on the assessment of emergency risks and response
resources and submit the plans to local EEBs for registration following relevant regulations.
160. Enterprises’ Environmental Emergency Plan Preparation and Registration Measures
(trial, 2015): Enterprises that discharge pollutants and may have environmental emergencies in
their production or operation, such as centralized WWTPs and domestic solid waste treatment
facilities, should apply for registration of their environmental emergency plans. Local EEBs that
receive the application should complete the registration in a timely manner and disclose the list of
registered enterprises to the public.
161. Notice on Strengthening EIA Management and Preventing Environmental Risks
(2012): Environmental risk assessment is an important part of EIA for a construction project. An
EIA without a chapter on environmental risk assessment is not acceptable to EEBs. Environmental
acceptance check reports should also have specific chapters on what environmental risk
prevention measures have been designed and how these measures have been implemented at
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construction completion. An environmental acceptance check report without this information is not
acceptable to EEBs.
162. Construction Projects’ Occupational Diseases and Hazardous Risk Classification
Catalogue (2021): 12 categories of risks covering 281 types of activities in 84 sectors are listed in
the catalogue. Livestock and poultry farming and wastewater treatment are defined as activities
with moderate risk of occupational diseases.
163. Guidance Manual for Operation in Confined Spaces (2020): It provides guidance for
entities or workers to identify occupational risks of poisoning and suffocation and take measures to
avoid accidents when they undertake maintenance, inspection, or cleaning in confined spaces (e.g.,
manhole, biogas digester, septic tank, wastewater treatment tank, fermentation tank, etc.).
164. In addition, China has also issued other regulations and guidelines such as the “Risk Rating
for Enterprise Environmental Emergencies�? (HJ941-2018), the “Technical Guidelines on Harmless
Treatment of Animals Dead from Diseases�? (2017), and the “Occupational Diseases Classification
and Catalogue�? (2013), etc.
Implementation mechanism and procedures
165. Environmental risks assessment and management: Potential environmental
emergencies (such as untreated wastewater spillage) and the induced environmental risks that
may happen under a construction project should be identified and assessed in EIA, and
corresponding measures for risk prevention and emergency response should be proposed. In
design stage, facilities to prevent leakage/spillage from spreading into external environment should
be designed following national standards and guidelines. In construction stage, measures or
facilities for environmental risks prevention and emergency response should be implemented
simultaneously with the project main parts and taken into consideration in the environmental
acceptance check for completion. In operation, effective environmental emergency response
mechanism in terms of institutional arrangement and management procedures should be
established, and environmental risk prevention and emergency response facilities should be kept
well all the time.
166. Environmental emergency plans registration: Entities that are responsible for O&M of
WWTPs and other facilities should prepare environmental emergency plans and report to local
EEBs for registration. The plans should be updated periodically, and emergency exercises should
also be conducted.
167. Odor impact management: The odor-generated enterprises, as the responsible parties,
should take necessary technical or management measures to eliminate or control the risks of odor
on people’s safety and health under the supervision and guidance of relevant government
agencies (e.g., EMBs, HCs, etc.) They should also ensure the safety and health management
facilities be designed, constructed, and put into operation simultaneously with the project main
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parts and establish necessary records and archives. Workers should take health and safety
training and make sure to wear necessary PPE at workplace.
168. Confined space risks management: Entities engaged in O&M of sewage collection and
treatment, livestock manure treatment, and other similar activities may involve entry into confined
spaces (e.g., manholes, biogas tanks, septic tanks, sewage treatment tanks, fermentation tanks,
and sewers, etc.) for cleaning, dredging, and maintenance. Workers must follow relevant operation
programs to prevent toxic gas poisoning, suffocation, burning, explosion, and other accidents.
Institutional organization and performance
169. Local governments are responsible for environmental emergency response and
management and mobilizing relevant departments to form an emergency command center. For
example, Honghu Government issued the city’s Environmental Emergency Plan in 2020, and then
established a specific environmental emergency response committee with the vice mayor as the
commander and various government authorities (such as EEB, DRC, emergency management
bureau, HURDB, public security bureau, fire protection bureau, meteorology bureau, and township
governments, etc.) as the members.
170. Environmental LETs undertake examination on environmental risks management facilities
in their routine environmental inspections on important enterprises such as urban WWTPs. The
Through the investigation on the sample township WWTPs of the sample cities/counties, the ESSA
team found that environmental risks assessment and corresponding emergency response
measures have been included in the EIA instruments as required; online influent and effluent
monitoring devices have been set up in a timely manner in the WWTPs; and most O&M entities
have prepared and environmental emergency plans and gone through the registration procedures
as required.
171. EMBs and HCs will be responsible for broad coordination and instruction on health and
safety issues involved in the PforR activities, while detailed management will be the responsibility
of the PIUs or O&M entities under the guidance of relevant sectoral authorities (e.g., ARABs, EEBs,
or HURDBs). Sectoral authorities at county level usually check OHS performance in their monthly
routine inspections.
172. The ESSA team found that, (i) Large-scale or new livestock and poultry farms have applied
appropriate techniques or taken management measures (e.g., dry manure collection, biological
fermentation bed, spraying deodorant, etc.) to eliminate odor impacts; and they have certain
facilities to treat dead animals in a harmless way or transfer the dead animals to professional
entities for harmless treatment. (ii) New solid waste transfer stations are usually equipped with
odor spraying facilities to reduce odor’s impacts on workers and residents’ health. (iii) Confined
spaces such as sewage treatment tanks and sludge rooms have been equipped with warning signs
and notice boards on hazardous substances outside the entries; on-job trainings have been
provided to workers who are involved in maintenance, inspection, and cleaning in confined spaces,
and PPE such as gas detection alarms, lights, and respirators are provided to workers to prevent
gas poisoning, suffocation, and other accidents. (iv) Some old solid waste transfer stations and
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small-scale livestock and poultry farms still have odor issues and should strengthen odor treatment
measures/facilities to reduce odor impacts.
Brief summary
173. Hubei Province has corresponding regulations, procedures, organization, and staff on
management of environmental safety and health associated with the PforR activities; and the
system is found equivalent to the WBG’s General EHS Guidelines, the EHS Guidelines for Waste
Management Facilities, and the EHS Guidelines for Water and Sanitation. It’s deemed sufficient to
meet the requirements of the PforR. It’s suggested to reduce odor impacts in domestic solid waste
transfer and livestock/poultry manure management to secure environmental safety and public and
occupational health.
4.6 Consistency with the Bank’s Core Principles
174. After assessing the four EMSs, namely the EIA and follow-up management system, the
pollution control system, the ecology protection system, and the environmental safety and health
management system, the consistency with the Bank's core principles and elements is analyzed in
this section with details presented in Error! Reference source not found..
Principle #1 - EIA and management: Program E&S management systems are designed to
promote E&S sustainability in Guangxi design; avoid, minimize, or mitigate adverse impacts; and
promote informed decision-making related to a program’s E&S effects. Social impact assessment
and management will be described in Chapter 5.
175. China has established a complete EIA legal framework composed of laws, regulations,
technical guidelines, standards, mechanisms, and procedures guided by the national
“Environmental Protection Law�?. This EIA system requires to conduct environmental screening and
classification at the early stage of project design and EIA. Construction projects are classified to
three categories (A: EIA report, B: EIA form, and C: EIA registration) based on project nature and
magnitude of environmental impacts. EIA instruments will include alternatives analysis, impacts
assessment (positive vs. negative, long-term vs. short-term, direct vs. indirect, cumulative, etc.),
mitigation measures, management responsibilities and budgets, public consultation, information
disclosure, monitoring plans, etc. In recent years, China has been promoting environmental
management reform to change from focusing on EIA approval to strengthening follow-up
inspection and progressing to project life-cycle environmental management. The ESSA team noted
in the sample cities/counties that most types of activities that the PforR will support have gone
through environmental management procedures in terms of EIA, “Three Simultaneousness�?,
environmental acceptance check, pollutant discharge permitting, and pollutant monitoring, etc.
Relevant government authorities such as EEBs, ARABs, and HURDBs have clear responsibilities
and institutional arrangement. Their LETs carry out regular inspections on related pollution control
by means of spot check, special inspection, online investigation, and on-site supervision, etc. The
EIA and follow-up supervision system is demonstrated sound by the findings from the site visits
and records review. The gaps identified in the practical work are expected to be filled by improving
technical and management measures.
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Principle #2 - natural habit protection: Program E&S management systems are designed to
avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources
resulting from the PforR; any program activity that involves the significant conversion or
degradation of critical natural habitats will not be supported by the PforR. Cultural resources
management will be described in Chapter 5.
176. China has brought critical natural habitats into the scope of ecological protection redline
mechanism for stringent protection. Ecological factors (including critical habitats and biodiversity)
are important sensitive receptors to be identified and assessed in EIA, and ecological impact
assessment is one of the important components of EIA instruments. It’s compulsory that EIA must
strictly follow the requirements of ecological protection redlines. Project siting must be subject to
approval by NRBs, EEBs, FGBs, and other related authorities, so the relationship between project
site and natural habitats or other environmental sensitive areas will be identified in the early stage
of project preparation. The PforR activities will be implemented in rural areas that have been
disturbed by human beings instead of critical natural habitats. During implementation, ecological
protection measures will be undertaken to mitigate any impacts on modified ecosystems as per
EIA recommendations. In addition, the environmental exclusion principles developed in this ESSA
will exclude any activity that might affect critical natural habitats from the PforR scope. Therefore,
the PforR activities will not cause significant conversion or degradation of critical natural habitats.
At the same time, the WSC mechanism and the RCS/LCS will help prevent soil erosion, improve
water management, protect ecological environment, and play an active role in Yangtze River
protection and ecological restoration.
Principle #3 - health and safety: Program E&S management systems are designed to protect
public and worker safety against the potential risks associated with (a) the construction and/or
operation of facilities or other operational practices under the PforR; (b) exposure to toxic
chemicals, hazardous wastes, and otherwise dangerous materials under the PforR; and (c)
reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards. Other
items on health and safety will be described in Chapter 5.
177. For the safety and health issues such as WWTPs’ potential environmental emergencies,
odor impacts of domestic solid waste transfer and livestock manure management, dead animals at
livestock farms, and risks of confined spaces, China and Hubei Province have had corresponding
legal framework, implementation mechanism, and institutional arrangement. The O&M entities will
implement environment, health, and safety (EHS) management measures under strict supervision
of local government authorities to eliminate the potential risks caused by untreated wastewater,
odor, dead animals, and confined spaces, etc. The O&M entities for these facilities/activities will
establish safe production, emergency response, and occupational health protection mechanisms
as required, and provide qualified PPE and EHS training to workers. Local authorities (ARABs,
HURDBs, EEBs, etc.) will conduct regular spot check and special inspection on these activities and
provide guidance to these entities. The safety and health management system is therefore deemed
satisfactory to serve the PforR. For the gaps identified in the practical work, improved technical and
management measures are expected to help solve the odor impacts on public and occupational
health.
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178. Conclusion: The comparison concludes that China’s EMSs in terms of legal framework,
management mechanism, and institutional arrangement are well established, and the
implementation performance are demonstrated substantially satisfactory. In general, the EMSs are
consistent with the Bank’s PforR ESSA Guidance and the core principles and elements and are
qualified to manage the environmental issues associated with the PforR activities such as domestic
wastewater collection and treatment, domestic solid waste collection and transfer, livestock and
poultry manure treatment and utilization, mulch film collection, and water and soil conservation, etc.
Action plans as well as suggestions have been recommended in the ESSA (as presented in
Chapter 7) to fill the gaps identified in the due diligence investigation, and the EMSs are expected
to be improved through the implementation of the PforR.
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5. Social Management System Assessment
179. The Program-for-Results (PforR) Financing Environmental and Social Systems
Assessment (ESSA) Guidance lays down a set of principles and elements for assessing the
borrower’s environmental and social systems systematically. This chapter, based on the types of
social risks and impacts of the Program, and the 6 core principles and 13 elements stipulated in
the Guidance, assesses the social management regulations, management mechanisms and
capacity and implementation performance related to the Program, identifies areas of improvement,
and proposes measures for managing social risks and increasing Program benefits.
180. Chapter 3 of this report shows that the social impacts and risks involved in the Program
activities fall into the following types: comprehensive social impacts (e.g., social conflict, fairness,
transparency, NIMBY, etc.), tangible cultural heritage, public and worker safety, restriction on land
use and resettlement, and impacts of ethnic minorities and vulnerable groups.
181. The social risks management is achieved in China from the national to local levels by
formulating and implementing a series of laws and policies, and establishing and running
appropriate management agencies and mechanisms, which contributes to social harmony.
Therefore, the social management system assessment consists of the three parts: review of laws
and regulations, appraisal of management agencies and mechanisms, and due diligence of
implementation performance. In China’s social management system, different social risks and
impacts are managed by regulations and competent government agencies (see Table 5-1).
5.1 Correlation Analysis with Bank Principles
182. Generally, all the six core principles of PforR ESSA are relevant to the Program’s social
management system. See Table 5-1 for a correlation analysis between the Chinese social
management system and the Bank policy.
Table 5-1: Correlation Analysis between the Chinese Social Management System and the
Bank Policy
Social impacts Bank policy China’s social impacts and risks management system
and risks principle Relevant social laws and regulations Social management agencies
Comprehensive Principle Notice of the National Development and State: NDRC;
social impacts, #1: social Reform Commission on Issuing the Measures
e.g., social impacts and for the Social Stability Risk Assessment of Hubei Province:
conflict, risks Major Fixed Asset Investment Projects (NDRCI 1. Leading authorities:
fairness, assessment 2021 Amendment) provincial development and
transparency, and reform commissions,
NIMBY management Notice of the General Office of the National provincial, municipal and
system Development and Reform Commission on
Issuing the Outline for the Preparation of the county political and
Chapter on the Social Stability Risk Analysis of legislative affairs
Major Fixed Asset Investment Projects and committees, offices for
Principle Assessment Report (Interim) (NDRCOI [2013]
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Social impacts Bank policy China’s social impacts and risks management system
and risks principle Relevant social laws and regulations Social management agencies
#6: social No.428) letters and visits;
conflict
Opinions on Strengthening Social Stability Risk 2. Assessors: municipal and
Assessment for Major Decisions under New county competent
Circumstances (GOCC [2021] No. 11, authorities (e.g., WWTP
2020.2.22) authorities, county housing
and urban-rural
Opinions on the Implementation of Measures to development bureaus) and
Strengthen Social Stability Risk Assessment appointed third parties
Mechanism for Major Decisions under New
Circumstances of Hubei Provincial Committee 3. Registration authorities:
of the CPC and the General Office of Hubei provincial (cross-
Provincial Government (2021.12.13) regional/cross-departmental
projects), or municipal and
Interim Regulations on Major Administrative county political and
Decision-Making Procedures (2019.9.1) legislative affairs
committees
4. Decision-making
authorities: municipal and
county executive meetings
of CPC and government
leaders
Regulations on Complaint Letters and Visits 5. Implementing agencies:
(2005.5.1) assessors and entrusted
operating agencies
6. Supervising agencies:
municipal and county
governments and their
grass-root agencies (e.g.,
township governments)
Tangible Principle Cultural Relics Protection Law (2017 State: National Cultural
cultural #2: cultural Amendment) Heritage Administration
heritage heritage
conservation Regulations for the Implementation of the Hubei Province: provincial,
municipal and county cultural
Cultural Relics Protection Law (2017)
relic protection authorities
Public and Principle Civil Code of the People’s Republic of China Public security:
worker safety #3: labor (2021.1)
and State: Ministry of Emergency
occupational Work Safety Law of the People’s Republic of Management
health China (2014.12)
Hubei Province: provincial
Law of the People’s Republic of China on the and county emergency
Prevention and Control of Occupational management bureaus,
Diseases (2018.12) production and operation
entities, associations, agencies
Guidelines on the Prevention and Control of providing technical
Occupational Diseases for Employers (2010.8) management services for work
Occupational Health and Safety Management safety
Systems—Requirements with Guidance for Public and occupational
Use (2018.3) health
Classification and Catalogue of Occupational
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Social impacts Bank policy China’s social impacts and risks management system
and risks principle Relevant social laws and regulations Social management agencies
Diseases (2013.12) State: National Health
Commission
Regulations on Labor Protection of Female
Workers of Hubei Province (2009.2.5) Hubei Province: provincial,
municipal and county health
The 14th Five-Year Plan for Prevention and commissions, provincial
Control of Occupational Diseases of Hubei occupational disease
Province (HPHC [2022] No.8) prevention and treatment
Work Safety Law of the People’s Republic of institutes, occupational health
China (2014.12) examination agencies
Law on the Prevention and Treatment of Labor management
Infectious Diseases (2020) State: Ministry of Human
Emergency Response Law of the People’s Resources and Social Security,
Republic of China (2007.11.1) All-China Federation of Trade
Unions
Regulations on the Prevention and Control of
Geologic Disasters (2004.3.1) Hubei Province: provincial,
municipal and county
Regulations on the Defense against federations of trade unions,
Meteorological Disasters (2010.4.1) and industrial unions; trade
unions of enterprises and
Regulations of the People’s Republic of China
public institutions
on Flood Control (2005.7.15)
Law of the People’s Republic of China on
Protecting against and Mitigating Earthquake
Disasters (2009.5.1)
Land Principle Measures for the Administration of the Pre- Land acquisition
acquisition, #4: land examination on the Use of Land for
restriction on acquisition, Construction Projects (2017.1) State: Ministry of Natural
land use and livelihood Resources
resettlement restoration Land Administration Law (2019.9.1)
Hubei Province: provincial,
and public Regulations for the Implementation of the Land municipal and county
participation Administration Law (2014 Amendment) governments, and natural
resources authorities
Regulations on the Expropriation of Houses on
State-owned Land and Compensation (Decree
[2011] No.590 of the State Council) (2011.1.21)
Urban house demolition
Notice on Issuing the Measures for the
Expropriation and Evaluation of Houses on Municipal and county
State-owned Land (JF [2011] No.77) (2011-6- governments, housing and
3) urban-rural development
bureaus, house demolition
Guidelines on Improving the Compensation agencies
and Resettlement System for Land Acquisition
(MLR [2004] No.238)
Notice on Doing a Good Job in Employment Rural house demolition
Training and Social Security for Land- agriculture and rural affairs
expropriated Farmers (SC [2006] No.29) authorities, natural resources
Notice of the Ministry of Labor and Social authorities, township
Security and the Ministry of Land and governments, village
Resources on Doing a Substantially Good Job
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Social impacts Bank policy China’s social impacts and risks management system
and risks principle Relevant social laws and regulations Social management agencies
in Social Security for Land-expropriated committees
Farmers (MLSS [2007] No.14)
Notice of Hubei Provincial Government on
Releasing Block Comprehensive Land Prices Livelihood restoration
of Hubei Province (2019.11.8) State: Ministry of Human
Measures for the Implementation of the Resources and Social Security
Expropriation of Houses on State-owned Land Hubei Province: provincial,
and Compensation of Hubei Province municipal and county human
(2015.7.6) resources and social security
Guidelines of Hubei Provincial Government on authorities, county and
Basic Pension Insurance for Land-expropriated township governments,
Farmers (HPPG [2014] No. 53) community committees, village
committees
Ethnic Principle Constitution (2018 Amendment) Ethnic minorities
minorities and #5: ethnic
vulnerable minorities Law of the People's Republic of China on State: National Ethnic Affairs
groups and Regional National Autonomy (2001 Commission
vulnerable Amendment)
Hubei Province: provincial,
groups Provisions of the State Council on the municipal and county ethnic
Implementation of the Regional National and religious affairs bureaus
Autonomy Law (2005.5)
Women
Provisions of Hubei Province on the
Implementation of the Law of the People's State: All-China Women’s
Republic of China on Regional National Federation
Autonomy (1988 9.27) Hubei Province: women’s
Notice of the State Council on Issuing the 13th federations at different levels
Five-year Plan for Promoting the Development
of Minority Areas and Smaller Ethnic Minorities
(SC [2016] No.79)
The 14th Five-Year Plan of Hubei Province for Children
High Quality Development of Ethnic Affairs
Functional authorities of
(2022.1)
governments at or above the
Law of the People's Republic of China on the county level, township
Protection of Women's Rights and Interests governments, sub-district
(2018.10.26 Amendment) offices, community committees,
village committees
Law of the Peoples Republic of China on the
Protection of Minors (2020.10.17)
Measures of Hubei Province on the
Implementation of the Law of the People's
Republic of China on the Protection of
Women's Rights and Interests (2007.10.1)
Guidelines of the CPC Central Committee and
the State Council on the Three-year Poverty
Alleviation Action
The 14th Five-Year Plan of Hubei Province for
the Development of Civil Affairs (2021.10. 29)
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Social impacts Bank policy China’s social impacts and risks management system
and risks principle Relevant social laws and regulations Social management agencies
Strategic Plan for Countryside Revitalization of
Hubei Province (2019.5)
Plan of Hubei Province for Women's
Development (2021-2030) (2021.12.25)
Plan of Hubei Province for Children's
Development (2021-2030) (2021.12.25)
5.2 Assessment of Social Regulations and Policies
7. China’s legal framework consists of the following: 1) laws and regulations promulgated by
the National People’s Congress and the State Council; 2) regulations, standards and technical
specifications promulgated by ministries and commissions; and 3) regulations promulgated by local
people’s congresses and governments. In general, systematic regulations, standards and policies
on land acquisition and resettlement (LAR), ethnic minority development, labor rights, public
participation and consultation, grievance redress, etc. have been promulgated and implemented at
the state, provincial, municipal, and county levels to effectively manage potential social risks and
impacts in the Program lifecycle.
8. Appendix 3 compares the Bank policy with the applicable social management regulations.
This section compares the relevant social management regulations with the Bank policy based on
the core principles and elements, then identifies gaps in social regulations and policies where
applicable and proposes actions and recommendations for improvement.
1. Core Principle #1: Sustainable social risks management system 9
9. Core Principle #1 includes two elements relevant to social regulations and policies. The
analysis of consistency of social policies of China and Hubei Province where the Program is
implemented with the Core Principle #1 and associated elements is summarized as follows.
Element 1: Operate within an adequate legal and regulatory framework to guide E&S impact
assessments, mitigation, management and monitoring at the PforR Program level.
10. Social stability risk assessment (SSRA): The Chinese government uses SSRA as a tool
to systematically manage substantial social risks and impacts that may be involved in major
projects, policies and reforms, and mitigates and manages social impacts actively by establishing
9 Chapter 5 of this report quotes the information related to social system analysis and the
core principles and elements in the PforR ESSA Guidance for a consistent comparative
analysis.
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and implementing a whole SSRA system, so as to promote scientific decision-making, and
sustainable Program and social development.
1. The NDRC promulgated the Interim Measures for the Social Stability Risk Assessment of
Major Fixed Asset Investment Projects in 2012, stating that the project organization
should investigate and analyze social stability risks when conducting preparatory work,
collect opinions from relevant people, identify risks, risk possibilities and risk impacts, and
propose prevention and mitigation measures, and social stability risk ratings after such
measures are taken.
2. The General Office of the State Council promulgated the Guidelines on Establishing a
Sound Social Stability Risk Assessment Mechanism for Major Decisions and Matters
(Interim) in 2012, requiring that an SSRA shall be conducted on major decisions, projects
and policies.
3. In February, 2020, the General Office of the CPC Central Committee and the General
Office of the State Council released the Opinions on Strengthening Social Stability Risk
Assessment for Major Decisions under New Circumstances, requiring that an SSRA shall
be carried out on major decisions including those on major construction projects. It
specifies the contents, methods, procedures and management of SSRA, and application
of SSRA results, and underlines that the contents of SSRA are integral to the Program's
feasibility study and application reports.
4. The Guidelines on Establishing a Sound Social Stability Risk Assessment Mechanism for
Major Decisions and Matters (Interim) promulgated by the General Office of the State
Council in 2012 was succeeded by the Rules of Hubei Province for Implementing Social
Stability Risk Assessment for Major Decisions (Interim), specifying requirements for the
implementation of SSRA in Hubei Province. In December, 2021, it was superseded by the
Opinions on the Implementation of Measures to Strengthen Social Stability Risk
Assessment for Major Decisions under New Circumstances of Hubei Province which
particularly stipulates the contents, methods, procedures, management and the use of
results of SSRA for major decisions in Hubei Province.
5. The Land Administration Law (effective from January 1, 2020) requires that an SSRA shall
be conducted before land acquisition and house demolition.
6. Assessment: SSRA is an important procedural requirement in project preparation and
feasibility studies. China and Hubei Province have formulated and implemented relevant policies,
mechanisms, standards, and management procedures to regulate SSRA. Field level inquiry in
Hubei Province and related cities/counties found that the related municipal and county authorities
take the SSRA seriously, and the conclusions and risk ratings are the key reference for the
governments in their decision-making. However, there is no systematic, mature and effective
monitoring mechanism to track and support the implementation of risk mitigation measures during
and after the implementation of the Program.
7. Recommendation: The borrower should establish and implement a social monitoring and
reporting mechanism at both the provincial and county level to monitor and evaluate the Program's
social impacts and risks and the implementation of risk management measures and outcomes.
Element 2: Incorporate recognized elements of good practice in E&S assessment and
management, including six aspects.
8. According to the social risk screening results (Appendix 1), the consistency of the Program
activities and national and Hubei provincial social impact management systems with 5 aspects of
Element 2 is analyzed below.
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(i) Early screening: During site selection and feasibility study of related projects, the
relevant authorities (e.g., natural resources bureau, cultural heritage bureau) shall be coordinated
to conduct a joint survey, and risks and impacts screening. For example, the Measures for the
Administration of the Pre-examination on the Use of Land for Construction Projects (2008), and the
Land Administration Law (effective from January 1, 2020) require that screening shall be
conducted so that the construction project complies with the land utilization plan and avoids any
acquisition of basic farmland. The Cultural Relics Protection Law (2014 Amendment) requires that
a cultural relic survey shall be conducted before project site selection to minimize impacts on
cultural relics. The Regulations on the Prevention and Control of Geologic Disasters (2004) require
that the project area shall not be selected in disaster areas, and related disaster prevention and
control requirements should be defined through a geological disaster assessment to reduce public
safety risks.
(ii) Alternatives: Options should be compared during project site selection and
feasibility study. The Administrative License Law of the People's Republic of China, and the
Decision of the State Council on Establishing Administrative License for Administrative
Examination and Approval Items Really Necessary to Be Retained require that the feasibility study
of a project shall compare E&S impacts of different options to avoid or minimize local negative E&S
impacts. The Notice on Issuing the Outline for the Preparation of the Chapter on the Social Stability
Risk Analysis of Major Fixed Asset Investment Projects and Assessment Report (Interim)
(NDRCOI [2013] No.428) stipulates that the project implementation units (PIUs) and assessment
agencies shall obtain the support of the local governments and related departments, grass-root
organizations, NGOs, etc. for the proposed project in terms of planning and site selection, land
acquisition, house demolition, compensation, resettlement, environmental protection, etc., thereby
selecting an option with acceptable social stability risks.
(iii) Developing measures to avoid, minimize or mitigate social impacts: The
Notice on Issuing the Outline for the Preparation of the Chapter on the Social Stability Risk
Analysis of Major Fixed Asset Investment Projects and Assessment Report (Interim) (NDRCOI
[2013] No.428) requires that plans and measures shall be proposed to prevent and mitigate risks.
According to the Guidelines on Establishing a Sound Social Stability Risk Assessment Mechanism
for Major Decisions and Matters (Interim), if the assessment report thinks that a high risk is present,
a decision of non-implementation shall be made, or a decision be made after the plan is adjusted
or the risk level reduced; if an moderate risk is present, a decision of implementation shall be made
after effective risk prevention and mitigation measures are taken; and if a low risk is present, a
decision of implementation may be made, provided that actions like explanation and persuasion to
the people affected are taken and reasonable requests of people affected are handled properly.
SSRA shall also address the legitimacy, rationality, feasibility and controllability of the proposed
activities, and require that an appropriate contingency plan be developed.
(iv) Clear articulation of institutional responsibilities and resources to support
implementation of plans: The Guidelines on Establishing a Sound Social Stability Risk
Assessment Mechanism for Major Decisions and Matters (Interim) requires that whether related
compensation, resettlement or assistance measures offered are reasonable, fair and timely and
whether appropriate manpower, material and financial resources are available shall be assessed.
(v) Public participation, information disclosure and grievance redress
mechanism: The SSRA policies of China and Hubei Province require that public consultation be
conducted with all stakeholders involved in a plan to collect their opinions and suggestions,
including advice, needs and public opinions on the proposed project from mass, online, mobile and
other emerging media. The Notice on Issuing the Outline for the Preparation of the Chapter on the
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Social Stability Risk Analysis of Major Fixed Asset Investment Projects and Assessment Report
(Interim) (NDRCOI[2013] No.428) stipulates, the PIUs and assessment agencies shall obtain
support of the local governments and related departments, grass-root organizations, NGOs, etc.
for the proposed project, and the completeness of public participation shall be assessed as well,
including if the procedural requirements of public participation, expert consultation and information
disclosure are all well implemented. For any project involving land acquisition and house
demolition, the Land Administration Law (effective from January 1, 2020) requires that the
government at or above the county level shall disclose the key information, once the land
acquisition is approved in accordance with related law, e.g. the purpose and boundary of land
acquisition, current status, compensation rate, resettlement mode, social security, etc. in the
township (town), village and village group for at least 30 days, to collect comments from the
affected rural collective economic organization and its members, village committee and other
stakeholders. It's required that any disputes over the ownership and right to use of the land shall
be resolved by parties concerned through consultation. If the consultation ends in failure, decisions
shall be made by the local government to resolve the disputes. Whereas parties concerned refuse
to accept such decisions, the disputes may be brought to the courts within 30 days after the
notification on the decision is received. No party shall change the status quo of the land before the
disputes over ownership and right to use are settled. Whereas a construction contractor or
individual refuses to accept any administrative punishment decision on dismantling the buildings
and other facilities, legal proceedings may be instituted before the court within 15 days starting
from the day when the decision is received. The Ministry of Natural Resources issued the Standard
Guidelines for Grass-root Government Affairs Disclosure in Rural Collective Land Acquisition on
June 27, 2019, making detailed provisions on project land acquisition policies, and the scope, time
limit and channels of disclosure during preparation, approval and implementation.
9. Assessment: The social impacts and risks are basically assessed and managed through
regulations in terms of SSRA, land acquisition and house demolition in China and Hubei Province.
There are clear mechanisms for impact early-stage screening, option comparison, and
arrangements for managing major social risks (e.g., LAR, social stability risks). The regulations
also defined the responsible agencies (see Table 5-1) to manage specific impacts. Comprehensive
system arrangements have been established in the regulations on social stability risk management,
land acquisition and house demolition for information disclosure, public participation and grievance
redress. Therefore, the social regulations and policies are generally consistent with Element 2.
However, there are lack of clear requirements for documentation of the process in terms of impact
screening and analysis, public participation, information disclosure, grievance redress, etc.
10. Recommendation: Define requirements of documentation in related project management
documents (e.g., contracts, agreements) at the PIAs of related counties, including (but not limited
to) keeping a record of the screening, public participation and information disclosure process and
outcomes and the operation of the grievance redress mechanism.
1. Core Principle #2: Cultural heritage management system
11. Elements 3 and 4 under Core Principle #2 define management requirements for natural
habitats, which were discussed in Section 3. Here only Element 5 is relevant to social management
system. The consistency analysis is discussed below:
Element 5: Take into account potential adverse effects on tangible cultural heritage and provide
adequate measures to avoid, minimize, or mitigate such effects.
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12. Cultural heritage conservation: The Program activities in Hubei Province involve small
civil works, such as the construction of urban wastewater collection and treatment system, transfer
of domestic refuse, and fecal residue and wastewater recycling facilities. According to the social
impact screening (Appendix 1), the Program is unlikely to affect any tangible cultural heritage.
China has established and implemented a sound cultural relic protection law to assess and
manage potential impacts of construction activities on cultural heritage. The Cultural Relics
Protection Law requires that no construction works or operations such as blasting, drilling and
digging are allowed within the area of historical and cultural protection site. The site selected for a
construction project shall keep away from immovable cultural relics as far as possible. If a
construction project is needed to be implemented, it will be approved by the cultural relic authority
firstly, and then by the urban-rural construction planning authority. Within the area of a protected
cultural relic, any facilities that may pollute such relic and its environment are not allowed to be
constructed, and any activities that may affect its safety and environment are not allowed to be
conducted. Any such facilities shall be disposed of within a specific time limit. Before launching a
large-scale construction project, the construction contractor shall firstly apply to the provincial
cultural relic authority for an archaeological investigation at places where cultural relics may be
buried underground within the project area.
13. Assessment: The Cultural Relics Protection Law and the Regulations for the
Implementation of the Cultural Relics Protection Law give full consideration to potential impacts on
cultural relics to protect cultural relics from being affected by construction. The regulations on
tangible cultural heritage protection of China and Hubei Province are consistent with Element 5.
1. Core Principle #3: Public and worker safety management system
14. Element 7 under Core Principle #3 defines requirements for toxic and hazardous
substances, and pest control related to environmental management system analysis. Below is the
analysis of consistency of social regulations on public and worker safety with Elements 6 and 8
under this core principle:
Element 6: Promote adequate community, individual, and worker health, safety, and security
through the safe design, construction, operation, and maintenance of Program activities; or, in
carrying out activities that may be dependent on existing infrastructure, incorporate safety
measures, inspections, or remedial works as appropriate.
15. Worker safety management: Proposed Program activities inevitably involve health and
safety risks of workers, including the occupational health management of the WWTP, labors
management related to the contractors and facilities of livestock and poultry manure recycling and
river cleanup. China has established and implemented a system to manage labor safety:
16. Laws such as the Labor Law (2018 Amendment), and the Civil Code make explicit
provisions on child labor, discrimination, forced labor, etc. For example, employers shall
not recruit minors (under 16 years); special protection shall be given to female and
underage (16-18 years) workers; workers shall not be discriminated against on the basis
of ethnic group, race, gender or religion; women shall enjoy the same employment rights
as men; forced labor shall be prohibited.
17. The Work Safety Law requires that production and operation entities must establish a
sound work safety responsibility system, and relevant rules and regulations, and improve
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work safety conditions to ensure work safety. It also requires that reporting information be
disclosed to the public for public supervision.
18. The Civil Code requires that work safety and health facilities of construction, reconstruction
and expansion works shall be designed, constructed and put into operation along with
these works.
19. The Requirements and Guidance for Occupational Health and Safety Management
promulgated in 2020 requires that enterprises shall identify and control potential
occupational health and safety hazards systematically, and eliminate safety accidents at
the beginning, thereby protecting worker health and safety. Enterprises may apply for
“occupational health and safety management system�? certification, and establish a
normative management system, realizing the source identification and whole-process
control of hazards, and continual improvement.
20. Assessment: A whole set of comprehensive laws and regulations on worker health and
safety has been established in China and Hubei Province to fully protect worker rights. The
regulations also require that appropriate safety measures, inspections or remedial works be taken
during design, construction and operation to ensure community, personal and worker safety. The
regulations on public and labor safety are consistent with Element 6.
Element 8: Include adequate measures to avoid, minimize, or mitigate community, individual, and
worker risks when the PforR Program activities are located in areas prone to natural hazards such
as floods, hurricanes, earthquakes, or other severe weather or affected by climate events.
21. Disaster safety management mechanisms: The Program is located in the Honghu Lake
and the Qingjiang River watersheds in Hubei Province, and may involve areas prone to natural
disasters, such as floods, lightning and landslides. During implementation, the flow of migrant
workers may lead to disease spreading (e.g., COVID-19). For urban-rural planning and major
project construction, the Regulations on the Defense against Meteorological Disasters requires that
governments at or above the county level shall fully consider meteorological factors and natural
disasters and propose measures to avoid or mitigate disasters. In addition, the Regulations on the
Defense against Meteorological Disasters requires that lightning protectors of newly constructed,
reconstructed or expanded buildings (structures), places and facilities shall be designed,
constructed, and put into operation along with these works. The Regulations of the People’s
Republic of China on Flood Control make systematic arrangements for floods in terms of
organization, flood prevention preparation and implementation, rescue, follow-up work, funding,
reward, and punishment, etc. The Regulations on the Prevention and Control of Geologic Disasters
make systematic arrangements for the investigation, prevention, and management of geologic
disasters, such as prevention, emergency response, governance and legal liabilities. The Law of
the People’s Republic of China on Protecting against and Mitigating Earthquake Disasters requires
that newly constructed, reconstructed or expanded construction works shall meet seismic design
requirements, and makes specific provisions on seismic safety assessment and earthquake
protection. According to the Law on the Prevention and Treatment of Infectious Diseases (April
2020), governments at or above the county level shall develop and implement infectious disease
prevention and control plans, and establish a prevention, treatment, and supervision management
system; news media shall conduct public welfare publicity on infectious disease prevention and
control, and public health education. According to the Notice on Targeted Health Management and
Orderly People Flow (Joint Prevention and Control Mechanism ZF [2020] No.203) promulgated by
the National Health Commission, all localities shall define prevention and control ranges precisely
based on pandemic risk rating and take comprehensive measures such as restriction of people
flow, nucleic acid testing and health monitoring. For medium- to high-risk areas, entry into the
project area, and people gathering shall be avoided where possible, and people entering the
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project area may flow freely only if their body temperatures are normal and proper personal
protection measures are taken. Entry into medium- to high-risk areas shall be avoided if not
necessary.
22. Assessment: The regulations on natural disaster prevention and control measures are
consistent with Element 8.
1. Core Principle #4: Involuntary resettlement management system
23. Element 9 under Core Principle #4 manages involuntary resettlement incurred by the
Program in six aspects, all of which are related to the social regulations and policies applicable to
the Program. Consistency is analyzed as follows:
(i) Minimizing negative impacts related to land acquisition: Similar to the analysis
of early screening of impacts under Element 2, the Measures for the Administration of the Pre-
examination on the Use of Land for Construction Projects (2008), the Land Administration Law
(effective from January 1, 2020), and the regulations on SSRA require that projects and
enterprises shall use land in an optimal and intensive way, utilize existing construction land and
avoid any occupation of farmland (especially permanent basic farmland) where possible, and
reduce LAR impacts through design optimization, thereby reducing social stability risks. At the
preparation stage, natural resources authorities will participate in the survey to confirm the land
used for the project, and the feasibility study will compare different options for LAR impacts. The
government authorities at provincial level such as the provincial DRC and NRB, which are
responsible for appraisal of the project feasibility study, land preliminary approval and other related
project documents, will check if the land use plan is rational during land use review and feasibility
study.
(ii) Identifying and addressing economic and social impacts arising from land
acquisition or loss of access to natural resources: Land Administration Law (effective from
January 1, 2020) stipulates, “Owners or users of the land to be acquired shall, within the time limit
specified in the announcement, go to fill the compensation registration form holding its assets
ownership certificate. The government at or above the county level shall organize the department
concerned to estimate the relevant costs and make them fully available.�? The land acquisition
compensation measures of Hubei Province make systematic arrangements for land acquisition
compensation and resettlement in accordance with the Land Administration Law, including for
those lacking legal title. During land acquisition, affected people shall confirm the results of detailed
measurement survey (DMS), and the land acquisition agency shall enter into compensation and
resettlement agreements with landowners and users before project approval. In addition, a whole
set of grievance redress mechanisms for land acquisition compensation have been established
from village or community level to townships governments level, and/or to the county level or
above. If any affected person is dissatisfied with the DMS result, and/or the compensation or
resettlement, he/she may file a grievance with the village committee, or with the township or
county/municipal government. According to the Regulations on Complaint Letters and Visits (2005),
governments at or above the county level shall perform such duties as acceptance, handling,
coordination, and supervision. If a grievant is dissatisfied with the disposition, he/she may settle the
dispute through litigation to protect its lawful rights and interests.
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(iii) Compensation and transition subsidy to be fully paid at replacement cost
before land use: The Land Administration Law (effective from January 1, 2020) defines
compensation policies, rates, principles, flows, schedules, etc. for different types of land use.
Article 47 stipulates, fair and reasonable compensation shall be granted for land acquisition to
ensure that the living standard of the affected farmers is not reduced, and their long-term
livelihoods are secured; in case of land acquisition, the land compensation fees, resettlement
subsidy, and compensation fees for rural residential houses, other ground attachments, young
crops, etc. shall be paid timely and fully according to the law, and social security costs for the
affected farmers shall be disbursed accordingly; the rates of land compensation fees and
resettlement subsidy for acquired agricultural land shall be fixed by provinces, autonomous regions
and municipalities by fixing and disclosing block comprehensive land prices, which shall be
adjusted or reissued at least every three years; compensation rates for acquired land other than
agricultural land, ground attachments, young crops, etc. shall be fixed by provinces, autonomous
regions and municipalities. For rural residential houses, fair and reasonable compensation shall be
provided on the principle of compensation before relocation and residential condition improvement
by such means as reallocating housing land for house construction, offering resettlement houses,
or granting cash compensation, and relocation, temporary resettlement and other costs resulting
from acquisition shall be compensated for in order to protect the lawful residential and property
rights of rural residents.
24. Compensation rates for land acquisition are usually adjusted every three years based on
local economic development and market conditions in Hubei Province. For example, the
compensation rates for land acquisition in Hubei Province were last adjusted by the Notice of
Hubei Provincial Government on Releasing Block Comprehensive Land Prices of Hubei Province
promulgated in November 8, 2019, stipulating that local compensation rates for attachments and
young crops on acquired land shall be determined by concerned municipal (prefecture)
governments based on local economic development and market conditions and registered by the
provincial natural resources department within three months after its promulgation. In addition, the
new Land Administration Law requires that land occupied or used for projects shall be
compensated for before occupation or use.
25. The compensation and resettlement mode for expropriated houses on state-owned land is
that a compensation and resettlement agreement be signed through third party market appraisal.
The state has promulgated the Regulations on the Expropriation of Houses on State-owned Land
and Compensation (Decree [2011] No. 590 of the State Council) and the Notice on Issuing the
Measures for the Expropriation and Evaluation of Houses on State-owned Land (JF [2011] No.77),
etc. to make systematic arrangements for land appraisal, process management, public
participation, compensation payment, resettlement policies, etc. Provincial, municipal and county
governments also offer such supporting measures as relocation subsidy, transition subsidy, and
compensation for production/business suspension losses based on local conditions. For example,
according to Articles 25 to 27 of Measures for the Implementation of the Expropriation of Houses
on State-owned Land and Compensation of Hubei Province (2015.7.6), 1) the value of the
expropriated house and the house for property right exchange shall be equivalent to the appraisal
value determined by qualified real estate appraisal agencies on the date when the decision on the
expropriation is announced in accordance with the measures for expropriation and evaluation of
houses on state-owned land; 2) the appraisal shall be conducted in accordance with China's
technical standards and evaluation procedures and with reference to the market prices of real
estate similar to the house expropriated; 3) Agencies, individuals and panels of experts responsible
for real estate appraisal shall conduct independent, objective and impartial evaluation and
appraisal of the expropriated house without being distracted by any organization or individual; and
4) municipal and county real estate authorities shall release the catalogue of legally registered real
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estate appraisal agencies with grade three or above qualifications and without bad credit records in
public on a regular basis so that affected people make a choice as needed.
(iv) Policy arrangements for livelihood restoration: The Land Administration Law
(2020) requires that the living standard of the affected farmers shall not be reduced, and their long-
term livelihoods shall be secured. In general, five main resettlement modes are available to land-
expropriated farmers: agricultural production, reemployment, equity participation, non-local
resettlement (Guidelines on Improving the Compensation and Resettlement System for Land
Acquisition (MLR [2004] No.238)), and pension insurance (Article 48 of the Land Administration
Law (2020), etc.). In addition to the above five modes, state policies, such as the Notice on Doing a
Good Job in Employment Training and Social Security for Land-expropriated Farmers (SC [2006]
No.29), also requires that each locality shall establish a social security system suited to the
characteristics and needs of land-expropriated farmers, secure employment training and social
security funds, promote land-expropriated farmers to get employed and be incorporated into urban
society, and ensure that the living standard of land-expropriated farmers is not reduced due to land
acquisition, and their long-term livelihoods are secured. Eligible land-expropriated farmers shall
have access to employment and startup supporting policies, occupational training, and public
employment services to promote their employment and startup. For example, according to the
Guidelines of Hubei Provincial Government on Basic Pension Insurance for Land-expropriated
Farmers (HPPG [2014] No. 53), land-expropriated farmers shall have access to the basic pension
insurance if: 1) their contracted land is legally expropriated by governments at or above county
level; 2) they have the Rural Land Contract or the Certificate of Contractual Right of Rural Land in
hand when their land is expropriated; 3) they are registered permanent residents at the place
where the expropriated land is located; 4) the area of arable land per capita is 0.3 mu or less after
the land expropriation; and 5) they are 16 years old or older. Below are compensation rates for
basic pension insurance of land-expropriated farmers in Hubei Province: governments at or above
county level provide land-expropriated farmers with one-off compensation no less than three times
the annual per capita net income of rural residents in the city or prefecture where the land is
expropriated; land-expropriated farmers who are 60 years old or older are entitled to such one-off
compensation in full amount; for land-expropriated farmers under the age of 60 ( 16 to 59 years
old), the amount of compensation shall be 1% lower than the aforesaid full amount for every 1 year
of difference between their actual age and the baseline age (60 years old).
(v) Policy arrangements for infrastructure restoration: For potential infrastructure
impacts arising from land acquisition and house demolition, the Land Administration Law and the
Regulations for the Implementation of the Land Administration Law stipulate, after the land
acquisition plan is approved and announced, the county government shall organize a land survey
within the range of land acquisition and disclose the results to the public for at least 30 days. Article
47 of the new Land Administration Law (2020) stipulates, “For rural residential houses, fair and
reasonable compensation shall be provided on the principle of compensation before relocation and
residential condition improvement, …�?
(vi) Information disclosure, public participation and informed decision-making:
Public participation runs through the whole project lifecycle and is an important measure to ensure
the success of LAR activities. The Ministry of Natural Resources issued the Standard Guidelines
for Grass-root Government Affairs Disclosure in Rural Collective Land Acquisition in June 2019,
sorting out matters to be disclosed, regulating the disclosure process, and improving modes of
disclosure to protect the people’s rights of information, participation, expression, and supervision
practically. The main objectives of public participation at different stages of LAR are as follows:
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26. During option argumentation and comparison, the project owner and design agency shall
conduct meaningful consultation with affected people and other stakeholders and improve
the engineering measures and determine the range of land use based on feedback,
thereby evading sensitive objects and minimizing LAR impacts.
27. Participation at the DMS stage includes land acquisition announcement, DMS publicity,
participation in the DMS, and confirmation, disclosure and review of DMS results.
28. At the SSRA stage, meaningful consultation will be conducted with stakeholders to assess
potential major social risks arising from land acquisition and house demolition, including
other major risks that are not directly related to but may materially affect the project.
29. During the drafting of the compensation plan, the plan should be disclosed to collect
comments from affected people, and a public hearing will be held when necessary.
30. Public participation at the implementation stage mainly includes production and life
resettlement, and effective information disclosure and consultation should be conducted in
the allocation and use of compensation.
31. Assessment: China has established a complete legal framework and policy system on
land acquisition, house demolition, resettlement, and compensation. Rural land acquisition and
house demolition are based mainly on the Land Administration Law (2020), the measures for the
implementation of the Land Administration Law of Hubei Province, and relevant compensation
rates. Urban house demolition is based mainly on the Regulations on the Expropriation of Houses
on State-owned Land and Compensation (2011). The Land Administration Law that was amended
on August 26, 2019, and came into effect on January 1, 2020 has substantively coordinated the
practices of land acquisition and house demolition in rural and urban areas. The new Land
Administration Law defines the scope of land acquisition for public interests, strengthens
preparatory risk management for land acquisition, and information disclosure and public
participation (including public hearings) in land acquisition and house demolition, and requires that
an agreement shall be signed with the landowner and user before land approval, and
compensation and resettlement funds be arranged in advance. The new law requires that land
acquisition compensation rates shall be fixed based on block comprehensive land prices, and
adjusted or reissued at least every three years, and that fair and reasonable compensation shall be
granted for land acquisition to ensure that the living standard of the affected farmers is not reduced.
Therefore, the new Land Administration Law will protect the rights and interests of affected persons,
ensure sustainable livelihoods, and improve living conditions more effectively. In general, the LAR
regulations are consistent with the requirements of Core Principle #4 and Element 9.
1. Core Principle #5: Management system for ethnic minorities and vulnerable groups
32. The three elements under Core Principle #5 are related to the social regulations system of
the Program. Consistency is analyzed below.
Element 10: Undertake meaningful consultations if the ethnic minorities are potentially affected
(positively or negatively), to determine whether there is broad community support for the PforR
Program activities.
33. Policy requirements for ethnic minority consultation: According to the seventh national
census in 2020, there are 6,500 sporadically distributed minority people in Honghu City involved in
the Program, accounting for 0.69% of the city's total population. In comparison, the Qingjiang River
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watershed within the scope of the Program is an area where minority people in Hubei Province live
in clusters. Enshi Tujia and Miao Autonomous Prefecture accommodates 29 minority groups,
including Han, Tujia, Miao and Dong nationalities, etc., with minority people accounting for 54% of
the total population. China’s Constitution stipulates that all ethnic groups of China are equal. The
Law of the People's Republic of China on Regional National Autonomy stipulates, in dealing with
special issues concerning the various nationalities within its area, the organ of self-government of a
national autonomous area must conduct full consultation with their representatives and respect
their opinions; the organ of self-government of a national autonomous area shall guarantee that
citizens of the various nationalities in the area enjoy the rights of citizens prescribed in the
Constitution and shall educate them in the need to perform their duties as citizens. On this legal
basis, when minority residents are affected similarly by land acquisition and house demolition, they
will not only enjoy the same rights as citizens, but also be subject to free, prior and informed
consultation in a culturally appropriate manner organized by local governments when necessary. In
addition, no organization or individual shall destroy grasslands or forests by any means or open up
arable land in a way that damages grasslands or forests, and the organ of self-government of a
national autonomous area shall make independent arrangements for local capital construction
projects in the light of local financial, physical and other conditions within the framework of national
plans. When developing resources or carrying out construction projects in a national autonomy
area, the state shall protect its interests, make arrangements favorable to its economic
development, and local minority residents’ production and livelihoods. On the other hand,
according to the regulations on SSRA, at the feasibility study stage of a project, the PIU (or through
a specialized agency) shall conduct an SSRA to identify impacts, propose mitigation measures,
and prepare an SSRA report; if a government at or above the county level applies for land
acquisition, a current status survey and an SSRA should be conducted for the land to be acquired.
Each municipal or county government has formulated local policies according to the applicable
regulations, such as the Opinions on the Implementation of Measures to Strengthen Social Stability
Risk Assessment for Major Decisions under New Circumstances of Hubei Province promulgated
by Hubei Provincial Committee of the CPC and Hubei Provincial Government in December 2021.
34. Assessment: Comprehensive ethnic minority development policies have been established
in China and Hubei Province to respect minority opinions, ensure ethnic equality and respect
minority customs, and no land of ethnic minorities shall be acquired without their prior consent and
the execution of the written agreement with each household concerned, keeping in line with Core
Principle #5 and Element 10.
Element 11: Ensure that ethnic minorities can participate in devising opportunities to benefit from
exploitation of customary resources and indigenous knowledge, the latter to include the consent of
ethnic minorities.
35. Policy basis for ethnic minority development: The Law of the People's Republic of
China on Regional National Autonomy stipulates, when developing resources or carrying out
construction in a national autonomy area, the state shall protect its interests, make arrangements
favorable to its economic development, and local minority residents’ production and livelihoods,
and include major ecological balance and environmental protection projects in the local national
economic and social development plan. From the perspective of public consultation, the Interim
Regulations on Major Administrative Decision-Making Procedures stipulates that prior public
participation shall be conducted when developing major economic and social development plans,
and determining major local infrastructure projects, and it also makes systematic provisions on the
schedule, form, process, recording, etc. of public participation. In light of the above, the 14th Five-
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Year Plan of Hubei Province for High Quality Development of Ethnic Affairs (2022.1) was
promulgated in January 2022, setting 18 concrete objectives of 4 categories (including promoting
ethical values, achieving common prosperity and development, creating a good life for all, and
advancing exchanges and integration between different nationalities) and specifying 8 key projects
to enhance the sense of community of the Chinese nation, promote integrated and innovative
development of green industries in ethnic minority areas, offer key support to rural revitalization,
and construct a big data management platform for ethnic and religious affairs.
36. Assessment: The central government and Hubei Provincial Government make top-down
systematic planning and arrangements in ethnic minority development to create job opportunities
for minority residents and improve their living standard and shall conduct prior public consultation
for relevant plans and projects in accordance with the Interim Regulations on Major Administrative
Decision-Making Procedures. This is consistent with Core Principle #5 and Element 11.
Element 12: Give attention to groups vulnerable to hardship or discrimination, including, as
relevant, the poor, the disabled, women and children, the elderly, ethnic minorities, racial groups,
or other marginalized groups; and if necessary, take special measures to promote equitable
access to PforR Program benefits.
37. Poverty and poverty reduction systems: There are complex causes of poverty, such as
illness, disability and education. In China, poor households refer mainly to those below the
minimum living security (MLS) standard, and are classified into: a) MLS households, whose per
capita annual income is below the MLS standard. The MLS standard was 7,968 yuan per capita
per annul in urban areas and 5,707 yuan per capita per annual in rural areas in Hubei Province in
2020; and b) extremely poor persons, old and disabled persons and persons under 16 years with
no ability to work, no income source, or statutory supporter, or whose statutory supporter is
incapable to support. Extremely poor persons in urban and rural areas of Hubei Province are
eligible for financial support of 15,900 yuan per person per annul and 10,764 yuan per person per
annul respectively in 2020. These poor households receive full national security in basic needs like
food, housing, medical care, children education, as well as occupational training and priority in job
placement (if applicable), etc.
38. The 14th Five-Year Plan of Hubei Province for the Development of Civil Affairs (2021.10.
29) requires that high-quality development of civil affairs commensurate with economic and social
development of Hubei Province shall be achieved by 2025: 1) basic living standards of the people
shall be significantly improved by promoting the tiered and classified social assistance system
underpinned by basic living assistance, social assistance for special purposes and temporary
assistance in emergencies and disasters with the support of private sectors, upgrading assistance
management services, putting policies in place effectively to protect orphans and de facto orphans,
and further enhancing mechanisms concerning living subsidies for the financially-challenged
disabled population, nursing care allowances for the severely disabled and social welfare for the
elderly; and 2) the quality of basic social services shall be improved markedly by coordinating
home-based and community elderly service providers, promoting the integration of medical and
health care for the elderly, optimizing the supply structure and quality of elderly care services,
improving the social care service system, strengthening government purchase of social services,
engaging more private professional market players, improving the quality and efficiency of
comprehensive marriage services, and further standardizing adoption of children. Below are the
key objectives to be achieved by 2025: the annual growth rate of MLS in rural areas shall be no
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lower than that of per capita consumption expenditure of the previous year; the MLS standard in
rural areas accounts for more than 75% of that in urban areas; living subsidies are provided to all
financially-challenged disabled people; nursing care allowances are offered to all severely disabled
people; trans-provincial marriage registration is fully achieved; all vagrants and beggars with
known identity information are returned to their homes; nonprofit cremains burying (storage)
facilities are available in all counties; at least 60% of beds in elderly care institutions meet
requirements for nursing care; comprehensive elderly care institutions are accessible in 60% of
townships (sub-districts); minor protection centers are available in 50% of townships (sub-districts);
the number of social service professionals stands at 80,000; volunteer service centers account for
80% of comprehensive community service facilities; the area of comprehensive community service
facilities accessible by every 100 residents tops 30 square meters; and the number of full-time
employees of social organizations reaches 400,000.
39. Protection of women’s rights and interests: As for gender equality and women’s
development, the Law of the People's Republic of China on the Protection of Women's Rights and
Interests (2018 Amendment) requires that women’s lawful rights and interests shall be protected,
and gender equality promoted, where the state shall ensure that women enjoy the same labor and
social security rights as men. For example, this law stipulates that women enjoy the same rights as
men in rural land contracting, income allocation, compensation for land acquisition or the use of
such compensation, and the use of land for building a house, etc. No any organization or individual
is allowed to infringe on women’s rights in the rural collective economic organizations on the
grounds that they are un-married, married, divorced or widowed. The Development Outline for
Chinese Women (2021-2030) promulgated by the State Council in March, 2010 specifies the
following goals: gender equality is practically put in place as a basic state policy to advance
innovation in systems and mechanisms for promoting gender equality and women's all-round
development; women have equal access to a full range of life-cycle health services, with their
health being improved continuously; women have equal access to education, with their literacy
skills and competences being enhanced; women enjoy the same rights as men in economic affairs,
with their financial status being improved steadily; women have the same rights as men in political
affairs, with their level of participation in the administration of state, economic, cultural and social
affairs being increased gradually; women enjoy equal access to multi-level and sustainable social
security, with their benefits being steadily improved; a more sound system of laws and policies
supporting family development is developed, with the new trend toward socialist family values
being widely promoted; the concept of gender equality enjoys greater support, creating a more
favorable environment for women's development; a more sound legal framework is established to
effectively safeguard legitimate rights and interests of women; and women's sense of gain,
happiness and security is increased significantly.
40. The Plan of Hubei Province for Women's Development (2021-2030) (2021.12.25) explicitly
specifies main goals of women's development by 2030 and makes explicit provisions on
assessment indicators and supporting measures in 8 aspects such as health, education, economy,
participation in decision making and administration, social security, family development,
environment, and law.
41. Child protection: The Law of the Peoples Republic of China on the Protection of Minors
(2020 Amendment) stipulates that minors shall enjoy all rights equally in accordance with the law,
regardless of the nationality, race, gender, household registration, occupation, religious belief,
education level, family status, physical and mental health of themselves or their parents or other
guardians. The law makes detailed provisions on family, school, social, network, government and
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judicial protection for the minors. The Plan of Hubei Province for Children's Development (2021-
2030) (2021.12.25) specifies main goals of child development by 2030 and supporting measures in
health, safety, education, welfare, family, environment, and legal protection, etc., and establishes
the annual monitoring, mid-term evaluation, and final evaluation mechanism for the achievement of
such goals.
42. Assessment: Based on the above analysis, there are systematic plans, measures and
institutional arrangements on the development, and rights and interests of ethnic minorities,
impoverished people, women, children and other vulnerable groups in China and Hubei Province,
ensuring that all relevant groups participate equally, and benefit from the Program fairly. Therefore,
the policies on vulnerable groups and women are consistent with Core Principle #5 and Element
12.
1. Core Principle #6: Social conflict management system
43. Element 13 requires that conflict risks be considered, including distributional equity and
cultural sensitiveness, and is not related to the Program in general. In addition, based on the
analysis of Core Principle #1 and Element 1, China manages social risks and impacts
comprehensively through social stability risk analysis. Therefore, the Program will not exacerbate
local social conflict.
5.3 Assessment of Social Management Mechanism and Capacity
44. Elements 1 and 2 under Core Principle #1 in the PforR ESSA Guidance propose principled
requirements for the responsibilities and capacity of the social agencies of the PIAs. The capacity
of such agencies is measured by corresponding core principles. It's required that agencies
responsible must have to commit all necessary resource inputs and appropriate measures to
manage social risks (Element 1). On the other hand, it is also required that impact assessment and
management requirements should establish clear requirements on organizational responsibilities
and resources, thereby supporting the implementation of relevant plans (Aspect V under Element
2).
45. As shown in Table 5-1, the provincial, municipal and county authorities in Hubei Province
have established clear management agencies for different social risks, which have been provided
with qualified staff. This section analyzes the organizational setup of the social management
system and assesses if the organizational settings are rational and needs improvement. It is
discussed through two levels: first, the organizational settings of each social management system;
second, the rationality and capacity of each social management system against the requirements
at Elements 1 and 2 under Core Principle #1. Where gaps are identified, actions and
recommendation will be proposed. This section will assess the roles and responsibilities of each
administrative agency, working regulations/procedures, staffing and capacity, cross-departmental
coordination, etc. through adequate consultation. It is observed the number of staffing is tens of
staff for each provincial and county level department. The staff number of departments are not
exactly the same in different areas and decided through official documents and procedures to
allocate/maintain human and other resources for meeting the dynamic demand. In addition, Table
4-1 in Appendix 4 sets out detailed stakeholder analysis conclusions, including the responsibilities
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of different government authorities involved in different types of activities, and results of authority
interviews under the social management system.
(1) Social risk assessment management agencies 10
1. Provincial development and reform commission: approving major fixed asset
investment projects based on social stability risks and other documents relevant
(attaching the SSRA report when applying for project approval).
2. Provincial political and legislative affairs committee: coordinating and directing
SSRA, convening different political and legislative affairs committees, and authorities for
cross-regional/departmental projects to discuss SSRA requirements, and stressing
typical risks when necessary.
3. Municipal/county government: conducting county-wide social stability risk assessment,
decision-making, implementation and supervision, and the SSRA report is discussed and
adopted by the executive meeting of the municipal and county CPC committee.
4. Municipal/county political and legislative affairs committees: reviewing and registering
the SSRA report and supervising the work of the assessor and implementing agency.
5. Assessor: conducting or appointing an independent appraisal agency to conduct SSRA,
and implementing SSRA measures
6. Independent appraisal agency: attending SSRA training and examinations organized by
the NDRC and getting registered at the provincial political and legislative affairs committee
in advance.
7. For example, on the heels of the Interim Measures for the Social Stability Risk Assessment
of Major Fixed Asset Investment Projects promulgated by the NDRC and the measures issued by
Hubei Provincial Development and Reform Commission for the implementation of the aforesaid
Measures, the government of Enshi Tujia and Miao Autonomous Prefecture urges all relevant
departments to put national and provincial policies in place and formulates detailed rules to
implement such policies, including the Rules of the Civil Affairs Bureaus (CABs) of Enshi Tujia and
Miao Autonomous Prefecture for the Implementation of the Social Stability Risk Assessment for
Major Decisions, the Five Measures for Carrying out Social Stability Risk Assessment and
Prevention for Major Matters issued by the Bureau of Urban Management of Enshi City, and the
Opinions on Practical Implementation of the Social Stability Risk Assessment and Mitigation
Mechanism for Major Environmental Matters (Interim) promulgated by the Ecology and
Environment Bureau of Enshi Tujia and Miao Autonomous Prefecture. These highly targeted and
exercisable documents have defined the standard procedures, scope and contents of assessment,
and agencies responsible, and established a sound SSRA system for major matters at the
prefecture, municipal, county, township (sub-district) and village levels under the legal framework
of China and Hubei Province. It is stipulated that CPC and government chiefs at different levels
10This section summarizes the responsibilities of the relevant agencies related to the Program's
social risk management, which may not be all responsibilities of the government authorities
concerned.
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and authorities are persons chiefly responsible for the SSRA of their respective organizations, and
the SSRA of major matters shall be included in the prefecture's overall performance assessment.
8. Assessment: The state and local regulations clearly stipulate responsibilities for the
agencies concerned and their manning quotas, and the related provincial authorities (provincial
political and legislative affairs committee) require that staff concerned should attend relevant
training. In addition, sufficient budgets are made available during SSRA to ensure that relevant
measures are implemented. The SSRA mechanisms of Hubei Province are effective, and
consistent with the Bank policy. On the other hand, project risk control measures are implemented
by the assessor under the supervision of the municipal and county authorities. For example, the
natural resources authority supervises land acquisition and house demolition compensation and
resettlement only, while other social risks, such as public participation (in relation to the opinions
and advice of affected people on the site of the Program), are supervised by another agency, such
as the bureau of letters and visits. Therefore, no Program-specific third-party monitoring
mechanism has been established.
9. Recommendation: Social monitoring and assessment arrangements should be
established for the Program to monitor social risks (including LAR) regularly, evaluate the social
performance of the Program, and improve social risk control measures pertinently and dynamically
based on assessment results.
(2) Cultural relic protection agencies
1. Provincial culture and tourism department: coordinating and directing cultural relic
investigation, protection and utilization, archeology, and major project implementation
through the cultural relic protection division
2. Municipal/county government: responsible for the territorial management of cultural
relic safety
3. Municipal/county cultural relic authority: coordinating and directing cultural relic
protection, conducting administrative law enforcement for cultural relics, assisting the
competent authority in reviewing projects involving cultural relic protection, supporting
the superior cultural relic and archeological authority in conducting cultural relic
investigation and exploration, and archeological excavation; where any cultural relic
burial area cannot be avoided in site selection, the provincial cultural heritage bureau
shall organize the archeological excavation agency to conduct cultural relic investigation
and exploration at the expense of the project owner
1. Municipal/county development and reform commission: organizing feasibility study
review for construction projects, and ensuring that the project design does not affect
cultural relics
2. Planning division of natural resources authority: assisting the cultural relic authority
in defining the range of cultural relic protection and construction control area during local
planning and project site selection
3. Assessment: For potential adverse impacts on tangible cultural heritage, there are state
and local regulations to avoid or minimize such impacts. According to the survey and interview with
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the provincial and county authorities, the existing cultural relics risks were managed effectively,
consistent with Core Principle #2.
(3) Land acquisition and house demolition agencies
1. Land use approval agencies:
1. Ministry of Natural Resources: approving project-specific basic farmland acquisition
2. Provincial natural resources department: approving project-specific permanent
acquisition of collective land (except basic farmland)
3. Municipal/county natural resources bureau: accepting land use applications for
construction projects, directing the PIUs to prepare necessary land approval documents,
and submitting such documents to the competent government
1. Land acquisition
1. Natural resources authority or land acquisition and house demolition authority of
government at or above county level: implementing the applicable laws and
regulations, drafting the local land utilization plan, directing land users to submit land
use application materials, and reviewing and submitting such materials; establishing a
leading group for land acquisition and house demolition compensation and
resettlement; disclosing relevant reports; drafting a compensation and resettlement
plan; organizing public hearings on land acquisition and house demolition; signing land
acquisition agreements with affected persons or entities, and conducting
compensation and resettlement
2. Township government and village/community committee: participating in and
supporting land acquisition and house demolition, especially DMS, door-to-door visit,
publicity communication, resettlement measure discussion, grievance redress, etc.
3. Municipal/county human resources and social security bureau: population with a
per capita cultivated area below the specified level after LA will be eligible for social
security. Land-expropriated farmers may cover basic pension insurance that is
equivalent to that of a worker, or respective basic pension insurance for a resident
voluntarily through application by themselves, and the application will be discussed in
the village collective economic organization, reviewed and 7-day disclosed by the
township government or sub-district office, approved by the local government, and
registration by the human resources and social security bureau. The FB will disburse
subsidies
4. Third party appraisal agency: a qualified real estate appraisal agency will be
appointed by the affected village or community under the direction of the natural
resources authority to appraise house compensation rates, where relevant
5. FB: preparing necessary budgetary funds according to the resettlement budget
submitted by the NRB and land user
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6. Audit bureau: auditing resettlement costs regularly according to the statutory process,
and giving opinions
7. Assessment: China has established a sophisticated organizational structure for land
acquisition management, with responsibilities clearly defined. The Land Administration Law
requires that land occupied or used for projects shall be compensated for before occupation or use,
and the finance and audit bureaus shall review the budget regularly. In addition, during the survey,
the competent authorities will implement or participate in land acquisition or occupation,
compensation, and resettlement for different types of projects, and have rich experience to
implement and manage land acquisition and compensation, consistent with Core Principle #4.
1. Livelihood restoration
1. Livelihood restoration measures are flexible, including agricultural resettlement,
reemployment, shares resettlement with assets, relocation, social security, etc., which
involve different management agencies. Specifically, agricultural resettlement is
usually conducted by the village collective economic organization, which may decide to
allocate undistributed collective land to households affected by land acquisition, or
conduct land reallocation if no undistributed collective land is available; reemployment
is chosen by affected households based on their own needs, where free training and
employment support are provided by the county labor and employment authority;
shares resettlement is determined by the PIU in consultation with affected
households; relocation is requested by the affected households for new land farming
at other areas, and decided by local governments after assessing and consulting with
the host village collective economic organizations; social security is implemented by
the county social security authority with the support of the township government and
village/community committee.
2. Assessment: Livelihood restoration is part of LAR. Different livelihood restoration
measures involve different implementing agencies, such as village collectives, social security
authorities, employment authorities, and enterprises, which have clearly defined responsibilities. In
addition, different livelihood restoration measures have different funding sources. Livelihood
restoration measures can be well implemented in practice due to rich experience and sound
regulations, consistent with Element 9 under Core Principle #4.
(4) Public safety, worker health and safety, and emergency engagement agencies
1) Worker health and safety
3. National Health Commission: preparing, adjusting and disclosing classes and
catalogs of occupational diseases, and supervising national occupational disease
prevention and treatment
4. Health Commission of Hubei Province: Formulating policies and standards related to
occupational health and radiation health and organizing their implementation. Carring
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out monitoring of key occupational diseases, special investigations, occupational
health risk assessment and occupational population health management. Coordinating
the prevention and control of occupational diseases.
5. Municipal/county health authority: supervising local occupational health examination
and management of occupational diseases , and ensuring that workers receive
occupational health and safety rights according to law
6. Hubei Provincial and local Human Resources and Social Security Bureaus
(HRSSBs): Responsible for the management of work-related injury insurance,
coordinating the tripartite mechanism of labor relations with representatives of trade
unions and enterprises, and jointly solving major issues related to labor relations.
7. Hubei Provincial Center for Disease Control and Prevention: Provide technical
guidance, training and quality control for the province's prevention and control work.
8. Hubei Provincial Occupational Disease Supervision Agency: drafting and
implementing the provincial plan for occupational disease prevention and control, and
being responsible for technical guidance, training and quality control
9. Occupational health examination agency: obtaining a practicing license, where the
lead physician shall have a practicing certificate, a middle-rank or above qualification,
an occupational disease diagnosis qualification, and at least three years of experience
in occupational health examination
10. Trade Union: directing workers and employers to enter into and perform employment
contracts, and establishing a collective bargaining mechanism to protect the lawful
rights and interests of workers
11. Women’s Federation: coordinating competent authorities to protect women’s rights
and interests
2) Community safety management
12. Production/operation entity: The key leader, e.g., the legal person, is responsible
comprehensively for its work safety, and the trade union shall supervise work safety
13. Hazardous chemical material production/operation/storage agency: setting up a
work safety management agency, or appointing full-time work safety staff
14. Emergency management department: guiding all departments in the region to
respond to emergencies such as work safety and natural disasters and comprehensive
disaster prevention, mitigation, and relief work. Responsible for the comprehensive
supervision and management of production safety.
15. In Hubei Province, a work safety mechanism is in place, saying safety is the
responsibility of the production and operation entities, participated by workers,
supervised by the government, self-disciplined by the industry, and supervised by the
public. Safety education aims to cover all people, and work safety training shall be
attended by each level of government officials
3) Natural disaster emergency engagement
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16. Provincial disaster reduction commission: It is the natural disaster rescue and
response agency of the provincial government, established at the provincial
emergency management department, with members being the provincial emergency
management department, finance department, and other competent authorities, such
as the agriculture and rural affairs department, water resources department, natural
resources department, housing and urban-rural development department, ecology and
environment department, statistics bureau, weather bureau, earthquake bureau, health
commission, broadcast and television bureau, red cross, communication bureau, and
fire brigade. The provincial disaster early warning and response system is started
based on assessment, and after it is started, the provincial disaster reduction
commission starts its working mechanism immediately, such as post-disaster relief and
reconstruction
17. Municipal/county government: when a natural disaster occurs, the local disaster early
warning and response system is started based on assessment
18. Assessment: For natural disaster management, Hubei Province has defined departmental
responsibilities, and can manage sudden natural disasters effectively, consistent with Element 8
under Core Principle #3.
(5) Ethnic minority management agencies
19. Provincial ethnic and religious affairs commission: developing the provincial
minority development plan as required by the provincial government, protecting the
lawful rights and interests of minority residents, and supervising relevant work
20. Prefecture ethnic and religious affairs bureau: implementing policies, laws and
regulations, and provincial and municipal/prefecture decisions on ethnic and religious
work; drafting local regulations and rules on ethnic and religious affairs; formulating
relevant policies and plans, and ensuring their implementation; directing the
implementation of national regional autonomy to protect the lawful rights and interests
of minority residents; drafting development plans for minority officials and talents, and
studying relevant policy advice.
21. Municipal/county ethnic and religious affairs bureau: identifying municipal/county
minority population, applying for ethnic minority development projects, and training
minority officials.
22. Assessment: Departmental responsibilities for economic and social development, and
minority official training in minority areas have been defined at the provincial, municipal/prefecture
and county levels, consistent with Core Principle #5.
(6) Vulnerable group protection agencies
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23. Poverty reduction offices (renamed as “countryside revitalization bureaus�? since 2021),
women’s federations, and civil affairs bureaus have been established, and poverty reduction
policies and plans are developed at the state, provincial and county levels to facilitate poverty
reduction, women’s development, and the management of the disabled, left-behind old people and
children, etc. in a unified manner. All authorities have appropriate staff and budgets and are
subject to performance assessment.
24. Civil affairs bureau: managing affairs related to old people and left-behind (distressed)
children needing assistance, including conducting survey, collecting statistics, filing
and recording, establishing a local management mechanism for left-behind (distressed)
children and a local old-age care mechanism, and securing funds
25. Women’s federation: guiding women to play a unique role in production and life, and
protecting the lawful rights and interests of women and children, providing assistance
to aggrieved women and children, building family civilization, etc.
26. DPF (Disabled Persons Federation): protecting the civil rights of the disabled,
collecting their opinions and needs, mobilizing the public to understand, respect, care
for and support them, and eliminate discrimination and obstacles, assisting the
government in developing outlines for disabled persons’ programs, and promoting their
rehabilitation, education, employment, rights protection, culture, and social security
27. Township government and village/community committee: a supervisor of left-
behind (distressed) children is appointed, and a regional old age care service center
and a women’s federation office are established at the township level; a children’s
director and a women's director are appointed; an old age care service station is
established in each village/community
28. For example, the civil affairs authority of Enshi City rallies the support of both public and
private sectors to help and protect the elderly, women, children, and other vulnerable groups
across the board.
29. Enshi City has established a leading group for the protection of minors and clarified the
duties and responsibilities of all members of said group in documents like the Division of
Responsibilities and Tasks of Members of the Leading Group for the Protection of Minors in Enshi
City (LGPM [2021] No. 1) and the Priorities of Work of the Leading Group for the Protection of
Minors in Enshi City in 2021 (LGPM [2021] No. 2). A designated children's rehabilitation service
center was founded in the Enshi Children’s Welfare Institute, and minor protection centers were
established in 17 townships (sub-districts). Each of the 17 townships (sub-districts) in Enshi City
has designated a children's supervisor, and each of the 208 incorporated villages in the city has a
children's director to provide one-to-one and one-to-many assistance to children in need without
delay by paying visits on a timely basis. In 2021, the Enshi Children's Welfare Institute had 48
centrally raised orphans, 757 scattered orphans received funds worth 1,251,390 yuan, and 1,342
de facto orphans received funds worth 1,774,340 yuan (including student grant of 70,000 yuan).
Both scattered orphans and de facto orphans were eligible for a subsidy of 1,270 yuan per person
per month. In 2021, 28 orphans and de facto orphans in the China Welfare Lottery-funded student
aid program received student grant of 10,000 yuan per person per academic year.
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30. Enshi City has established an all-round subsidy system for the financially-challenged senile
elderly and senior citizens with disabilities, with subsidies totaling 830,500 yuan being disbursed to
14,821 eligible senior citizens from January to December of 2021. In addition, old age subsidies
totaling 13,387,150 were paid to 231,370 elderly people during the same period.
31. Enshi City manages registration information of 2,108 left-behind children, 3,734 left-behind
elderly people, and 1,014 left-behind women separately and include their information in the
national child welfare information system and the national elderly service information system
(systems of the “Jinmin Program�?) to improve separate registration management and achieve real-
time update and dynamic management of information. A system of social care for left-behind
elderly, children and women has been established with the support of senior citizens’ associations,
children's homes, social service centers and other platforms to promote mutual aid and self-help
and identify and resolve difficulties and problems in time.
32. Assessment: There are competent authorities that manage different vulnerable groups in
China, such as poverty reduction offices or countryside revitalization bureaus for poverty issues,
DPF for disabled people, civil affairs bureaus for the left-behind old people and children, and
women’s federations for women. These authorities are flexibly staffed and may engage extra staff
as necessary in additional to their regular staff. Therefore, the state and local governments have
clearly defined responsibilities in the rights protection of vulnerable groups, and their management
capacity complies with Core Principle #5.
5.4 Assessment of the Social Effects of Implementation
33. The assessment of social effects of implementation is mainly based on the information
obtained from the demonstration and sample cities/counties. The cities/counties investigated are
Honghu City whose scope of administrative jurisdiction covers three fourths of the Honghu Lake
watershed, Lichuan City, Enshi City, as well as Jianshi County, Xuan’en County and Badong
County in Enshi Tujia and Miao Autonomous Prefecture in the Qingjiang River watershed. Field
visits and investigations were conducted in these 6 cities/counties to collect relevant information for
social system assessment.
34. The social effects of implementation assessment also takes into account the characteristics
of national autonomous areas involved in the Program. Enshi Tujia and Miao Autonomous
Prefecture has 28 ethnic minorities, including Tujia and Miao nationalities living in clusters, and
sporadically distributed Dong, Bai, Moggol and Hui nationalities.
35. The social practice effects assessment considers previous similar typical projects and
investigates the implementation of laws and regulations on various social impacts, major problems
and feedback from stakeholders concerned. Special attention is paid to analyzing the
implementation of policies consistent with the World Bank's principles to assess whether the
objectives set out in the core principles and elements can be met. Therefore, this section provides
analysis and assessment against the six core principles and elements of social relevance.
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1. Core Principle #1: Sustainable social risks management system
Element 1: Operate within an adequate legal and regulatory framework to guide E&S impact
assessments, mitigation, management, and monitoring at the PforR Program level.
36. There are both physical and non-physical Program activities. Non-physical Program
activities only affect the production and life of farmers or community residents, thereby indirectly
affecting their living habits and production costs. Physical Program activities, such as urban
wastewater collection and treatment facilities, soil and water conservation, domestic refuse
collection and transfer facilities, and fecal residue and wastewater treatment facilities, may cause
land use and livelihood related impacts. Non-physical Program activities, including the promotion of
the use of organic fertilizers and standardized collection and management of agricultural film will
not cause direct losses, but will improve farmers' environmental awareness and gradually change
their farming methods and living habits, which requires the improvement of production and living
skills and competences.
1. Physical Program activities
2. Social impacts of physical Program activities are mainly identified, analyzed and managed
on the basis of SSRA or social impacts specified in feasibility study.
3. The investigations in the sample counties show that an SSRA was conducted for physical
Program activities, including the urban WWTPs and domestic refuse collection, transfer or
treatment facilities, that involve permanent land acquisition or house demolition in accordance with
relevant laws and regulations on SSRA. Physical Program activities without permanent land
acquisition or house demolition were supported by the feasibility study, including assessment of
possible social impacts, carried out at the preparatory stage of the Program. For example, 3
SSRAs were conducted for wastewater treatment, refuse transfer, fecal residue and wastewater
recycling facilities in Lichuan City, Hubei Province from 2020 to 2021.
4. According to the Political and Legislative Affairs Committee of Enshi City, the PIUs were
responsible for social stability risks incurred, for example, the municipal housing and urban-rural
development bureau is responsible for the construction, operation and management of wastewater
treatment facilities, including the early-stage assessment (e.g., SSRA). Competent
municipal/county authorities may designate subordinate or third-party agencies to conduct the
design, assessment, construction, operation and management of relevant physical Program
activities, depending on institutional arrangements and staffing. For example, the housing and
urban-rural development bureau of Enshi City appointed a public wastewater utility to take charge
of urban wastewater management. The utility allocated 8 administrative personnel to manage 16
urban WWTPs and related wastewater collection facilities in 14 townships and 5 sub-district offices
to ensure their effective operation and management and conducted routine work such as
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supervision and assessment. The construction, operation, and management of these facilities,
including early-stage SSRA, were undertaken by a third-party or designated agency. 11
5. SSRA is usually conducted by a specialized consulting agency and the SSRA report needs
to be reviewed by experts before they are put on records by the municipal/county political and
legislative affairs committee.
6. Non-physical Program activities
7. Non-physical Program activities, including the promotion of the use of organic fertilizers and
standardized collection and management of agricultural film, will not cause direct losses, but will
improve farmers' environmental awareness and gradually change their farming methods and living
habits, which requires the improvement of production and living skills and competences. Social
impacts arising from such activities are mainly managed by providing training and implementing
supporting policies.
Education and training:
8. Since the beginning of the 21st century, the Ministry of Agriculture and Rural Affairs and
local provincial/municipal authorities have established farmer training mechanisms to enable
farmers to receive free agriculture-related training every year. For example, according to the Notice
on Doing a Good Job in Cultivating High-Quality Farmers in 2022 issued by the General Office of
the Ministry of Agriculture and Rural Affairs in April 2022, the promotion of farmer training on
farmland protection, improvement of the capacity of developing, managing and protecting farmland
in line with high standards, and realization of eco-friendly planting and breeding and scientific
application of fertilizers and drugs are among the key tasks to be achieved. As a response, in
March 2022, the Department of Agriculture and Rural Affairs of Hubei Province promulgated the
Notice on the Priorities of Agricultural and Rural Programs in Hubei Province in 2022, specifying a
plan to additionally train 30,000 farmers. The training covers crop planting, livestock and poultry
breeding, use of organic fertilizers, NPS pollution prevention and control, and agricultural film
management, etc. For example, the first phase of the "Backbone Agricultural Workers Training
Program" held from November 11 to 17, 2021 in Daijia Town, Honghu City, Hubei Province saw
100 graduates completing courses such as regenerative rice cultivation, rice pest control, soil
testing and formulated fertilization, and agricultural environmental protection. All costs arising from
relevant training programs were covered by special funds from the agricultural and rural affairs
authority (Figure 1 in Appendix 7). In 2021, Lichuan City in Hubei Province disbursed 300,000 yuan
for the training of 173 farmers, including 52 females.
9. The training programs were organized by competent authorities such as the
municipal/county agriculture and rural affairs bureau and other designated agencies like the
Leading Group for Training High-caliber Farmers, the Leading Group for Rural Affairs of Honghu
11 Sub-district offices and townships are equivalent administrative divisions. Generally, a
sub-district office is an administrative division in the urban area of a city, while a
township is an administrative division in the rural area of a city.
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City, and the Leading Group for Rural Affairs of Lichuan City, etc. The analysis above shows that
farmer training in new production modes is supported by both national and local systematic
management mechanisms covering national and provincial policies, financial support and market-
based coordination. In the meantime, local agriculture and rural affairs authorities have make
specific organizational arrangements to put such mechanisms in place, in an effort to provide
farmers with professional training free of charge, and help them broaden knowledge, increase
income and enhance environmental awareness.
Supporting policy and assistance:
10. Investigations reveal that county agriculture and rural affairs authorities formulate soil
testing schemes every year to promote formulated fertilization and the replacement of chemical
fertilizers with organic fertilizers. According to the Department of Agriculture and Rural Affairs of
Hubei Province, the coverage rate of soil testing and formulated fertilization increased from 81.9%
in 2015 to 92.5% in 2021. The government of Lichuan City, Hubei Province provided active
guidance for farmers in implementing formulated fertilization, agricultural film management and
environmental protection in farming. For example, the pepper planting industry in Huangnipo
Village, Tuanbao Town, Lichuan City gained momentum by coordinating large farmers, specialized
agricultural service providers offering agricultural supplies and life-cycle technical support and
purchasing agricultural products, and small farmers, forming a community of shared interests. To
improve quality and competitiveness of pepper products, specialized agricultural service providers
developed standard pepper planting schemes in relation to accurate fertilization, unified farmland
management, and life-cycle training and instructions in farmland management in light of the result
of social testing carried out by the local government every year, promoting soil testing and
formulated fertilization, the replacement of chemical fertilizers with organic fertilizers and
agricultural film management indispensable for developing eco-friendly agriculture. The
Department of Agriculture and Rural Affairs of Hubei Province is promoting the "lead goose"
agricultural development pattern across the province,12encouraging one or more large farmers in
a village to help 20 to 30 small farmers catch up. Figure 2 in Appendix 7 shows the collected
agricultural films and cards for soil testing and formulated fertilization in the hands of pepper
growers in Huangnipo Village, Tuanbao Town, Lichuan City.
Element 2: Incorporate recognized elements of good practice in E&S assessment and
management.
(i) Early screening: according to the investigations, relevant responsible agencies,
including the housing and urban-rural development bureau responsible for urban wastewater
collection and treatment and urban and rural refuse collection, transfer and treatment, and the
construction contractor of fecal residue and wastewater recycling facilities, carried out adequate
investigation and verification at pre-construction stages of proposal making, feasibility study, and
design. At the stage of proposal making, the professional design agency usually provides multiple
proposals to be discussed by relevant responsible agencies. After a specific proposal is fixed, the
design agency conducts feasibility study, including its feasibility, reliability, economic effectiveness,
and E&S sustainability from technical, economic, environmental, social, safety, health and other
aspects.
12 The lead goose is the bird that leads a flying formation.
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11. The social sustainability study needs to meet the following requirements under the law to
avoid specific social impacts: 1) WWTP must be located at least 100 meters away from the nearest
residential area according to relevant laws and regulations on environmental protection; 2) the
feasibility study shall be subject to the pre-examination on the use of land by the provincial natural
resources department before it is submitted to the higher authority for approval, so as to avoid
occupying basic farmland, going beyond the local annual land quota, or involving other
environmentally and socially sensitive areas specified in relevant plans; and, 3) the sites of fecal
residue and wastewater recycling facilities shall be subject to approval by local competent
authorities, including approval by the ecology and environment authority for facilities near
environmentally sensitive areas and that by the cultural relic protection authority for facilities
adjacent to a protected cultural relic, etc.
12. According to the feasibility study report on the Wens pig farming and fecal residue and
wastewater recycling facilities in Honghu City, the sites selected are "far away from villages and
located in areas with favorable transportation and plague prevention and control conditions", and
approval and registration by the natural resources, agriculture and rural affairs, township
governments and other relevant authorities are available (Figure 3 in Appendix 7).
(ii) Alternatives: The feasibility study process for construction projects requires the
comparison of different proposals. For example, before the Feasibility Study Report on the
Domestic Refuse Incineration Plant in Enshi City was submitted in May 2020, the municipal
housing and urban-rural development bureau appointed a professional consulting agency in
August 2018 to compare alternative sites. After that, the Site Selection Report, analyzing and
comparing the three alternatives from the aspects of environment, society, and technology, was
submitted, and the recommended site was approved at the expert review on the Site Selection
Report where the experts unanimously concluded that the report took full account of factors such
as improving the surrounding environment and supporting infrastructure. According to the
feasibility study report on the WWTP upgrading and improvement in Honghu City, alternatives
were compared in site selection in the following principles: 1) the WWTP should be located
downstream rivers and lakes in the city, 2) the WWTP should be located downwind when it comes
to the prevailing wind blowing in the urban area in the summer; 3) the engineering and geological
conditions are favorable; and, 4) land acquisition and hose demolition are minimized and the health
protection zone is available as per environmental assessment requirements. In the end, an optimal
site was selected.
(iii) Developing measures to avoid, minimize or mitigate social impacts: The
provincial political and legislative affairs committee and municipal/county SSRA authorities
confirmed that the feasibility study report or other similar preliminary assessment documents must
include the identification and analysis of social impacts of the Program and measures to manage
such impacts. A risk identification, analysis, prevention, management, and control plan must be
included in the SSRA compulsory for any program activities under the law, including those
requiring permanent expropriation of house or land. For example, the SSRA for the WWTP and
supporting pipeline system in Tanjiaba, Enshi City requires the development of measures to
identify, prevent and control social impacts and risks, including site selection and verification to
avoid or minimize land acquisition and house demolition, establishment of the social risks
management team, payment of funds required in advance, and formulation of environmental and
emergency management plans, etc. The SSRA registration form was submitted to relevant
authorities to obtain their approval for the implementation of Program activities. For example, the
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SSRA report on the waste-to-energy power plant in Enshi City, Hubei Province identified design
rationality and risks, land use and construction impacts, and risks in personnel safety management
during operation and maintenance, etc., with prevention and mitigation measures being developed.
(iv) Defining the organizational responsibilities and budget sources for the
implementation of mitigation measures: In Hubei Province, the housing and urban-rural
development authority is responsible for the collection and treatment urban domestic wastewater
and refuse; the agricultural and rural affairs authority is responsible for the promotion of the use of
organic fertilizers, agricultural mulching film collection, and fecal residue and wastewater recycling;
and the water and soil conservation agency designated by the water resources authority is
responsible for the conservation of water and soil. The arrangements for municipal/county-level
management are broadly in line with provincial arrangements.
13. Program activities in different regions are usually planned first before being implemented
according to the annual work plans and fund availability of relevant responsible agencies. The
feasibility study, capacity assessment of PIUs and financial arrangement are usually made
available for a specific Program activity at the stage of design before construction. Only Program
activities approved by the development and reform authorities of Hubei Province, Enshi Tujia and
Miao Autonomous Prefecture (where demonstration counties are located) or Jingzhou City (an
administrative division having jurisdiction over Honghu City) can move to subsequent stages of
design and construction.
14. According to interviews with integrated municipal/county departments, project preparation,
construction, operational and management are subject to daily guidance and supervision by
ecology and environment, natural resources, labor and employment, health and hygiene, finance
and auditing departments to ensure that environmental and social management measures are in
place.
(v) Public participation, information disclosure and grievance redress
mechanism (GRM): It is confirmed by the political and legal affairs committee of Enshi City in the
interview that public consultation was conducted for relevant Program activities as required in the
process of SSRA. The SSRA passed an expert review and was filed with the government. It is
learned from the natural resources authority of Enshi City that the process of land acquisition was
subject to public disclosure and DMS in strict accordance with the policy requirements.
15. Municipal/county authorities of letters and visits stated that a full set of grievance redress
mechanisms were put in place at provincial, municipal and county levels in accordance with the
Regulations on Complaint Letters and Visits. For example, Jianshi County developed the
communal grievance mechanism consisting of three levels: grievance redress by the PIU
concerned directly; grievance redress by the village or community committee in collaboration with
the township government or sub-district office; and grievance redress by the county office for
letters and visits, or via the hotline/mailbox of the county head. The process involves information
collection, initiation of relevant procedures within 7 days, and completion of grievance redress and
feedback within 2 months. In addition, residents can resolve disputes through civil actions in the
courts. In general, the grievance redress mechanism is a standardized and effective mechanism.
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16. Assessment: Field investigations in Hubei Province and relevant counties/cities involved in
the Program show that the Program implementation and social impact management comply with
national and local laws and regulations. In the early stage of Program implementation, the
feasibility study, SSRA, and reviews have been conducted. In addition to meticulous technological,
environmental social, health and safety, institutional and budgetary design and arrangements,
public consultation and information disclosure are carried out during relevant assessment
procedures under the law, with comments from relevant authorities and reasonable public opinions
being sufficiently considered in the Program design. In the process of on-site consultation, field
visits are paid to a larger number of community residents and administrators, and they are
generally satisfied with the management mechanism of social risks and the operation of the
Program. However, the investigation reveals that recording and documentation of the public
participation and grievance redress process are weak, and there is no mechanism for monitoring
the implementation of social risks management plans of specific Program activities.
17. Recommendation: It is recommended that efforts are made to strengthen the monitoring of
social risks management and enhance the recording and documentation of the public consultation
and grievance redress process in relation to the operation of various facilities.
1. Core Principle #2: Cultural heritage management system
Element 5: Take into account potential adverse effects on tangible cultural heritage and provide
adequate measures to avoid, minimize, or mitigate such effects.
18. As confirmed by the natural resources and cultural relic protection authorities of Hubei
Province and the sample counties/cities, opinions of the cultural relic management authorities were
consulted and followed during development of local land use plans, including the information of
relics distribution in the region and the results of the cultural relic census. At the land pre-
examination and site selection stages, the project site selection complies with the overall local land
use planning, which ensures that no other construction works or blasting, drilling, excavation and
other operations are carried out within the area of protected cultural relics as required by the
Cultural Relics Protection Law. The project appraisal is joined by experts from the cultural relics
protection authority at the invitation of the local development and reform commission. If cultural
relics are discovered during the construction of the project, the construction contractor will report to
the provincial administrative department of cultural relics according to the Cultural Relics Protection
Law and organize archaeological excavation units to conduct archaeological investigation and
exploration of the buried cultural relics within the scope of the project.
19. Assessment: In each aspect of the project, the parties involved were able to avoid,
minimize, and mitigate impacts on heritage resources in accordance with the requirements of the
Cultural Relics Protection Law. For unavoidable impacts, strict protection schemes were developed
and implemented.
1. Core Principle #3: Public and worker safety management system
Element 6: Promote adequate community, individual, and worker health, safety, and security
through the safe design, construction, operation, and maintenance of Program activities; or, in
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carrying out activities that may be dependent on existing infrastructure, incorporate safety
measures, inspections, or remedial works as appropriate.
20. Physical Program activities involve different levels of health and safety hazards at
construction and operation stages, such as natural disasters, high temperature, toxic and harmful
gases, wastewater, or other toxic and harmful liquids generated at the construction and production
sites, etc.
21. Investigations in Honghu City, Lichuan City, Enshi City, Xuan’en County, Jianshi County
and Badong County in Hubei Province show that health and safety assessment, a part of the
feasibility study, was carried out at the stage of the Program design. For example, the Chapter 8 of
the feasibility study report on the WWTP upgrading and improvement in Honghu City particularly
assessed health and safety issues during its construction and operation, and provided measures to
manage identified hazards including natural disasters, high temperature, radiation, and fire, etc. In
the operation phase, the county occupational health, labor and health authorities carried out
inspections against the key enterprises every year and requested corrective measures for any
identified problems. The health authority also regularly checked whether relevant occupational
health and safety measures were in place and whether the three simultaneous measures were
implemented and conducted annual monitoring of occupational hazards of the enterprises.
22. During the investigations in the sample counties/cities, field visits were paid to the
enterprises engaging in Wens breeder pig raising and fecal residue and wastewater recycling in
Honghu City, wastewater treatment enterprise in Honghu City, fecal residue and wastewater
recycling enterprises and domestic refuse collection and treatment enterprises in Lichuan City and
Enshi City, during which their employee management (including health and safety management)
regulations and rules, employment contracts, annual employee training plans, employee safety
protection measures, routine safety management logs were checked, and enterprise managers,
employees and residents in surrounding communities were consulted. In general, the investigated
enterprises have developed labor management, workplace, and worker safety protection measures,
and conducted health and safety management as required during the Program construction and
operation. However, there are management gaps among these enterprises. Problems include:
inadequate occupational health management of facilities in relation to wastewater treatment, fecal
residue and wastewater recycling, refuse treatment, waste landfill, and plastic waste; the absence
of early-stage occupational health assessment and declaration of occupational hazards; the lack of
knowledge of occupational health management laws and regulations; inappropriate environmental
management of waste landfill; and adverse impacts on the health of employees and residents in
surrounding communities. Recycling plants have provided institutional training, including safety
training. Only qualified workers were allowed to carry out relevant operations and they received
occupational health exams at least once a year. In addition to the publicity of occupational disease
prevention and control in relevant enterprises, competent authorities conducted follow-ups to gain
an understanding of basic information about occupational diseases and employees' physical
examinations and requested corrective measures for any identified problems.
23. According to the Health Commission of Hubei Province and the health authorities of the
sample counties/cities, the relevant enterprises should conduct special health risk assessments in
the pre-construction evaluation stage, such as the feasibility study on the upgrading and upgrading
of the Honghu City Sewage Treatment Plant above. For enterprises involved in occupational
disease hazards in the assessment, they should self-declare through the “National Occupational
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Disease Project Application System�?. Regular inspections are carried out every year, and the
reporting system should be improved in a timely manner. For positions involving occupational
health hazards, employees should be given necessary training and equipping with personal
protective equipment. Relevant employees should be arranged to undergo regular physical
examinations at occupational health inspection institutions. Local health departments have special
occupational health supervision departments to conduct "double random" law enforcement
inspections on enterprises. Due to the randomness of the daily inspections of local health
departments, and the fact that there are many enterprises involved in occupational health hazards
in each locality, For example, about 50 enterprises in Lichuan City and 170 enterprises in Enshi
City, the inspection focus is generally on mining, cement and other key industries with high
occupational risks, the inspection frequency of some industries with occupational disease risk level
of "average" is relatively small.
24. Assessment: In general, sound safety and health management systems were put in place
at national and local levels, and the PIUs basically followed regulatory requirements for safety and
health during construction or operation. However, occupational health examination of workers
needs to be strengthened.
25. Action: Occupational health management and training in the WWTPs, fecal residue and
wastewater recycling facilities, and refuse treatment facilities (e.g., waste landfill and plastic waste
treatment facilities) should be enhanced.
Element 8: Include adequate measures to avoid, minimize, or mitigate community, individual, and
worker risks when the PforR Program activities are located in areas prone to natural hazards such
as floods, hurricanes, earthquakes, or other severe weather or affected by climate events.
26. The Program is vulnerable to potential natural disasters such as floods and water and soil
erosion, which is particularly prominent in Enshi City, Lichuan City, Badong County, Xuan’en
County and Jianshi County in mountainous areas of western Hubei Province. Relevant design
documents of the Program have assessed risks brought by natural disasters to communities and
workers and developed management plans. For example, the feasibility study report on the waste-
to-energy power plant in Enshi City identified and analyzed the geological structure and
earthquake impacts for site selection, discussed water and soil conservation in a separate chapter,
and developed plans to guarantee workers' safety during construction and operation in the light of
the conclusions of natural disasters analysis and assessment. The 14th five-year plans of Hubei
Province and Enshi Tujia and Miao Autonomous Prefecture stipulate that water and soil
conservation programs shall be carried out in all cities and counties every year to reduce
ecological and safety hazards caused by water and soil erosion. For example, Enshi City plans to
develop three ecologically clean small watersheds from 2023 to 2025, with the water and soil
erosion control area being increased to 37 square kilometers. Similar to other Program activities,
water and soil conservation requires early-stage field investigation and design before construction,
including worker safety during construction and community efforts (e.g., publicity and training in
communities concerned) in water and soil conservation after it's handed over to local village
collectives. For example, publicity and educational programs are carried out in schools and
communities involved in water and soil conservation programs in Enshi City every year to enhance
public awareness of water and soil conservation. Refer to Figure 4 in Appendix 7 for public
participation efforts made by the water resources authority of Enshi City.
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27. Assessment: In the aspect of natural disaster management, systematic analysis was
carried out at the design phase of each Program activity, and prevention and control plans were
proposed. Necessary management was also available during construction, operation, management
and maintenance.
1. Core Principle #4: Involuntary resettlement management system
28. The six aspects under Element 9 are analyzed as follows:
(i) Minimizing negative impacts related to land acquisition:
29. The field visits paid to facilities like the WWTPs, and fecal residue and wastewater recycling
facilities in Honghu City, Enshi City and Lichuan City in Hubei Province show that the pre-
examination on the use of land for construction projects, registration of farmland, and examination
and screening were carried out at the preparatory stage of the Program in accordance with
relevant regulatory requirements and stipulated land acquisition procedures, ensuring that the
occupation of basic farmland and impacts on other sensitive facilities are avoided. The WWTP and
waste landfill in Lichuan City and the waste-to-energy power plant in Enshi City obtained the land
use certificates according to law. Agreements on land acquisition, if required, were signed with
affected entities or individuals and compensation was paid accordingly. It means that
compensation and resettlement measures have been put in place to minimize negative impacts
arising from the Program implementation. Refer to Figure 5 in Appendix 7 for information about the
registration form of farmland occupied by the fecal residue and wastewater recycling facilities in
Lichuan City, Hubei Province and the pre-examination on the use of land for the refuse transfer
station in Tuanbao Town, Lichuan City.
(ii) Identifying and addressing economic and social impacts arising from land
acquisition or loss of access to natural resources
30. During the consultation, the Department of Natural Resources of Hubei Province and
natural resources authorities in the sample counties confirmed that the land users, local
governments and natural resources authorities conducted DMS according to law and registered
properties of all affected entities and individuals within the boundary of land acquisition, laying the
foundation for subsequent resettlement and compensation. Refer to Figure 6 in Appendix 7 for
information about the DMS registration form during the acquisition of land used for the urban
WWTP in Enshi City in 2018.
31. It's confirmed during field visits to fecal residue and wastewater recycling facilities in
Lichuan City and Enshi City that no farmland was transferred to land for construction projects. To
acquire land required, land leasing contracts were typically signed through consultation with local
village committees/land users and farmers, and farmers directly received rents in the ways
specified in the contracts within agreed time limits. Before the land was taken on lease, farmers
and the PIUs of concerned facilities confirmed the land area and ground attachments.
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32. During the visit to the counties/cities concerned, the villager representatives were consulted,
and they were generally satisfied with the process of land acquisition, compensation, and
resettlement. They were enabled to report their grievances to the village committee or the PIU for
resolution.
(iii) Compensation and transition subsidy to be fully paid at replacement cost
before land use
33. Compensation rates for land acquisition are usually adjusted every three to five years
based on local economic development and market conditions in Hubei Province, according to the
Department of Natural Resources of Hubei Province. The compensation rates for land acquisition
of Hubei Province were last adjusted in the Notice on Releasing Block Comprehensive Land Prices
of Hubei Province promulgated in October 2019. The compensation rates for house demolition
within the urban planning area of counties/cities concerned were subject to the market price at the
time of LA to ensure that the compensation is consistent with the replacement cost. As to Program
activities where land is leased rather than obtained through permanent land acquisition (e.g., the
fecal residue and wastewater recycling facilities), the land rent was agreed by concerned parties
through consultation on the basis of equality. Refer to Figure 7 of Appendix 7 for the land leasing
contracts for the Enshi Xidu Chuwang Farming Cooperative and the fecal residue and wastewater
recycling facilities, according to which the land area was 18.27 mu and the agreed amount of
compensation was 550 yuan per mu per annum, the market price of land on lease as confirmed in
the field investigation.
(iv) Livelihood restoration
34. The municipal/county social security authorities confirmed that the basic endowment
insurance, employment training and support policies for land-expropriated farmers ensured that
land-expropriated farmers do not lose their livelihoods after land acquisition. Land-expropriated
farmers can choose to participate in different types of social security schemes as needed: 1)
respective basic pension insurance for urban and rural residents. The minimum amount of basic
pension was 115 yuan per month each person in Hubei Province in 2021. Those who have not
reached the retirement age will receive the social security subsidies paid by local governments to
their personal pension accounts directly, and the pensions will be paid by the local human
resources and social security authority on a monthly basis after they reach the retirement age;
affected people may choose to pay higher pension contributions to receive more pensions after
reaching the lawful retirement age; 2) pension insurance for urban workers. For those who chose
this type of insurance, subsidies will be provided in cash for a period equivalent to the number of
contributory years to encourage more individuals to join such insurance schemes so as to receive
higher pensions after reaching the retirement age. In 2021, the basic pension for retired urban
workers in Hubei Province was 3,000 yuan per capita per month. Those under the retirement age
may make money by finding jobs with the aid of training and employment support offered by the
government. For example, the investigation showed that the waste-to-energy power plant in
Honghu City, Hubei Province employed 21 nearby community residents (including 5 females) aged
between 45 and 59 to take charge of temporary jobs like cleaning and facility maintenance,
allowing them to earn additional income (about 2,000 to 3,000 yuan per month) without affecting
farming. Refer to Figure 8 of Appendix 7 for information about female residents doing sanitation
work in the waste-to-energy plant in Honghu City.
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(v) Policy arrangements for infrastructure restoration
35. As confirmed by the municipal/county natural resources bureaus, any potential social
impacts and risks caused by land acquisition and house demolition to infrastructure were identified
and evaluated by professional agencies during the land detail measurement survey (DMS), and
related management plans were developed accordingly. Moreover, as introduced, the SSRA
should be carried out at the preparatory stage to identify all relevant social impacts and risks may
arise from the Program, which involves the solicitation of public opinions and suggestions. These
measures are meant to ensure that infrastructure and community services affected by the Program
are protected, or restored as soon as possible, or improved in the light of public opinions.
(vi) Information disclosure, public participation and informed decision-making
36. According to the natural resources authority of Enshi City in Hubei Province, public hearing
is mandatory in the process of land acquisition and house demolition to secure approval for the use
of land. Any affected entities or individuals unwilling to attend the hearing are required to submit a
written statement issued by the village or community committee to indicate voluntary waiver of the
hearing.
37. Assessment: Hubei Province has established the systematic impacts screening
mechanism by strictly following the relevant provisions of the regulations in the aspect of
resettlement management. An effective and whole-process management mechanism are in place
for redressing the impacts on affected people in terms of land acquisition, resettlement and
livelihood restoration, clarification of roles and responsibilities of the PIUs and financial support,
which ensures that the land acquisition and resettlement impacts are properly managed. Interests
and rights of those lacking legal title in land/assets are also made clear by relevant laws and
regulations. A systematic mechanism of replacement cost-based compensation for land acquisition
and house demolition, including transition fee due to relocation, is established and well
implemented. According to the investigation, affected people have benefited from the Program by
taking part in relevant repayable activities, and the villagers' representatives in the sample counties
were satisfied with implementation process of land acquisition, resettlement and compensation
payment.
1. Core Principle #5: Management system for ethnic minorities and vulnerable groups
Element 10: Undertake meaningful consultations if the ethnic minorities are potentially affected
(positively or negatively), to determine whether there is broad community support for the PforR
Program activities.
38. Enshi Tujia and Miao Autonomous Prefecture is the only autonomous prefecture for ethnic
minorities in Hubei Province. According to the seventh national census in 2020, the prefecture has
3,456,100 permanent residents of which over 50% are minority groups, including Tujia (about 45%)
and Miao (5.5%) nationalities and other smaller minority groups. There are no autonomous
townships or villages for the Tujia and Miao nationalities in the prefecture. However, Bajiao
Township in Lichuan City and Xiaoguan Township and Changtanhe Township in Xuan'en County
are autonomous townships for the Dong nationality, a small minority group in local city/county.
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39. It is learned in the interviews with the provincial/county ethnic affairs authorities that the
Program impacts on ethnic minorities are effectively managed in two ways. On the one hand, in
accordance with the Constitution and relevant ethnic affairs management laws and regulations, the
representatives of affected ethnic minorities are fully consulted on special issues to ensure that
their opinions are respected. The organ of self-government in the national autonomous area is also
responsible for safeguarding minority citizens' constitutional rights. On the other hand, public
consultations are carried out in accordance with the relevant requirements for assessment of
general construction projects. For example, Lichuan City is a county-level city with 472,770
minority residents, accounting for about 63% of the city's total population, from 11 minority groups
including Tujia and Miao nationalities in Enshi Tujia and Miao Autonomous Prefecture. According
to the ethnic and religious affairs bureau of Lichuan City, projects in ethnic minority areas follow the
bottom-up approach. To be more specific, the ethnic minority village submits a project proposal to
the township government, and then the township government confirms whether the proposed
project is needed through investigations and files an application with relevant county departments
(including the county ethnic and religious affairs bureau) for the implementation of the confirmed
project and funds required. After that, relevant municipal departments receiving the application
conducts field investigations, reviews the project implementation plan, discusses the plan on the
management meeting, and includes the project in the database of planned projects of Lichuan City
if it's considered acceptable. In the end, funds are secured for the implementation of the accepted
project. When implementing a specific Program activity, investigations and consultations with
public officers and common residents in ethnic minority villages on E&S impacts possibly arising
from the project are conducted, with reasonable suggestions being considered in the Program
design. Program activities involving LA are implemented mainly in accordance with the Land
Administration Law and the Rules for the Implementation of the Land Administration Law.
Whenever LA is required for any Program activity in an ethnic minority area, the PIU and the land
acquisition agency will conduct information disclosure and public consultation in a culturally
appropriate way in advance so that they are informed of the project, policies on land acquisition,
resettlement and compensation, as well as the provisions of the LA agreement. On the basis of
broad support from ethnic minorities affected, the land acquisition agency carries out the DMS and
consultations to obtain information about minority households and their land and properties,
discloses the results of the DMS, and each affected household signs the DMS form and LA
agreement as confirmation in line with the Land Administration Law and the Rules for the
Implementation of the Land Administration Law.
40. Assessment: The investigation confirms that the right to be informed and the development
needs of ethnic minorities are fully respected in the process of implementing the Program activities.
Existing project management systems typically applicable for projects in ethnic minority areas are
followed to show full respect to minority groups. Thus, the social practice effects are consistent
with the bank policy.
Element 11: Ensure that ethnic minorities can participate in devising opportunities to benefit from
exploitation of customary resources and indigenous knowledge, the latter to include the consent of
ethnic minorities.
41. According to the investigations in Enshi City and Lichuan City in Enshi Tujia and Miao
Autonomous Prefecture, local minority groups and Han people show almost no difference in
language, manners and customs and no tangible cultural heritage of special concern is found. In
addition, ethnic minority development funds are available at state, provincial, municipal and county
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levels every year. For example, Hubei Province received the state-level ethnic minority
development fund totaling 130 million yuan in 2021. Enshi City received state-level fund of 16.46
million yuan and provincial-level fund of 3.52 million yuan, and Lichuan City received state-level
fund of 16.8 million yuan (the highest in Hubei Province) and provincial-level fund of 2.94 million
yuan. The funds were fully used for the development of characteristic agricultural and tourism
products and infrastructure improvement in ethnic minority areas. For example, the state-level
fiscal fund totaling 400,000 yuan disbursed to Huanglianxi Village, Bajiao Dong Ethnic Township,
Enshi City was used for integrated development of tourism and the indigenous Yulu green tea. The
provincial-level fund, totaling 30,000 yuan, received by the ethnic culture inheritance base at the
Xinyi Kindergarten of Lichuan City was used for promoting the publicity and education of local
traditional ethnic cultures. Besides, state-level fiscal fund of 2.62 million yuan was disbursed for the
road transportation projects in Gaoqiao Village and Shuanghe Village, Liangwu Township, Lichuan
City. Refer to Appendix 8 for information about the investigation and assessment of the process
and outcomes of implementation of relevant Program activities in ethnic minority areas.
42. Assessment: Despite varying cultures in ethnic minority areas involved in the Program,
plans and relevant protective projects are put in place every year to protect the cultures of ethnic
minorities. The implementation of the Program does not damage or negatively affect the cultures of
ethnic minorities.
Element 12: Give attention to groups vulnerable to hardship or discrimination, including, as
relevant, the poor, the disabled, women and children, the elderly, ethnic minorities, racial groups,
or other marginalized groups; and if necessary, take special measures to promote equitable
access to PforR Program benefits.
43. The survey of the women's federations in sample county/city shows that there is no
discrimination against women in general. Women are entitled to the same social status and job-
related benefits as men, and targeted events or programs are carried out to protect women's rights
and interests and promote women's development in line with their characteristics and needs. For
example, the women's federation in Honghu City, Hubei Province organized study tours, joined by
8 members including the chairman of the women's federation and representatives of e-commerce
startups, to the hand-embroidery, online celebrity training and handicraft bases in Huangshi City
and Wuhan City in 2020, and held the "Women's Wisdom" sessions and female entrepreneur
forum attended by female entrepreneurs, who shared their experience in health, clothes matching
and starting of e-commerce businesses, in 2021. In the same year, Lichuan City organized a large
number of women-specific training sessions attended by 6,512 women and creating 3,135 job
opportunities, including 57 entrepreneurship and employment training sessions in childcare,
housekeeping, and hand knitting, and 12 sessions of training entrepreneurship individuals in
promoting labor cooperation between Hangzhou City and Enshi Tujia and Miao Autonomous
Prefecture. The women's federation of Enshi City offered 16 training sessions in handcraft (straw
plaiting) attended by about 400 females.
44. The investigations show that both government authorities and enterprises attached great
importance to women's health and safety. The employment contracts of Honghu Wens Breeder Pig
Technology Co., Ltd., Lichuan Landfill and other enterprises had special clauses protecting
women's rights and interests. For example, Honghu Wens Breeder Pig Technology Co., Ltd.
included provisions preventing pregnant, birth-giving and breastfeeding women from being
dismissed in the contract termination clauses of employment contracts. Municipal/county women's
federations guided enterprises in providing physical examinations for women on a regular basis,
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including genetic screening for pregnant women. These measures were taken by agencies
supported by the Program and in other relevant projects, safeguarding women's rights and
interests. For example, in 2021, Enshi City provided free-of-charge cervical and breast cancer
screening for 9,600 rural women and secured financial aid of 280,000 yuan for 28 financially
challenged women with cervical and/or breast cancer, and humanitarian aid of 40,000 yuan for 35
poor women with other types of cancer. The women's federations at various levels have played a
crucial role in safeguarding women's rights and interests by enabling aggrieved women to file a
complaint with the local office of the women's federation or the director of the local women's
congress. For example, the women's federation of Enshi City has established multiple mechanisms
to protect women's rights and interests: 1) the joint mediation by the court and the women's
federation. The municipal women's federation (family dispute mediation commission) is responsible
for providing pretrial mediation for 6 types of marriage and family disputes brought before the court.
In 2021, applications for mediation for 58 matrimonial actions field with courts in Enshi City were
received, with 36 actions being subjected to mediation and 31 actions being mediated successfully;
2) a sound mechanism for managing women's letters and visits. Women are guided in filing a
complaint in a well-organized way according to law. Among 30 complaints field by women, 5 were
resolved after investigation and 4 were replied to via telephone, with all complaints being settled.
45. According to the Law on the Protection of the Rights and Interests of Senior Citizens, a
senior citizen is an individual Chinese resident who is 60 years old or more. Seniors in need refer
to senior citizens exposed to poverty, disease, inability, disability, absence of supporters, and other
difficulties and risks formidable for them or their families, as explained by the Department of Social
Assistance, Ministry of Civil Affairs in 2021. The Department of Civil Affairs of Hubei Province
confirms that a full set of mechanisms are in place to protect the seniors, including: 1) social and
medical insurance schemes for senior citizens aged 60 years and above to meet their basic needs;
2) additional old-age subsidies for the seniors at or above 80; 3) special subsidies (1,400-2,274
yuan per capita per month in urban areas and 10,248-24,321 yuan per capita per annum in
Honghu City, depending on the self-care abilities of the seniors) for the support of extremely poor
senior citizens whose income is below the minimum living standard (700 yuan per capita per month
in urban areas and 6,100 yuan per capita per annum in rural areas in Honghu City in 2021). All
eligible senior citizens can benefit from these inclusive mechanisms. What's more, relevant policies
are implemented to enable the seniors to benefit from the Program. According to the field
investigation, young villagers usually go out for non-farming jobs while the elderly people work on
the land. For example, the water and soil conservation carried out in 5 counties/cities involved in
the Program will improve the quality of rural arable land, particularly of land covered with stones
and rocks in areas harassed by severe stony desertification. It enables the replacement of humans
with machines in farming, improving farming efficiency and reducing physical burden on the
seniors. Refer to Figure 9 of Appendix 7 for information about land before and after the treatment
of stony desertification. It shows that only corns were grown on land covered with stones before
the treatment, and the treated land becomes suitable for the growth of multiple crops.
46. The local civil affairs authorities have established sound mechanisms to protect children.
For example, the CAB of Lichuan City established a leading group for the care and protection of
left-behind children in rural areas, led by the head of the competent department of the municipal
government and joined by officials from the municipal education and public security bureaus, in a
bid to deal with children-related major issues in a timely manner. One children's supervisor in each
township government, one children's director in each village (community) committee, and one or
more full time (part-time) mental health counselors in each school providing compulsory education
work together to collect and submit relevant information, promote family care for children, and
provide additional childcare whenever necessary. Besides, municipal and township financial
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budgetary arrangements are made every year to secure funds for special purposes and routine
work in relation to children.
47. Assessment: China has put a sound management system in place to safeguard the rights
and interest of women, seniors, and children. These groups, particularly those living in rural areas
where young people go out for non-farming jobs, will benefit from improved production and living
environment and enjoy other benefits brought by the Program.
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6. Public Participation and Grievance Redress Mechanisms
6.1 Public Participation
48. Stakeholder engagement is an important aspect of this ESSA and a requirement of the
Bank policy. During the ESSA, stakeholders have been identified subject to the impacts of
activities, interest in the activities, and power of influence on decisions, mainly including
government authorities at different levels, villages and communities, activity implementation
agencies, women’s federations, NGOs, affected persons, etc. (see Appendix 4). During the ESSA
preparation, extensive participation and consultation activities were conducted in the relevant
counties and districts in Hubei, including the consultation meetings with provincial and county
authorities held in Hubei in September 2022.
6.1.1 Initial participation activities
49. At the preparation stage, the Bank team and ESSA consulting team engaged with relevant
authorities of the Hubei provincial governments from June 2022 to September 2022 many times,
covering the Bank’s PforR provisions, E&S policies, implementation management practices,
operating processes, assessment document preparation, etc. Appendix 5 records in detail the list
of interviews and participating units in government departments at all levels in Hubei Province, and
the total number of interviewers is not less than 40 people.
50. From June 2022, extensive public participation has been conducted in Hubei to prepare
and improve this report (see Error! Reference source not found.), including many consultation
meetings with provincial authorities, involving provincial-level DRC, FB, ARAB, RRB, HURDB, EEE,
NRB, women’s federations, and ERABs, etc. At the county level, Honghu, Enshi and Lichuan were
visited, and online focus group discussions held with the corresponding government authorities of
Badong, Jianshi, and Xuan’en counties. In the above focus group discussions, exchanges were
made with government authorities, relevant enterprises, village officials, villager representatives,
etc., and rural domestic waste collection and transfer, land filling, waste incineration, wastewater
treatment, livestock and poultry breeding, livestock and poultry manure recycling, and agricultural
mulch film recycling sites were visited. These activities cover the following:
1. Responsibilities and organizational setup of each authority
2. Prevailing main sectoral policies and regulations
3. Scope of implementation, policy requirements, implementation progress, effects, and main
issues related to wastewater collection and treatment, agricultural NPS pollution control,
river management, etc., in work of different authorities
4. Enterprise scale, recruitment mode, worker benefits, safety and skills training, occupational
health hazards and inspection, availability of protective equipment, facility land approval,
EIA, SSRA, social impact assessment (SIA), geological disasters, management, etc.
5. Villager employment, especially participation in waste, wastewater, and river management
projects
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6. Wastewater collection and treatment, house connection, charging, issues, and suggestions
7. Local use of chemical and organic fertilizer, and effects
6.1.2 Public consultation on the ESSA
8. The first version of the draft ESSA was provided to Hubei province for public consultation
and comments in August 2022. The Hubei PPMO organized all relevant provincial and county
government authorities to have consultation meetings with the ESSA team on September 14, 2022
and collected written feedback and submitted it to the ESSA Team. Subsequently, the PPMO
organized the ESSA consultation meetings between provincial and county government
departments and the ESSA team on September 19 and 25 respectively. The feedback from the
governments and the responses made by the ESSA team are presented in Appendix 7. The
governments of Enshi Prefecture and Honghu City have disclosed the ESSA on the official
websites of DRCs on 9 and 10 October 2022, respectively.
6.2 Grievance Redress Mechanisms
9. Existing GRMs usually include community and enterprise GRMs. The community GRM
has three levels: (i) grievances are reported directly to the relevant PIUs to seek a solution; (ii)
grievances are reported to the village or community committee for addressing them; and (iii)
grievances are reported to the county government’s appealing office or the county head’s
hotline/mailbox, etc., which includes a mechanism of collection, initiation within seven days, and
solving within two months. In addition, residents can resolve more serious disputes through civil
actions in court. In general, the GRM is functional and effective. An enterprise GRM basically has
two aspects. First are workers’ grievances. These are handled through a three-tier labor dispute
resolution mechanism: the enterprise labor disputes and redressing mechanism, the township
government’s labor dispute mediation center, and the county government’s labor mediation center.
On the enterprise level, workers can seek a solution through the enterprise/factory manager
mailbox or the trade union. If a dispute cannot be addressed satisfactorily, the worker can go
through the government mediation mechanism or seek a solution by labor arbitration. Second, the
enterprise sets up an external relations department and assigns a contact and a telephone number
to collect complaints and suggestions from the public. If these complaints cannot be resolved in a
satisfactory manner by the enterprise, then they can be referred to the second and third tiers of the
community GRMs and civil litigation.
10. Assessment: Based on interviews with village committees and villager representatives,
village-level GRMs are sophisticated in general and most (reportedly more than 90 percent)
grievances can be solved effectively at the village level, with very few solved through civil litigation.
GRMs for laborers of enterprises are quite normative and can solve worker grievances. However,
some enterprises have not disclosed the grievance contacts and telephone numbers to the public;
therefore, it is necessary for enterprises to establish a GRM at the construction and operation
stages.
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7. Conclusions, Recommendations, and Action Plans
7.1 Conclusions
11. The PforR aims to improve the coordination mechanism, promote ecological protection, and
reduce water pollution in selected areas of the Yangtze River Basin. Although the PforR will
inevitably have some temporary, small-scale, and mitigatable adverse impacts on the environment
and local communities during the implementation, it will largely improve the quality of regional
environment and the well-being of local people. Through E&S screening, activities with high E&S
risks have been excluded. Provided that the existing E&S systems are implemented effectively, the
PforR will not have any major negative E&S impacts, and the PforR’s overall E&S risk rating is
Substantial considering that the PforR will be implemented by local governments in a wide region
of the province.
12. It’s identified in the ESSA that proper E&S management systems have been established in
Hubei to identify, assess, avoid, mitigate, manage, and monitor the E&S impacts and risks related
to the PforR activities, including (1) a complete regulatory system, including applicable laws,
regulations, policies, standards, and technical guidelines at the state and local levels; (2) clear
implementation mechanisms, including clear administrative procedures, institutional arrangements,
and responsibilities for E&S impacts and risk management, and necessary professionals and
financial resources; and (3) outcome performance of the E&S systems. The random surveys on the
past cases in the sample counties show that E&S impacts and risk management measures have
been implemented effectively. Based on the assessment, the E&S systems related to the PforR
are generally consistent with the requirements of the Bank’s PforR policy and guidance.
13. The ESSA has also identified the following areas for improvement:
1. Odor issues exist in traditional livestock and poultry farms and some domestic solid waste
transfer stations.
2. During the implementation of the sub-projects, the public participation and appeal records
are not well documented and archived; the implementation of the social risk management
plan of a single project lacks monitoring means.
3. On the whole, the state and local governments have established a relatively complete
safety and health management system, and the implementing agencies have basically
followed the regulatory requirements during construction or operation; at the same time,
during the project implementation process, workers' occupational health examination The
management needs to be strengthened. For example, some enterprises have not carried
out occupational health assessment in the early stage of the project, some have not
reported to the occupational disease hazard project, and some enterprise managers are
not familiar with the legal and regulatory requirements of occupational health management;
on the other hand, the government's law enforcement supervision force needs to be
strengthened. Some small-scale or "general" occupational health hazard industry
enterprises are not included in the local government's health management system.
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7.2 Recommendations
4. For the above-mentioned E&S issues, the following recommendations have been proposed:
1. Recommendation 1: Measures should be taken to strengthen odor control in
livestock/poultry waste management and domestic solid waste transfer to reduce odor
impacts. It is suggested that local ARABs and HURDBs ensure the odor treatment
facilities are well designed, constructed, and operated for new or upgraded
livestock/poultry manure treatment facilities and domestic solid waste transfer stations.
2. Recommendation 2: Monitoring of social risk management should be strengthened. When
conducting social risk assessment, the screening of social risks and impacts, public
participation, and appeal records during the construction and operation of various facilities
should be managed and documented, including the monitoring arrangements for the
implementation of the social risk management plan, and the Included in the scope of
social monitoring. To this end, each sub-project should configure or arrange necessary
human resources to ensure the implementation of the above measures.
3. Recommendation 3: Enterprises such as sewage treatment plants, livestock and poultry
manure recycling enterprises, and waste treatment facilities should strengthen
occupational health training and management.
7.3 Action Plans
4. To effectively execute these recommendations, the following actions should be included in
the Program Action Plan (PAP) and taken during the PforR implementation (Table 7-1).
Table 7-1: E&S Action Plans
No. Action Responsibility Timing Completion Measurement
1 Implement measures to PPMO; provincial Throughout PPMO will submit completion acceptance
ensure the odor treatment and county level Program reports for the odor treatment facilities as
facilities are well designed, ARABs; implementation well as semi-annual progress reports to the
constructed, and operated for provincial and stage Bank, to provide information about
new or upgraded county level completion and operation of the relevant
livestock/poultry manure HURDBs; facilities.
treatment facilities and
domestic solid waste transfer
stations.
2 During the social risk PIUs Throughout The project design and related assessment
assessment of specific Program documents include the social risk
subprojects, the monitoring implementation management plan, in which arrangements
arrangements for the stage for social impact and risk monitoring
implementation of the social mechanisms, requirements of
risk management plan should documentation for public participation and
be included. At the same GRM are included.
time, the records of public
participation and appeals Ensure appropriate arrangement and
during the construction and availability of social management and
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No. Action Responsibility Timing Completion Measurement
operation of various facilities monitoring personnel.
should be documented and
archived and included in the The implementation of the above contents is
scope of social monitoring. reflected in the monitoring report.
Each sub-project shall
allocate or arrange
necessary human resources
to ensure the implementation
of the above measures.
3 Enterprises such as sewage Provincial and Throughout The provincial county/city health commission
treatment plants, livestock county level HCs Program have reached an annual training plan for the
and poultry manure recycling implementation relevant facility enterprises (at least once a
enterprises, and waste stage year during the project implementation
treatment facilities (such as period). The training plan shall at least
landfills and plastic waste include training time, training location, and
treatment) should strengthen training content.
occupational health training
and management. The provincial county/city health commission
have reached an occupational health
inspection plan for the relevant facilities in
the project county.
The implementation of the above contents is
reflected in the monitoring report.
4 ToRs for TA activities that PPMO Throughout PPMO will submit the ToRs to the Bank for
may have potential Program review and concurrence prior to
downstream E&S risks and implementation commencement of TA activities.
impacts include requirements stage
for assessment of such risks
and impacts.
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8. Management and Monitoring
5. As per the Bank PforR Policy13 and the agreements between the Bank and the borrower,
the two parties will manage and monitor the PforR implementation from different perspectives.
8.1 The Borrower
6. The borrower is responsible for implementing the PforR, monitoring implementation
progress, evaluating the indicators, and performing relevant commitments as per the legal
documents, including the PAP. Such responsibilities involve the borrower keeping the E&S
management systems effective, implementing monitoring plans, and identifying and solving
problems in a timely and effective manner. The borrower should do the following:
1. Develop and implement the "Environmental and Social Risk Management Manual"
2. Implement the agreed E&S actions as per the PAP and maintain the E&S management
systems and implementation capacity as recommended by the ESSA.
3. Submit semi-annual progress reports on the PAP implementation to prove continuous
compliance with the applicable E&S management mechanism.
4. Monitor, evaluate, and audit system performance regularly as necessary.
5. Review GRM performance, procedures, and results regularly and include specific grievance
cases in the progress reports.
6. Consult the Bank for any change made to the E&S systems during implementation.
7. Hubei PPMO is responsible for overall management of the PforR activities. The PMOs at
county level (set up under local DRCs) are responsible for overall implementation of county-level
activities. The PIUs can include DRCs, WRBs, ARABs, HURDB, EEBs, NRBs, etc., and they are
also responsible for implementing the proposed E&S actions. The PIUs should have specific
divisions and staff to implement the E&S actions, report to the county PMOs, and provide
information to the PPMO and the Bank for supervision and monitoring.
8.2 The Bank
8. The Bank is to provide support to the implementation of the PforR and oversee the E&S
management performance against the ESSA requirements, especially the PAP. The Bank will
monitor the borrower’s commitment to compliance with E&S risk management, including actions to
13 As per the Bank's PforR policy (paragraph 12), the borrower is responsible for preparing and implementing the PforR program. The
PforR program’s scope and objectives and the borrower’s contractual obligations to the Bank are set out in the legal agreemen ts
with the Bank. These obligations include the requirement to carry out the PforR program with due diligence and to maintain
appropriate monitoring and evaluation arrangements (including credible disbursement-linked indicator verification protocols),
fiduciary and environmental and social PforR program systems, and governance arrangements.
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strengthen institutional capacity. The Bank will evaluate the PforR performance based on the risk
assessment conducted at the preparation stage and hence help the borrower handle expected and
unexpected risks and give recommendations for managing the risks. The Bank will also conduct
field visits and provide support to the PIUs and stakeholders and review audit and progress reports.
The Bank team will submit memoranda to the Bank management group to report on the PforR
implementation performance regularly, through document review, consultation with the PIUs and
stakeholders, field visits, etc. The main activities are as follows:
9. Verify the implementation of agreed actions, including any agreed capacity-building activity
and any designated E&S mitigation measure.
10. Conduct regular monitoring to ensure that the borrower’s ESMS performance at the
implementation stage is accepted by the Bank.
11. Identify any extra management measure that might be taken for underperformance or any
unexpected challenge during implementation.
12. Ensure the effective operation of GRMs through semi-annual reports.
13. The Bank will conduct field visits regularly as a supplement to the self-supervision of the
PIUs and provide other support agreed on between both parties.
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Appendix 1: Boundary of Hubei Government Program and the PforR
Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
Result area of Category Main activities at provincial and county levels the PforR of the PforR
the FYP
(1) Land-based Land-based 1. Establishing land spatial basic information platform; establishing the None None Not a PforR
ecosystem planning system provincial-wide “three lines and one list�? ecological environment zoning investment priority
protection and management and control system
restoration
Land-based 2. Honghu City: City-wide comprehensive land improvement covering Same as the RA2
ecological total area of 160,000 mu (e.g., ecological restoration, etc.) left column Integrated
restoration River Basin
3. Xuanen County: Rocky desertification control in Lijiahe Town Management
covering an area of 20,000 mu; Soil erosion control on mountainous area – sustainable
in south Xuanen covering areas of 34.29 km2 (soil and water conservation soil and
forest and grass, slope land terracing); and Mountain torrent gullies control water
4. Badong County: Ecological restoration along highways (Slope conservation
vegetation; Landscaping, etc.); Comprehensive treatment of soil and water
losses on sloping farmland (terracing slope farmland, small-scale water
conservation works); Rocky desertification control covering areas of
50,000 mu, etc.
5. Jianshi County: Malanxi mountain torrent gully control (16.1 km
long); 1500 ha of land improvement in Longping Township.
6. Lichuan City: 20,000 mu of soil erosion control on sloping farmland;
75 km2 of rocky desertification control; 90 km2 of ecological restoration in
mountainous areas, etc.
7. Enshi City: Comprehensive control of rushing gullies in Shaziba
sub-catchment (reinforced concrete channels with total length of 996.1m,
two absorption basins, drainage ditches with total length of 564m,
concreted slope protection retaining wall with total length of 200 m, slope
protection by masonry lattice with total surface area of 750 m2),etc.
8. Closing hillside for erosion control; returning farmland to forest; None None High potential E&S
Construction of dams and ponds; Contaminated land remediation; risks
landslide control; ecological disaster management and move away from
disasters; ecological restoration of abandoned mines; green mine
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
construction; control sinkholes in coalmining areas; vacating those the PforR of the PforR
phosphorus mining and production enterprises with low capacity or
abnormally operated; - tailings treatment, etc.
9. Advancing forest chief system; natural forest protection; biodiversity None None Not a PforR
survey, observation, and conservation; farmland improvement; tractor investment priority
roads construction; construction of irrigation & drainage facilities;
construction of wetland parks; and flood control projects, etc.
(2) Integrated Co-management 10. Honghu City: Wufeng River rehabilitation (riverbank and slope Same as the RA2
water environment of “there protection, 4 km long, river ecological restoration); shorelines rehabilitation left column, but Integrated
management for waters�?14 and of Xinti-Paishui River and its lakes (clean-up construction waste, exclude River Basin
key basins shorelines supplementation of green plants); Water and soil conservation in activities Management
restoration hongpaihe sub-catchment (trunk stream ecological rehabilitation, involving - sustainable
revegetation) etc. environmental soil and
sensitive areas water
11. Xuanen County: 5 km ecological rehabilitation for Baiyankou Rver in conservation
Zhushan Town; 5 km ecological rehabilitation for Hongjia River in Zhushan
Town; 5 km ecological rehabilitation for Gangou River ecological
rehabilitation in Gaoluo Town.
12. Badong County: Soil erosion control in Jiaojiawan (920 m of box
culvert, slope protection, revegetation) etc.
13. Janshi County: River shoreline ecological protection (gabion
ecological revetment, 20,000 m long, shoreline ecological conservation
forestation, 8536 m2, river side ecological restoration, 6895m2) etc.
14. Lichuan City: Improvement of small water bodies in 15 townships:
integrated improvement of Xiaoxi stream sub-catchment (revetment, 10
km long, and forestation along the stream sides), etc.
15. Enshi City: Ecological rehabilitation for the upstream of Caijia River
(building new revetment 3779.66m, rehabilitation of 6 branch ditches with
14 “Three waters�? refers to water pollution control, water ecology restoration and water resource protection.
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
new retaining walls 341.96m) etc. the PforR of the PforR
16. Centralized treatment of industrial wastewater; Phosphorous None None High potential E&S
pollution reduction; river system connection; water diversion; returning risks
embankment to lake bodies; polluted groundwater remediation, etc.
17. Internal pollution sources control of lakes; construction of wetland None None Not a PforR
parks; development of river/lake shorelines protection plans; and flood investment priority
control, etc.
(3) Coordinated Cooperative 18. Enforcement of cross-basin ecological and environmental regulatory None None Not a PforR
basin ecological control over system; and establishment of river basin emergency response linkage investment priority
environment water pollution mechanism, etc.
improvement and information
sharing
(4) Agriculture Agriculture clean 19. Livestock/poultry manure treatment and utilization: 5 demonstration Same as the RA3
green production and projects (CNY 20 million investment for each) in Honghu; livestock/poultry left column Reducing
development comprehensive manure utilization in Yuanbao Township of Lichuan; city-wide Water
control of non- livestock/poultry manure treatment and utilization in Enshi; building 15 sets Pollution and
point pollution of fermentation facilities for small-scale livestock/poultry farms in Enshi; Transmission
sources livestock/poultry manure utilization in Badong, etc. of Plastic
Waste
20. Chemical fertilizers reduction: replace of chemical fertilizers with
organic fertilizers on 141,000 mu of tea demonstration bases in 5
townships of Lichuan; application of additional 1000 kg/a organic fertilizers
on 200,000 mu of farmland in Xuanen; and application of straws and
organic fertilizers on 1 million mu of farmland in Honghu, etc.
21. Agricultural mulch film collection: mulch film collection in Badong,
etc.
22. Water saving irrigation; pesticide reduction and integrated pests None None Not a PforR
management; increased quality and efficiency of crops production; investment priority
transformation and upgrading livestock and poultry farms; ecological and
healthy aquaculture; comprehensive utilization of straw; etc.
(5) Deepening Cooperation in 23. Establishing tri-provincial cooperation mechanism for river/lake Same as the RA1
inter-jurisdiction green Improving
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
cooperation in development environmental and ecological protection column
leftthe PforR Institutions
of the PforR
green and
development Innovations
24. Cross-provincial trading of energy consumption indicators; cross- None None Not a PforR
provincial cooperation in circular economy, energy, and environmental investment priority
protection, etc.
Domestic solid 25. Jianshi County: 4,090 trash cans, 4,090 garbage sorting and Same as the RA3
waste sorting collection booths, and 3,147 garbage sorting propaganda boards; 80 left column Reducing
and collection garbage compression trucks (5 ton for each), 40 hook-arm trucks (12 ton Water
for each), 40 mobile compression boxes (12m3 for each), 20 kitchen waste Pollution and
collection vehicles, 11 hazardous waste collection vehicles; and 9 Transmission
comprehensive domestic solid waste sorting stations in the central city, of Plastic
etc. Waste
26. Lichuan City: procurement of 68,000 (40 L) trash cans for two
classified wastes, 2 hazardous waste vehicles, 10 road washing vehicles
or mechanical sweepers, 100 trach cans (240 L) for 4 classified wastes,
stalls for dissemination of 4 categories of wastes; urban/township
(6) Solid waste compacting transfer stations, 11 kitchen waste collection vehicles, 3000
classification and kitchen trashes; 24 small sized compacting transfer stations to be installed
resource at remote rural villages.
utilization
27. Badong County: construction of a new transfer station.
28. Xuan’en County: procurement of 91,000 users’ sorting bins, 2790
sets of sorting rooms with trash cans, 279 village-level garbage collection
and transportation vehicles, 9 township-level kitchen waste degradation
tanks; and construction of a transfer station for each of the 7 townships.
29. Honghu City: construction of 796 deep buried trash cans for 19
townships, procurement of 40 transfer vehicles (16 ton for each), 19
routine inspection vehicles, 2 safety management vehicles.
30. Enshi City: provision of 3362 trash cans (240L) to rural villages, 7
hanging bucket garbage truck (3t), etc.
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
the PforR of the PforR
31. Improvin 32. Industrial wastewater treatment facilities: provision of industrial None None Not a PforR
g wastewater wastewater collection pipelines and treatment station for industrial park of investment priority
collection and Jianshi County, industrial wastewater treatment plant of Honghu industrial
treatment park, etc.
facilities and
sewer 33. Rural domestic wastewater collection and treatment: village None None Not a PforR
networks wastewater treatment facilities (200-400m³/d) in Badong and Honghu. investment priority
34. County domestic wastewater collection and treatment: new Same as the RA3
Dashaba WWTP (50,000m3/d); upgrade of Guanpo WWTP (60,000m3/d) left column Reducing
for Enshi; construction of Lichuan No. 2 WWTP (50,000m3/d); upgrade of Water
Xuan’en WWTP (30,000 m3/d), etc. Pollution and
Transmission
35. Township domestic wastewater collection and treatment: Extension of Plastic
(7) Upgrading of urban sewer network to collect township domestic wastewater in Enshi; Waste
urban and household connections and WWTPs in 13 townships of Enshi; WWTPs,
township sewer networks, and storm water separation in 14 townships of Lichuan;
environmental WWTPs (500-15000m3/d) and sewer networks in townships of Jianshi;
infrastructure WWTPs and sewer networks in townships of Xuanen; WWTPs (500-
3,000m3/d) and sewer networks in townships of Badong; new or upgrading
WWTPs in townships of Honghu, etc.
Domestic solid 36. Leachate treatment stations, sanitary landfills, and 4 small None None High potential E&S
waste treatment township-level solid waste incineration stations in Jianshi; waste-to-energy risks
and disposal incinerators in Enshi and Lichuan; old landfill sites remediation in Lichuan;
facilities, and kitchen waste treatment station and leachate treatment station in Badong;
sludge treatment and domestic solid waste treatment facilities at townships, centralized
facilities sorting facilities (100 t/d), centralized sludge treatment center, and
remediation of 7 existing simple township landfill sites in Xuan’en, etc.
Safe disposal of 37. Centralized treatment center, and temporary storage and transfer None None High potential E&S
hazardous facilities for hospital waste in Lichuan risks
wastes
(8) Rural living Rural living 38. Improvement of rural latrines, household garbage management, None None Not a PforR
environment environment wastewater collection and treatment, village appearance improvement,
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
improvement improvement and rural greening and beautification the PforR of the PforR investment priority
(9) Establishment Security of rivers 39. Strengthening of integrated water environment management Same as the RA2
of long-term and lakes’ systems, including integrated water environment protection plans left column Integrated
mechanisms for ecological flows River Basin
protection of 40. Development of river health assessment and/or ecological flow Management
Yangtze River in guidelines based on national standards
Hubei province 41. Implementation of water allocation schemes based on national
standards
42. Improvement of water environment monitoring systems, and
development of ecological environment intelligent early warning and
forecast network platform
43. Determination of ecological flow requirements and incorporation into
county water allocations to ensure long-term restoration and protection of
the freshwater ecosystem services
44. Strengthening of RCS coordination through the integration of county Same as the RA1
and municipal, provincial, and basin-level RCS information platforms with left column Improving
required data-sharing and applications; public engagement in water Institutions
environment management, through awareness campaigns, participatory and
management and river cleanup activities, and development and Innovations
dissemination of public engagement manual for the RCS, targeted at
climate awareness and women’s participation
45. Watershed ecological compensation
46. Development of provincial-level policies, regulations and guidelines
on integrated water environment, ecological protection, and plastic waste
management
47. Carry out special rectification of prominent ecological and None None Not a PforR
environmental problems in the Yangtze River economic belt; Integrated investment priority
improvement of regional ecological environment in key areas; and
Improvement of long-term monitoring mechanism for wastewater
discharge outlets on rivers, etc.
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Hubei’s 14th FYP for Yangtze River Economic Belt Green Development (2021-2025) Activities to Related Reason for non-
be included in result areas inclusion
(10) Supporting Green 48. Pilots for realizing the value of ecological products; demonstrations None
the PforR of the PforR Not a PforR
None
green development for ecological civilization development; and green technology and investment priority
development pilots and innovation demonstration areas, etc.
pilots and demonstrations
demonstrations
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Appendix 2: E&S Risks/Impacts Assessment
Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
RA1: 1. Strengthening 1. Software development 3. Software development 5. The activities 7. The activities Low
Improving of RCS involves collection, provision, and and data process will involve will only involve are in line with
Institutions coordination use of data on basin management no spatial location. information sharing national and local
and through the with no direct negative E&S risks. among government laws, regulations, and
Innovations integration of authorities such as procedures with no
county and 4. Risk is low. water resource, political risks.
municipal, 2. Risk is low. ecology and
provincial, and environment, 8. The activities
basin-level RCS agricultural and rural will enhance river/lake
information affairs, housing and management level and
platforms with urban-rural benefit to local people,
required data- development, etc. so will be widely
sharing and supported by the
applications. public. There is no
reputation risk.
6. Risk is low.
9. Risk is low.
2. Establishment 10. The mechanism 13. Subsequent point and 16. Implementation 18. The activities Moderate
of tri-provincial establishment and studies will non-point pollution sources of the activities will are in line with
cooperation have no direct negative E&S control activities will be require strong cross- national and local
mechanism for impact, and only involve OHS conducted on existing rural sectoral coordination laws, regulations, and
ecological farmland or construction land,
risks of PMO and research staff. among various procedures with no
environment and China has a strict nature government authorities political risks.
protection with 11. The operation of conservation site and incl. ecology and
established mechanism,
focus on river/lake ecological redline system, so environment, water 19. The activities
protection implementation of the proposed no natural habitat or any other resources, agricultural will improve water
regulations, standards and environmentally sensitive area and rural affairs, environment and
guidelines may trigger will be involved. housing and urban- benefit to local people,
downstream activities that produce rural development, and so will be widely
3. Development of indirect E&S impacts, such as 14. Implementation of the
provincial-level natural resources, etc. supported by the
river/lake protection, point and research outcomes will be public. There is no
policies, non-point pollution sources extensive and may involve
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
regulations and control, including reduced minority villages. reputation risk.
guidelines on application of pesticide & chemical
integrated water fertilizers, livestock & poultry 17. Risk is
environment, manual treatment, wastewater moderate.
15. Risk is moderate. 20. Risk is low.
ecological collection and treatment, solid
protection, and waste collection and disposal.
plastic waste These downstream activities will
management be implemented orderly &
scientifically in line with laws,
regulations, policies and plans,
resulting significant positive long-
term E&S effect. The adverse
impact of wastewater, waste gas,
and land acquisition will be
foreseeable and can be mitigated
by taking proven technology and
management measures.
12. Risk is moderate.
4. Public 21. Developing public 24. There may be some 27. Implementation 30. The activities Moderate
engagement in engagement programs and water pollution problems and of the activities will are in line with
water environment conduction public engagement corresponding public involve supports from national and local
management, activities will not involve direct complaints in the project area. water resources, laws, regulations, and
through negative E&S impact, and only ecology and procedures with no
awareness involve OHS risks of PMO and 25. There are few minority environment, political risks.
campaigns, research staff. villages in the affected areas in agricultural and rural
participatory Hubei. affairs, housing and 31. The activities
management and 22. These activities will not urban-rural, etc. will enhance river/lake
river cleanup trigger downstream activities and management level,
activities, and will have no direct negative E&S 26. Risk is moderate. 28. Strong cross- improve water
development and risks. They will promote sectoral coordination is environment, and
dissemination of subsequent river/lake and water necessary to address benefit to local people,
public environment management. the public concerns so will be widely
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
engagement about water supported by the
manual for the environmental public. There is no
RCS, targeted at 23. Risk is low. pollution. reputation risk.
climate
awareness and
women’s 29. Risk is 32. Risk is low.
participation moderate
RA2: 1.Strengthening of33. Developing systems, plans 36. Implementation of water 38. Implementation 40. The activities Substantial
Advancing integrated water and guidelines will have no direct allocation scheme will involve of the activities will are in line with
Ecological environment negative E&S risk, and only extensive areas, including require strong cross- national and local
Protection management involve OHS risks of PMO and minority villages. sectoral coordination laws, regulations, and
through systems, including research staff. among various procedures with no
Integrated integrated water government authorities political risks.
River Basin environment 34. Implementation of the incl. ecology and
proposed plans, guidelines may 37. Risk is moderate. 41. The activities
Management protection plans environment, water
trigger future downstream resources, agricultural will improve water
activities such as wastewater and rural affairs, environment and
collection and treatment, livestock housing and urban- benefit to local people,
2. Development of and poultry manure disposal, so will be widely
river health rural development, and
reduced application of chemical natural resources, etc. supported by the
assessment fertilizers, closing of industrial public. There is no
and/or ecological plants, resulting indirect E&S reputation risk.
flow guidelines effects.
based on national 39. Risk is
standards moderate.
42. Risk is low.
35. Risk is substantial.
3.Implementation 43. Existing water allocation 47. Implementation of water 50. Implementation 52. The activities Substantial
of water allocation scheme based on national allocation will be extensive and of the activities will are in line with
schemes based standards has considered the may involve minority villages. require strong cross- national and local
on national environment, urban and rural, sectoral coordination laws, regulations, and
standards industrial and agricultural 48. Water allocation will among various procedures with no
demands in an integrated way. impact both upstream and government authorities political risks.
Therefore, implementation of the downstream areas, involving incl. ecology and
sensitive areas of. A well- 53. The activities
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
4. Determination scheme is unlikely to cause developed scientific, environment, water will improve water
of ecological flow significant adverse E&S impacts reasonable, and balanced resources, agricultural environment, increase
requirements and on the current water users. water allocation scheme will and rural affairs, efficiency of water
incorporation into not have negative impact on housing and urban- use, and benefit to
county water 44. Implementation of the these areas. rural development, and local people, so will be
allocations to research on ecological flow will natural resources, etc. widely supported by
ensure long-term have no direct E&S risk but may the public. There is no
restoration and have substantial downstream reputation risk.
protection of the impacts in terms of water demand 49. Risk is moderate.
competition for different 51. Risk is
freshwater moderate.
ecosystem uses/demands. As the research
will take multi-factors including 54. Risk is low.
services
environment, industrial and
agricultural production, urban and
rural water supply demand into
consideration with purpose of
determining a scientific,
reasonable, and balanced water
allocation scheme, it is unlikely
that the research
recommendations would cause
significant adverse E&S impacts
on the environment or water
users.
45. The potential downstream
water resource infrastructures as a
result of the TA activities is not
within the boundary the PforR
activities.
46. Risk is substantial.
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
5.Improving water 55. Improving water 57. Installing supplementary 59. Implementation 61. The activities Low
environment environment monitoring systems monitoring stations in the of the activities will are in line with
monitoring will conduct some minor-scale civil demonstration sub-basins and involve certain national and local
systems works, equipment installation and monitoring activities will no coordination between laws, regulations, and
monitored data sharing. These negative impact on water WRBs and EEBs. procedures with no
activities may involve short-term environment of the sub-basins. political risks.
water disturbance, minor land
acquisition, and OHS risks of PMO 62. The activities
60. Risk is low. will improve water
and the stations’ staff, which will 58. Risk is low.
have minor direct negative E&S environment and
risk. benefit to local people,
so will be widely
supported by the
public. There is no
56. Risk is low. reputation risk.
63. Risk is low.
6. Financing of 64. Construction soil and water 67. Activities will take place 70. Implementation 72. The activities Moderate
sustainable soil conservation activities may involve in rural areas without of the activities will are in line with
and water land acquisition, construction site encroachment of any critical require strong cross- national and local
conservation management, such social issue as natural habitat and other sectoral coordination laws, regulations, and
activities, (such as workers and community safety environmental sensitive areas among various procedures with no
terracing slope that never been disturbed by government authorities political risks.
land, ecological 65. Construction activity will human activities. incl. WRBs, FGBs,
slope protection, have short-term, limited ARABs, and EEBs, etc. 73. The activities
treatment of rocky environmental impact, e.g. fly 68. There are few minority will improve rural
desertification, dust, noise, solid waste, villages in the affected areas in infrastructure and
tree-grass wastewater, and disturbance of Hubei agricultural production
local habitat. 71. Risk is conditions and benefit
planting moderate.
measures, etc.) to local people, so will
69. Risk is moderate. be widely supported
66. Risk is moderate. by public. There is no
reputation risk.
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
74. Risk is low.
RA3: 1.Improved 75. Small and medium sized 78. Activities will take place 81. Implementation 83. The activities Substantial
Reducing integrated WWTPs may involve land main in constructed area of of the activities will are in line with
Water wastewater acquisition, household towns without encroachment of require strong cross- national and local
Pollution and management connections cost, small–to- any critical natural habitat and sectoral coordination laws, regulations, and
Transmission systems and medium scale employment, other environmental sensitive among various procedures with no
of Plastic services at county vulnerable groups interest, and areas that never been government authorities political risks.
Waste and township level worker & community health and disturbed by human activities. incl. housing and
safety risks during construction urban-rural 84. The activities
and operation. 79. There are few minority development, and will improve rural
villages in the affected areas in ecology and environment and
76. The activity during Hubei. environment, etc. benefit to local people,
construction will have short-term, so will be widely
limited environmental impacts, supported by the
such as dust, noise, solid waste 80. Risk is moderate. public. There is no
and wastewater, as well as habitat 82. Risk is reputation risk.
disturbance, water loss and soil moderate.
erosion risks. Facility operation
will generate such impacts as 85. Risk is low.
odor, sludge, accidental discharge
of wastewater that incompliance
with applicable standards.
77. Risk is substantial
2. Prevention of 86. Agricultural mulch 89. White pollution from 93. Implementation 96. The activities Substantial
plastics entering collection, recycling activities will agricultural plastic is of the activities will are in line with
waterbodies involve moderate level of worker widespread in rural area. There involve various national and local
through collection health risk. is insufficient understanding of government authorities laws, regulations, and
and recycling of the hazard of agricultural mulch incl. agriculture and procedures with no
agricultural plastic 87. In the processes of among farmers who has low rural affairs, ecology political risks.
agricultural mulch collection, awareness on classified solid and environment, and
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
film storage, recycling processing may waste management. municipal 97. The activities
influence with urban appearances administration, etc. will reduce plastic
and result in secondary 90. Activities will take place pollution, improve rural
environmental pollution if in rural areas without 94. The environment, and
mishandled. encroachment of any critical implementation will benefit to local people,
natural habitat and other require to interview a so will be widely
environmental sensitive areas large number of supported by the
that never been disturbed by farmers, which may public. There is no
88. Risk is moderate. human activities. need heavy workload reputation risk.
and encounter difficulty
91. There are few minority in coordination.
villages in the affected areas in
Hubei. 98. Risk is low.
95. Risk is
substantial.
92. Risk is moderate.
3. Reduced 99. Livestock/poultry manure 101. Agricultural NPS 105. Implementation 108. The activities Substantial
nutrient runoff via treatment and utilization may have pollution caused by manure of of the activities will are in line with
improved potential risk of groundwater livestock & poultry is require strong cross- national and local
management and pollution due to wastewater widespread in farming areas. sectoral coordination laws, regulations, and
utilization of infiltration. Manure, wastewater, Control measures are being among various procedures with no
livestock/poultry odor, and biogas will influence the taken. government authorities political risks.
manure, focusing health of workers and nearby incl. agriculture and
on large-scale residents. Biogas will also have 102. Activities will take place rural affairs, ecology 109. The activities
animal farms the risk of explosion. Unqualified in rural areas without and environment, will reduce agricultural
fertilizers produced from manure encroachment of any critical hygiene and health, NPS pollution,
or over-application of fertilizers will natural habitat and other market regulation, etc. improve rural
have negative impacts on soil environmental sensitive areas environment, and
environment, etc. that never been disturbed by 106. Management of benefit to local people,
human activities. manure treatment, so will be widely
fertilizer consumption, supported by the
103. There are few minority and fertilizer marketing public. There is no
100. Risk is substantial. villages in the affected areas in will go through many reputation risk.
Hubei. procedures so may
need heavy workload,
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Results Areas Typical activities Likely E&S effects E&S contextual risks Institutional capacity Political and Overall risk
and complexity risks reputational risks ranking
and encounter difficulty 110. Risk is low.
in coordination.
104. Risk is moderate.
107. Risk is
substantial
4. Improved 111. Waste collection and 114. Activities will take place 117. Implementation 119. The activities Substantial
integrated urban- transfer stations will involve small- urban and rural areas at of the activities will are in line with
rural domestic scale land acquisition, and worker township level without require strong cross- national and local
solid waste & community health and safety encroachment of any critical sectoral coordination laws, regulations, and
collection and risks at the construction and natural habitat and other among various procedures with no
transportation operation stages. environmental sensitive areas government authorities political risks.
systems and that never been disturbed by incl. agriculture and
services in the 112. Construction of waste human activities. But waste rural affairs, housing 120. The activities
demonstration collection and transfer stations will collection and transfer stations and urban-rural will reduce agricultural
counties produce short-term, limited may be close to water source development, ecology NPS pollution,
environmental impacts, such as conserves, nature conserves, and environment, improve rural
dust, noise, solid waste, and and other environmentally hygiene and health, environment, and
wastewater, as well as habitat sensitive areas. etc. benefit to local people,
disturbance and soil erosion. so will be widely
Facilities operation will produce 115. There are few minority supported by the
odor, sludge, leachate, noise, solid villages in the affected areas in public. There is no
waste, etc., and may affect the Hubei. 118. Risk is reputation risk.
health of workers and nearby moderate.
residents.
116. Risk is moderate. 121. Risk is low.
113. Risk is substantial.
Appendix 3: Comparison with the Bank PforR Policy and Directive
Principle #1: Program E&S management systems are designed to promote E&S sustainability in the program design; avoid, minimize, or mitigate adverse impacts;
and promote informed decision-making relating to a program’s E&S effects.
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PforR core Consistency and
China’s E&S management requirements and practices
principles/elements recommendations
Element 1: Operate Environmental: China has established a complete legal framework on environmental management. (1) Based on Consistent.
within an adequate legal Environmental Protection Law, China has been building up numerous environmental management laws,
and regulatory regulations, standards, technical guidelines, such as Environmental Impact Assessment Law (2018), Law on the
framework to guide E&S Prevention and Control of Water Pollution (2017), Law on the Prevention and Control of Atmospheric Pollution
impact assessments, (2018), Law on the Prevention and Control of Solid Waste Pollution (2020), Law on the Prevention and Control of
mitigation, management, Soil Pollution (2018), Construction Projects Environmental Protection Management Regulations (2017),
and monitoring at the Construction Projects EIA Classification Catalogue (2021), EIA Technical Guidelines, etc., which constitutes the
PforR level. legal framework and implementation mechanism for guiding assessment of environmental impact and
subsequently managing environmental risks of the PforR activities. (2) Hubei Province has established a
provincial program management office (PPMO) under Hubei DRC, coordinating various provincial departments
(e.g., EEB, ARAB, HURDB, NRB, WRB, FGB, etc.) for implementation of the PforR. These provincial government
authorities, together with local counterparts will be responsible for mobilizing their resources, taking necessary
actions, and designating their statutory regulatory bodies to manage the PforR environmental impacts/risks. This
ESSA has checked and confirmed the adequacy of China’s environmental management system applicable to the
Program in terms of legal and regulatory framework and government management performance.
Specifically, the national environmental management systems are also compared with the Bank’s EHS guidelines
and good international industry practice (GIIP).
The domestic solid waste management system is found equivalent to the WBG EHS Guidelines for Waste
Management Facilities and it covers good international industry practice (GIIP) such as use of containers or bags
for waste at the point of collection for each household, separation of recyclable materials at the point of
generation, covering collection and transfer vehicles along the entire route of transport to avoid windblown litter,
and encouraging residents to put waste out at designated locations, etc.
The domestic wastewater collection and treatment system is found equivalent to the WBG’s EHS Guidelines for
Water and Sanitation and it covers GIIP such as improving septic tank design and O&M; considering separate
sewer systems for domestic wastewater and storm water runoff in the overall planning and design of new
sewerage systems; establishing routine maintenance programs; operating and maintaining wastewater treatment
facilities and achieving effluent water quality consistent with applicable national requirements; covering emission
points (e.g., aeration basins, sludge thickeners) as needed to reduce odors, etc. The national Discharge Standard
of Pollutants for Municipal Wastewater Treatment Plant (GB18918-2002) has set limits on allowable
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PforR core Consistency and
China’s E&S management requirements and practices
principles/elements recommendations
concentrations of BOD, COD, SS, nitrogen, and phosphorous as same as the recommendation of the WBG’s
EHS Guidelines.
Social: i) Notice of the National Development and Reform Commission on Issuing the Interim Measures Largely consistent. There is no
for the Social Stability Risk Assessment of Major Fixed Asset Investment Projects (NDRCI 2012): For any mechanism available for
major fixed asset investment project in China, the owner shall conduct an SSRA at the preparatory stage to monitoring the implementation
identify risks and degree of impact, solicit opinions from the affected people, propose measures to prevent and of social risk management
mitigate risks, and determine the recommended social stability risk rating after such measures are taken. ii) plans of specific projects.
Guidelines on Establishing a Sound Social Stability Risk Assessment Mechanism for Major Decisions
and Matters (Interim) (CPCCCO [2012] No.2): An SSRA shall be conducted for any decision-making on major
project or matter that concerns the immediate interests of the public, and is likely to cause social stability risks,
such as LA and HD, farmers’ burden, state-owned enterprise restructuring, environmental impacts, social Recommendation: It is
security, and public welfare. iii) The Opinions on Strengthening Social Stability Risk Assessment for Major recommended that efforts are
Decisions under New Circumstances promulgated by the General Office of the CPC Central Committee and made to strengthen the
the General Office of the State Council in February 2020: An SSRA shall be carried out on major decisions monitoring of social risks
including those on major construction projects. It specifies the contents, methods, procedures, and management management and include the
of SSRA, and application of SSRA results, and underlines that the contents of SSRA are integral to the Program's monitoring of the
feasibility study and application reports. implementation of social risks
management plans in the
The SIA system applicable to the Program is adequate. Specific laws and regulations are sorted out by the SSRA.
following principles and elements.
Element 2: Incorporate Environment: China has established a complete EIA system, covering such aspects as screening, alternatives Consistent.
recognized elements of comparison, reasonableness analysis of site selection, impact assessment (positive vs. vegetative, direct vs.
good practice in E&S indirect, cumulative, etc.), mitigation measures, institution framework for managing environmental risk, estimated
assessment and cost of environmental protection facilities, extensive public consultation, information disclosure, and so on. At
management, including the preparation stage, lots of first and secondary data, copies of EIA documents for investment projects similar to
the PforR activities were collected, evidence that the EIA system is a good practice, as summarized in following
6 aspects.
Social: The state laws and regulations on project screening include the Measures for the Administration of the Largely consistent.
Pre-examination on the Use of Land for Construction Projects (2008.11.29), Cultural Relics Protection Law (2017Recommendation: Define
Amendment), Land Administration Law (2020.1.1), Regulations on the Prevention and Control of Geologic requirements of
Disasters (2004.3.1), and Notice of the National Development and Reform Commission on Issuing the Interim documentation in related
Measures for the Social Stability Risk Assessment of Major Fixed Asset Investment Projects (NDRCI 2012), and project management
Opinions on Strengthening Social Stability Risk Assessment for Major Decisions under New Circumstances documents (e.g., contracts,
(GOSC, 2020.2.22) agreements), including (but
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PforR core Consistency and
China’s E&S management requirements and practices
principles/elements recommendations
not limited to) keeping a
record of public participation
and information disclosure
process and outcomes and
the operation of the grievance
redress mechanism.
(i) early screening of Environment: The Environmental Impact Assessment Law clearly requires that early screening should be Consistent.
potential impacts; conducted for each construction project to confirm the project EIA classification. Construction Projects EIA
Classification Catalogue (2021) provides an EIA classification guide for 55 sectors (173 types of projects), and
proposes criteria for major, intermediate and minor impacts based on project type, scale and environmental
sensitivity. Development of EIA report for project with major impact, EIA form for project with intermediate
impact, and EIA registration for project with minor impact are required respectively. Every construction project
must be subject to the procedures of environmental impact identification and classification.
Social: Guidelines on Establishing a Social Stability Risk Assessment Mechanism for Major Decisions Consistent
and Matters (Interim): Scope of assessment: The Party and government institutions shall conduct an SSRA
before making any decision on any major project or policy or matter that concerns the immediate interests of the
public, and is likely to cause social stability risks, such as LA and HD, farmers’ burden, state -owned enterprise
restructuring, environmental impacts, social security, and public welfare. Decisions subject to SSRA shall be
made by relevant local authorities according to the above regulations and in the light of the realities, and the
SSRA of any major construction project shall be an integral part of its feasibility study. Measures for the
Administration of the Pre-examination on the Use of Land for Construction Projects: The area and type of
the land used for the project shall be identified before the feasibility study report or project proposal is reviewed
to avoid the expropriation of basic farmland, and nature reserves, etc.
(ii) consideration of Environment：It is required for an EIA for construction project to make comparison of site/alignment Consistent.
strategic, technical, and
alternatives on environmental background conditions, especially when environmental sensitive areas are
site alternatives
concerned. In the meantime, alternatives of pollution prevention and control measures, technical process for
(including the “no action�?
treating pollution will be compared in terms of environmental economic benefits or losses. The EIA will review
alternative);
historical environmental issues to clarify that if the proposed plan/project is not implemented, the environment
will continue deteriorating, which is equivalent to the analysis on the difference between with and without the
proposed project.
Social: Cultural Relics Protection Law: Article 20: The site selected for a construction project shall keep awayConsistent
from immovable cultural relics as far as possible. If the impact on a protected culture relic can't be avoided for
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China’s E&S management requirements and practices
principles/elements recommendations
special circumstances, the original site shall be protected by whatever possible means. Article 29: Before
launching a large-scale capital construction project, the construction contractor shall firstly apply to the cultural
relic authority of concerned province, autonomous region and municipality for an archaeological investigation at
places where cultural relics may be buried underground within the project area. Regulations on the Prevention
and Control of Geologic Disasters: Article 13: The development and implementation of overall plan for land
utilization and other plans for the construction of a major project shall take full account of the requirements on
prevention and control of geologic disasters so as to avoid and mitigate the losses arising from geologic
disasters. The plans on prevention and control of geologic disasters shall be an integral part of overall plans
developed at municipal, village or township levels.
(iii) explicit assessment Environment：According to The Technical Guidelines for Environmental Impact Assessment, the EIA for a Consistent.
of potential induced,
construction project, should predict the temporal and spatial cumulative impact, if triggered.
cumulative, and trans-
boundary impacts; Social: Outline for the Preparation of the Chapter on the Social Stability Risk Analysis of Major Fixed Asset Consistent
Investment Projects and Assessment Report (Interim) (NDRCOI [2013] No.428): Analysis of potential induced
and cumulative risks shall be conducted, with effective risks management measures being taken.
(iv) identification of Environment: It is stipulated in Environmental Impact Assessment Law that the EIA for construction project Consistent.
measures to mitigate should propose measures to prevent, control and/or mitigate negative environmental impacts. The Technical
adverse E&S risks and Guidelines for Environmental Impact Assessment also requires that specific and operational environmental
impacts that cannot be protection measures shall be proposed and in EIA and tailored to manage the specific impact assessed, and be
otherwise avoided or included in the EMP. Any EIA documents without appropriate environmental protection measures and
minimized; implementation schedule would not be accepted by review and approval.
Social: Guidelines on Establishing a Social Stability Risk Assessment Mechanism for Major Decisions Consistent
and Matters (Interim): The SSRA report shall specify the scope and procedures of SSRA, opinions of relevant
parties and opinions accepted, social stability risks potentially caused by any major decision, conclusions of
SSRA, proposals, risks prevention and mitigation measures, and emergency response plans, etc. If the
assessment report thinks that a high risk is present, a decision of non-implementation shall be made, or a
decision may be made after the plan is adjusted or the risk level is reduced; if an moderate risk is present, a
decision of implementation shall be made after effective risk prevention and mitigation measures are taken; and
if a low risk is present, a decision of implementation may be made, provided that actions like explanation and
persuasion to the people affected are taken and reasonable requests of people affected are handled properly.
The SSRA report, signed by person in charge of the assessor, shall be submitted to the decision-making
authority for review step by step, with copies being sent to the decision implementation, political and legislative
affairs, comprehensive social governance, stability maintenance, legislative affairs, and letters and visits
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authorities.
(v) clear articulation of Environment: The Technical Guidelines for Environmental Impact Assessment requires that EIA document Consistent.
institutional should define institutional responsibilities, financial resources for managing various environmental protection
responsibilities and facilities/measures, and prepare environmental monitoring and supervision plan, including environmental
resources to support elements and indicators to be monitored, as well as monitoring time and frequency, etc.
implementation of plans;
Social: Guidelines on Establishing a Sound Social Stability Risk Assessment Mechanism for Major Consistent
Decisions and Matters (Interim): Implementation agency of SSRA: SSRA of any major decision shall be
conducted by the assessor. For decisions made by the local party committee and government, the assessor
shall be designated by such party committee and government; for decisions made by any department of the local
party committee and government, the assessor shall be designated by such department or the leading
department in consultation with other relevant departments; for decisions made by multiple party and
government institutions at different levels, the assessor shall be designated by the initial decision-making
authority. During the SSRA, the assessor may organize an assessment group composed of officials from the
political and legislative affairs, comprehensive social governance, stability maintenance, legislative affairs, and
letters and visits authorities, NGOs, specialized agencies, experts, and representatives of the affected people.
Notice of the National Development and Reform Commission on Issuing the Interim Measures for the
Social Stability Risk Assessment of Major Fixed Asset Investment Projects: Article 3: At the feasibility
study stage of a project, the PIU (or through a specialized agency) shall conduct an SSRA to identify impacts,
carry out public consultation, propose mitigation measures, and prepare an SSRA report. Regulations for the
Implementation of the Land Administration Law: Article 25: In accordance with approved land acquisition
plans, the land administration authority of the municipal/county government shall, in conjunction with other
relevant departments, formulate land acquisition compensation and resettlement plans, announce such plans at
the townships and villages affected, consider the opinions of rural collective economic organizations and farmers
affected. All costs arising from land acquisition shall be fully disbursed within 3 months after the approval of land
acquisition compensation and resettlement plans.
(vi) responsiveness and Environment: It is stipulated in Environmental Impact Assessment Law that the EIA for construction project that Consistent.
accountability through are subject to the development of EIA report shall carry out public consultation pursuant to the legal requirement.
stakeholder consultation, Projects that are subject to the development of EIA form are not legally required to carry out public consultation
timely dissemination of but will be required by local ecology & environment authority or the project owner to carry out public consultation.
the PforR information, The Scheme for Environmental Impact Assessment Information Disclosure Mechanism for Construction Projects
and responsive GRMs. requires that the construction agency (project owner) shall disclose the environmental information related to the
selected project site, the whole process of construction, operation, that ecology and environmental authority shall
disclose its acceptance, review and approval of EIA report/EIA form and whole-process supervision information.
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Social: Land Administration Law: Article 47: For expropriation of land by the state, the local governments at Largely consistent. Recording
and above the county level shall make an announcement and organize implementation after approval according and documentation of the
to the legal procedures. If a government at or above the county level is to apply for land acquisition, it shall public participation and
conduct the current status survey and SSRA, and disclose the range and purpose of acquisition, current status, grievance redress process
compensation rate, resettlement mode, social security, etc. in the township, village and village group affected for are weak during the
at least 30 days to collect comments from the rural collective economic organization and its members, village implementation of Program
committee and other stakeholders affected. activities.
Recommendation: It is
recommended that efforts are
made to strengthen the
monitoring of social risks
management and enhance the
recording and documentation
of the public consultation and
grievance redress process in
relation to the construction
and operation of various
facilities.
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Principle #2: Program E&S management systems are designed to avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources
resulting from the program.
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Element 3: Identify, and Environment：According to The Technical Guidelines for Environmental Impact Assessment - Ecological Consistent.
screen for adverse Impact, identification and screening of ecological environmental elements (such as wild-fauna and flora,
effects on potentially important habitat, biodiversity) is one of the important assignments for EIA to identify environmental protection
important biodiversity targets. At the early stage of project proposal and EIA preparation, natural resources and ecology & environment
and cultural resource authorities will strictly implement the redline mechanism for ecological protection based on Opinions on
areas and provide Delineating and Strictly Observing the Red Line for Ecological Protection, and local Scheme for Delineating Red
adequate measures to Lines for Ecological Protection when reviewing and approving the selected project site. If any project that
avoid, minimize, or encroaches the red line for ecological protection and may course adverse impact on natural reserves, the
mitigate adverse effects. proposed project site will be rejected. The main activities under this PforR will be located at constructed or
agricultural production areas of township or countryside, which belong to artificial ecosystem, or have been
disturbed by human activities. Furthermore, any activities that may impact natural habitat will be excluded from
the PforR, as stated in the exclusion principles. Therefore, the PforR will not have adverse impact on important
biodiversity.
Social: Cultural Relics Protection Law: Article 20: The site selected for a construction project shall keep awayConsistent.
from immovable cultural relics as far as possible. If the impact on a protected culture relic can't be avoided for
special circumstances, the original site shall be protected by whatever possible means. Article 29: Before
launching a large-scale capital construction project, the construction contractor shall firstly apply to the cultural
relic authority of concerned province, autonomous region and municipality for an archaeological investigation at
places where cultural relics may be buried underground within the project area.
Element 4: Support and Environment: The PforR activities will be taken place at constructed or agricultural production areas of township Consistent.
promote the protection, or countryside, belonging to artificial ecosystem, or have been disturbed by human activities. The activities only
conservation, cover very limited geographic area with minor possibility of involving important natural habitat. (1) China has
maintenance, and many laws & regulations on conserving and managing natural ecology, e.g. Law on Wetland Conservation, Law
rehabilitation of natural on Wild Animal Conservation, Regulation on Wild Plants Conservation, Regulation on Natural Reserves, Opinion
habitats. Avoid on Delineating and Strictly Observing the Red Line for Ecological Protection, etc. The PforR is designed and will
significant conversion or be constructed, operated to strictly comply with the requirements of these laws and regulations. (2) The
degradation of critical important fauna and flora resources and natural habitats have been included within the ecological red lines.
natural habitats. If When selecting the PforR activities sties, the national red line mechanism for ecological protection will be strictly
avoiding the significant abided by and be under the strict regulatory management of natural resource and ecology & environment
conversion of natural authorities and will not easily touch the ecological protection red line and affect the natural habitat. (3) The PforR
habitats is not technicallyexclusion principles have excluded any activities that may impact natural habitat. (4) EIA documents will develop
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feasible, include measures for ecological protection which will be included into EMP. (5) The contractors will be required to
measures to mitigate or perform their contractual responsibilities on eco-environment protection to reduce disturbance to artificial and
offset the adverse natural ecosystem and restore vegetation in the first time after the completion of construction. (6) The water and
impacts of the PforR soil conservation system and river/lake chief system implemented in China will effectively prevent water & soil
activities. erosion, manage water environment of a basin, protect eco-environment quality. The said systems will play
active role in protecting and restoring the Yangtze River. In summary, the PforR activities will not course
significant conversion or degradation of critical natural habitats.
Element 5: Take into Social: Cultural Relics Protection Law: Article 17: No construction works or operations such as blasting, Consistent.
account potential drilling and digging are allowed within the area of a protected cultural relic. If such works or operations are
adverse effects on unavoidable, measures must be taken to ensure the safety of the protected cultural relic, and such works or
physical cultural property operations shall be subject to the approval by the government approving and announcing its status as a
and provide adequate protected cultural relic. Article 20: The site selected for a construction project shall keep away from immovable
measures to avoid, cultural relics as far as possible. If the impact on a protected culture relic can't be avoided for special
minimize, or mitigate circumstances, the original site shall be protected by whatever possible means. Article 29: Before launching a
such effects. large-scale capital construction project, the construction contractor shall firstly apply to the cultural relic authority
of concerned province, autonomous region and municipality for an archaeological investigation at places where
cultural relics may be buried underground within the project area. Article 31: The expenses needed for
archaeological investigation, prospecting, or excavation, which have to be carried out because of capital
construction or construction for productive purposes, shall be included in the budget of the construction
contractor for the construction project. Regulations for the Implementation of the Cultural Relics Protection
Law: Article 25: The scope and rates of funds for archaeological investigation, exploration and excavation shall
be in line with applicable Chinese regulations.
Principle #3: Program E&S management systems are designed to protect public and worker safety against the potential risks associated with (a) the construction
and/or operation of facilities or other operational practices under the program; (b) exposure to toxic chemicals, hazardous wastes, and otherwise dangerous
materials under the program; and (c) reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards.
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Element 6: Promote Environment: With regard to production and business activities that may course environmental emergencies , Consistent.
adequate community, China promulgated such regulatory documents as Emergency Management Measures for Environmental
individual, and worker Emergencies, Administrative Measures for Record Keeping on Preparedness Plan of Enterprises, Public
health, safety, and Institutions for Environmental Emergencies (trial), Notice on Further Strengthening Environmental Impact
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security through the safe Assessment Management to Prevent Environmental Risk etc. Governments at various levels are required to
design, construction, prepared preparedness plan for environmental emergencies, which are included into government actions on
operation, and establishing emergency organization, preparing emergency supplies, and conducting emergency exercises.
maintenance of program Enterprises and public institutions engaged in businesses that may have environmental emergency risks are
activities; or, in carrying required to develop preparedness plan for environmental emergencies which will be archived by ecology &
out activities that may be environment authority who will prepare emergency supplies and conduct emergency exercises. Larger or key
dependent on existing enterprises are found to implement the relevant requirement, while small-scale enterprises such as WWTPs at
infrastructure, township level remains to be improved in this respect to enhance their ability to manage risks.
incorporate safety
measures, inspections,
or remedial work as The occupational and community health and safety management system is substantially compliant with the
appropriate. WBG’s General EHS Guidelines, the EHS Guidelines for Waste Management Facilities, and the EHS Guidelines
for Water and Sanitation and it covers GIIP such as installing railing around all process tanks and pits within
WWTPs; implementing confined spaces entry programs consistent with applicable national requirements;
providing field workers with proper PPE and training on its proper use and maintenance; ventilating enclosed
processing areas and ventilate equipment prior to maintenance; and avoiding siting WWTPs or solid waste
management facilities near densely populated neighborhoods, etc.
Social: China has established a full set of work safety management systems at the design, construction, and Consistent.
operation stages of projects. Safety management is the top priority during project implementation. The
implementation of safety management measures is subject to all-round supervision by competent industry
supervision and emergency management (work safety) authorities. The owner, construction contractor and
operator of a project must establish a well-staffed safety management organization, and competent
administrative authorities have developed work safety management mechanisms to supervise the effectiveness
and outcomes of work safety in the project. In addition, the emergency management bureau (work safety
authority) is responsible for supervising and regulating all industries and key sectors. Thus, China's work safety
management system is adequate for safety supervision of the PforR Program activities.
i) Labor Law: Article 53: Labor health and safety facilities shall comply with the national standards. Newly
constructed, reconstructed or expanded labor health and safety facilities must be designed, constructed and put
into operation together with main parts of the project. Article 54: The employer must provide labor health and
safety conditions, and necessary labor protection articles complying with the state provisions to workers, and
workers dealing with operations with occupational hazards shall receive health checkup regularly. Article 57:
The state shall establish a statistical reporting and handling system of accidents and occupational diseases.
Article 61: Pregnant female workers shall not be arranged to deal with physical labor of intensity level III
stipulated by the state and prohibited labor, and female workers pregnant for seven months or more shall not
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work overtime or at night.
ii) Work Safety Law: Article 21: The primary person in charge of a production and operation entity shall be
responsible for establishing and improving its work safety responsibility system, developing policies, rules, and
operating procedures for work safety, developing and implementing work safety education and training plans,
supervising and inspecting work safety to eliminate hidden risks of work safety accidents in a timely manner,
preparing and implementing emergency rescue plans for work safety accidents, and reporting work safety
accidents in a timely and honest manner. Article 73: Authorities for work safety supervision and management
shall establish an offence reporting system so that work safety offenses are reported via various channels (e.g.,
by telephone, e-mail or mail). Article 74: Any organization or individual shall have the right to report any
potential accident or work safety violation to authorities for work safety supervision and management. Article
72: Any community or village committee shall report any identified potential accident or work safety violation by
any local production or operation entity to the local government or competent authority.
iii) Law on the Prevention and Control of Occupational Diseases (2018 Amendment): Article 4: Employees
shall be entitled to occupational health protection according to law. Employers shall create work environment and
conditions meeting the national occupational health standards and health requirements and take measures to
ensure that employees receive occupational health protection. Trade unions shall oversee the prevention and
control of occupational diseases and protect the lawful rights and interests of employees according to law. When
formulating or amending rules and regulations on the prevention and control of occupational diseases,
employers shall solicit the opinions of trade unions. Article 5: Employers shall establish and improve a
responsibility system for the prevention and control of occupational diseases, strengthen the management of
prevention and control of occupational diseases, improve their capabilities of prevention and control of
occupational diseases, and assume responsibilities for their own occupational hazards. Article 6: The primary
person in charge of an employer shall assume the overall responsibility for the employer's prevention and control
of occupational diseases. Article 7: Employers must make work-related injury insurance available for its
employees according to law. Article 9: An occupational health supervision system shall be implemented in
China. Article 10: The State Council and the local governments at and above the county level shall prepare
plans on the prevention and control of occupational diseases, which shall be included in the national economic
and social development plan and organize the implementation of such plans.
Element 7: (i) Promote Environment: Regarding environmental pollution risks of odor substances generated from livestock & poultry Consistent.
the use of recognized manure and domestic solid waste transfer stations and infectious disease risks, China has promulgated Law on
good practice in the Prevention and Control of Occupational Disease, Law on Amina Epidemic Prevention , etc., to set up
production, fundamental requirements on OHS to relevant enterprises and their responsibility. When constructing facilities
management, storage, generating odor, odor pollution control facilities will be installed simultaneously to eliminate at sources potential
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transport, and disposal ofhazards from malodorous substances and dead livestock & poultry to public health and occupational health
hazardous materials safety. Enterprises are required to develop and implement safety and OHS system. Operators will be provided
generated under the with on-the-job trainings and standard labor protection products. The sector authorities (e.g., agricultural & rural
PforR. affairs, housing & urban-rural development, ecology & environment) will conduct regulatory management,
inspections and provide guidance. This system can basically satisfy requirement for managing harmful
substances though there are still rooms for improving transfer stations and livestock & poultry farms to control
odor.
Social: i) Work Safety Law: Article 21: An entity engaged in building construction or road transportation, or an Largely consistent. Sound
entity manufacturing, marketing, or storing hazardous substances shall establish a work safety management safety and health
body or have full-time work safety management personnel. Article 22: The work safety management body and management systems are put
work safety management personnel of a production and operation entity shall be responsible for: (1) organizing in place at national and local
or participating in the development of the work safety policies, rules and operating procedures and the levels, and the PIUs have
emergency rescue plans for work safety accidents; (2) organizing or participating in and honestly recording its followed regulatory
work safety education and training; requirements for safety and
(3) supervising the implementation of safety control measures for the major hazard installations of the production health during construction or
and operation entity; (4) organizing or participating in the emergency rescue rehearsals of the production and operation. However,
operation entity; (5) inspecting its work safety condition, conducting screening for any work safety risks in a occupational health
timely manner, and offering recommendations for improving work safety management; (6) prohibiting and examination of workers needs
redressing any command against rules, forced operation at risk, or violation of the operating procedures; and, (7) to be strengthened. Problems
supervising the work safety related corrective actions taken by the production and operation entity. include the absence of early-
stage occupational health
ii) Regulations on the Safety Management of Hazardous Chemicals: Article 4: A hazardous chemical entity assessment and declaration
shall provide safety education, legal education and on-the-job technical training to its employees. Employees of occupational hazards; the
shall accept education and training and may not hold office until they have passed the relevant examinations. lack of knowledge of
iii) Occupational Health and Safety Management Systems —Requirements with Guidance for Use: This is occupational health
a regional standard on OHS management systems, designed to systematically identify and control occupational management laws and
health and safety risks that may arise in organizational activities, products and services, prevent safety regulations; the failure to
accidents, and protect workers’ health and safety. Enterprises may apply for OHS management system include small enterprises or
certification, establish a normative management system for the source identification and whole-process control those exposed to "moderate"
of hazards, and realize continual improvement and compliance. An assessment includes: 1) OHS pre- occupational hazards in the
assessment; 2) inspection reports on OHS and fire protection; 3) test reports on OHS and fire protection; 4) local health management
chemical safety reports for hazardous chemicals; 5) copy of manufacturing license (when required); and 6) copy system.
of business license. The following shall be reviewed comprehensively: 1) the organizatio n’s work safety permit; Recommendation: The
2) production or service flowchart; 3) organizational chart; 4) list of applicable laws and regulations; 5) location implementation of OHS
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map; 6) factory layout; 7) workshop layout; 8) list of major hazards; 9) OHS targets, indicators and management management systems at
plan; and 10) certificate of compliance, etc. some enterprises (e.g.,
WWTPs, fecal residue and
iv) Guidelines for Occupational Disease Prevention and Control for Employers : The general requirements wastewater recycling facilities,
for occupational disease prevention and control, classified and tiered management, occupational health file and refuse treatment facilities)
management, and OHS assessment, etc. are stipulated, including: a corporate occupational health policy shall is yet to be improved.
be developed, and an occupational disease prevention and treatment agency and an occupational health
management agency shall be established, with relevant functions being clearly defined and full/part-time
occupational health officers being appointed; occupational disease prevention and control shall be included in
the management-by-objective responsibility system; an occupational disease prevention and control plan, and
an implementation plan shall be developed; a sound occupational health management system and job SOPs
shall be established; sound occupational health files shall be established; efforts shall be made to establish a
sound workplace occupational hazard monitoring and evaluation system, provide necessary financial support for
occupational disease prevention and control, develop a sound emergency rescue plan for occupational
diseases, and make work-related injury insurance available.
v) The 14th Five-Year Plan for Prevention and Control of Occupational Diseases of Hubei Province
(HPHC [2022] No.8): By 2025, Hubei Province shall establish a sounder occupational health management
system, enhance the occupational health management capacity, significantly promote the quality of occupational
health management, improve the workers' health, and strengthen treatment and support of patients with
occupational diseases and work-related injury insurance. Below are the main objectives: the number of
contributors of work-related injury insurance is increased steadily; over 90% of industrial enterprises and projects
exposed to occupational hazards are declared; over 85% of workplaces pass the occupational hazard
monitoring; over 90 of non-medical radiation workers receive the radiation dose monitoring; over 85% of key
groups exposed to occupational hazards have a good knowledge of occupational health protection; the rate of
accessibility of centralized pneumoconiosis rehabilitation service in townships (communities) is over 90%;
occupational health violations are fully investigated and handled; existing medical resources are made use of to
establish provincial medical institutions providing occupational diseases treatment; at least one provincial agency
is designated to provide technical guidance on the protection against occupational hazards such as dust,
poisonous chemicals, noise and radiation; at least one public medical and health institution in every city
(prefecture) is designated to provide diagnosis of occupational diseases; at least one public medical and health
institution in every city, county and district to provide occupational health examination.
(ii) Promote the use of Environment: The PforR will not include activities of pesticide application. China has a mature pesticide Consistent.
integrated pest management system. Pesticide Management Regulations, Regulations on Crop Pest Control, etc., have been
management practices to promulgated. In agriculture practice, the production and operation of pesticides shall be subject to a licensing
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manage or reduce the system. Pesticide users are required to apply pesticides as prescribed. Crop farming promotes pesticide
adverse impacts of pests reduction by using ecological management, healthy cultivation, biological control, physical control and other
or disease vectors green prevention and control technologies. Agriculture & rural affair authorities at various levels designate full-
time institutions responsible for comprehensive regulatory management on pest control and reduced application
of pesticides.
(iii) Provide training for Environment: Odor from livestock/poultry manure and domestic solid waste contains such hazardous chemicals Consistent.
workers involved in the as H2S and NH3 that are harmful to people’s health. In accordance with Regulations on the Safety Management
production, procurement,of Hazardous Chemicals, hazardous chemicals catalogue, Law on Safety in Production, Law on Prevention and
storage, transport, use, Control of Occupational Diseases, enterprises are required to improve their deodorization facilities/measures,
and disposal of provide their operators with standard PPEs. Agriculture & rural affairs, housing & urban-rural, urban
hazardous chemicals in management authorities will supervise the performance of enterprises.
accordance with the
relevant international Social: Consistent.
guidelines and i) Regulations on the Safety Management of Hazardous Chemicals: Article 4: A hazardous chemical entity
conventions. shall provide safety education, legal education and on-the-job technical training to its employees. Employees
shall accept education and training and may not hold office until they have passed the relevant examinations.
ii) Occupational Health and Safety Management Systems—Requirements with Guidance for Use: This is
a regional standard on OHS management systems, designed to systematically identify and control occupational
health and safety risks that may arise in organizational activities, products, and services, prevent safety
accidents, and protect workers’ health and safety. Enterprises may apply for OHS management system
certification, establish a normative management system for the source identification and whole-process control
of hazards, and realize continual improvement and compliance. An assessment includes: 1) OHS pre-
assessment; 2) inspection reports on OHS and fire protection; 3) test reports on OHS and fire protection; 4)
chemical safety reports for hazardous chemicals; 5) copy of manufacturing license (when required); and 6) copy
of business license. The following shall be reviewed comprehensively: 1) the organization’s work safety permit;
2) production or service flowchart; 3) organizational chart; 4) list of applicable laws and regulations; 5) location
map; 6) factory layout; 7) workshop layout; 8) list of major hazards; 9) OHS targets, indicators and management
plan; and 10) certificate of compliance, etc.
iii) Guidelines for Occupational Disease Prevention and Control for Employers: The general requirements
for occupational disease prevention and treatment, tiered and classified management, occupational health file
management, and OHS assessment, etc. are stipulated, including: a corporate occupational health policy shall
be developed, and an occupational disease prevention and treatment agency and an occupational health
management agency shall be established, with relevant functions being clearly defined and full/part-time
occupational health officers being appointed; occupational disease prevention and control shall be included in
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the management-by-objective responsibility system; an occupational disease prevention and control plan, and
an implementation plan shall be developed; a sound occupational health management system and job SOPs
shall be established; sound occupational health files shall be established; efforts shall be made to establish a
sound workplace occupational hazard monitoring and evaluation system, provide necessary financial support for
occupational disease prevention and control, develop a sound emergency rescue plan for occupational
diseases, and make work-related injury insurance available.
Element 8: Include Social: Consistent.
adequate measures to
avoid, minimize, or i) Regulations on the Defense against Meteorological Disasters: Article 27: When implementing major
mitigate community, national construction projects and major regional economic development projects, and preparing urban and rural
individual, and worker development plans, governments at or above the county level shall consider climatic feasibility and risks of
risks when the PforR meteorological disasters and take actions to avoid or mitigate such impacts. Article 23: Lightning protection
activities are located in devices of buildings, places and facilities shall comply with the national lightning protection standards. Lightning
areas prone to natural protection devices of newly constructed, reconstructed or expanded buildings, places and facilities must be
hazards such as floods, designed, constructed, and put into operation together with main parts of the project.
hurricanes, earthquakes, ii) Regulations of the People’s Republic of China on Flood Control: Systematic arrangements for flood
or other severe weather control in terms of organization, preparation, implementation, emergency rescue, recovery, and funding, etc. are
or affected by climate made.
events.
iii) Regulations on the Prevention and Control of Geologic Disasters: Article 10: A geologic disaster
investigation system shall be practiced at the state, provincial and county levels. The land and resources
authority shall work out the planning on prevention and control of geologic disasters within its own jurisdiction
according to the result from investigation of geologic disasters within such jurisdiction as well as the planning of
the next higher level on prevention and control of geologic disasters and submit it to the government at the same
level for approval and promulgation after expert evaluation. Systematic arrangements for the investigation,
prevention and control of geological disasters are made in terms of the prevention, emergency response and
control of geological disasters, and legal responsibilities, etc.
iv) Law on Protecting Against and Mitigating Earthquake Disasters: Article 35: The construction projects
newly built, expanded or rebuilt shall meet the seismic fortification requirements. The major construction projects
and the construction projects which may induce serious secondary disasters shall be subject to the seismic
safety evaluation as required, and the seismic fortification shall be conducted in accordance with the seismic
fortification requirements determined by the approved seismic safety evaluation reports. The seismic safety
evaluation entities of construction projects shall, in accordance with the relevant standards of the state, carry out
seismic safety evaluation, and be responsible for the quality of the seismic safety evaluation reports. The
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construction projects other than those prescribed in the preceding paragraph shall be fortified against
earthquakes according to the seismic fortification requirements determined by the seismic intensity zoning map
or the ground motion parameter zoning map. The construction projects in densely populated places such as
schools and hospitals shall be designed and constructed in compliance with the seismic fortification
requirements higher than those for other buildings in the locality, and effective measures shall be taken to
increase the capability of seismic fortification.
v) Notice on Targeted Health Management and Orderly People Flow (Joint Prevention and Control
Mechanism ZF [2020] No. 203: Pandemic control areas shall be defined accurately based on pandemic risk
level, and such prevention and control measures as people flow restriction, nucleic acid testing and health
monitoring shall be taken timely. For medium and high-risk areas, entry into project areas and people gathering
shall be avoided where possible, and people entering the project area may flow freely only if their body
temperatures are normal and proper personal protection measures are taken. Entry into medium-to-high-risk
areas shall be avoided if not necessary.
Principle #4: Program E&S systems manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement and assists
affected people in improving, or at the minimum restoring, their livelihoods and living standards.
China’s social management requirements Consistency
PforR core
analysis and
principles/elements
recommendation
Element 9: i) Measures for the Administration of the Pre-examination on the Use of Land for Construction Projects: The Consistent
area and type of the land used for the project shall be identified before the feasibility study report or project proposal is
i) Avoid or minimize land reviewed to avoid the acquisition of basic farmland, and nature reserves, etc.
acquisition and related
adverse impacts. ii) Guidelines on Establishing a Sound Social Stability Risk Assessment Mechanism for Major Decisions and
Matters (Interim) (CPCCCO [2012] No.2): An SSRA shall be conducted for any project involving LA and HD, farmers’
burden or social security.
iii) Guidelines on Establishing a Social Stability Risk Assessment Mechanism for Major Decisions and Matters
(Interim): If the assessment report thinks that a high risk is present, a decision of non-implementation shall be made,
or a decision may be made after the plan is adjusted or the risk level is reduced; if an moderate risk is present, a
decision of implementation shall be made after effective risk prevention and mitigation measures are taken; and if a
low risk is present, a decision of implementation may be made, provided that actions like explanation and persuasion
to the people affected are taken and reasonable requests of people affected are handled properly. For impact and risk
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management, the legitimacy, rationality, feasibility and controllability of measures shall be assessed.
iv) Opinions on Strengthening Social Stability Risk Assessment for Major Decisions under New
Circumstances: SSRA, if required, shall be an important part of the feasibility study of any major construction project.
Major decisions, items and matters with low social stability risks decided to be put in place when conditions are ripe
shall be advanced in a well-planned way in accordance with the risk control plan. If social stability risks are identified
and the conditions are not ripe, the decision making shall be subject to approval or be postponed until the original plan
is improved, the conditions are ripe and risks are eliminated. Decisions, items and matters urgently needed to be put
in place despite high risks shall be advanced prudently and carefully after precautionary and mitigation measures are
taken. Those with major social stability risks and fall short of relevant requirements shall in no case be put in place.
v) Notice of Hubei Provincial Government on Implementing the Strictest Farmland Protection System: Detailed
provisions on the occupation of farmland are formulated.
1) The occupation of permanent basic farmland for greening, afforestation, lake digging, landscaping, non-agricultural
construction and other non-agricultural purposes shall be included in the scope of assessment under the target-based
responsibility system for farmland protection, and efforts shall be made to more effectively investigate and punish
illegal acts. 2) Illegal occupation of arable land for greening, afforestation, lake digging and landscaping is strictly
prohibited. Occupation of permanent basic farmland for growing trees, turf and other plants for greening and
afforestation is prohibited. The scale and scope of land to be occupied shall be subject to the approval of the
government authority, and the type of land to be occupied shall be identified carefully. No project involving the
occupation of arable land in violation of laws and regulations shall be approved, in which case neither the afforestation
area is recognized nor the forestry subsidy will be provided. Occupation of arable land for lake digging and filling and
landscaping in the guise of river, wetland and lake improvement is prohibited. Projects where approval procedures are
not completed and illegal occupation of arable land occurs must be stopped immediately and rectifications shall be
made within a specified time limit. 3) Occupation of arable land for constructing excessive landscaped roadways is
prohibited. Approval procedures must be completed for land for landscaping of transportation and water conservancy
projects in strict accordance with regulations, and a balance between land occupation and compensation must be
maintained if any arable land is occupied. The scale of landscaped roadways shall be strictly controlled, and excessive
construction of green belts on arable land on either side of any railway, national and provincial highway (including
expressway), and county/township road in violation of laws and regulations shall be stopped immediately. 4)
Occupation of permanent basic farmland for expanding nature reserves is prohibited. New nature reserves shall
conform to the national land and space planning, and no permanent basic farmland shall be occupied. 5) No arable
land shall be occupied for non-agricultural purposes in violation of laws and regulations. No approval or permit shall be
granted for the occupation of rural land for construction projects. 6) Illegal land use and approval are prohibited. No
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unauthorized adjustment of county/township land and space planning shall be made to circumvent the approval of the
occupation of permanent basic farmland. Occupation of land to be used for any construction project shall be subject to
approval, and project construction shall be carried out on the land in line with the approved purposes, requirements for
location and quantity of land, and standards. Temporary use of land shall be managed stringently, and any land user
shall apply for temporary use of land as per legal procedures. Engineering and technical measures such as removal
and reuse of soil of cultivated soil horizon shall be taken to minimize damage to such soil horizon if any permanent
basic farmland is to be temporarily occupied. The land reclamation plan shall be subject to the review by the
municipal/prefecture natural resources authority, and the approval by the county natural resources authority before the
land is temporarily occupied. Upon the expiration of the term of temporary use of land, the land user shall stop using
the land in violation of laws and regulations, and timely carry out land reclamation to restore the original land
conditions for growing crops. Where arable land and permanent basic farmland are temporarily occupied or used for
any construction project without approval or in violation of regulations, severe punishment shall be imposed according
to laws and regulations and the original land conditions for growing crops shall be restored within the specified time
limit. 7) The red lines for ecological conservation, permanent basic farmland protection and urban development shall
be coordinated to give priority to farmland protection and conservation and improve the spatial layout of farmland and
land used for ecological conservation and construction projects. Land use control shall be strengthened, and the red
lines for farmland protection and the quotas for land used for construction projects shall be put in place to strictly
control non-agricultural use of farmland. 7) The requisition–compensation balance policy for arable land shall be
effectively put in place to ensure that arable land occupied by construction projects are adequately compensated by
equivalent arable land. 8) Special protection for permanent basic farmland shall be enhanced. Designated permanent
basic farmland shall in no way be occupied or used by any entity or individual for unauthorized purposes. No entity or
individual shall destroy the cultivated soil horizon of permanent basic farmland.
(ii) Identifying and i) Land Administration Law: Article 26: Owners or users of the land to be acquired shall, within the time limit Consistent
addressing economic specified in the announcement, go through compensation registration on the strength of the real estate ownership
and social impacts certificate as required by the local land and resources authority. For expropriation of land by the state, the local
arising from land governments at and above the county level shall make an announcement and organize implementation after approval
acquisition or loss of according to the legal procedures.
access to natural
resources: ii) Regulations for the Implementation of the Land Administration Law: Article 25: Municipal/county government
of the locality whose land has been expropriated shall, upon approval of the LA plan according to law, organize its
implementation, and make an announcement in the township and village where land acquisition occurs on the
approval organ of the LA, number of the approval document, use, scope and area of the acquired land as well as the
rates for compensation of LA, measures for the resettlement of agricultural workers and duration for processing LA
compensation. Article 26: Land compensation fee shall go to the rural collective economic organization, and
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compensation for ground attachments and standing crops shall be disbursed to their owners.
iii) Provide i) Real Right Law: Article 42: For collective land acquired, land compensation, resettlement subsidy, compensation Consistent
compensation sufficient for ground attachments and standing crops, etc. shall be fully paid according to law, and social security funds for land-
to purchase replacement expropriated farmers shall be appropriated to secure their livelihoods and protect their lawful rights and interests.
assets of equivalent Where any house or other immovable property of any entity or individual is expropriated, compensation shall be
value and to meet any granted according to law to protect the lawful rights and interests of the affected entity or individual. Where any
necessary transitional personal residence is expropriated, the affected person’s housing conditions shall be secured.
expenses, paid before
taking land or restricting ii) Land Administration Law: Article 48: Fair and reasonable compensation shall be granted for land acquisition. In
access. case of land acquisition, the land compensation, resettlement subsidy, and compensation for rural residential houses,
other ground attachments and standing crops, etc. shall be paid timely and fully according to law, and social security
costs for the affected farmers shall be disbursed.
iii) Regulations on the Expropriation of Houses on State-owned Land and Compensation (Decree [2011]
No.590 of the State Council) (2011.1.21): Article 19: The compensation for the value of houses to be expropriated
shall not be less than the market price of the equivalent real estate on the date of the public notice of the house
expropriation decisions. The value of the houses to be expropriated shall be assessed and determined by real estate
appraisal agencies with appropriate qualifications in accordance with the procedures for evaluating houses to be
expropriated. Anyone who has objection to the appraised value of the houses to be expropriated may apply for
reassessment. Anyone who disagrees with the result of re-assessment may apply for appraisal by the real estate
appraisal expert panel.
iv) Measures for the Expropriation and Evaluation of Houses on State-owned Land (JF [2011] No.77) (2011-6-
3): Article 16: The real estate appraisal agency shall, in line with the power of attorney or entrustment contract,
disclose preliminary house appraisal results to the house expropriation authority. The house expropriation authority
shall disclose such results to the affected people. During disclosure, the real estate appraisal agency shall appoint a
registered appraiser to explain such results on site and correct any error.
v) Notice of Hubei Provincial Government on Releasing Block Comprehensive Land Prices of Hubei Province
(2019.11.8): Block comprehensive land price consists of land compensation (40%) and resettlement subsidy (60%).
Permanent basic farmland to be expropriated upon approval shall be compensated at the highest compensate rate
effective in the city/district/county concerned. Provisions herein shall be applicable for the expropriation of land of
state-owned farms, forestry centers, meadows and fisheries for non-agricultural purposes. In addition, there are
concrete provisions on the compensation rates for ground attachments and standing crops, the expropriation of land of
state-owned farms, forestry centers, meadows and fisheries for non-agricultural purposes, and the requisition of paddy
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fields, grasslands and unexploited land.
vi) Measures for the Implementation of the Expropriation of Houses on State-owned Land and Compensation
of Hubei Province (2015.7.6): Articles 25 to 27: 1) The value of the expropriated house and the house for property
right exchange shall be equivalent to the appraisal value determined by qualified real estate appraisal agencies on the
date when the decision on the expropriation is announced in accordance with the measures for expropriation and
evaluation of houses on state-owned land; 2) The appraisal shall be conducted in accordance with China's technical
standards and evaluation procedures and with reference to the market prices of real estate similar to the house
expropriated; 3) Agencies, individuals and panels of experts responsible for real estate appraisal shall conduct
independent, objective and impartial evaluation and appraisal of the expropriated house without being distracted by
any organization or individual; 4) Municipal and county real estate authorities shall release the catalogue of legally
registered real estate appraisal agencies with qualifications of grade three or above and without bad credit records in
public on a regular basis so that affected people make a choice as needed.
iv) Provide supplemental i) Land Administration Law: Article 48: Efforts shall be made to ensure that living standard of farmers affected by Consistent
livelihood improvement land expropriation are not reduced, and that their long-term livelihoods are secured.
or restoration measures
if taking of land causes ii) Guidelines on Improving the Compensation and Resettlement System for Land Acquisition (MLR [2004]
loss of income- No.238): 1) Agricultural resettlement: When rural collective land out of urban planning areas is acquired, land-
generating opportunity expropriated farmers shall be first provided with necessary arable land in forms of mobile collective land, contracted
(e.g., loss of crop land turned over by contractors and arable land arising from land development so that they continue to pursue
production or agricultural production. 2) Reemployment resettlement: conditions shall be created actively to provide free labor skills
employment). training to land-expropriated farmers and place them to corresponding jobs. Under equal conditions, land users shall
first employ land-expropriated farmers. When rural collective land within urban planning areas is acquired, land-
expropriated farmers shall be included in the urban employment system and the social security system. 3) Dividend
distribution resettlement: when any land with long-term stable yields is to be used for a project, the affected rural
collective economic organization may become a project shareholder with compensation fees for LA or rights to use
construction land in consultation with the land user. The rural collective economic organization and rural households
will receive dividends as agreed. 4) Non-local resettlement: if basic production and living conditions are not available
locally to land-expropriated farmers, non-local resettlement may be practiced under the leadership of the government
in consultation with the rural collective economic organization and rural households.
iii) Notice on Doing a Good Job in Employment Training and Social Security for Land-expropriated Farmers
(SC [2006] No.29): Employment training and social security for land-expropriated farmers shall be an important part of
land acquisition system reform. Local governments shall, against the backdrop of coordinating economic and social
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development in urban and rural areas, enhance employment training and social security, include employment of land-
expropriated farmers in the economic and social development plans and annual plans of local governments, establish
a social security system suited to the characteristics and needs of land-expropriated farmers, take effective measures
to secure employment training and social security funds, help land-expropriated farmers get employed and assimilate
into the urban community, and ensure that the living standard of land-expropriated farmers is not reduced due to land
expropriation and that their long-term livelihoods are secured.
iv) Notice of the Ministry of Labor and Social Security and the Ministry of Land and Resources on Doing a
Substantially Good Job in Social Security for Land-expropriated Farmers (MLSS [2007] No.14): All localities
shall establish a social security system for land-expropriated farmers as soon as possible. Funds required for social
security for land-expropriated farmers shall be fully transferred to the special account and credited to the individual or
pooling account within 3 months after the approval of the land acquisition compensation and resettlement plan.
v) Guidelines of Hubei Provincial Government on Basic Pension Insurance for Land-expropriated Farmers
(HPPG [2014] No. 53): Land-expropriated farmers shall have access to the basic pension insurance if: 1) their
contracted land is legally expropriated by governments at or above county level; 2) they have the Rural Land Contract
or the Certificate of Contractual Right of Rural Land in hand when their land is expropriated; 3) they are registered
permanent residents at the place where the expropriated land is located; 4) the area of arable land per capita is 0.3
mu or less after the land expropriation; and 5) they are 16 years old or older. Below are compensation rates for basic
pension insurance of land-expropriated farmers in Hubei Province: governments at or above county level provide land-
expropriated farmers with one-off compensation no less than three times the annual per capita net income of rural
residents in the city or prefecture where the land is expropriated; land-expropriated farmers who are 60 years old or
older are entitled to such one-off compensation in full amount; for land-expropriated farmers under the age of 60 ( 16
to 59 years old), the amount of compensation shall be 1% lower than the aforesaid full amount for every 1 year of
difference between their actual age and the baseline age (60 years old).
v) Restore or replace i) Land Administration Law: Article 47: For expropriation of land by the state, the local governments at and above Consistent
public infrastructure and the county level shall make an announcement and organize implementation after approval according to the legal
community services that procedures. If a government at or above the county level is to apply for land acquisition, it shall conduct the current
may be adversely status survey and SSRA, and disclose the range and purpose of acquisition, current status, compensation rate,
affected by the Program. resettlement mode, social security, etc. in the township, village and village group affected for at least 30 days to collect
comments from the rural collective economic organization and its members, village committee and other stakeholders
affected.
ii) Regulations for the Implementation of the Land Administration Law: Article 25: Municipal/county government
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of the locality whose land has been acquired shall, upon approval of the LA plan according to law, organize its
implementation, and make an announcement in the township and village where land acquisition occurs on the
approval organ of the LA, number of the approval document, use, scope and area of the acquired land as well as the
rates for compensation of LA, measures for the resettlement of agricultural workers and time limit for completing LA
compensation.
iii) Real Right Law: Article 36: If any immovable or movable property is damaged, the right holder may request
repair, rework, replacement or restoration.
(vi) Information i) Land Administration Law: Article 26: Owners or users of the land to be expropriated shall, within the time limit Consistent
disclosure, public specified in the announcement, go through compensation registration on the strength of the real estate ownership
participation and certificate as required by the local land and resources authority. For expropriation of land by the state, the local
informed decision- governments at and above the county level shall make an announcement and organize implementation after approval
making: according to the legal procedures. Article 47: If a government at or above the county level is to apply for land
acquisition, it shall conduct the current status survey and SSRA, and disclose the range and purpose of acquisition,
current status, compensation rate, resettlement mode, social security, etc. in the township, village and village group
affected for at least 30 days to collect comments from the rural collective economic organization and its members,
village committee and other stakeholders affected.
ii) Regulations on Complaint Letters and Visits: Article 6: The government at or above the county level shall
designate a working body as the administrative organ in charge of complaint letters and visits within its scope of
jurisdiction, and such administrative organ shall perform the following duties: (1) accepting complaints, making
arrangements to deal with complaints, and forwarding the complaints to competent authorities; (2) handling the
complaints as required by the governments of the same level or higher levels; (3) coordinating the handling of the
important complaints; (4) supervising and checking the handling of complaints; (5) studying and analyzing the
complaints, conducting investigation and research, and timely putting forward suggestions for improving relevant
policies and work of the government at the same level; and (6) giving instructions to promote the handling of
complaints by other departments of the government at the same level and the authorities of complaint letters and visits
of the governments at lower levels.
iii) Document No.1 of the Central Government (2020): Leaders, especially municipal and county leaders, shall pay
regular visits to departments at grass-roots level to deal with complaints proactively. Diversified legal services like
designating one legal adviser for each village shall be offered, and civil mediation shall be strengthened to ensure that
disputes and conflicts are resolved at the village and township level where possible. Unblocked complaint channels
shall be made available for farmers to have their reasonable complaints resolved timely and properly.
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iv) Standard Guide to Grass-root Government Affairs Disclosure on Collective Land Acquisition (June 2019,
Ministry of Natural Resources): Efforts shall be made to define matters to be disclosed and the scope of disclosure,
standardize the disclosure procedures, improve modes of disclosure, and practically safeguard the people's rights to
know, participate, oversee and be heard. The main objectives of public participation at different stages of LAR are as
follows:
• During project preparation, option argumentation and comparison, the project owner and design agency shall
conduct meaningful consultation with affected people and other stakeholders, improve the engineering measures, and
determine the range of land use based on feedback, thereby evading sensitive objects and minimizing LAR impacts.
• Participation at the DMS stage includes land acquisition announcement, DMS publicity, participation in the DMS, and
confirmation, disclosure and review of DMS results.
• At the SSRA stage, meaningful consultation shall be conducted with stakeholders to assess potential major social
risks arising from land expropriation and house demolition, including other major risks that are not directly related to
but may materially affect the project.
• During the drafting of the compensation plan, the plan should be disclosed to collect comments from affected people,
and a public hearing will be held when necessary.
• Public participation at the implementation stage mainly includes effective information disclosure and consultation in
relation to production and livelihood restoration and the allocation and use of compensation to ensure that opinions of
the affected people are heard and agreements are signed through negotiation.
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Principle #5: Program E&S systems give due consideration to the cultural appropriateness of, and equitable access to, Program benefits, giving special attention to
the rights and interests of indigenous people and vulnerable groups.
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Element 10: i) Constitution: Article 4: All ethnic groups in the People's Republic of China are equal. Consistent
Undertake prior
informed consultations ii) Law of the People’s Republic of China on Regional National Autonomy: Article 51: In dealing with special
if the ethnic minorities issues concerning the various nationalities within its area, the organ of self-government of a national autonomous area
are potentially affected must conduct full consultation with their representatives and respect their opinions. Article 52: The organ of self-
(positively or government of a national autonomous area shall guarantee that citizens of the various nationalities in the area enjoy
negatively) free of the rights of citizens as prescribed in the Constitution.
charge, to determine iii) Social Stability Risk Assessment of Major Fixed Asset Investment Projects: Article 3: At the feasibility study
whether there is broad stage of a project, the PIU (or through a specialized agency) shall conduct an SSRA to identify impacts, propose
community support for mitigation measures, and prepare an SSRA report. On the other hand, if a government at or above the county level
the PforR Program applies for land acquisition, a current status survey and an SSRA should be conducted for the land to be expropriated.
activities. The SSRA report shall be reviewed by experts organized by the designated authority of the county government before
being approved. Local governments have issued opinions/notices on the implementation of SSRA, such as the
Opinions on the Implementation of Measures to Strengthen Social Stability Risk Assessment Mechanism for Major
Decisions under New Circumstances of Hubei Provincial Committee of the CPC and the General Office of Hubei
Provincial Government (2021.12.13)
iv) Land Administration Law (2020): Article 47: For expropriation of land by the state, the local governments at and
above the county level shall make an announcement and organize implementation after approval according to the
legal procedures. If a government at or above the county level is to apply for land acquisition, it shall conduct the
current status survey and SSRA, and disclose the range and purpose of acquisition, current status, compensation
rate, resettlement mode, social security, etc. in the township, village and village group affected for at least 30 days to
collect comments from the rural collective economic organization and its members, village committee and other
stakeholders affected.
Element 11: Ensure i) Law of the People’s Republic of China on Regional National Autonomy: Article 65: While exploiting resources Consistent
that ethnic minorities and carrying out construction in national autonomous areas, the state shall give consideration to the interests of these
can participate in areas, make arrangements favorable to local economic development and pay proper attention to the productive
devising opportunities pursuits and the life of local minority nationalities. Article 66: State organs at higher levels shall incorporate major
to benefit from projects for maintaining ecological balance and achieving comprehensive environmental protection in national
exploitation of autonomous areas into national economic and social development plans.
customary resources
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and indigenous ii) Interim Regulations on Major Administrative Decision-making Procedures (2019.9.1): Prior public consultation
knowledge, the latter to shall be conducted for decision makings in relation to the development of important plans for economic and social
include the consent of development and other aspects, the development of major public policies and measures to develop, utilize and protect
ethnic minorities. important natural and cultural resources, the implementation of major public construction projects in the administrative
region, and other major matters that have a significant impact on economic and social development, involve material
public interests, or the immediate interests of the public. Article 14: The decision-making entity shall fully solicit
opinions in the form widely available for public participation. Opinions may be solicited in such forms as symposiums,
hearings, field visits, written solicitation of opinions from the public, questionnaires, and opinion polls, etc. Article 15: If
public opinions are solicited for a matter subject to decision-making, the decision-making entity shall disclose the draft
decision and its explanation, and the mode and period of solicitation of public opinions by publicly available means,
such as government website, new media, newspapers, radio and TV, etc. The period of solicitation of public opinions
is usually not less than 30 days, and explanations shall be made when the solicitation of public opinions begins if such
period is to be shortened due to emergencies. For matters of extensive public concern, or highly technical matters, the
decision-making entity may make explanations by means of expert interview, etc. Article 16: If any matter subject to
decision-making concerns immediate interests of citizens, legal persons or other organizations, or involves a major
dispute, a public hearing may be held in accordance with any applicable laws, regulations and rules. The decision-
making entity or the organizer of the public hearing shall disclose the draft decision and its explanation in advance,
and make clear the time and venue of the public hearing. Article 29: If the public participation procedure is performed,
the decision-making entity shall submit the draft decision together with main accepted public opinions to the decision-
making authority for discussion. Article 30: When the draft decision is discussed, the meeting attendees shall give
opinions adequately, and chief administrative officer shall give a final opinion. If such final opinion differs from the
majority opinion, the reason shall be given at the meeting.
iii) The 14th Five-Year Plan of Hubei Province for High Quality Development of Ethnic Affairs (2022.1): Efforts
shall be made to achieve high-quality development of ethnic affairs in Hubei Province in the new era by accomplishing
6 key tasks, including enhancing the sense of community of the Chinese nation in an innovative way, promoting the
sense of belonging for the Chinese nation in all aspects, advancing socialist modernization for all nationalities,
promoting extensive exchanges and integration among all nationalities, improving modernization of governance of
ethnic affairs, and strengthening centralized and unified leadership of the CPC over ethnic affairs. In addition, 18
objectives of 4 categories (including promoting the sense of belonging, achieving common prosperity and
development, creating a good life for all, and advancing exchanges and integration among different nationalities), and
8 key projects (enhancing the sense of community of the Chinese nation, promoting integrated and innovative
development of green industries in ethnic minority areas, offering key support to rural revitalization, and constructing a
big data management platform for ethnic and religious affairs) are also specified.
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Element 12: Give i) Notice of the State Council on Issuing the 13th Five-year Plan for Promoting the Development of Minority Consistent
attention to groups Areas and Smaller Ethnic Minorities (SC [2016] No.79): The development of advantaged and characteristic
vulnerable to hardship industries, especially stockbreeding and traditional handicrafts, of poor ethnic minority areas and villages shall be
or discrimination, supported, and efforts shall be made to achieve rural revitalization and poverty alleviation by developing village-
including, as relevant, specific leading products and industries and making use of the Internet in poor villages. Poverty alleviation by e-
the poor, the disabled, commerce, photovoltaic, rural tourism, etc. shall be implemented to increase loc al residents’ income, and major
women and children, infrastructure and construction projects shall be carried out in ethnic minority areas to improve livelihoods. Basic social
the elderly, ethnic service mechanisms in ethnic minority areas shall be improved to provide support in old-age services, social
minorities, racial assistance, social welfare, special care and resettlement. The disaster assistance and emergency relief system for
groups, or other natural disasters shall be improved in ethnic minority areas. Urban and rural minimum living security (MLS) standards
marginalized groups; for ethnic minority areas shall be fixed rationally, and the sound development of public welfare and charity programs
and if necessary, take shall be supported.
special measures
promote equitable ii) The 14th Five-Year Plan of Hubei Province for the Development of Civil Affairs (2021.10. 29): High-quality
access to PforR development of civil affairs commensurate with economic and social development of Hubei Province shall be achieved
Program benefits. and by 2025: 1) basic living standards of the people shall be significantly improved by promoting the tiered and classified
if necessary, take social assistance system underpinned by basic livelihood assistance, social assistance for special purposes and
special measures to temporary assistance in emergencies and disasters with the support of private sectors, upgrading assistance
promote equitable management services, putting policies in place effectively to protect orphans and de facto orphans, and further
access to PforR enhancing mechanisms concerning living subsidies for the financially-challenged disabled population, nursing care
Program benefits. allowances for the severely disabled and social welfare for the elderly; and 2) the quality of basic social services shall
be improved markedly by coordinating home-based and community elderly service providers, promoting the
integration of medical and health care for the elderly, optimizing the supply structure and quality of elderly care
services, improving the social care service system, strengthening government purchase of social services, engaging
more private professional market players, improving the quality and efficiency of comprehensive marriage services,
and further standardizing adoption of children. Below are the key objectives to be achieved by 2025: the annual
growth rate of MLS in rural areas shall be no lower than that of per capita consumption expenditure of the previous
year; the MLS standard in rural areas accounts for more than 75% of that in urban areas; living subsidies are provided
to all financially-challenged disabled people; nursing care allowances are offered to all severely disabled people;
trans-provincial marriage registration is fully achieved; all vagrants and beggars with known identity information are
returned to their homes; nonprofit cremains burying (storage) facilities are available in all counties; at least 60% of
beds in elderly care institutions meet requirements for nursing care; comprehensive elderly care institutions are
accessible in 60% of townships (sub-districts); minor protection centers are available in 50% of townships (sub-
districts); the number of social service professionals stands at 80,000; volunteer service centers account for 80% of
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comprehensive community service facilities; the area of comprehensive community service facilities accessible by
every 100 residents tops 30 square meters; and the number of full-time employees of social organizations reaches
400,000.
iv) Other poverty alleviation policies: In China, poor households refer mainly to those below the minimum living
security (MLS) standard, and are classified into: a) MLS households, whose per capita annual income is below the
MLS standard. MLS standards and relevant policies are updated by the local governments every year. The MLS
standard was 7,968 yuan per capita per annum in urban areas and 5,707 yuan per capita per annum in rural areas in
Hubei Province in 2020; and b) extremely poor persons, old and disabled persons and persons under 16 years with no
ability to work, no income source, or statutory supporter, or whose statutory supporter is incapable to support.
Extremely poor persons in urban and rural areas of Hubei Province were eligible for financial support of 15,900 yuan
per person per annum and 10,764 yuan per person per annum respectively in 2020. These poor households receive
full support from the Chinese government in food, clothing, medical care, housing, children education, and basic
income which is no less than the local MLS standard. All localities shall establish files for the poor households, and
offer living and housing subsidies, free children education, interest-free loans, special occupational training, and
priority in job placement, etc.
v) Law of the People’s Republic of China on the Protection of Women’s Rights and Interests (2018
Amendment): Article 22: Women shall enjoy the same labor and social security rights as men. Article 24: Men and
women shall receive equal pay for equal work, and women shall enjoy the same remuneration rights as men. Article
26: Any employer shall protect women’s health and safety at work and shall not assign women to unsuitable jobs.
Women shall receive special protection during menstruation, pregnancy, lying-in and breastfeeding. Article 27: No
employer shall reduce female workers’ salaries or dismiss female workers or unilaterally terminate the labor
(employment) contract or service agreement with them on the basis of marriage, pregnancy, lying-in and
breastfeeding. Article 28: The state shall ensure that women are entitled to social insurance, social assistance, social
welfare and healthcare rights, and encourage and support public welfare activities for women. Article 29: The state
shall put maternity insurance system in place and establish a sound security system for women in other aspects
related to maternity.
vi) Development Outline for Chinese Women (2011-2020): The overall objective is to include gender awareness in
the legal system and public policies to promote women’s all-round development and gender harmony in keeping with
economic and social development. Women shall have equal access to basic medical and health services, with their
health being improved continuously; women shall have equal access to education, with their educational background
being enhanced consistently; women shall have equal access to economic resources and enjoy the same rights as
men to engage in economic development, with their financial status being improved markedly; women shall have the
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same rights as men in government and political affairs, with their level of political participation being increased
gradually; women shall enjoy equal access to social security, with their benefits being significantly improved; women
shall have the same rights as men in environmental decision-making and management, with the environment of
development being improved; and a sound legal framework shall be established to effectively safeguard legitimate
rights and interests of women.
Principle #6: Program E&S systems avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial disputes.
Element 13: Consider conflict risks, including distributional equity and cultural sensitivities.
Not relevant.
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Appendix 4: Stakeholder Analysis
The ESMS of the PforR Program will involve different stakeholders, including individuals,
government authorities and other agencies. Stakeholders are either affected by any activity or
affect the construction and operation of any activity. Therefore, for each activity under the Program,
stakeholders involved will be identified through a mechanism. Stakeholders under each type of
outcomes under the ESMS of the PforR Program are consistent, including affected parties,
interested parties and management authorities. Refer to Appendix 4-1 for the result of stakeholder
identification and analysis on the basis of the investigations conducted for the Program.
Appendix 4-1: Stakeholder identification and analysis
Affected Interested
Result Area Typical activities Management agencies
entities entities
RA1: 1. Establish provincial, municipal None Individuals or Water conservancy, and
Improvement and county river chief information NGOs concerned ecology and environment
in institutional platform about departments of
and innovation environmental governments at different
mechanisms quality levels
2. Develop provincial regulations, None Individuals or Central and provincial
policies and guidelines on water NGOs concerned government
environment management about departments, and water
environmental conservancy, and
quality ecology and environment
departments of
governments at different
levels
3. Promote public participation None Individuals or Water conservancy, and
under the river chief system NGOs concerned ecology and environment
about departments of
4. Improve public awareness of environmental governments at different
river and lake protection and quality levels
pollution prevention
RA2: 1. Strengthen the None Water consumers Provincial and county
Improvement integrated water water conservancy,
in environment Individuals or ecology and environment
comprehensive management system, NGOs concerned and other relevant
watershed including the about functional departments
management development of water environmental
and ecological environment quality
protection management plans
2. Develop guidelines for
river health assessment
and ecological
watershed according to
national standards
3. Implement water
allocation plans
according to national
standards
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Affected Interested
Result Area Typical activities Management agencies
entities entities
1. Identify requirements for None Water consumers Provincial and county
ecological flow, and water conservancy,
include them in the water Individuals or ecology and environment
allocation plans of NGOs concerned and other relevant
counties involved in the about functional departments
Program to ensure environmental
ecosystem restoration quality
and protection in the long
run
2. Implement sustainable Residents at Service providers 1. Competent authorities,
soil and water places such as provincial and
conservation (e.g., involved in county agriculture and
terracing of sloped land, soil and rural affairs, and
ecological slope water ecology and
protection, treatment of conservation environment
stony desertification, projects departments
forest and grass growing,
etc.) 2. County governments
3. Township governments
4. Village committees
RA3: 1. Improve the comprehensive Residents Service providers 5. Competent authorities,
Reduction of township domestic wastewater affected by such as provincial and
water pollution management and collection land county housing and
and transfer of system expropriation urban-rural
waste plastics development, and
Residents agriculture and rural
benefiting affairs departments
from
improved 6. County governments
domestic
wastewater 7. Township governments
treatment 8. Village committees
2. Prevent plastics from entering Farmers Individuals or 9. Competent authorities,
water by collecting and recycling using NGOs concerned such as provincial and
agricultural film agricultural about county agriculture and
film environmental rural affairs
quality departments
Entities
collecting Entities 10. County
and manufacturing or governments
disposing of selling agricultural
agricultural film 11. Township
film governments
12. Village
committees
3. Reduce nutrient loss through Farmers Individuals or 13. Competent
surface runoff by improving NGOs concerned authorities, such as
livestock manure management Rural about provincial and county
and utilization households environmental agriculture and rural
whose land quality affairs departments
is
expropriated Organic fertilizer 14. County
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Affected Interested
Result Area Typical activities Management agencies
entities entities
for the manufacturers governments
construction
of fecal 15. Township
residue and governments
wastewater 16. Village
recycling committees
facilities
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Appendix 5: Stakeholder Engagement
No. Date Authorities involved E&S topics
1 14 June PPMO, and provincial level ARAB, Kick-off meeting：
2022 FB, DRC, EEB, NRB, HURDB,
FGB, WRB, etc. 1. PDO, scope, result areas, DLIs, etc.
2. ESSA arrangements
2 15 June PPMO, and provincial level DRC, 3. Provincial-wide county & township domestic
2022 EEB, HURDB, WRB, and FB, etc. wastewater collection, treatment, and disposal
4. Main types of water and soil conservancy
activities the related land use pattern, influence on
common households, relevant policies, and
management measure.
5. Public participation mechanism under RCS
for environmental management
6. Urban and rural domestic solid waste
collection, transfer, and disposal
3 16 June provincial level HRUDB, ARAB, 7. Working contents of provincial-side urban
2022 and EEB domestic wastewater collection, treatment, urban
and rural domestic solid waste collection, transfer,
and disposal
8. Farmers training mechanism, policies, and
integrated plan on agri. mulch collection
9. Promoting the use of organic fertilizers and
non-point pollution sources management
10. EIA review & approval, EIA follow-up
management, pollutants discharge permits, etc.
4 17 June 1. Honghu City government 2. City-wide waste agri. mulch collection and
2022 authorities, e.g., ARAB, HURDB, recycling
UMLEB, WRB, NRB, EEB, WF,
HC, CAB, ERAB, HRSSB, RRB, 3. City-wide livestock & poultry manure
Compliant Bureau, UBLEB, etc. management
5 18 June Lichuan City government 4. Urban and rural domestic solid waste
2022 authorities, e.g., ARAB, HURDB, collection, transfer, and disposal
UMLEB, WRB, NRB, EEB, WF,
HC, CAB, ERAB, HRSSB, RRB, 5. Domestic wastewater collection and
Compliant Bureau, UBLEB, etc. treatment at county and township levels
6 19 June Enshi City government authorities, 6. Working contents of high-caliber farmers
2022 e.g., ARAB, HURDB, UMLEB, training
WRB, NRB, EEB, WF, HC, CAB,
7. LAR, land transfer, facility farmland
ERAB, HRSSB, RRB, Compliant
management and implementation
Bureau, UBLEB, etc.
8. SSRA and implementation
9. Occupational health supervision and
management
10. GRM operation, e.g., letters and visits, and
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No. Date Authorities involved E&S topics
labor arbitration, etc.
11. Ethnic minority development
12. Support for vulnerable groups, and
management and monitoring of population lifted out
of poverty
13. Protection of women’s rights and interests
14. Cultural relic protection
7 20 June Provincial DNR 15. Delineation and supervision of ecological
2022 protection red lines
8 21 June Provincial DF 16. Delineation and supervision of natural
2022 reserves
17. Water & soil conservation forest management
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Appendix 6: Feedback of Public Consultation on the ESSA
No. Issue Opinion Participants Report revision
Version of policies
1 Measures for the Administration of To be updated Hubei Provincial Updated
the Pre-examination on the Use of NRB
Land for Construction Projects as
amended in January 2017 should
be applicable
2 Regulations for the Implementation To be updated Hubei Provincial Updated
of the Land Administration Law as NRB
amended in September 2021
should be applicable
Policy analysis and understanding
3 Information about domestic refuse To be updated in line Jianshi County Updated
sorting and resource utilization in with the written proposal UMLEB
Jianshi County is incomplete
4 The phrase "livestock farming, To be amended as Hubei Provincial Updated
wastewater treatment, and "industries like livestock HC
sanitation management are defined farming and wastewater
as occupational hazards and risks" treatment are
is not accurate considered to be
associated with
moderate risks"
Investigation and analysis of system operation
5 The frequency of law enforcement To be amended as "they Hubei Provincial Updated
and inspection by the health are not frequently HC
authority in relation to enterprises inspected"
exposed to moderate occupational
hazards is not accurately defined.
They are indeed inspected, but not
inspected frequently.
6 Information about "occupational To provide additional Hubei Provincial Updated
safety and health management" information like "work HC
mechanism is incomplete safety and health
facilities of construction
projects should be
designed, constructed
and put into operation
along with main parts of
such projects, and
relevant documents and
files should be created
and maintained"
7 The phrase "the separate drainage To be amended as "the Hubei Provincial Updated
system is constructed together with separate drainage HURDB
rain and sewage diversion of system is constructed,
completed combined sewer and rain and sewage
diversion of completed
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No. Issue Opinion Participants Report revision
systems" should be adjusted combined sewer
systems is to be
completed gradually"
8 Additional information about fecal To provide additional Badong County Updated
residue and wastewater information like "for ARAB
management in Badong County example, the veterinary
should be provided station of the Bureau of
Agriculture and Rural
Affairs of Badong
County requires that all
new livestock farms
should consider the
construction of fecal
residue and wastewater
treatment facilities at the
preparatory stage, and
that all existing livestock
farms should provide
training and technical
guidance for technical
personnel on a regular
basis to improve fecal
residue and wastewater
management"
Organizational setup and responsibilities
9 The expression "labor The labor administration Hubei Provincial Updated
administration authorities of authorities should be HRSSB
cities/counties" is inaccurate replaced by the "human
resources and social
security authorities"
10 Job duties and responsibilities of To be amended Hubei Provincial Updated
the provincial, municipal, and according to the written HC
county health authorities are not proposal
accurately defined
Action plans
11 The term "occupational health To be amended as Hubei Provincial Updated
management training" in relation to "occupational health HC
enterprises and facilities involved in training"
the Program is not appropriate
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Appendix 7: Field Visit Records
1. High-Calibre farmers training conducted on Nov 11-17, 2021 in Daijia Town, Honghu City, in terms of rice pest
control technology, test-based formula fertilization, agricultural environmental protection, etc.
2. Agri. Mulch collected by pepper planter at Huangnipo village, Tuanbao Town, Lichuan City; Test-based
formula fertilisation card provided by Lichuan BARA to planters
3. Winn’s pig farming and manure utilization facilities, 4. public participation in soil and water conservation
examed and endorsed by BNR, BARA, township advocated by Enshi BWR
government of Honghu City
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5. Agricultural land use endorsement form for livestock & 6. Registration form for physical quantity survey on land
poultry manure utilization facility; Pre-examination and acquisition for the construction of urban WWTPs in Enshi
approval on land occupation for solid waste transfer city seat in 2018
station at Tuanbao Town
8. A
fem
ale
clea
n-
kee
per,
hire
d by
wast
e-to-
ener
gy
incin
erators of Honghu City from nearby community
7. Land use contract of Xidu-Chuwang livestock farming
cooperative for manure utilization facilities
9. Farmland before and after rocky desertification treatment in Lichuan City
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10. Yuquan river sub-catchment rehabilitation in Qiyao village, Wangying Town, Lichuan City
11. classified solid waste trashes installed in a rural 12. deep buried garbage can – a collection station
village, Honghu City serving for township
13. Yanwo WWTP in Honghu City seat (1000m3/d) 14. Waste-to-energy incinerator, located at Wulin Town,
Honghu City (800t/d)
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15. Biological fermentation bed of Huaishan cattle farm, 16. Manure composting of Huaishan cattle farm,
Lichuan City Lichuan City
17. Domestic solid waste sanitary landfill, serving for 18. Domestic solid waste collection room, serving for an
Lichuan City seat urban residential quarter in Enshi City seat
19. Xincheng transfer station (compressed, 50t/d) in 20. Mulch film collection and processing factory, Enshi
Enshi City City
Appendix 8: Special Survey on Program Activities in Ethnic Minority Areas
1. Ethnic minority areas involved in the Program
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The Program involves Enshi Tujia and Miao Autonomous Prefecture, Hubei's only autonomous
prefecture with 28 ethnic minorities, including Tujia, Miao, Dong, Bai, Moggol and Hui nationalities.
According to the seventh national census in 2020, the prefecture has 3,456,100 permanent
residents of minority groups including Tujia (about 45%) and Miao (5.5%) nationalities and other
smaller minority groups. Lichuan City is a county-level city with 472,770 minority residents, the
highest in Enshi Tujia and Miao Autonomous Prefecture, accounting for about 63% of the city's
total permanent population. It has 11 minority groups including Tujia and Miao nationalities.
2. Identification of Program activities in ethnic minority areas
Program activities in ethnic minority areas follow the bottom-up approach. To be more specific, the
village concerned submits a project proposal to the township government, and then the township
government confirms whether the proposed project is needed through investigations, and files an
application with relevant county departments (including the county ethnic and religious affairs
bureau) for the implementation of the confirmed project and funds required. After that, municipal
departments receiving the application conducts field investigations, reviews the project
implementation plan, discusses the plan on the management meeting, and includes the project in
the database of planned projects of Lichuan City if it's considered acceptable. In the end, funds are
secured for the implementation of the accepted project. When implementing a specific project,
investigations and consultations with public officers and common residents in ethnic minority
villages on E&S impacts possibly arising from such project are conducted, with reasonable
suggestions being considered in the project design.
3. Basic procedures of land expropriation
Before the examination of expropriation of any collective land or land for agricultural facilities, the
field investigation, survey and demarcation are conducted by relevant departments in accordance
with the laws and regulations to determine the boundary lines of the Program in question. In the
meantime, the DMS is carried out to get various impacts caused by land expropriation registered,
with the DMS form being signed and confirmed by the villagers. For any Program activity requiring
permanent land expropriation, the DMS result and the compensation plan for land expropriation
should be disclosed in the affected communities for at least 30 days, and the DMS result and the
draft agreement should be disclosed in the affected communities for at least 10 days. No land
expropriation/land use agreement is entered into unless no objection is raised at the end of the
disclosure period. After the agreements are signed and relevant land approval procedures are
completed, the approval authority requires in the approval documents that the land user should
provide adequate compensation for any losses arising from land expropriation in line with the
compensation plan for land expropriation or other similar basis of compensation. Before any land
unused is returned, land restoration is conducted, and the loss of soil fertility is compensated as
required.
4. Program benefits to ethnic minority residents
Facilities constructed in the Program are expected to benefit the local minority residents. For
example, the soil and water conservation carried out in the Program will significantly improve local
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ecological environment, quality of arable land, and income of local residents. The water and soil
conservation in small watersheds will also greatly increase the tourism attractiveness of ethnic
minority villages, better tap the economic potential of local traditional customs, cultures and
specialties, and increase financial income of local residents.
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Improved quality of arable land and increased income as a result of treatment of stony
desertification
For example, according to the investigation, the treatment of stony desertification, part of water
and soil conservation efforts carried out Liziba Village, Sanchaji Town, Enshi City, will improve the
quality of rural arable land, particularly of land covered with stones and rocks in areas harassed by
severe stony desertification. It enables the replacement of humans with machines in farming,
improving farming efficiency and reducing physical burden on the seniors. Efforts to improve the
land quality are made free of charge upon the consent of concerned farmers without expropriation
of land. As shown in the face-to-face consultation, the farmers in ethnic minority areas have seen
significant improved quality and increased amount of arable land. During the treatment, stones on
a vast expanse of land were broken and the land was turned into arable land before being returned
to its original owner. Refer to Figure 9 of Appendix 7 for information about the land before and after
the treatment of stony desertification in Liziba Village. It shows that only corns were grown on land
covered with stones before the treatment, and a stretch of land became suitable for the growth of
multiple crops after the treatment.
Rural prosperity and improved rural environment as a result of small watershed
management
In Yuquan River, Qiyue Village, Wangying Town, Lichuan City, landslide and floods that were
frequent in the past have been eliminated after efforts like the repair and improvement of raised
paths through fields, small reservoirs, and riverbanks were made. The advantages of the village in
tourism, special food culture, and unique fruits were exploited to the full, attracting a large number
of tourists and benefiting local residents as a result. No land expropriation was incurred, and
reinforcement and repair were conducted within the scope of original river channel. With financial
support from the government, ethnic minority residents were allowed to get jobs flexibly and
receive remuneration during the Program implementation. Refer to Figure 10 of Appendix 7 for the
picture of the small watershed of Yuquan River, Qiyue Village. It has become a tourist attraction
rather than a polluted area in the village.
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