Environmental and Social Monitoring Report

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Environmental and Social Monitoring Report
Environmental and Social Monitoring Report

Annual Report
February 2021

Reporting period: March 2020 – December 2020

Uzbekistan: Livestock Value Chain Development
Project

Prepared by Umida Solieva for the Agency for Implementation of Projects in the Field of Agro-
industry and Food Security and Asian Development Bank.

This environmental and social monitoring report is a document of the borrower. The views
expressed in this document do not necessarily reflect the views of ADB's Board of Directors,
Management or staff and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
Environmental and Social Monitoring Report
Table of Contents
List of Tables and Figures......................................................................................................................... 2
Abbreviations .............................................................................................................................................. 2
Part I: Introduction ................................................................................................................................... 3
   1.1.       Short description of the project ........................................................................................... 3
   1.2.       Summary of activities and project progress during the previous 12 months ......... 4
   1.3. A summary of the implementation of the ESMS in each PFI, and the
   consolidation of the annual reports on the environmental and social performance of
   the PFIs ................................................................................................................................................... 6
   1.4. Project organization and environmental management team, including
   organizational relationships with PFIs, sub-borrowers etc. ..................................................... 7
Part II: Environmental issues .............................................................................................................. 10
   2.1. Summarize the previous 12 months of environmental issues faced by the PFIs,
   and faced by the sub-borrowers. ................................................................................................... 10
   2.2. Provide explanations of any instances in which environmental standards or
   guidelines were exceeded or environmental incidences happened .................................... 10
   2.3. Recommendations are required to show how any exceedances or will be
   prevented in the future. .................................................................................................................... 11
Part III: Compliance with ADB’s Social Protection Requirements and ADB’s Prohibited
Investment Activities List .................................................................................................................... 11
   3.1.       Provide assessment on these two sets of requirements ............................................ 11
   3.2. Provide summary of actions taken to ensure compliance or corrective actions
   taken in case of non-compliance ................................................................................................... 11
Part IV: ESMS operations (for PFIs which are financing B-category sub-projects) ............. 12
   4.1.       Site inspections and audits – to summarize the number and type of site visits .. 12
   4.2. Noncompliance case – to summarize the details, including the number of notices
   given out by the PFIs or by the local government to the sub-borrowers, how and how
   many issues covered ........................................................................................................................ 12
   4.3.       Corrective action plans – to report on timeliness of preparation and completion
              12
   4.4. Consultation and complaints – to report on any consultations undertaken and
   list any complaints received and how they were handled or resolved................................ 12
Part V: Conclusion and action plan .................................................................................................. 12
   5.1. Conclusion ................................................................................................................................... 13
   5.2.       Summary of actions taken during the previous reporting period ............................. 14
   5.3.       Action plan for the next reporting period ........................................................................ 14

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Annex 1. Photographs ............................................................................................................................. 15
Annex 2. Example of packages of environmental and social documents submitted by sub-
borrowers ................................................................................................................................................... 17

List of Tables and Figures
Table 1. Number of sub-projects of PFIs by lines ................................................................................. 4
Table 2. Share of lines in PFIs which were financed from the project funds, in percentage .......... 5
Table 3. Summary of sub-projects by PFIs, their environmental categorization and sub-loan
amount for the previous 12 months ......................................................................................................... 5
Table 4. Issues in PFIs on ESMS and actions required ..................................................................... 14

Figure 1. Project Organizational Chat (Source: Project Administration Mannual, 2019) ................ 8
Figure 2. Project’s environmental management team .......................................................................... 9

                                                               Abbreviations
 ADB                              Asian Development Bank
 EIS                              Environmental Impact Statement
 EMP                              Environmental Management Plan
 ESMR                             Environmental and Social Monitoring reports
 ESMS                             Environmental and Social Management Systems
 FCL                              Foreign Currency Loans
 IR                               Involuntary Resettlement
 JSCB                             Joint Stock Commercial Bank
 JSCMB                            Joint Stock Commercial Mortgage Bank
 LVCDP                            Livestock Value Chain Development Project
 PFI                              Participating Financial Institution
 PMO                              Project management office
 SCEEP                            State Committee for Ecology and Environmental Protection
 SEE                              State Environmental Expertise
 TA                               Technical assistance
 USD                              United States Dollar
 UzAIFSA                          Agroindustry and Food Security Agency

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                                   Part I: Introduction
    1.1. Short description of the project
1.      The livestock sector is crucial to national food security and its growth contributes
significantly to poverty reduction and development. The aim of Livestock Value Chain
Development Project (LVCDP) is to increase livestock sector, diversify animal products, improve
the quality and also their safety of both animals and animal products. As the livestock includes
wide range of animals including cattle, sheep, goats, horses, birds and bees, their sustenance
requires large amount of feed products and also careful care. Therefore, LVCDP includes
financing of entire livestock value chain, including not only production/processing of animal
products but also producing of animal feed and expansion/improvement of veterinary service
provision.
2.      The proposed project will support the development of livestock value chains by increasing
outreach of participating financial institutions (PFIs) to livestock farmers and entrepreneurs
throughout the country. The project impact will be contribution of the agriculture sector to inclusive
economic growth, income and employment increased. The outcome will be production and
marketing of livestock products increased. The project has two outputs as outlined below:

    (i) Access to finance in the livestock subsector increased. The project will provide long-
        term funds to PFIs to extend subloans to eligible subborrowers for capital investment.
        Investment subprojects will include but not be limited to livestock production, processing,
        input supply, and service delivery. The project will improve access to market-based bank
        finance for producers, processing enterprises, input suppliers and service providers in
        the livestock value chain. As such, it will help increase livestock productivity and
        sustainability, processing capacity and utilization, and marketing of inputs and livestock
        products.

     (ii) Support services to the livestock subsector improved. The project will facilitate the
          development of private sector veterinary practices to improve access to clinical
          veterinary services and animal management and health advice, including effective use
          of anti- microbial drugs.

3.      Soft components of the LVCDP aim to build the capacity of key stakeholders including PFI
and veterinary service providers. For PFIs representatives, capacity building in livestock-related
credit policy, product development, procedures, outreach strategy, and in the identification,
appraisal, and management of livestock sector lending are considered, while for veterinary
service providers, in identification, monitoring, and controlling the risks related to livestock
maintenance.
4.      Six national PFIs have been selected as eligible financial entities registered and
complained with Uzbek laws and regulation. All selected PFIs have an approved Environmental
and Social Policy and have adopted the Procedure for Environmental and Social Management
System (ESMS) for Livestock Development Project.
5.      The project implementation period is 2020 – 2025.

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        1.2. Summary of activities and project progress during the previous 12
            months
(number of sub-loans, types of sub-loans’ activities, results of categorization, verification by
Agroindustry and Food Security Agency (UzAIFSA) and by Asian Development Bank (ADB) (if
any), site monitoring and audit by PFIs and by UzAIFSA, implementation of reporting
requirements).

6.     The LVCDP implementation has been started in March 2020, and within 10 months, 373
sub-projects were financed. During the implementation of the LVCDP, the sub-projects were
divided into 12 lines. Namely:
     • stock-breeding            • horse breeding
     • small ruminants           • bee keeping
     • dairy processing          • fish farming
     • fodder production         • agricultural machinery
     • rabbit breeding           • meat processing
     • poultry                   • building of a farm

7.      The number of sub-projects and their delineation into lines in numbers and percentages
are presented in Table 1 and Table 2. The foremost share of the project was allocated for
purchasing cattle (262 sub-projects), while processing of animal products, purchasing agricultural
machineries and building of farm were the least implemented projects (total 7 sub-projects).
However, many sub-projects include not only one line, but several at once. For instance, sub-
project plans to import cattle for milk production and processing of dairy products. In this case,
main line was taken into account during delineation into 12 lines. Therefore, the actual number
for processing are more than presented in the table.

Table 1. Number of sub-projects of PFIs by lines

                                                                                                  Number of Subprojects
                                                                                                                                                                                  Agricultural machinery
                                                                                    Fodder production

                                                                                                                                                                                                                             Building of a farm
                                                                 Dairy processing

                                                                                                                                                                                                           Meat processing
                                               Small ruminants

                                                                                                        Rabbit breeding

                                                                                                                                    Horse breeding

                                                                                                                                                     Bee keeping

                                                                                                                                                                   Fish farming

                                                                                                                                                                                        and other

                                                                                                                                                                                                                                                  Total
    №
                                                                                                                          Poultry
                                      Cattle

                   PFIs

    1    JSCB Xalq Bank               167      10                 1                 2                                                3                                                                                        2                   185
    2    JSCB Qishloq Qurilish Bank   27       6                                    3                                     2                           4             1                   1                                                         44
    3    JSCB Turonbank               29       14                 1                 1                                     2                                                                                                                       47
    4    JSCB Uzpromstroybank          2                                            3                                     16                                                            1                                                         22
    5    JSCMB Ipoteka bank            2                                            1                                                                              11                                       1                                     15
    6    JSCB Microcreditbank         35                                            1                   12                7                                        5                                                                              60
                Total                 262      30                 2                 11                  12                27         3                4            17                   2                   1                 2                   373

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Table 2. Share of lines in PFIs which were financed from the project funds, in percentage

                                                                                                                         Portfolio (%)

                                                                                                                                                                                               Agricultural machinery
                                                                                   Fodder production

                                                                                                                                                                                                                                            Building of a farm
                                                               Dairy processing

                                                                                                                                                                                                                        Meat processing
                                             Small ruminants

                                                                                                       Rabbit breeding

                                                                                                                                         Horse breeding

                                                                                                                                                                                                                                                                 Total (%)
                                                                                                                                                           Bee keeping

                                                                                                                                                                          Fish farming
    №

                                                                                                                            Poultry
                                Cattle
              PFIs

    1   JSCB Xalq Bank      90.3            5.4                0.5                 1.1                  0                   0           1.6                 0              0                     0                       0                 1.1                   100
        JSCB Qishloq
    2                       61.4           13.6                0.0                 6.8                  0                  4.5            0               9.1            2.3               2.3                           0                   0                   100
        Qurilish Bank
    3   JSCB Turonbank      61.7           29.8                2.1                 2.1                  0                  4.3            0                 0              0                     0                       0                   0                   100
        JSCB
    4                           9.1         0.0                 0                 13.6                  0                  72.7           0                 0              0               4.5                           0                   0                   100
        Uzpromstroybank
        JSCMB Ipoteka                                                                                                                                                                                                   6.
    5                       13.3              0                 0                  6.7                  0                   0             0                 0            73.3                    0                                           0                   100
        bank                                                                                                                                                                                                            7
        JSCB
    6                       58.3            0.0                 0                  1.7                 20                  11.7           0                 0            8.3                     0                       0                   0                   100
        Microcreditbank

8.       During this period, environmental and social suitability of every sub-project to both national
and ADB requirements were checked by PFIs’ specialists on environment and social aspects.
First three sub-projects from each PFI have been reviewed by TA Environmental Consultant on
compliance with ESMS requirements. Further, an assessment on compliance with relevant
national environmental and social legislation and ESMS requirements have been conducted by
PFIs themselves.
9.       It needs to be mentioned that all sub-projects funded during the reporting period were
defined as B and C category (on environment) and C category (on involuntary resettlement) in
accordance with ADB categorization. Thus, 134 sub-projects were classified as “B” and 239 sub-
projects were classified as “C” on environment and all 373 sub-projects as category “C” on
resettlement (Table 3).

Table 3. Summary of sub-projects by PFIs, their environmental categorization and sub-loan amount for
the previous 12 months

    №           PFIs                      ESMS                                    Number of sub-loans                                                     Number of sub-                                                  Sub-loan
                                         approval                                  by environmental                                                           loans by                                                    amount
                                           date                                       categories                                                            involuntary                                                 (million USD
                                                                                                                                                           resettlement                                                       $)
                                                                                                                                                             categories
                                                                                  B                          C                        Total                C        Total
    1   JSCB Xalq Bank                   23.10.2019                               35                        150                        185                185        185                                                                  45.305
    2   JSCB Qishloq Qurilish            11.10.2019                               19                        25                         44                  44        44                                                                    8.890
        Bank
    3   JSCB Turonbank                   07.10.2019                               1                              46                   47                   47                            47                                                9.568
    4   JSCB Uzpromstroybank             20.09.2019                               21                             1                    22                   22                            22                                                6.371
    5   JSCMB Ipoteka bank               08.11.2019                               15                              -                   15                   15                            15                                                4.539
    6   JSCB Microcreditbank             23.09.2019                               43                             17                   60                   60                            60                                               15.648
        Total                                                                                                                         373                                                373                                              90.322

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10.     The sub-projects were classified as category “C” if it was likely to have minimal or no
adverse environmental impacts. Such sub-projects were the ones which involved only purchasing
animals for their existing farms. The sub-projects were classified as category “B” if its potential
adverse environmental impacts are site-specific. Here, such sub-projects mainly included the
construction and / or installation of static equipment for the development of the livestock sector.
For such sub-projects EMPs have been developed based on template and typical impacts
provided in ESMS (Appendix 3).
11.     After sub-loans approval and funds disbursement, PFIs’ Environmental Coordinators
conducted monitoring of EMP implementation during site visits. Results of monitoring were
registered in recommended Site Inspection Monitoring Checklist (ESMS, Attachment 5). It should
be noted that site visits conducted by PFIs and PMO Environmental Specialist were limited due
to COVID-19 situation during reporting period.
12.     An Annual Environmental and Social Monitoring reports (ESMR) contained whole
information about financed sub-projects have been presented by PFIs to PMO for further
aggregation in general ESMR.

1.3. A summary of the implementation of the ESMS in each PFI, and the
    consolidation of the annual reports on the environmental and social
    performance of the PFIs

13.      During LVCDP implementation, all PFIs followed the guidelines for application of ESMS
developed by ADB consultant. The ESMS Procedure was discussed with PFIs and approved by
management of all PFIs.
14.      The ESMS of LVCDP includes several steps in order to determine the suitability of the
activities for financing from environmental and social aspects. Initially, in the screening and
selection phase, a desk review was carried out by PFIs, based on the provided sub-projects’
related documents.
15.      In the screening and selection phase, primarily, there was paid attention to the aim of the
sub-projects’ activities, in order to identify if they did not belong to the ADB’s Prohibited Investment
Activities List according to Safeguards Policy Statement (2009) or list of ineligible loans, regulated
by Central Bank of Uzbekistan (Appendixes 1-2a of ESMS).
16.      The sub-projects related to the purchasing of animals were requested to reveal the scope
of the sub-project as the limits for purchasing of animals and processing of animal products were
provided in ESMS Arrangements report of the project. The sub-projects are not allowed to exceed
the limits: for cattle purchase (500 heads); and for poultry purchase (100 thousand heads); and
processing (slaughter - 10 thousand cattle and 10 million poultry per year).
17.      As the next step of screening, category of the sub-project was defined in accordance with
Appendix 2b and Appendix 3. As it was mentioned above, only category B and C (on environment)
were defined as eligible for funding.
18.      Screening of sub-projects on compliance with social requirements of ESMS (Appendix 4)
was next stage of sub-project selection. More detailed description of the process is described in
Part 3 of the report.

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19.       During the screening process, the PFIs requested sub-burrowers to submit package of
documents necessary to confirm environmental and social compliance of potential sub-projects
with ESMS. Depending on type of funding sub-projects, different packages of documents were
collected. Thus, for newly constructed farms sub-borrowers provided Positive Conclusion of
State Environmental Expertise under State Committee on Ecology and Environment Protection
(SCEEP).
20.       For operating farms valid environmental standards (permission for waste disposal and
sewage water disposal), agreements with relevant agency were requested from sub-borrowers.
21.       To ensure compliance with national standards on buffer zone the google coordinates of
the sub-project location are required to check a distance in accordance with Sanitarian Rules and
Norms (SanPiN) of Uzbekistan No.0350-17 "Sanitary rules and regulations for the protection of
atmospheric air". Correspondingly, agreements (non-objections) from residents whose houses
are located nearby to the planned sub-project location were collected to eliminate any possible
incidents / litigation / complaints related with noise, vibrant and/or smell. In majority cases, these
people were workers of the relevant farms.
22.       The monitoring for the sub-projects with category B was organized by the PFIs to check if
each sub-borrower met the requirements of the ESMS in accordance with the national regulations
and requirements of ADB.
23.       Based on the yearly monitoring activities, each PFI submitted annual Social-
Environmental Annual Report to UzAIFSA, listing the sub-projects they financed, their categories
and lines. Most importantly, they answered to several questions related to the incidents and/or
difficulties they faced during the implementation of ESMS and suggestions for improving the future
cases.
24.       Although, most of the banks indicated that they did not face any difficulties for
implementation of ESMS of the project, there were some suggestions. Particularly, PFI “Ipoteka
bank” JSCMB expressed the difficulties in following different ESMS requirements and filling
various check lists for every sub-project financed by International Financial Institutions, including
ADB. Consequently, they suggested to develop one universal framework and form, which could
be applicable for all financed projects.

    1.4. Project organization and environmental management team, including
         organizational relationships with PFIs, sub-borrowers etc.

25.    The Agency for Implementation of Projects in the Field of Agro-industry and Food Security
(AIFSA) is the executing agency. A project management office (PMO) is set up under the existing
organization of AIFSA. The PMO is provided with staff and operational costs and is responsible
for monitoring the project implementation, including training, capacity development, and providing
technical support to PFIs. The PMO is responsible for (i) reviewing and monitoring subproject
implementation, (ii) overseeing project financial audits, and (iii) implementing veterinary services
capacity development activities. Each PFI has established a project implementation unit (PIU)
under its existing structure to oversee the implementation of the credit line activities at the
respective PFI. The project organization chart is in Figure 1.

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         Figure 1. Project Organizational Chat (Source: Project Administration Mannual, 2019)

26.     Project environmental team is presented by safeguards specialist in PMO, safeguards
specialist in PFIs, and TRTA environmental consultant. As a rule, a department which deals with
Foreign Currency Loans (FCL) leads ESMS implementation. Most of PFIs appointed officers from
FCL Departments responsible for addressing ESMS requirements during sub-projects
preparation and their implementation (ESMS Coordinators).

27.    Besides this, two banks recently organized new departments for addressing ESMS
requirements of the projects. Specifically, “Ipoteka Bank” JSCMB developed the Department of
Environmental and Social Risk Management, while “Uzpromstroybank” JSCB arranged their
department called «Green Banking». Environmental specialist of UzAIFSA as the representative
of executing organization, worked with the head of these departments and ESMS Coordinators
on ESMS implementation progress. The Project environmental team is also supported by ADB
TA environmental consultant who is involved in the project on the intermittent base.
Organizational chat of environmental management team is provided in Figure 2.

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Environmental and Social Monitoring Report
UzAIFSA                                     ADB
           TA ADB                                     PMO                           Environmental Specialist
          Consultant

          MCB                   QQB                                                     UPSB                                           IpotekaBank
                                                            TuronBank                                       XalqBank
         ESMS                  ESMS                                                 Green Banking                                      Env.Soc.Risk
                                                              ESMS                                           ESMS
       Coordinator           Coordinator                                                Dep.                                            Department
                                                            Coordinator                                    Coordinator
                                                                                   ESMS Coordinator                                  ESMS Coordinator

Branch # 1       Branch #    Branch        Branch        Branch      Branch #      Branch      Branch #    Branch        Branch #      Branch         Branch #
Responsible         2…        # 1…          # 2…          # 1…          2…          # 1…          2…        # 1…            2…          # 1…             2…
officer (RO)      (RO) for   (RO) for      (RO) for      (RO) for     (RO) for      (RO)        (RO) for   (RO) for       (RO) for     (RO) for        (RO) for
 for ESMS          ESMS       ESMS          ESMS          ESMS         ESMS          for         ESMS       ESMS           ESMS         ESMS            ESMS

                                                      Figure 2. Project’s environmental management team

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10

28.     During the sub-project screening phase, the branch representatives of PFIs presented
package of documents to responsible department on ESMS of related PFI. Those departments
regularly sent the documents for review to environmental specialist of UzAIFSA. The specialist
revised the documents, the sub-projects’ categorization and consulted the PFIs’ ESMS specialist
on additional actions if needed. Therefore, interaction of UzAIFSA with PFIs for the
implementation of the ESMS was constantly carried out.

Part II: Environmental issues
2.1.   Summarize the previous 12 months of environmental issues faced by the
       PFIs, and faced by the sub-borrowers.
29.      During the project implementation period, within 10 months, PFIs did not face to significant
environmental problems for each sub-project.
30.      The environmental impacts of most sub-projects included the general impacts of animal
husbandry such as manure, wastes (including storage and distribution of agricultural waste),
wastewater, water use, air emissions and odor. Even though the national environmental norms
were not exceeded by any sub-project, contracts were signed with the relevant organizations for
water use and waste management to the mitigate their consequences. In addition, an
environmental management plan (EMP) was developed individually for every sub-project included
construction and rehabilitation works.
31.      EMP was required to address the potential impacts and risks identified through the
assessment and consultation of the sub-projects. The EMP of every sub-project included what
needs to be managed, in which project phase the management needs to take place, the frequency
of required management actions and also indicate the responsible person for arrangements’
implementation. According to this document, the PFIs monitored the EMP implementation of each
sub-project. As the project LVCDP is focused on livestock sector, waste management (especially
manure and wastewater discharge), occupational health and safety, work with the public,
Grievance Redress Mechanism (GRM) Functioning were the main objects for the management
of sub-projects. The directors (owners) of the sub-projects were always indicated as the
responsible person for arrangements of the management.
32.      Some issues have been faced at the beginning of the LVCDP implementation, and they
were related to compliance with sanitarian (buffer) zones for livestock subjects. In three cases,
the proposing for funding livestock farms of sub-borrower were located closer than indicated in
(SanPiN) of Uzbekistan No.0350-17. However, because proposing for funding livestock farms use
advanced technology, the Government agency responsible for establishing buffer zones provided
their official non-objections.
33.      In addition, as described above, non-objection from the local community was received as
well.

2.2.   Provide explanations of any instances in which environmental standards or
       guidelines were exceeded or environmental incidences happened

34.    Prior to the implementation of any type of activity in the field of livestock production, all
beneficiaries of subprojects were aware of environmental and social safeguards requirements.
During the implementation period of 2020, problems related to noise and vibration, water and air

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quality were not been identified. There were no any accidents or emergency situation. Complaints
from nearby residential populations were not received. PFIs also checked compliance of the
monitored sub-projects with environmental requirements.

2.3.   Recommendations are required to show how any exceedances or will be
       prevented in the future.
35.    There were no any exceedances in the frame of established norms for the current
subprojects, because according to the results of the state environmental review all subprojects
received a positive approval of the SEE.

Part III: Compliance with ADB’s Social Protection Requirements and
ADB’s Prohibited Investment Activities List
   3.1.    Provide assessment on these two sets of requirements

36.      ADB's requirements for social protection were met. It can be seen from the categorization
of the sub-projects on Involuntary resettlement (IR). Specifically, the screening for IR safeguard
included prohibited subproject activities including expropriation, physical and economic
displacement, loss of income sources, displacement of renters or lease holders, state land
involving informal settlers, and restrictions on legally designated parks or protected areas.
According to the requirements of the project, the sub-projects must be categorized as C in IR.
Also, country does not have indigenous people communities as defined in ADB’s SPS making it
categorized as C for IP safeguards.
37.      In order to categorize the sub-projects as C on IR (Appendix 4 of ESMS), the land
acquisition document must be submitted to prove that the land for the subproject activity has not
been acquired through expropriation. The document for each sub-project was obtained from the
district khokimiyats (administration) through application proving that the land was allocated by
khokim (head of district administration) and its decision to permit to organize the sub-project
activity. Therefore, the loan application package for sub-project organization was required to
contain the khokimiyat’s prior approval of land allocation, without which a loan application was
not considered complete and was not considered for a loan.
38.      According to the list of prohibited types of investment activities, a preliminary screening
was carried out for each sub-project. There, an attention was paid to the aim of the sub-project
activities, in order to identify if they did not belong to the ADB’s Prohibited Investment Activities
List according to Safeguards Policy Statement (2009). None of the sub-project included the
activities enlisted as prohibited by ADB.

   3.2.    Provide summary of actions taken to ensure compliance or corrective
           actions taken in case of non-compliance
39.     All requirements are implemented based on the documents of the ESMS. Implementation
of corrective actions was not required.
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Part IV: ESMS operations (for PFIs which are financing B-category
sub-projects)

      4.1.   Site inspections and audits – to summarize the number and type of site
             visits
40.      Currently, out of 134 financed B-category subprojects, all were inspected by PFIs’ branch
representatives except one from JSCMB Ipoteka Bank. The monitoring was not carried out there
since the sub-project was signed on 31.12.2020.
41.      The responsible departments for ESMS implementation of PFIs which were described in
Project organization and environmental management team of Part 1.4 of this report were not able
to organize field visits to sub-projects due to the COVID-2019 pandemic situation in country.
42.      However, the branch representatives of every PFIs organized visits to every sub-project
in spite of their categorization as according to the regulations of PFIs, the field visits are organized
in order to review the site and property appraisal. Simultaneously, the environmental conditions
of the site were inspected, and PFIs’ specialists provide advices on organization of environmental
measures according to the EMPs. For site visits PFIs specialists used a format of a Site Inspection
Monitoring checklist (ESMS, Appendix 5)
43.      The monitoring visits by responsible departments of PFIs are planned to take place in
2021.

      4.2.   Noncompliance case – to summarize the details, including the number
             of notices given out by the PFIs or by the local government to the sub-
             borrowers, how and how many issues covered
44.      No cases of non-fulfillment of requirements have been identified.

      4.3.   Corrective action plans – to report on timeliness of preparation and
             completion

45.      No corrective action plans were required

      4.4.   Consultation and complaints – to report on any consultations
             undertaken and list any complaints received and how they were handled
             or resolved

46.      Consultations were conducted as required. No complaints were received.

Part V: Conclusion and action plan

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  5.1. Conclusion
47.       The current Annual Safeguard Monitoring Report was developed on the basis of PFIs’
annual reports. The Social-Environmental Annual Report of PFIs of the project provided
information on the ESMS implementation of the project. During the implementation of the project,
373 sub-projects were financed during 10 months.
48.       According to the ADB’s three categorization, the sub-projects were defined as followings:
     • Environmental categorization: 134 sub-projects were classified as “B” and 239 sub-
          projects were classified as “C”;
     • Involuntary Resettlement categorization: all sub-projects were classified as C;
     • Indigenous People categorization: all sub-projects were classified as C as Uzbekistan
          does not have indigenous people communities as defined in ADB’s SPS.
49.       According to the ESMS arrangements of LVCDP, each sub-project was carried out by
SEE on the basis of the developed draft EIS and received positive Environmental Conclusions of
the SCEEP. An environmental management plan (EMP) was developed individually for every sub-
project to address the potential impacts and risks identified through the assessment of the sub-
projects.
50.       During the project implementation period, within 10 months, PFIs did not face any
significant environmental problems for each sub-project. It was identified through the monitoring
activities which were organized by PFIs. By the end of the year, all sub-projects were inspected
by PFIs’ branch representatives except one as the sub-project financing was approved on the last
day of reporting year. During the visits, the environmental conditions of the sites of sub-projects
were inspected, and PFIs’ specialists provided advices on organization of environmental
measures according to the EMPs. However, responsible departments for ESMS implementation
of PFIs which are located in the head of every PFIs were not able to organize field visits to sub-
project fields due to the restrictive measures of COVID-19. During the monitoring visits, the
environmental conditions of the site and their correspondence to EMP were inspected. Moreover,
PFIs’ specialists provide advices on organization of environmental measures according to the
EMPs. The field visits by responsible departments for ESMS arrangement implementation will be
organized in 2021 and the results will reveal the correlation of activity organization according to
the EMP.
51.       In terms of social impact, the project helped create 3,854 new jobs for the local population.
In particular, it is expected that 2,518 men and 1,336 women will be involved in the activities of
the sub-projects once they are fully operational.
52.       Presented reports from 6 PFIs provided information on the effectiveness of environmental
and social measures for 2020. It should also be noted that the responsible staff of PFIs had some
difficulties while preparing the annual reports. The reason for the difficulty was explained with the
frequent change of the responsible staff for ESMS in the PFIs. Here, assistance for PFIs on
preparation of annual reports were provided from the specialists of UzAIFSA.
14

          5.2.     Summary of actions taken during the previous reporting period
53.     Initially, in March 2020, training was conducted by ADB and UzAIFSA on the topic
"Livestock Value Chain Development". Also, within PFIs, online seminars were held on the topic
"Implementation of the environmental and social management system in the bank's credit cycle."
54.     Moreover, UzAIFSA specialist on environmental and social aspects communicated
constantly with PFIs responsible specialists on ESMS during the reporting period. The required
documents for participation in the project, their categorization processes were reviewed for most
of the sub-projects. The check lists completion was also checked, and consultations were given
on improvement of ESMS implementation. Last but not least, the categorization correspondence
of every sub-project was monitored through the financial documents.

            5.3.    Action plan for the next reporting period
55.     The capacity building activity has been planned for 2021 to improve the skills of evaluating
sub-loans, as well as in the field of social and environmental management in financing livestock
sector. An environmental consultant will be recruited by UzAIFSA to deliver training seminars and
also to review ESMS implementation of sub-projects to ensure compliance with the recent
updates in national (legislation of Republic of Uzbekistan) and international requirements.
56.     Moreover, collection/preparation of PFIs’ quarterly progress reports, sub-loan documents
and PFIs' audited financial statements for periodic ADB review missions.
57.     Ensure on-time compilation of the annual report on ESMS.
58.     If necessary, provide assistance to PFIs and beneficiaries of environmental and social
issues.

Table 4. Issues in PFIs on ESMS and actions required

 PFIs                Issues                                  Actions required   Responsibility    Time
 JSCB Xalq Bank      Capacity building in ESMS               Participate in     Deputy Chairman   2021.
                     organization according to ADB           ESMS training      of the Board      Q2
                     safeguard requirements, specifically
                     the requirements of LVCDP
 JSCB Qishloq        Capacity building in ESMS               Participate in     Deputy Chairman   2021.
 Qurilish Bank       organization according to ADB           ESMS training      of the Board      Q2
                     safeguard requirements, specifically
                     the requirements of LVCDP
 JSCB Turonbank      Capacity building in ESMS               Participate in     Deputy Chairman   2021.
                     organization according to ADB           ESMS training      of the Board      Q2
                     safeguard requirements, specifically
                     the requirements of LVCDP
 JSCB                Capacity building on the requirements   Inspect the ESMS   The Green         -
 Uzpromstroybank     of LVCDP                                arrangements       Banking
                                                             report of LVCDP    department
 JSCMB Ipoteka       No issues                               Not required       -                 -
 bank
 JSCB                Capacity building in ESMS               Participate in     Deputy Chairman   2021.
 Microcreditbank     organization according to ADB           ESMS training      of the Board      Q2
                     safeguard requirements, specifically
                     the requirements of LVCDP

                                                                                                      14
15

Annex 1. Photographs
  a. Training conducted by ADB TA Consultant and UzAIFSA on the topic "Livestock Value
     Chain Development", March 2020
16

     b. Field visit sub-projects

                                   16
17

Annex 2. Example of packages of environmental and social
documents submitted by sub-borrowers

                  Google map of the proposed sub-project
18

National Environmental Clearance – Positive Conclusion of Environmental Expertise

                                                                                    18
19

                                  REPUBLIC OF UZBEKISTAN

                    LIVESTOCK VALUE CHAIN DEVELOPMENT PROJECT

Samarkand JSCB “Turonbank”

                             SUB-PROJECT INFORMATION SHEET

   1.        Branch Code: 00282. and Location: Samarkand region, Samarkand city,
             st. M.Ulugbek,
             house 62;
   2.        Sub-borrower ID Number: 303662574;
   3.        Sub-borrower Name and Address: FE “ELBEK YOSH KUCH”, Samarkand region,
             Oqdaryo district, mahalla Yangiqurgon;
   4.        Legal Status of Sub-borrower: Private, legal entity in the form of farm household;
   5.        Brief Description of Sub-Project: Simmental and Holstein breed cattle in amount of 50
             heads;
   6.        Sub-project Cost: 141 291 USD;
   7.        Sub-borrowers Contribution: 42 486 USD;
   8.        Amount of Sub-loan and Currency: 98 805 USD;
   9.        Utilization of Sub-loan (by items):

                                                                                          in USD
         Project Costs (Itemized list)            Owners’           LVCDP           Total Cost
                                                 Financing         Financing
 Purchase of cattle                                                  98 805           98 805
 Feed supply (12 months)                           42 486                             42 486
 TOTAL                                             42 486            98 805          141 291
 Percent of Total:                                  30%               70%             100%

   10.       Date of Approval of Sub-loan (by PFI): 13.03.2020;
   11.       Number and Date of Sub-loan Agreement: No. 138 from 13.03.2020;
   12.       Interest Rate (national currency): 19%;
   13.       Other Charges and Fees: in the amount of 0,25% of the sub-loan amount;
   14.       Repayment terms of Sub-loan: every 6 months;
   15.       DSCR: 1,8;
   16.       Environmental Category: C; EA required: No (Sub-borrower has positive conclusion of
             State committee for nature protection of Samarkand region)

Deputy Chairman of the Board
Kaldibaev S.T.

Date: 20.04.2020
20

                                REPUBLIC OF UZBEKISTAN

                   LIVESTOCK VALUE CHAIN DEVELOPMENT PROJECT

                           PROCUREMENT COMPARISON FORM

     1.    Procurement Method: Commercial Practice
     2.    Sub-borrower: FE “ELBEK YOSH KUCH”;
     3.    Items to be procured: Simmental and Holstein breed cattle in amount of 33 heads;
     4.    Value of Items (each item separately):
              • Simmental and Holstein breed cattle in amount of 50 heads – 98 805 USD
     5.    Number of suppliers contacted (for each item separately): 3 (three);
     6.    Number of suppliers who responded (for each item separately): 3 (three);
     7.    Suppliers (for each item separately): 3(three)

Simmental and Holstein breed cattle in amount of 50 heads

     №            Name of supplier, country                       Date received   Price (USD)
     1. LLC “MUSINOV MAMUR ZAFAR” (Uzbekistan)                     15.03.2020       113 625
     2. FE “ARPA SABZAVOTLARI” (Uzbekistan)                        15.03.2020       108 685
     3. LLC “MAXSUS MEXANIZATSIYALASHGAN SUV                       15.03.2020        98 805
        QURILISH” (Uzbekistan)
     8.    Ranking of the Suppliers based on the price offer:

Simmental and Holstein breed cattle in amount of 50 heads

     № Name of supplier, country                                                  Price (USD)
     1. LLC “MAXSUS MEXANIZATSIYALASHGAN                        SUV   QURILISH”      98 805
        (Uzbekistan)
     2. FE “ARPA SABZAVOTLARI” (Uzbekistan)                                         108 685
     3. LLC “MUSINOV MAMUR ZAFAR” (Uzbekistan)                                      113 625

     9.    Offers not incompliance with the terms of the tender: No
     10.   Best supplier:
     • Simmental and Holstein breed cattle in amount of 50 heads, LLC «MAXSUS
         MEXANIZATSIYALASHGAN SUV QURILISH » (Uzbekistan)
     11.   Contract Price: 98 805 USD.
     12.   Contract award date: contract №2 dated 03.04.2020.
     13.   Complains received from other bidders in the process (if any): None

Director of
FE “ELBEK YOSH KUCH”                                                          Qarshiev B.X.

Date: 20.04.2020
                                                                                              20
21

ENVIRONMENT SCREENING CHECKLISTs

PART 1 – to be filled by sub-borrower applying for financial support for new or extended
                                       facilities

      Basic Information
1     Name of the registered                             FE “ELBEK YOSH KUCH”
      business or company:
2     Which year started/registered                            28.12.2015
3     Location/full address:                    Samarkand region, Oqdaryo district, mahalla
                                                              Yangiqurgon
4     Nature and scope of
      business: (which sub/sector,         Type           Y/N     %       Type          Y/N    %
      mainly breeding, processing or       Livestock      Y       100     Breeding      Y      100
      others? If a combination, rough      Poultry                        Processing
      %?)                                  Beekeeping                     Slaughter
                                           Fish                           Other
                                           Sericulture
                                           Rabbits
                                           Other

5     Designed (production)               66 cattle
      capacity:
      (per year and/or per day; if not
      applicable, need to explain
      here)
6     Actual capacity or scale:           16 cattle
      (per year and/or per day; Briefly
      explain the difference with the
      designed capacity or scale)
7     Main production process(es):        The production process consists of:
      (Provide simple flowchart to        Cattle cultivation;
      show main input of materials,       Milking process;
      water, energy (heat, steam or
      fuels etc), output of               Water consumption - Acc clear GOST "Drinking water"
      intermediate and final products,    in the watering of one head of cattle must be 48 liters per
      and wastes (gaseous, liquid or      day. Then - 1 052,2 m3/year, water consumption for
      solid) etc                          technological needs with cattle content of 5 liters per
                                          day. Then - 109,5 m3/year, household needs of workers.
                                          Then - 36,5 m3/year, the water consumption for the
                                          catering unit is an average of 200 liters a day. Then -
22

                                       73,0 m3/year, the approximate size of the territory under
                                       irrigation is 300 m2. Then – 270,0 m3/year.

                                       Heating - Out of stock

                                       Electricity - 8 hours/day - connection to a local network

                                       Waste:
                                       Industrial waste - According to the “Collection of
                                       specific indicators of production and consumption waste
                                       generation”, 13 kg of manure from one unit of cattle per
                                       day is generated. Then – 284,7 tons/year.

                                       Collateral waste - The average daily generation of
                                       waste from the dining room for one dish is 0,01 kg. The
                                       number of visitors to the dining room is 4 people. For a
                                       day, for one person, prepare 3 dishes for one meal.
                                       Then – 0,0438 tons/year.

                                       In accordance with the norms for the accumulation of
                                       garbage and other household waste, solid household
                                       waste is generated as a result of the life of the
                                       enterprise’s employees – 0,2 tons/year.

                                       Waste from cleaning the area with hard surface
                                       (estimates) - As a result of cleaning hard surfaces,
                                       waste is generated in the amount of 0,6 tons/year, as a
                                       result of cleaning the territory with soil, solid household
                                       waste is generated – 2,1 tons/year.

                                       Emissions to the atmosphere - this project calculated
                                       the distribution of emissions of harmful substances into
                                       the atmosphere. According to the results of calculating
                                       the variance of the maximum surface concentrations of
                                       pollutants, it is clear that for any of the ingredients there
                                       are no cases of exceeding quotas and the maximum
                                       concentrations do not go beyond the boundaries of the
                                       object
 8   Main product(s):                  Milk (liters per year)
     Describe briefly the name, main
     usage, chemical or biochemical
     composition etc.
                                       Male               4
     Profile of employees              Female             2

                                                                                                  22
23

                                         Total             6
9    Other information

     Subproject basics
10   Amount of loan requested:           98 805 US dollars
     In local currency and USD
11   Intended use of the loan:           Simmental and Holstein breed cattle in amount of
     Briefly describe if it is for new   50 heads
     line of business/production,
     expansion or upgrade/rehab
     existing business /production or
     other uses?
12   Designed (production)               Milk (348 000 liters per year)
     capacity:
     per year and/or per day; if not
     applicable, need to explain here

13   Tech. process(es):                  The production process consists of:
     If applicable, provide simple       Cattle cultivation;
     flowchart to show main input of     Milking process;
     materials, water, energy (heat,
     steam or fuels etc), output of      Water consumption - Acc clear GOST "Drinking water"
     intermediate and final products.    in the watering of one head of cattle must be 48 liters per
                                         day. Then - 1 052,2 m3/year, water consumption for
                                         technological needs with cattle content of 5 liters per
                                         day. Then - 109,5 m3/year, household needs of workers.
                                         Then - 36,5 m3/year, the water consumption for the
                                         catering unit is an average of 200 liters a day. Then -
                                         73,0 m3/year, the approximate size of the territory under
                                         irrigation is 300 m2. Then – 270,0 m3/year.

                                         Heating - Out of stock

                                         Electricity - 8 hours/day - connection to a local network

14   Main product(s) of sale or          Milk
     R&D:
     Describe briefly the name, main
     usage, chemical or biochemical
     composition etc.
15   List wastes the subproject          Gaseous             0.19 t/y
     will be generate (where             emissions
24

     relevant) :                        Wastewater    3200 m3/year
     Provide estimate their amount if   Solid waste   400 kg/year
     you can per year or per day etc.   Manure        2400 kg/year
                                        Hazardous
                                        waste

     Planned method of waste            Gaseous
     disposal/management                emissions
                                        Wastewater
                                        Solid waste

                                        Manure
                                        Hazardous
                                        waste

     Other relevant information

 Director of
 FE “ELBEK YOSH KUCH”                                                Date: 20.04.2020
 Qarshiev B.X.

                                                                                    24
25

    PART 2 – To be filled by the FI(s)

         Existing business and facilities (if applicable)
1        Is it in prohibited, phased No not subject
         out or discouraged
         sub/sector by national,
         provincial or local policy?
         Is it in prohibited, phased No not subject
         out or discouraged
         sub/sector according to
         FI’s internal
         guidelines/checklist?
         What kind of
         environmental permit it      Type                       Y/N    Issuing   Validit    Issuing
         has? And obtained                                              date      y          authority
         when?                                                                    date
                                      For operating farms
                                      Statement on               Not
                                      Environmental
                                      Consequences (SEC)
                                      for:
                                           - final number
                                              animals/birds
                                           - new
                                              processing
                                      Positive Conclusion of     Not
                                      Environmental
                                      Expertise (EE) on
                                      SEC

         Subproject requesting loan
         What environmental
         clearance and permits       Type                      Y/N     Issuin   Validi   Issuing
         required received?                                            g date   ty       authority
         Specify                                                                date
                                     For New farms
                                     ZVOS                      Not
                                     EMP                       Not
                                     Positive Conclusion       Not
                                     of EE on ZVOS
                                     For operating farms
                                     If type of production     Not
                                     not be changed and
                                     existing capacity of
                                     production not be
                                     increased SEC for:
26

                                       -     final number   Not
                                             animals/bird
                                             s
                                         - new              Not
                                             processing
                                    If type of production   Yes
                                    be changed and
                                    capacity be
                                    increased:
                                    ZVOS report             Yes
                                    EMP                     Yes
                                    Positive Conclusion     Yes   12.03.   3        State Committe
                                    of EE on ZVOS                 2020     years    e for Nature
                                                                                    Protection of
                                                                                    Uzbekistan, Sa
                                                                                    markand
                                                                                    Regional
                                                                                    Committee for
                                                                                    Nature Protec
                                                                                    tion
                                    SEC report              Not
                                    Positive Conclusion     Not
                                    of EE on SEC
        FI received a copy of      Yes
        received environmental
        clearance and permits?
        Other relevant
        information
        Has its siting been
        screened using the REA
        (see below)? what is the
        conclusion on
        environmental risks
        posed by its siting?
        Conclusion of the
        screening

Head of the Samarkand branch
JSCB “Turonbank”
Ochilov X.I.                                          Signature                    Date: 20.04.2020

                                                                                                 26
27

                   Rapid Environmental Assessment (REA) Checklist
                                   (To be completed by FI(s))

Country/Project                Samarkand region, Oqdaryo district, mahalla Yangiqurgon
Title:

Sector Division:                                      Livestock

  Screening Questions                                Yes   No     Remarks
  A. Project Siting                                        Not    There are no environmental
  Is the Project area adjacent to or within any of                vulnerable areas near the
  the following environmentally sensitive areas?                  project location

  ▪ Cultural heritage site                                 Not

  ▪ Legally protected Area (core zone or buffer            Not
    zone)
  ▪ Wetland                                                Not
  ▪ Mangrove                                               Not

  ▪ Estuarine                                              Not

  ▪ Special area for protecting biodiversity               Not

  B. Potential Environmental Impacts
  Will the Project cause…
  ▪ impairment of historical/cultural areas;               Not
    disfiguration of landscape or potential
    loss/damage to physical cultural resources?
  ▪ disturbance to precious ecology (e.g.                  Not
    sensitive or protected areas)?
  ▪ alteration of surface water hydrology of               Not
    waterways resulting in increased sediment in
    streams affected by increased soil erosion at
    construction site?

  ▪ deterioration of surface water quality due to          Not
    silt runoff and sanitary wastes from worker-
    based camps and chemicals used in
    construction?
  ▪ increased air pollution due to project                 Not
    construction and operation?
28

     Screening Questions                                Yes   No    Remarks
     ▪ noise and vibration due to project                     Not
       construction or operation?

     ▪ involuntary resettlement of people? (physical          Not
       displacement and/or economic displacement)

     ▪ disproportionate impacts on the poor, women            Not
       and children, Indigenous Peoples or other
       vulnerable groups?

     ▪ poor sanitation and solid waste disposal in            Not
       construction camps and work sites, and
       possible transmission of communicable
       diseases (such as STI's and HIV/AIDS) from
       workers to local populations?
     ▪ creation of temporary breeding habitats for      Yes         It is possible in case of poor
       diseases such as those transmitted by                        management.         Mitigations
       mosquitoes and rodents?                                      measures have to be applied
                                                                    during operation phase
     ▪ social conflicts if workers from other regions         Not
       or countries are hired?

     ▪ large population influx during project                 Not
       construction and operation that causes
       increased burden on social infrastructure and
       services (such as water supply and sanitation
       systems)?

     ▪ risks and vulnerabilities related to                   Not
       occupational health and safety due to
       physical, chemical, biological, and
       radiological hazards during project
       construction and operation?
     ▪ risks to community health and safety due to            Not
       the transport, storage, and use and/or
       disposal of materials such as explosives, fuel
       and other chemicals during construction and
       operation?

     ▪ community safety risks due to both accidental          Not
       and natural causes, especially where the
       structural elements or components of the
       project are accessible to members of the
       affected community or where their failure
       could result in injury to the community
       throughout project construction, operation
       and decommissioning?

                                                                                              28
29

  Screening Questions                               Yes    No       Remarks
  ▪ generation of solid waste and/or hazardous      Yes             Mitigations measures have to
    waste?                                                          be applied during operation
                                                                    phase
  ▪ use of chemicals?                                      Not

  ▪ generation of wastewater during construction    Yes               Mitigations measures have to
    or operation?                                                     be applied during operation
                                                                      phase
Typical sub-project monitoring plan would be prepared to monitor the implementation of EMP.
PFIs could use information from this table to conduct further monitoring of EMP implementation.

                               Environmental Monitoring Plan

  Project       What is to be      How and where will      Frequency of         Responsibility
  phases          monitored         it be monitored         monitoring
                  (mitigation          (visually of         (quarterly,
               measures from           measured)             monthly,
                previous table                                weekly)
              could be included)
Appendix 4. INVOLUNTARY RESETTLEMENT SCREENING/CATEGORIZATION
                                CHECKLIST

                            (To be completed by PIU Safeguard specialist)

     INVOLUNTARY RESETTLEMENT SCREENING/CATEGORIZATION CHECKLIST

   Name of
                           FE “ELBEK YOSH KUCH”
   Subborower:

   Subproject Title:       Simmental and Holstein breed cattle in amount of 50 heads

   Location:               Samarkand region, Nurobod district, mahalla Oqsoy, village of Oqsoy

Probable Involuntary Resettlement Effects                         Not
                                                    Yes    No               Remarks
                                                                  Known
Involuntary Acquisition of Land
                                                           Not
1. Will there be land acquisition?
2. Is the site for land acquisition known?               Not
3. Is the ownership status and current usage of          Not
land to be acquired known?
4. Will easement be utilized within an existing          Not
Right of Way (ROW)?
5. Will there be loss of shelter and residential land    Not
due to land acquisition?
6. Will there be loss of agricultural and other          Not
productive assets due to land acquisition?
7. Will there be losses of crops, trees, and fixed       Not
assets due to land acquisition?
8. Will there be loss of businesses or enterprises       Not
due to land acquisition?
9. Will there be loss of income sources and means        Not
of livelihoods due to land acquisition?
Involuntary restrictions on land use or on access to legally designated parks and protected
areas
10. Will people lose access to natural resources,        Not
communal facilities and services?
11. If land use is changed, will it have an adverse      Not
impact on social and economic activities?
12. Will access to land and resources owned              Not
communally or by the state be restricted?
Information on Displaced Persons: N/a

Any estimate of the likely number of persons that will be displaced by the Project?              [ ]
No       [ ] Yes
If yes, approximately how many? Not

Are any of them poor, female-heads of households, or vulnerable to poverty risks?                [ ]
No    [ ] Yes

                                                                                                 30
31

Are any displaced persons from indigenous or ethnic minority groups?                           [ ]
No    [ ] Yes

 Note: The project team may attach additional information on the project, as necessary.

  IR Categorization:                               Prepared by: (Sub-borrower)
                                                   Name and Signature: Qarshiev B.X.
   A - significant IR impacts (200 or more); RP   Designation: Director of
  required                                         FE “ELBEK YOSH KUCH”
   B – insignificant IR impacts; RP required      Date: 20.04.2020
  X C – no impact; no requirement                  Reviewed by: (RDBx designated officer)
                                                   Name and Signature: Saidov F.D.
                                                   Designation: Head of the division of Center of
                                                   coordination investment activity and project
                                                   management
                                                   Date: 20.04.2020

  Filled Environmental and Social Checklist
32

Certificate on land ownership

                                32
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